OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 25, 1984

Mr. Jim Wooldridge
Delta Solvents & Chemicals Company
610 Fisher Road
Longview, Texas 75604

Dear Mr. Wooldridge:

This is in response to your letter of July 23 to Gilbert J. Saulter, Regional Administrator, requesting clarifications of the Hazard Communication standard (29 CFR 1910.1200). Your questions are answered as follows:

1. Must bulk chemical storage tanks and the plumbing be marked and labeled to show all hazards?

Answer: The standard permits several alternative warning methods under 1910.1200(f)(5) as follows:

"(5) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraphs (f)(4) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.

Appropriate hazard warnings are required for all hazardous chemicals present.

2. When containers are filled for storage must they be labeled on the distribution property?

Answer: Containers should be labeled as soon as practicable. A delay between filling and labeling is permissible. Bulk storage tanks from which filling is taking place must be labeled.

3. Must the label identify all products in mixtures?

Answer: Employers need not list all of a product's constituents individually on the label. This interpretation is evident when one reviews the definition of the terms "identity" and "common name" under section 29 CFR 1910.1200(c) of the standard. Essentially, a common name may appear on the label as long as the material safety data sheet (MSDS) is similarly identified.

4. Must Safety Data Sheets identify all products and per- centages in mixtures?

Answer: The information required under 29 CFR 1910.1200(g) must be given only for the hazardous chemicals present within a product mixture, unless they are present in concentrations of less than 1.0 percent, and less than 0.1 percent for carcinogens. The standard does not require the listing of percentages of chemicals in mixtures. In the case of trade secrets or when specific information is unavailable, these facts must be explained on the MSDS; blanks are not permitted.

5. Would signs posted in our drum filling area and storage area take the place of labels on our property?

Answer: No, containers must be identified as soon as possible. Signs may be used in place of labels on stationary process equipment pursuant to paragraph (f)(5) of the standard. (See answer to question number 1.)

Please feel free to contact us if further assistance is needed.


John B. Miles, Jr., Director
Directorate of Field Operations