Applicability of the Hazard Communication Standard to stevedores in the containerized shipping 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 17, 1988

Alan J. Kaplan, Director
Safety Engineer
Sea-Land Corporation
Post Office Box 800
Iselin, New Jersey 08830

Dear Mr. Kaplan:

This is in response to your letter of June 15, concerning the training requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) as applied to stevedores. Your letter requests reconsideration of our previous correspondence to you of June 6, 1988.

Definitions of target organ and hazards of chemicals 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.

September 17, 1987

Mr. Frank L. Pellegrini
Law Offices
A Professional Corporation
Suite 400, Chouteau Center
133 South Eleventh Street
St. Louis, Missouri 63102

Dear Mr. Pellegrini:

This is in response to your letter of July 21 concerning the Hazard Communication Standard, 29 CFR 1910.1200.

Your questions and our responses are as follow:

Question 1:

Define target organs.

Answer:

Application of the Hazard Communication Standard to art materials 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.

September 17, 1987

Mr. Martin J. Neville
Fanelli, Neville, Varian & Staker
Attorneys at Law
277 North Avenue
New Rochelle, New York 10801

Dear Mr. Neville:

This is in further response to your letter of July 17, concerning the application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard to the art materials industry.

National Paint and Coatings Association's (NPCA) Health Effects Labeling Approach

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.

September 10, 1987

Mr. J. Andrew Doyle
Counsel National Paint & Coatings Association
1500 Rhode Island Avenue, N.W.
Washington, D.C. 20005

Dear Mr. Doyle:

Thank you for the opportunity to review and comment on the National Paint and Coatings Association's (NPCA) Health Effects Labeling Approach (Advance Supplement to Volume II May 7, 1987).

Presence of chromium in monocomponent photocopier toner is under investigation.

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.

 

Applicability of the HCS to manufacturers of steel coils.

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 18, 1987

Mr. John W. Comrie
Corporate Counsel
IPSCO Incorporated
Post Office Box 1670
Regina, Saskatchewan, Canada S4P 3C7

Dear Mr. Comrie:

This is in response to your letter of July 10, regarding compliance with the Occupational Safety and Health Administration's Hazard Communication Standard (OSHA), 29 CFR 1910.1200.

High speed cobalt steel drill bits evaluated as a "article" 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 2, 1986

Mr. Charles M. Mullen, Jr.
Safety Engineer
Precision Twist Drill Company
301 Industrial Avenue
Crystal Lake, Illinois 60014

Dear Mr. Mullen:

This is in response to your letters of August 19 and 26 regarding the "article" definition given under the Hazard Communication Standard, 29 CFR 1910.1200. Specifically, you asked if a drill bit meets this definition.

General information related to 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.

September 26, 1986

Mr. Albert G. Romanchuk, Sr.
President
Romanchuk Floor Maintenance, Inc.
P.O. Box 83
South Wales, N.Y. 14139

Dear Mr. Romanchuk:

Thank you for your letter of September 5 requesting information from the Occupational Safety and Health Administration (OSHA) related to the Hazard Communication standard.

Hazard Communication Standard as it applies to wholesalers and distributors of 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.

September 16, 1986

The Honorable Dan Glickman
Member, U.S. House of Representatives
U.S. Court House Box 403 - Room 224
Wichita, Kanssas 67201

Dear Congressman Glickman:

Requirements for listing multiple exposure limits on MSDSs under 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.

August 18, 1986

Paul W. Willard, Ph.D.
Manager, Product Regulatory
Toxicology
3M Center
St. Paul, Minnesota 55144

Dear Dr. Willard:

This is in response to your letter of June 25 concerning the requirements for listing multiple exposure limits on material safety data sheets under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).