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.