Application of the HCS to Borax Powered Hand Soap.

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.

June 30, 1986

Richard H. Schwank
President, PSP, Inc.
Peacher-Schwank Plastics, Inc.
10109 Two Notch Road
Columbia, South Carolina 29206

Dear Mr. Schwank:

President Reagan has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of May 21, concerning the application of the Hazard Communication Standard (HCS), 29 CFR 1910.1200 to Borax Powered Hand Soap.

Application of the Hazard Communication standard to waste oils.

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.

June 17, 1986

Mr. Paul Carstens
Safety Director
Petrochem Services, Inc.
Post Office Box 337
Lemont, Illinois 60439

Dear Mr. Carstens:

This is in response to your letter of June 17, concerning the application of the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200 to your waste oils. Please accept my apology for the delay in response.

Criteria for severe solvent refinement under the Hazard Communication Standard.

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.

May 6, 1986

Mr. Ed Starbuck
Vice President - Operations
San Joaquin Refining Co., Inc.
Standard & Shell Streets
P.O. Box 5576
Bakersfield, California 93388

Dear Mr. Starbuck:

This is in response to your letter of March 25, 1986 on the subject of criteria for severe solvent refinement under the Hazard Communication Standard.

Training requirements for post-emergency response operations

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 25, 1991

Mr. C. L. Pettit
Senior Analyst
Remedial Contractors Institute
Suite 1000
1730 Rhode Island Avenue, N.W.
Washington, D.C. 20036

Dear Mr. Pettit:

This is an update to your inquiry of December 20, 1990, concerning guidelines recently issued by the Occupational Safety and Health Administration (OSHA). We appreciate the opportunity to give you information on the intent of these guidelines (OSHA Instruction CPL 2-2.51).

Labeling and MSDS requirements for product containing trace quantities of ethylene oxide.; Criterion that must be satisfied in order to assert that a product or operation is exempt for the EtO Standar

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.

April 7, 1986

Ms. Diana L. Wilbur
Director of Safety
The Mogul Corporation
P. O. Box 200
Chagrin Falls, Ohio 44022

Dear Ms. Wilbur:

This is in response to your letter of September 9, 1985, concerning the Occupational Safety and Health Administration's (OSHA) standards for ethylene oxide (EtO) (29 CFR 1910.1047) and for hazard communications (29 CFR 1910.1200). I apologize for the delay in responding to your inquiry.

With regard to your first question, the ethylene oxide standard in 29 CFR 1910.1047(a)(2) states:

Application of the HCS to flavor extracts

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.

March 21, 1986

The Honorable Daniel P. Moynihan
United States Senate
Washington D. C. 20510

Dear Senator Moynihan:

This is in response to your letter dated March 4 on behalf of your constituent Mr. Barry Striem of Essential Products Co., Inc., regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). Mr. Striem expressed concern about the application of the HCS to flavor extracts used in his business.

Applicability of the HCS to castings.

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.

March 20, 1986

The Honorable Carl Levin
United States Senate
Washington, D.C. 20510

Dear Senator Levin:

This is in response to your letter dated February 6 on behalf of your constituent, Mr. Don Birtwistle of Great Lakes Castings Corporation, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).

Application of the Hazard Communication Standard to lift trucks.

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.

March 17, 1986

Mr. Kevin C. Donaghue
Rollins Burdick Hunter of Oregon, Inc.
Pacwest Center, Suite 600
1211 S. W. Fifth Avenue
Portland, Oregon 97204-3799

Dear Mr. Donaghue:

Thank you for your letter dated November 11, 1985, addressed to Mr. Carl Halgren, in regard to the Hazard Communication Standard. Please accept my apology for the delay in response. The overwhelming number of letters and telephone calls regarding the Hazard Communication Standard has caused unavoidable delays in responding to the public's concerns.

Hazard evaluation requirements under the Hazard Communication standard.

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.

March 12, 1986

Mr. Loren Anderson, CIH
International Business Machines, Corp.
740 New Circle Road
Lexington, Kentucky 40511

Dear Mr. Anderson:

This letter is in reference to our previous telephone conversation on March 12 regarding hazard evaluation.

MSDS and labeling requirements for copper or aluminum wire or metal products.

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.

March 11, 1986

The Honorable John H. Chafee
United States Senate
Washington, D.C. 20510

Dear Senator Chafee:

This is in response to your letter dated February 20 on behalf of your constituent, Mr. Bruce C. Ferguson of Ferguson Perforating and Wire Company, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).