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|Title: 06/29/1987 - The HCS's requirement for target organ effects on labels for shipped containers of hazardous chemicals.|
|Record Type: Interpretation||Standard Number: 1910.1200|
June 29, 1987
Mr. Frank L. Pellegrini
A Professional Corporation
133 South Eleventh Street
St. Louis, Missouri 63102
Dear Mr. Pellegrini:
The definition of "health hazard" located at 29 CFR 1910.1200(c) includes a reference to Appendix A, which provides further definitions and explanations of the scope of health hazards. Section 1910.1200(d), "Hazard determination," also, states that Appendix A is to be consulted for health hazards covered.|
The first paragraph of Appendix A makes it clear that employees exposed to health hazards must be apprised of both the change in body function and the signs and symptoms that may occur to signal the changes. Appendix A includes a target organ categorization of health effects that may occur. Examples of signs and symptoms of exposure, as well as indications of substances which have been found to effect the target organs, are set forth at the end of Appendix A. The reference to the change in body function and to target organ effects in Appendix A makes it clear that "appropriate hazard warnings" for any given hazardous substances are those that warn about potential danger of significant risk. Appendix A. in referring to target organ effects states that "these examples are presented to illustrate the range and diversity of effects and hazards found in the workplace, and the broad scope employers must consider in this are, but are not intended to be all-inclusive." Appendix C lists sources that employers may use to evaluate the hazards of chemicals they produce or import and the body parts that may be effected.
Safety Emporium carries target organ labels you can use for OSHA compliance.
The "hazard warning" must convey the hazard of the chemical. Appendix A makes it clear that employees must be apprised of the change in body function and the signs and symptoms that may occur to signal that change.|
It is our position that when 1910.1200(f)(1)(ii) is read in conjunction with the definitions of `hazard warning' and `health hazard', set forth at 1910.1200(c), and the provisions for hazard determination set forth in 1910.1200(d), it is clear that the intent of the labeling requirement goes far beyond the effects must be included on the label is a reasonable interpretation of the 'appropriate hazard warning' requirement. OSHA feels that this interpretation is consistent with the underlying goal of the standard.
I hope your questions have been answered. If you need further assistance, please feel free to contact me again.
Leo Carey, Director
This handy poster explains the common hazardous chemical labeling systems. Get yours at Safety Emporium.
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=19562&p_text_version=FALSE