Application of the HCS to non-manufacturing scrap dealers who collect waste metal for resale.
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 23, 1986
Mr. Edward L. Merrigan
Washington Council
National Association of Recycling Industries, Inc.
6000 Connecticut Avenue, N. W.
Washington, D. C. 20815
Dear Mr. Merrigan:
This is in response to your letter of January 13 requesting an "interpretation, ruling, or modification" regarding the Hazard Communication Standard (HCS) (29 CFR 1910.1200) promulgated by the Occupational Safety and Health Administration (OSHA) on November 25, 1983. Please accept my apologies for our delay in replying.