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 20, 1986

The Honorable Carl Levin
United States Senate
Washington, D.C. 20510

Dear Senator Levin:

This is in response to your letter dated February 6 on behalf of your constituent, Mr. Don Birtwistle of Great Lakes Castings Corporation, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).

Under normal circumstances, a casting would be considered an "article" under the HCS and would be exempt from the provisions of the standard. However, if the casting is going to another manufacturing facility where it will be used in such a way as to release a hazardous chemical, information will have to be provided to the manufacturing purchaser of the product in accordance with the standard. The HCS requires manufacturers of such products to make determinations as to whether the casting is exempt based upon its "normal conditions of use." Welding, burning, cutting, gouging, sanding and other operations will release metal dusts or fumes which are considered hazardous chemicals. Castings undergoing these types of processes must have a material safety data sheet to inform the user of the hazards associated with exposure to metal dusts and fumes.

If we may be of further assistance please feel free to contact us again.


Patrick R. Tyson
Acting Assistant Secretary