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 23, 1990

Mr. Raymond D. Tripp
National Insulation and Abatement Contractors Association
99 Canal Center Plaza
Suite 222
Alexandria, Virginia 22314

Dear Mr. Tripp:

Thank you for your letter of June 12, regarding the application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 to the labeling of fabricated products.

Specifically, you wanted to know if the fabricator of a product must formulate a label specific to the fabricated product or if the fabricator may simply attach a label or multiple labels developed by the original manufacturer(s) to the fabricated products when the components have been chemically unchanged. Under the HCS, a fabricator of a product capable of resulting in downstream exposure to employees working with it is responsible for transmitting hazard information just as a chemical manufacturer would under the HCS. As such, the fabricator is responsible for formulating his or her own label specific to the fabricated product.

Therefore, the fabricator is responsible for performing a hazard determination on each product he produces. The manufacturer of the fabricated product must consider anticipated downstream exposure potentials under normal conditions of use of the product and include appropriate hazard information on the product's accompanying label. As the manufacturer of the "value-added product", you are responsible under the HCS to make a similar hazard determination for all the materials comprising your final product such as the "ASJ and FRK facing" and the material used to adhere the facing to the fiber glass board. Any material found to be a health hazard under the HCS must be included on the final product's MSDS. You may rely on the hazard determination performed by the manufacturer of each of the materials used in your fabrication process. Material safety data sheets (MSDSs) for each of the components of your product may be physically attached to one another and serve as the combined MSDS for a product so long as the composite MSDS's are identified as a whole and can be cross-referenced with the required label.

You can not, however, place multiple labels on your product. The HCS requires the name and address of the manufacturer to be on the label of the product. As the manufacturer or fabricator of the "value-added" product you describe, your name and address must appear on the label. One label, therefore, is necessary for each of the products you manufacture, even though more that one MSDS may be combined to serve as the MSDS information for the product. The identity of the product on the combined MSDS must be the same as on the label to allow employees to access the appropriate material safety data sheet.

I hope this discussion has been helpful to you. Please feel free to contact us again if we can be of further assistance to you.


Patricia K. Clark, Director Designate
Directorate of Compliance Programs