- Standard Number:
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.
July 17, 1989
MEMORANDUM FOR: JAMES W. STANLEY REGIONAL ADMINISTRATOR ATTENTION: ACTING ASSISTANT REGIONAL ADMINISTRATOR FOR TECHNICAL SUPPORT THROUGH: LEO CAREY, DIRECTOR DIRECTORATE OF FIELD PROGRAM FROM: PATRICIA K. CLARK, ACTING DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS SUBJECT: Hazard Communication Standard (HCS) Labeling Requirements for Industrial Thermometers
This is in response to your memo of June 6, which forwarded a memo from the Manhattan Area Office requesting an interpretation of the Hazard Communication Standard as it applies to labeling requirements for industrial thermometers.
If industrial thermometers are expected to break during normal conditions of use, exposing employees to mercury, they are not considered articles for purposes of the HCS. Under the labeling provisions of the HCS each thermometer container would have to be labeled, tagged, or marked with the required label information.