Separate SDSs and labels for dual components

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 9, 2017

Mr. John P. Lenore
Quaker Chemical Corporation
13210 Barton Circle
Whittier, California 90605

Dear Mr. Lenore:

HCS Labeling requirements regarding intra-plant and intercompany shipping

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 3, 2018

Mr. David O. Rivers
R&S Compliance Group, LLC
2707 W. Price Ave
Tampa, Florida 33611

Dear Mr. Rivers:

Labeling refrigerant cylinders

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 3, 2016

Ms. Caroline Davidson-Hood
Air-Conditioning, Heating, and Refrigeration Institute 
2111 Wilson Blvd., Suite 500
Arlington, Virginia 22201

Dear Ms. Davidson-Hood:

HCS pictogram labeling of DOT-39 Non-Refillable Cylinders

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 12, 2018

Mr. Joe Trauger 
Senior Vice President of Policy and Government Relations
Air-Conditioning, Heating, and Refrigeration Institute
2111 Wilson Blvd., Suite 500
Arlington, Virginia 22201

Dear Mr. Trauger:

Listing and disclosing Benzene as a human carcinogen on the label and SDS

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.

July 24, 2017

Dr. Burton Z. Davidson, Ph.D, P.E.
31 Chandler Ct.
Monroe Township, New Jersey 08831

Dear Dr. Davidson:

Conformation of labeling requirements of 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.

 

Maintaining MSDSs on a computer data base.

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 Laboratory Standard; MSDS and labeling requirements.

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 28, 1999

Ms. Maricela Carter
Baker Hughes; Baker Petrolite
Safety Programs
3900 Essex Lane
Houston, TX 77027

Dear Ms. Carter,

Practical accommodation for hazard communication labels on small shipped chemical containers

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 11, 2013

Mr. John Davies, CIH
Henkel Corporation
32100 Stephenson Highway
Madison Heights, MI 48071

Dear Mr. Davies:

Acceptable use of pictograms on chemical labels under the revised 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.

December 23, 2014

Ms. Elena Frenkel
Senior Regulatory Officer
PHARMCO-AAPER
58 Vale Road
Brookfield, Connecticut 06804

Dear Ms. Frenkel,