Definition of "article" under the HCS in reference to medical supplies and devices.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 5, 1990

Mr. Robert C. Wilbur
Vice President for Government Relations
Health Industry Distributors Association
1101 Connecticut Avenue, N.W., Suite 700
Washington, D.C. 20036

Dear Mr. Wilbur:

Clarification on OSHA's Hazard Communication Standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 28, 1989

Mr. Gerald L. Baril
Senior Industrial Hygienist
Lovell Safety Management Co., Inc.
161 William Street
New York, New York 10038-2604

Dear Mr. Baril:

This is in response to your letter of November 20 to the Occupational Safety and Health Administration (OSHA) seeking clarification on several items addressed by OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200.

Regarding labeling requirements order the OSHA's Hazard Communication Standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 16, 1990

Mr. Robert G. Bartlett
President
National Stone Association
1415 Elliot Place, N.W.
Washington, D.C. 20007-2599

Dear Bob:

Application of the HCS MSDS requirements to distributors selling hazardous chemicals to consumers and employers.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 16, 1990

Mr. David L. Wolf Manager,
Business Services Ohio Hardware Association
Post Office Box 1828
Columbus, Ohio 43216

Dear Mr. Wolf:

MSDS requirements for drugs

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 13, 1993

Dr. Jay D. Willey
Eastland Medical Plaza
1505 Eastland Drive
Suite 210
Bloomington, Illinois 61701

Dear Dr. Willey:

This is in response to your April 26 letter addressed to Congressman Thomas Ewing concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. Your letter specifically questioned the requirements for Material Safety Data Sheets (MSDS) for drugs.

Employee exposure to hazardous chemicals while working around small sensors.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 31, 1993

Ms. Denese A. Deeds, CIH
Senior Consultant
Industrial Health & Safety Consultants, Inc.
915 Bridgeport Avenue
Shelton, CT 06484

Dear Ms. Deeds:

This is in response to your letter of June 21, to Mr. John Miles concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200. Mr. Miles forwarded your inquiry to the Office of Health Compliance Assistance for response. Please accept our apologies for the delay in responding to your letter.

Requirement for additional employee training whenever new hazards are identified.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 7, 1993

Mr. Earle Wilson
Compliance Technologies Incorporated
One Henderson
Suite 2
Box 874
Brewton, Alabama 36427

Dear Mr. Wilson:

This is in response to your inquiry of August 11, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

Material safety data sheets (MSDSs) under the Hazard Communication Standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 6, 1990

Mr. John E. Lee III
Director of Safety and Loss Control
National Oats Company
1515 H Avenue N.E.
Cedar Rapids, Iowa 52402

Dear Mr. Lee:

Employee exposure to consumer products.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 27, 1990

Mr. Dan J. Helm
Compliance Software/Haz-I-Dent
1721 Stuart Court
Duluth, Minnesota 55803

Dear Mr. Helm:

Thank you for your letter, received in this office October 2, regarding employee exposure to consumer products under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

Communication Standard (HCS) to hydrotreated refined oils.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 9, 1990

Mr. Dave Peel
Vice President Manufacturing
BresLube
Post Office Box 130
Breslau, Ontario NOB 1MO
Canada

Dear Mr. Peel:

Thank you for your letter of October 11, regarding the application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) to hydrotreated re-refined oils.

Your letter specifically raises two issues:

Issue No. 1: