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• Standard Number: 1910.1200

July 17, 1989 

MEMORANDUM FOR:   JAMES W. STANLEY
                 REGIONAL ADMINISTRATOR

ATTENTION:        ACTING ASSISTANT REGIONAL ADMINISTRATOR
                 FOR TECHNICAL SUPPORT

THROUGH:          LEO CAREY, DIRECTOR 
                 DIRECTORATE OF FIELD PROGRAM

FROM:             PATRICIA K. CLARK, ACTING DIRECTOR
                 DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:          Hazard Communication Standard (HCS) Labeling
                 Requirements for Industrial Thermometers
This is in response to your memo of June 6, which forwarded a memo from the Manhattan Area Office requesting an interpretation of the Hazard Communication Standard as it applies to labeling requirements for industrial thermometers.

If industrial thermometers are expected to break during normal conditions of use, exposing employees to mercury, they are not considered articles for purposes of the HCS. Under the labeling provisions of the HCS each thermometer container would have to be labeled, tagged, or marked with the required label information.

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