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OSHA Hazard Communication Letters of Interpretation
Applicability of the revised Hazard Communication Standard to the grain industry.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Grain-dust coverage retained; distinguish separate exposure/control standards
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its main HazCom conclusion remains consistent: hazardous grain dust requires applicable information, labels, SDSs, and training. Current hazardous-chemical coverage expressly includes combustible dust; assess respiratory and other hazards as well as explosion potential.
The HCS communicates hazards rather than setting an exposure limit, but that does not mean no other OSHA rule limits grain dust. Current Table Z-1 lists a 10 mg/m³ eight-hour TWA for grain dust (oat, wheat, barley). Apply relevant grain-handling requirements and exposure-control duties separately. The letter's “merely requires hazard information” wording is not a waiver of those obligations.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 20, 1987
The Honorable Glenn English
House of Representatives
Washington, D.C. 20515
Dear Congressman English:
Thank you for your letter of October 27 on behalf of your constituent, Mr. Joe N. Hampton, Oklahoma Grain and Feed Association, regarding a change in regulations affecting the grain industry.
The rule in question is the Hazard Communication Standard (29 CFR 1910.1200) which was first promulgated by the Occupational Safety and Health Administration (OSHA) in 1983. On August 24, 1987, OSHA extended the application of this rule from the manufacturing industries (which includes some grain processing operations) to all industries where employees are exposed to any type of hazardous material (which would include grain elevators). A copy of the August 24 rule is enclosed for your use.
The rule affirms that employees have the right to know the hazards of materials they work with, as well as appropriate steps they can take to protect themselves. This is to be accomplished by having a hazard communication program in each covered facility, with labels on containers of such hazardous materials, more detailed information in the form of material safety data sheets, and employee training programs.
Grain dust is a hazardous material under the definition of the rule. In addition to evidence regarding its physical hazard potential (i.e., explosions in grain elevators), there are a number of studies which indicate that it causes respiratory problems in workers. It is thus subject to the rule to provide information to workers and to ensure that they are aware of proper protective measures. These types of activities have been implemented by many employers for years, but promulgation of the standard ensures a minimum level of protection for all exposed workers. The rule does not, as your constituent's letter implied, require grain dust to be eliminated nor does it set a permissible exposure limit for grain dust. It merely requires hazard information to be transmitted.
[ILPI note: The HCS itself does not set a PEL; separate current standards do. Table Z-1 lists grain dust (oat, wheat, barley) at 10 mg/m³ as an eight-hour TWA. Also check applicable grain-handling requirements. Historical HCS: 1910.1200, 1987 expanded rule (PDF).]
We hope this information will be helpful to you. If we can be of further assistance, please do not hesitate to contact us.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-11-20.