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.

August 11, 1986

Mr. Davis Thekkanath Sr.
Supervising Engineer
Oshkosh Truck Corporation
2307 Oregon Street
Oshkosh, Wisconsin 54903

Dear Mr. Thekkanath:

This is in response to your letter of June 25 regarding the Hazard Communication Standard (HCS).

The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. It is our interpretation that items such as a truck radiator, an engine, or a battery are not containers and therefore would not be required to be labeled. However, the containers that held such chemicals as ethylene glycol and battery acids would need to be labeled since they meet the definition of a "hazardous chemical" under the standard.

If you have any further questions, please feel free to contact us again.


John B. Miles, Jr., Director

June 25, 1986

John B. Miles Jr., Director
Directorate, Field Operations
U.S. Department of Labor
200 Constitution Ave. N.W.
Washington, DC 20210

Subject: 29 CFR Part 1910.1200 Hazard Communication


Oshkosh Truck Corporation is a manufacturer of heavy duty trucks. The trucks as shipped to our customers, have ethylene glycol solution in the radiator, lubricating oil in the engine transmission and axles, battery fluids in the battery, to name a few. Our question concerns the applicability of the subject requirements for the vehicle operation.

Mr. Steve Simon, of your office, in a recent telephone conversation with the writer advised that the subject regulation is not applicable to items on the vehicle that are functional requirements for vehicle operation.

We would therefore appreciate your confirming this in writing at you earliest.



Davis Thekkanath Sr.
Supervising Engineer