Standard Interpretations - Table of Contents
• Standard Number: 1910.1200

May 23, 1991

Mr. Lawrence M. Friedman
Toledo Building Services
Post Office Box 2223
Toledo, Ohio 43603-2223

Dear Mr. Friedman:

This is in further response to your letter of March 22, to Secretary of Labor Lynn Martin, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200, as it applies to the janitorial service industry, SIC 7349.

The HCS was expanded to include all industries where employees are exposed to hazardous chemicals on August 24, 1987. It provides all exposed workers with the right-to-know information about the hazards of the chemicals they work with, as well as appropriate protective measures. In addition to having a right-to-know, exposed workers have a need to know this information. OSHA's rulemaking record indicates that the rule is both necessary and feasible in all industries where such exposures occur.

As the HCS is a performance-oriented rule, employers in all types of establishments have the flexibility to adapt implementation of the requirements to address the specific needs of their workplaces. There are many types of businesses which have a large number of chemicals and do not have fixed worksite locations. The HCS has been successfully applied by employers to many different work environments.

The literacy of the workforce in general is a problem, and is not limited to any specific type of industry. Workers' inability to access and effectively use written information requires more effort to be placed upon proper training. You indicated that you have no problem training people to do their tasks. This training should also include information about how to do those tasks safely, including how to protect themselves from hazardous chemicals. We believe that training under the HCS can be done effectively for workers with different kinds of e