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HMIS and NFPA codes on material safety data sheets

Summary A manufacturer asked OSHA to require HMIS and NFPA codes on material safety data sheets. OSHA said some numerical or alphabetical systems can be used for workplace labeling when the overall hazard communication program is effective, but the agency does not endorse a particular system or require its codes on sheets. The guidance matters to employers choosing hazard-label formats.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-05-01
Date issued
May 1, 1989
Status
Active
Status last verified October 10, 2026

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May 1, 1989

Mr. Nelson C. Holly
Safety Administrator
Certaineed Corporation
[Recipient address omitted]
Dear Mr. Holly:

This is in response to your letter of October 31, 1988, requesting that HMIS and NFPA labeling information be included on the material safety data sheet.

The preamble to the Hazard Communication Standard (HCS) recognizes the existence of numerous labeling systems that are currently in use in industry. Many of the systems rely on numerical or alphabetical codes to convey the hazards. Although, the intent of the standard is to permit the use of these systems for inplant labeling, provided the entire hazard communication program is effective, the Occupational Safety and Health Administration (OSHA) does not endorse specific services or products. It would, therefore, be inappropriate for OSHA to require a particular labeling system's code on the material safety data sheet.

We hope this information is helpful to you in clarifying your concern. If we can be of further assistance, please feel free to contact us.

Sincerely,

Thomas J. Shepich, Director Directorate of Compliance Programs

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