Employer duties under the hazard communication rule

June 25, 1993

Mr. Michael J. Willis
[Recipient address omitted]
Dear Mr. Willis:

This is in response to your letter of April 21, concerning the responsibilities of the employer and the federal government in protecting worker safety and health.

In your letter you refer to the material safety data sheets (MSDSs) and employee training responsibilities of the employer. While employee training requirements are a part of many different OSHA standards, your reference to material safety data sheets (MSDS) suggests that your letter concerns the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard, 29 CFR 1910.1200.

During the rule-making process for the Hazard Communication Standard, the feasibility of the proposed regulation was assessed. OSHA concluded that the provisions of the standard were economically feasible for all industries covered within the scope of the standard. The Hazard Communication Standard includes requirements, such as labeling and MSDS, to ensure the downstream flow of information to employers and employees concerning physical and health hazards of workplace chemicals. In addition, it requires employers to take active steps to develop and implement information and training programs so that employees will be knowledgeable about chemical hazards of the workplace.

OSHA provides for consultation assistance to employers who want help in establishing and maintaining a safe and healthful workplace. This service is provided at no cost to the employer and is delivered by State governments using well-trained occupational health and safety professionals. No penalties are proposed or citations issued for hazards identified by the consultant. Consultation can provide assistance in developing and implementing effective workplace safety and health programs. Training and education services are also provided, as well as limited assistance away from the worksite. Additional information concerning consultation assistance, including a directory of OSHA-funded consultation projects, is included in the enclosed OSHA publication No. 3047, Consultation Services for the Employer.

We hope this information is helpful. If you have any further questions please feel free to contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]