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.

February 16, 1989

Ms. Judy Peterson
Manager, Research and Standards Development
Corporate Safety and Health Administration
Boeing Support Services
Post Office Box 3707
Seattle, Washington 98124-2207

Dear Ms. Peterson:

This is in response to your letter of September 28, 1988, addressed to Ms. Jennifer Silk, regarding the requirements for the labeling of chemicals leaving the workplace under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard 29 CFR 1910.1200. Please accept our apology for the delay in response.

Hazardous chemicals transported to another plant of the same company whether across State lines or within the State are required to be labeled by the employer. 1910.1200(f)(5) requires the employer to label all chemicals in the workplace with the identity of the hazardous chemicals and appropriate hazard warnings. The two exceptions to this provision are when alternative methods are used to identify stationary process containers and when hazardous chemicals are transferred to portable containers for the immediate use of the employee that performed the transfer.

We hope this information is helpful to you. Please contact us again if further assistance is needed.


Thomas J. Shepich, Director
Directorate of Compliance