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OSHA Hazard Communication Letters of Interpretation
HCS application to vehicles, vehicle components, and replacement batteries
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Core vehicle-system distinction generally retained
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central distinction remains useful: the current definition of container excludes engines, fuel tanks, and other operating systems in a vehicle. A vehicle's operating systems should be distinguished from separate containers of hazardous fuels, acids, or other chemicals supplied for use or servicing.
This is not a blanket exemption for every battery, replacement component, or product used with a truck. Evaluate the actual item under the article definition and applicable current HCS scope, including hazards of normal use and foreseeable emergencies. Hazardous chemicals that remain covered require applicable labels, SDSs, and employee information and training; see the SDS FAQ discussion of articles.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 11, 1986
Mr. Davis Thekkanath Sr.
Supervising Engineer
Oshkosh Truck Corporation
2307 Oregon Street
Oshkosh, Wisconsin 54903
Dear Mr. Thekkanath:
This is in response to your letter of June 25 regarding the Hazard Communication Standard (HCS).
Ensure your workers are trained with safety posters and more from Safety Emporium.
The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. It is our interpretation that items such as a truck radiator, an engine, or a battery are not containers and therefore would not be required to be labeled. However, the containers that held such chemicals as ethylene glycol and battery acids would need to be labeled since they meet the definition of a "hazardous chemical" under the standard.
[ILPI note: Current counterpart: container definition, excluding engines, fuel tanks, and other vehicle operating systems. A separately supplied battery or chemical product requires its own article/scope analysis; the vehicle-system discussion is not a blanket product exemption.]
If you have any further questions, please feel free to contact us again.
Sincerely,
John B. Miles, Jr., Director
June 25, 1986
John B. Miles Jr., Director
Directorate, Field Operations
U.S. Department of Labor
OSHA
200 Constitution Ave. N.W.
Washington, DC 20210
Subject: 29 CFR Part 1910.1200 Hazard Communication
Gentlemen:
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
Oshkosh Truck Corporation is a manufacturer of heavy duty trucks. The trucks as shipped to our customers, have ethylene glycol solution in the radiator, lubricating oil in the engine transmission and axles, battery fluids in the battery, to name a few. Our question concerns the applicability of the subject requirements for the vehicle operation.
Mr. Steve Simon, of your office, in a recent telephone conversation with the writer advised that the subject regulation is not applicable to items on the vehicle that are functional requirements for vehicle operation.
We would therefore appreciate your confirming this in writing at you earliest.
Sincerely,
OSHKOSH TRUCK CORPORATION
Davis Thekkanath Sr.
Supervising Engineer
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-08-11.