Enforcement of the Hazard Communication Standard as it relates to "vegetable oil mist"

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 19, 1991

Dr. P. J. Wakelyn
Manager, Environmental Health and Safety
National Cotton Council of America
1110 Vermont Avenue, N.W., Suite 430
Washington, D.C. 20005

Dear Dr. Wakelyn:

Thank you for your letter of December 19, 1990, regarding our meeting of the previous day during which we discussed the Occupational Safety and Health Administration's (OSHA) enforcement of the Hazard Communication Standard (HCS), 29 CFR 1910.1200 as it relates to "vegetable oil mist."

Requirement for MSDSs with hazardous chemicals.

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.

August 28, 1992

The Honorable Michael R. McNulty
Member, United States House of Representatives
U.S. Post Office
29 Jay Street
Schenectady, New York 12305

Dear Congressman McNulty:

This is in response to your letter of July 24, to the Occupational Safety and Health Administration (OSHA), written on behalf of your constituent Mr. Robert J. Stein, Jr., of Delmar, New York. Mr Stein wrote to you concerning his inability to obtain a Material Safety Data Sheet (MSDS) for a product to which he was exposed in 1989.

Need to supply a material safety data sheet for oil lubricated compressors.

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.

November 2, 1987

James E. Lord
Kaeser Compressors, Inc.
239 Industrial Drive
P.O. Box 7416
Fredericksburg, VA 22404

Dear Mr. Lord:

This is in response to your letter to Angelo Costa of our Norfolk, VA office concerning the need to supply a material safety data sheet for oil lubricated compressors. Your letter was referred to this office for reply.

Clarification of requirements for 40 hours of training.; Site specific training is required for employees who receive general training.

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.

December 11, 1987

Mr. Gregory D. Kugler
Environmental Scientist
Andrews Environmental Engineering Inc.
1320 South Fifth Street
Springfield, Illinois 62703

Dear Mr. Kugler:

This is in response to your inquiry of September 22, requesting whether the certification program you described is equivalent to the 40 hours of training required in paragraph (e)(2) of 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response).

Coverage of wood dust under the Hazard Communication Standard (HCS)

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.

MEMORANDUM FOR:     REGIONAL ADMINISTRATORS

THROUGH:            DANIEL MICK, COUNSEL FOR REGIONAL TRIAL LITIGATION
                    LEO CAREY, DIRECTOR FIELD PROGRAMS

FROM:               THOMAS J. SHEPICH, DIRECTOR
                    DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Coverage of Wood Dust Under The Hazard
                    Communication Standard (HCS)

On September 9, 1986, a memo concerning the coverage of wood dust under the HCS was sent to you. The memo established the agency's position concerning citations for wood dust.

Standards applicable to the process of wrapping meat in plastic.

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.

November 23, 1987

Mr. Donn S. Dutton
High, Stack, Lazenby, & Palahach
Attorneys at Law
3929 Ponce De Leon Boulevard
Coral Gables, Florida 33134

Dear Mr. Dutton:

This is in response to your inquiry of October 28, concerning your client, Ms. Barbara Prince.

The Occupational Safety and Health Administration (OSHA) may have some air contaminant standards that are applicable to the process of wrapping meats in plastic. Before it can be established whether OSHA does, the air contaminants released would have to be identified.

Applicability of the revised Hazard Communication Standard to the grain industry.

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.

November 20, 1987

The Honorable Glenn English
House of Representatives
Washington, D.C. 20515

Dear Congressman English:

Thank you for your letter of October 27 on behalf of your constituent, Mr. Joe N. Hampton, Oklahoma Grain and Feed Association, regarding a change in regulations affecting the grain industry.

Clarification of Material Safety Data Sheet 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.

October 9, 1987

MEMORANDUM FOR:  REGIONAL ADMINISTRATORS

THRU:            LEO CAREY, DIRECTOR
                 DIRECTORATE OF FIELD OPERATIONS

FROM:            THOMAS SHEPICH, DIRECTOR
                 DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:         Clarification of Material Safety Data Sheet
                 Requirements Under the Hazard Communication Standard.

The following clarification relates to the Material Safety Data Sheet (MSDS) requirements of the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200.

Guidance on whether "patch test kits" are exempt from the labeling requirements of HCS.

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.

December 24, 1992

Dr. Clifford W. Lober
American Academy of Dermatology
930 N. Meacham Road
Post Office Box 4014
Schaumburg, Illinois 60168-4014

Dear Dr. Lober:

This is in further response to your inquiry of October 9, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

Additional requirements for distributors from the August 24, 1987 expansion of the HCS.

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.

October 5, 1987

Mr. Edward L. Merrigan
Attorney at Law
6000 Connecticut Avenue, N.W.
Washington, D.C. 20815

Dear Mr. Merrigan:

This is in response to your letter of September 17, requesting confirmation of previously provided interpretations of the Hazard Communication Standard, 29 CFR 1910.1200.