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 http://www.osha.gov.

June 27, 1988

MEMORANDUM FOR: MICHAEL G. CONNORS
  REGIONAL ADMINISTRATOR
 
THROUGH: LEO CAREY, DIRECTOR
  DIRECTORATE OF FIELD PROGRAMS
 
FROM: THOMAS J. SHEPICH, DIRECTOR
  DIRECTORATE OF COMPLIANCE PROGRAMS
 
SUBJECT: Overwarning on Hazard Labels

This is in response to your memorandum of May 18 on the above subject. Specifically, you wish to know whether it is acceptable under the Hazard Communication Standard (HCS) for a company to use the same comprehensive list of health hazard target organs on the warning labels for an entire line of products.

Acceptability in terms of compliance with the HCS will depend upon whether, in fact, each product possesses all of the listed hazards. Any target organ hazard which is not demonstrated by at least one valid positive study for the chemical which is so labeled is not an appropriate hazard warning.