Standard Interpretations - Table of Contents
• Standard Number: 1910.1200(g)(2)(xii); 1910.1200(g)(5); 1910.1200(f)(1)(iii); 1910.1200(f)(11)


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 http://www.osha.gov .


January 19, 2000

Mr. Michael J. Kelleher
Arent Fox Kintner Plotkin & Kahn, PLLC
1050 Connecticut Avenue, NW
Washington, DC 20036-5339

Dear Mr. Kelleher:

Thank you for your letter of June 28, 1999 to the Occupational Safety and Health Administration (OSHA), concerning Material Safety Data Sheets (MSDSs). You asked if your client can list its name on an MSDS instead of listing the Japanese manufacturer from whom it imported the product. We apologize for this delay in response.

The Hazard Communication Standard (HCS), 29 CFR 1910.1200, allows downstream users to add or substitute their name on the labels and MSDSs of hazardous chemicals. However, if the downstream user substitutes its name, thereby removing the original manufacturer's name, it becomes the responsible party for insuring the accuracy