Distributor of health care products would be a "distributor" rather than a "retail distributor" under the HCS.

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.

February 15, 1989

Mr. Thomas E. Knauer
Attorney at Law
Hunton & Williams
Post Office Box 1535
Richmond, Virginia 23212

Dear Mr. Knauer:

This is in further response to your letter regarding the Hazard Communication Standard (HCS) promulgated by the Occupational Safety and Health Administration (OSHA). Your inquiry concerned the compliance responsibilities for a client that is a major distributor of health care products.

MSDS should be distributed for welding wire containing hazardous chemicals.

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.

February 14, 1986

Mr. A. H. Krieg
President
Widder Corporation
Great Hill Road
Post Office Box 1069
Naugatuck, Connecticut 06770-1069

Dear Mr. Krieg:

Senator Lowell Weicker, Jr., has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of December 30, 1985, to him.

Labeling and MSDSs for a stump router cutter head which has carbide tips on the cutter teeth.

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.

October 26, 1987

Mr. Keith Doty
President
Hodges Manufacturing Company, Inc.
Route 4, Box 328B
Mountain Home, Arkansas 72653

Dear Mr. Doty:

This is an update to our response of October 1 to your inquiry concerning your labeling and material safety data sheet responsibilities under the expanded Hazard Communication Standard.

As you explained, your company manufactures stump removal equipment. Each stump router cutter head has carbide tips on the cutter teeth. Your customers sharpen the cutter teeth by grinding the carbide tips.

Retention requirements for superseded MSDSs.

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.

October 1, 1987

Mr. Dudley Robinson
Director of Government Affairs
Printing Industry of Illinois-Indiana Association
70 East Lake Street
Chicago, Illinois 60601

Dear Mr. Robinson:

This is in response to your letter of September 1, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard.

Hazard Communication Standard (HCS) Material Safety Data Sheet Requirements for the Construction Industry.

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 7, 1989

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.

January 22, 1990

Mr. Ernest Isenberg
Western EXTRALITE Company
2120 Wyandotte Street
Kansas City, Missouri 64108-19648

Dear Mr. Isenberg:

This is in response to your letter of December 5, 1989 addressed to Alan C. McMillan, Deputy Assistant Secretary, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) requirements.

Procedures a demolition and salvage constructor could employ in lieu of providing material safety data sheets for specific metals.

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 9, 1990

Mr. Robert L. Brooks
Right-to-Know Management Systems, Inc.
113 Wembley Road
Wilmington, Delaware 19808

Dear Mr. Brooks:

Solvents classified as a combustible liquid on the basis of the MSDS

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 3, 1993

Mr. Andrew Marmaduke,

Regional Environmental Specialist
Safety-Kleen
2727 Paces Ferry Road 2 Paces West,
Suite 1660
Atlanta, Georgia 30339

Dear Mr. Marmaduke:

MSDS requirements for scrap materials

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.

April 4, 1991

Mr. Robert D. Johnson
Resource Consultants, Inc.
Post Office Box 1848
Brentwood, Tennessee 37024

Dear Mr. Johnson:

MSDS labelling requirements.

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.

July 10, 1992

Thomas A. Dawson, D.D.S., P.C.
508 M-55
Tawas City, Michigan 48763

Dear Dr. Dawson:

This is in response to your letter dated February 10, to the Michigan Department of Public Health concerning requirements for rating of hazards on Material Safety Data Sheets (MSDS). Your letter was referred to the Occupational Safety and Health Administration (OSHA) for a response since you recommended that these hazard ratings be included as part of the MSDS requirements of the Federal Hazard Communication standard.