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.

March 17, 1986

Mr. Kevin C. Donaghue
Rollins Burdick Hunter of Oregon, Inc.
Pacwest Center, Suite 600
1211 S. W. Fifth Avenue
Portland, Oregon 97204-3799

Dear Mr. Donaghue:

Thank you for your letter dated November 11, 1985, addressed to Mr. Carl Halgren, in regard to the Hazard Communication Standard. Please accept my apology for the delay in response. The overwhelming number of letters and telephone calls regarding the Hazard Communication Standard has caused unavoidable delays in responding to the public's concerns.

OSHA considers lift trucks to be machines and not containers. Containers are required to be labeled according to the standard. Labeling vehicle components seems to be impractical and would be cumbersome.

Material safety data sheets do not have to be provided for lift trucks. However, material safety data sheets are required for the gasoline and other fuels used by the lift trucks. Employees should be aware of the potential for exposure to carbon monoxide and associated physical hazards of petroleum fuel products such as fire and explosion.

Labeling of vehicle components is not necessary. Lift trucks do not meet the current definition of an "article" because of potential exposures to carbon monoxide and physical hazards of petroleum fuel products. The "article" definition was one of the issues upon which OSHA requested comment in the November 27, 1985, publication of the Federal Register. Comments were accepted until February 25, 1986.

If we can be of further assistance please contact our Office of Health Compliance Assistance at (202) 523-8036.


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


                Industrial Hygienist 
                Hazard Communication 
                Health Compliance Assistance

                Director of Field Operations

FROM:            JAMES W. LAKE 
                Regional Administrator 
                Region X

SUBJECT:         Request for Hazard Communication Interpretation

Based on a December 13, 1985, telephone conversation with Joseph Hopkins of your office, I am forwarding a request for an interpretation regarding lift trucks and the hazard communication standard.

The requester, Mr. Kevin C. Donaghue, has been notified that his questions have been referred to your office and that a response will be forthcoming. I would appreciate a copy of your response.

Occupational Safety and Health Administration 909 First Avenue Seattle, Washington 98174 December 13, 1985

November 11, 1985

Mr. Carl Halgren
Area Director
U. S. Department of Labor
Occupational Safety
& Health Administration
1220 S. W. Third, Room 640
Portland, Oregon 97204

Dear Mr. Halgren:

I recently had a meeting with Hyster Company concerning the Hazard Communication Standard. During our meeting several items were discussed including the Standards inevitable expansion. There were three questions which Hyster Company would appreciate a written response from OSHA:

1. Does Hyster Company have to provide Material Safety Data Sheets (MSDS) for lift trucks (by-product of combustion-carbon monoxide)?

2. Does Hyster Company have to label all radiators (antifreeze), brake lines (brake fluid), gasoline, propane, diesel tanks (fuel), crank case (various oils), etc.?

3. Are they exempt from having to comply with items one and two because lift trucks are considered articles?

I appreciate you considering these questions and am looking forward to your reply.


Loss Control Consultant
Rollins Burdick Hunter of Oregon, Inc.
Pacwest Center, Suite 600, 1211 S.W. Fifth Avenue
Portland, Oregon 97204-3799
Telephone 503-224-9700