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OSHA Hazard Communication Letters of Interpretation
Requirements under the Hazard Communication standard for visibility of labels on shipments of palletized bags.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical visibility allowance needs current label review
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its fact-specific allowance for labels hidden inside palletized bags should not be treated as general permission to ship hazardous chemicals with inaccessible labels. Under the current HCS, shipped-container label requirements and Appendix C apply, and paragraph (f)(9) requires labels to be legible, in English, and prominently displayed on the container or readily available in the work area throughout each work shift, as applicable.
Assess each hazardous-chemical container and how employees encounter it, rather than assuming that a pallet label replaces every bag label. The special current bulk-shipment provision is not a general exception for ordinary bags on a pallet. The letter's description of sodium carbonate hazards also does not replace current hazard classification of the actual product.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
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.
Source: OSHA's original letter page.
July 2, 1986
Mr. Frank J. Karasinski
Safety & Loss Prevention Manager
FMC Corporation
2000 Market Street
Philadelphia, Pennsylvania 19103
Dear Mr. Karasinski:
This is in response to your letter of May 29 concerning the labeling requirements of the Hazard Communication Standard (HCS), 29 CFR 1910.1200.
[ILPI note: At issuance: original 1983 rule (PDF). Current counterparts: required label elements and label legibility/display. The pallet-specific allowance below is not a general current exemption for hidden labels.]
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
Your letter raises questions about the visibility of labels on shipments of palletized bags. The purpose of a label is to provide an immediate visual warning to employees before a potential exposure to the products contents occur. Additionally the label identity serves as a point of cross reference with the material safety data sheet.
The standard's intent is met as long as the placement of the label permits it to be seen before employees are potentially exposed to the hazardous chemical. If for instance the product is flammable or shock sensitive then the label warnings must be visible before handling, so that special care if necessary, can be taken. On the other hand, for a product that only presents a toxicity hazard when a bag is opened then a label that is visible when the bag is readied for opening is acceptable.
As you can see proper placement of labels is dependent on a product characteristics and the ways and means employees may be exposed to them. Labeling therefore must be considered on a case by case basis. Obviously however, the more visible a label the better the chance that it will he effective.
We hope the above information will assist you in your HCS compliance activities. Please contact us again if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
May 29, 1986
Mr. John Miles
U.S. Department of Labor
OSHA
200 Constitution Avenue, N.W.
Room N-3606
Washington, D.C. 20210
Dear Mr. Miles:
I discussed today with Mr. Roy Gibbs the labeling requirements of the OSHA Hazard Communication Standard.
FMC manufactures sodium carbonate and ships it both in bulk and bagged form. On the bags all of the printed information is on one side, including the hazard statement and first-aid information.
Recently one of the distributors that FMC sells bagged sodium carbonate to on pallets was visiting one of his customers to whom he resells our soda ash (in the same FMC bags and on the same pallets). There is shrink-wrap around the bags on the pallets to hold them in place. Due to the nature of PMC's automatic palletizing equipment, the bags of sodium carbonate are placed on the pallet face down. Therefore the printed information, including the hazard statement, is not visible on any of the bags until the shrink wrap is removed and a bag is turned over.
An OSHA inspector happened to be at the location of the customer of our distributor. The inspector told the customer that the bags were not labeled properly since the hazard warming was not visible when the pallet was in an intact condition -- that is, with the shrink-wrap around it. There was not a question as to the content of the hazard warning. Apparently the inspector feels that additional labeling should be on each bag or on the wrapping of the pallet. Our customer has canceled their orders from us.
Sodium carbonate does not have a significant health hazard except for being an irritant in Certain Situations. In my discussion with Mr. Gibbs, he said that recently questions had arisen on the same issue. His initial interpretation was that due to the low degree of hazard of sodium carbonate, PMC was in compliance with HCS.
I would appreciate a written interpretation as soon as possible on this labeling issue so that we can give a satisfactory answer to our customer and also be in full compliance with the Standard.
Sincerely yours,
Frank J. Karasinski
Safety & Loss Prevention Manager
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-07-02-0.