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Material safety data sheet format under the 1998 hazard communication rule

Summary A senator relayed a county employee's request for one format for material safety data sheets. OSHA said its 1998 rule recommended an ANSI format but let chemical suppliers choose how to present required information. It said a global harmonized format was being developed; the page does not establish whether the 1998 format discussion remains current.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1998-11-13-0
Date issued
November 13, 1998
Status
Unknown
The letter addresses the 1998 MSDS format and anticipates a harmonized global format; OSHA's page does not establish whether that format discussion remains current.
Status last verified October 9, 2026

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The current status of this document is unclear
The letter addresses the 1998 MSDS format and anticipates a harmonized global format; OSHA's page does not establish whether that format discussion remains current. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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.

November 13, 1998

Senator Alfonse M. D'Amato
United States Senate
[Recipient address omitted]
Dear Senator D'Amato:

This is in response to a memorandum forwarded from your office to the Occupational Safety and Health Administration (OSHA). This memorandum was written by Mr. Russell Calcagno, III, Facilities Management Analyst, Monroe County, regarding the need for a uniform format for Material Safety Data Sheets (MSDSs).

In the OSHA Instruction, Inspection Procedures for the Hazard Communication Standard, CPL 2-2.38D, which became effective on March 20, 1998, OSHA recommended the use of the American National Standards Institute (ANSI) Z400.1-1993 for the preparation of MSDSs. However, OSHA cannot mandate one format for MSDSs as the Hazard Communication Standard (HCS), 29 CFR 1910.1200, is a performance-oriented standard. This means that OSHA has set the framework for information transmittal but that manufacturers, importers, and distributors are allowed to determine the format in which this information will be provided.

While MSDSs are an invaluable resource for hazard information, they are only one facet of hazard communication in the workplace. Labels, a written program, and training are also required by the HCS to ensure that employees have the tools they need to work safely with hazardous chemicals. An effective hazard communication program would use all of these facets to ensure that employees know how to handle chemicals appropriately, including in emergency situations such as the one referenced in Mr. Calcagno's memorandum.

You should also be aware that there is an extensive international effort underway to develop a globally harmonized system for hazard communication, including a uniform format for MSDSs. The United States is an active participant in this process, which should lead to an agreed-upon global format.

We trust that this adequately answers Mr. Calcagno's concerns. If further information is required, please feel free to contact OSHA's Office of Health Compliance Assistance on 202-219-8036.

Sincerely,

Charles N. Jeffress
Assistant Secretary

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