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|Title: 07/23/1990 - Regarding the application of the OSHA's Hazard Communication Standard to the labeling of fabricated products.|
|Record Type: Interpretation||Standard Number: 1910.1200|
July 23, 1990
Mr. Raymond D. Tripp
National Insulation and Abatement Contractors Association
99 Canal Center Plaza
Alexandria, Virginia 22314
Dear Mr. Tripp:
Thank you for your letter of June 12, regarding the application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 to the labeling of fabricated products.
Specifically, you wanted to know if the fabricator of a product must formulate a label specific to the fabricated product or if the fabricator may simply attach a label or multiple labels developed by the original manufacturer(s) to the fabricated products when the components have been chemically unchanged. Under the HCS, a fabricator of a product capable of resulting in downstream exposure to employees working with it is responsible for transmitting hazard information just as a chemical manufacturer would under the HCS. As such, the fabricator is responsible for formulating his or her own label specific to the fabricated product.
|Therefore, the fabricator is responsible for performing a hazard determination on each product he produces. The manufacturer of the fabricated product must consider anticipated downstream exposure potentials under normal conditions of use of the product and include appropriate hazard information on the product's accompanying label. As the manufacturer of the "value-added product", you are responsible under the HCS to make a similar hazard determination for all the materials comprising your final product such as the "ASJ and FRK facing" and the material used to adhere the facing to the fiber glass board. Any material found to be a health hazard under the HCS must be included on the final product's MSDS. You may rely on the hazard determination performed by the manufacturer of each of the materials used in your fabrication process. Material safety data sheets (MSDSs) for each of the components of your product may be physically attached to one another and serve as the combined MSDS for a product so long as the composite MSDS's are identified as a whole and can be cross-referenced with the required label.|
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I hope this discussion has been helpful to you. Please feel free to contact us again if we can be of further assistance to you.
Patricia K. Clark, Director Designate
Directorate of Compliance Programs
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=20044&p_text_version=FALSE