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.

October 20, 1999

James M. Kuszaj, Ph.D.
9650 Strickland Road
Suite 103-209
Raleigh, North Carolina 27615

Dear Dr. Kuszaj:

We are in receipt of your letter of March 22, 1999 regarding labeling provisions under the Hazard Communication Standard (HCS), 29 CFR 1910.1200. You described a labeling system used by your client and asked if this system meets the requirements of the HCS. This letter follows up on a phone conversation you had with a member of my staff. Please excuse this delay in providing these written comments.

The labeling system you described is designed for four different solvents with similar hazards. These solvents are used rotationally in one piece of equipment. You have proposed to label the equipment permanently with the manufacturer's name and the products' appropriate hazard warnings, including target organ effects. The solvent identity would be adhered to the equipment using  stick-on  labels. Differences in health effects that the solvents present (such as carcinogenicity) would be printed on the  stick-on  label.

The labeling requirements of the HCS include the identity of the hazardous chemical(s); appropriate hazard warnings; and the name and address of the chemical manufacturer, importer, or other responsible party. The labeling system you have proposed appears to meet these requirements.

Thank you for your interest in occupational safety and health. If you require further information, you may contact the Office of Health Compliance Assistance at 202-693-2190.


Richard E. Fairfax, Director
Directorate of Compliance Programs