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.