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|Title: 09/25/1984 - Requirements for alternate warning methods, delays between filling and labeling a chemical container, and label identification of mixtures under HCS.|
|Record Type: Interpretation||Standard Number: 1910.1200(c); 1910.1200(f)(4); 1910.1200(f)(5); 1910.1200(g)|
September 25, 1984|
Mr. Jim Wooldridge
Dear Mr. Wooldridge:
This is in response to your letter of July 23 to Gilbert J. Saulter, Regional Administrator, requesting clarifications of the Hazard Communication standard (29 CFR 1910.1200). Your questions are answered as follows:
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Answer: The standard permits several alternative warning methods under 1910.1200(f)(5) as follows:
Appropriate hazard warnings are required for all hazardous chemicals present.
Answer: Containers should be labeled as soon as practicable. A delay between filling and labeling is permissible. Bulk storage tanks from which filling is taking place must be labeled.
Answer: Employers need not list all of a product's constituents individually on the label. This interpretation is evident when one reviews the definition of the terms "identity" and "common name" under section 29 CFR 1910.1200(c) of the standard. Essentially, a common name may appear on the label as long as the material safety data sheet (MSDS) is similarly identified.
Answer: The information required under 29 CFR 1910.1200(g) must be given only for the hazardous chemicals present within a product mixture, unless they are present in concentrations of less than 1.0 percent, and less than 0.1 percent for carcinogens. The standard does not require the listing of percentages of chemicals in mixtures. In the case of trade secrets or when specific information is unavailable, these facts must be explained on the MSDS; blanks are not permitted.
Answer: No, containers must be identified as soon as possible. Signs may be used in place of labels on stationary process equipment pursuant to paragraph (f)(5) of the standard. (See answer to question number 1.)
John B. Miles, Jr., Director
Directorate of Field Operations
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19227&p_text_version=FALSE