1910.1200(g)(6)

MSDS distribution responsibilities for chemical manufacturers and importers, distributors and retail distributors.

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 5, 1988

Mr. Robin W. Grover
Keck, Mahin & Cate
Attorneys at Law
1730 Pennsylvania Avenue, N.W.
Washington, D.C. 20006-4706

Dear Mr. Grover:

This is in response to your letter of September 22, regarding the duties of distributors of products covered by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200.

Manufacturers' use of the Internet for distribution of MSDSs to downstream users.

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 20, 1997

Kevin Johnson, CIH, CSP
Corporate EH&S Manager
Chiron Diagnostics Corporation
63 North Street
Medfield, Massachusetts 02052-1688

Dear Mr. Johnson:

Thank you for your letter of January 6, regarding manufacturers' use of the Internet for distribution of Material Safety Data Sheets (MSDSs) to downstream users.

Distribution of Material Safety Data Sheets.

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.

June 24, 1996

Mr. Jason Scriven
3E Company
4920 Carroll Canyon Road
San Diego, California 92121

Dear Mr. Scriven:

This letter is in response to your April 2 letter addressed to Mr. Joseph A. Dear, Assistant Secretary of the Occupational Safety and Health Administration (OSHA). Specifically, you raised three questions concerning the distribution of Material Safety Data Sheets (MSDS) under OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200. The questions and our response are provided below.

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.

February 7, 1997

Mr. Bobby Logue, CEO
Envirocare International Incorporated
121 Shivel Drive
Hendersonville, Tennessee 37075


Dear Mr. Logue:

Thank you for your inquiry of November 24, 1996, regarding the Hazard Communication Standard (HCS). The questions you posed have primarily to do with a manufacturer's responsibility for distributing MSDSs to downstream users of hazardous chemicals and the involvement of a third party, such as Envirocare, in this process.