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Safety data sheet duties for laboratories

Summary A company asked what the Hazard Communication Standard requires laboratories to do with material safety data sheets. OSHA said laboratories have a narrower duty than other workplaces: they must retain sheets their suppliers send, but need not request or otherwise obtain missing sheets. The answer matters to laboratory employers handling hazardous chemicals.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-06-05
Date issued
June 5, 1989
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication Laboratories
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

June 5, 1989

Mr. Dennis P. Johnson
Staff Industrial Hygienist
Kerr-McGee Corporation
[Recipient address omitted]
Dear Mr. Johnson:

This is in response to your letter of November 28, 1988, and a follow-up to your telephone conversation with Mrs. Jennifer Courtney of my staff, in which you requested an interpretation of the Hazard Communication Standard (HCS), 29 CFR 1910.1200, as it relates to laboratories and our requirements with respect to material safety data sheets (MSDS). Please accept my apology for the delay in this written response.

The HCS addresses laboratories in a more limited fashion than it does for other types of establishments. An employer is only required to maintain those MSDS which the supplier sends. There is no affirmative obligation for a laboratory to request or otherwise procure data sheets.

We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.

Sincerely,

Patricia K. Clark, Acting Director
Directorate of Compliance Programs

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