Transmitting bulk shipment labels by technological or other means

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 9, 2022

Ms. Sarah J. Sorenson
The Mosaic Company
3033 Campus Dr., Suite W400
Plymouth, MN 55441

Dear Ms. Sorenson:

HCS 2012 labeling of refrigerant 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.

August 22, 2016

Mr. James Burke
USA Refrigerants
P.O. Box 289
Old Bridge, New Jersey 08857

Dear Mr. Burke:

Labeling outer containers of chemical cleaning products while in storage.

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 5, 2017

DEP/OHE/DM/27674

Mr. William Balek
Director of Legislative and Environmental Services
International Sanitary Supply Association (ISSA)
3300 Dundee Road
Northbrook, Illinois 60062-2303

Dear Mr. Balek:

 

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:

Hazard Communication Standard – SDS responsible party and hazards not otherwise classified

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 18, 2018

Messrs. Nick Stone and Kirk Nelson
Authoring Services Department
MSDSonline – A Velocity EHS Solution
222 Merchandise Mart Plaza, Suite 1750
Chicago, Illinois 60654

Dear Messrs. Stone and Nelson:

Applicability of the Hazard Communication standard to pesticides.

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 1, 1986

Mr. S. M. Duskin
Executive Vice President
Southern Agricultural
Chemicals Association
P.O. Box 686
Dawson, Georgia 31742

Dear Mr. Duskin:

This is in response to your letters of October 3, 1985, and April 10 regarding the Hazard Communication Standard (HCS). Please excuse our delay in responding and any inconvenience it may have caused.

The following are our responses to your specific questions, which we have repeated for ease of reference:

Labeling Provisions 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.

July 25, 1991

Mr. J. J. Hinton
Manager, Industrial Hygiene
Safety and Industrial Hygiene Department
Texaco Inc.
Post Office Box 1404
Houston, Texas 77251

Dear Mr. Hinton:

This is in further response to your letter of May 6, to the Occupational Safety and Health Administration (OSHA) regarding clarification of the labeling provisions of the Hazard Communication Standard (HCS), 29 CFR 1910.1200. I apologize for the delay of this response.

Labeling of small containers in the laboratory

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 3, 2015

Mr. Sumit K. Ghosh
Motorola Mobility, LLC
222 Merchandise Mart Plaza, Suite 1800
Chicago, Illinois 60654

Dear Mr. Ghosh:

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:

Hazard communication 2012-compliant labels and safety data sheets on shipped containers 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.

July 28, 2015

Ms. Martha Jolkovski
Acting Executive Director
Independent Lubricant Manufacturers Association
400 N. Columbus Street, Suite 201
Alexandria, Virginia 22314

Dear Ms. Jolkovski,