Use of multiple countries' information on labels 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.

February 10, 2015

Ms. Tammy L. Blakeslee, President
EnviroNet LLC
P.O. Box 386 M.O.
Shrewsbury, Massachusetts 01545

Dear Ms. Blakeslee:

Practical accommodation for the labeling of small packages 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.

February 10, 2015

Mr. Mark Collatz
Director of Regulatory Affairs
Adhesive and Sealant Council
7101 Wisconsin Avenue #990
Bethesda, Maryland 20814

Dear Mr. Collatz:

Correct use of product identifiers on safety data sheets and labels

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 19, 2015

Ms. Maureen Ruggeberg
Regulatory Affairs Specialist
Lawson Products, Inc.
8770 W. Bryn Mawr, Suite 900
Chicago, Illinois 60631-3515

Dear Ms. Ruggeberg:

Requirements for labeling of products shipped for export only to non-U.S. destinations, under the revised Hazard Communication Standard (HCS 2012)

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, 2015

Mr. Robert Soral
Product Regulatory Affairs Director
Oil-Dri Corporation of America
410 North Michigan Avenue
Chicago, Illinois 60611

Dear Mr. Soral:

Safety data sheets for custom blend fertilizers

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.

February 25, 2016

Mr. Chris Jahn
President
The Fertilizer Institute
425 Third Street, S.W.
Suite 950
Washington, DC 20024

Dear Mr. Jahn:

Container labeling requirements for importer under HCS 2012

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 20, 2016

Mr. Stuart Chundrlek
ThreeBond International Inc.
6184 Schumacher Park Drive
West Chester, Ohio 45069

Dear Mr. Chundrlek:

HCS labeling of imports and exports

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, 2015

Mr. Stephen Wieroniey
Manager, Occupational Health and Product Safety
American Coatings Association
1500 Rhode Island, N.W.
Washington, DC 20005

Dear Mr. Wieroniey:

What is the correct grouping/placement of the six required elements for labels

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 27, 2014

Mr. Mark Kardon
The Penray Companies, Inc.
440 Denniston Court
Wheeling, Illinois 60090-4731

Dear Mr. Kardon:

Labels on ampoules 5mL or smaller

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 20, 2013

Ms. Karen Bruntrager
Mr. Carlos Celestino
United States Pharmacopeial Convention
12601 Twinbrook Parkway
Rockville, MD 20852

Dear Ms. Bruntrager and Mr. Celestino:

Manufacturer's name and address on the label of a chemical product under HCS 2012

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 22, 2013

Mr. Dennis Morikawa
Morgan, Lewis & Bockius LLC
1701 Market Street
Philadelphia, PA 19103-2921

Dear Mr. Morikawa: