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|Title: 11/09/1990 - Container labeling requirements under the OSHA Hazard Communication Standard|
|Record Type: Interpretation||Standard Number: 1910.1200(f)|
November 9, 1990
Mr. John W. Boyan
General Services Administration,
Western Distribution Center
(9FS) Rough and Ready Island,
Stockton, California 95203
Dear Mr. Boyan:
Thank you for your letter of October 24, regarding interpretation of the Occupational Safety and Health Administration's (OSHA) container labeling requirements under the Hazard Communication Standard (HCS), 29 CFR 1910.1200(f).
Your letter presents the following interpretation which you received from Ms. Jennifer Miller of OSHA's Training Institute regarding this issue:
There is no OSHA requirement for hazardous warning labels on the outer shipping container.]"
If the shipping container is the actual container holding the hazardous chemical, it would have to be labeled in accordance with the HCS, but labeled in such a way that the "appropriate hazard warning" did not interfere with any DOT required shipping labels or container shipping information.|
We hope this clarifies this issue for you. For your further reference, we are enclosing a copy of OSHA's recently revised compliance instruction, CPL 2-2.38C, "Inspection Procedures for the Hazard Communication Standard," (issued October 22, 1990). This document contains interpretative language and guidance on OSHA policies and procedures for compliance with the requirements of this performance-oriented standard. We hope this information is useful to you. Please feel free to contact us again if we can be of further assistance.
Patricia K. Clark Director
Get your DOT labels, placards, and accessories at Safety Emporium.
October 24, 1990
Patricia K. Clark, Director
Directorate of Compliance Programs
OSHA U.S. Department of Labor,
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C. 20210
Dear Ms. Clark:
This is to request your assistance in interpreting CFR 29 1910.1200 (f), Labels and Other Forms of Warning. Our Safety Officer has been in contact with your associates at the OSHA Technical Institute in Des Plains, Illinois. Ms. Jennifer Miller informed us that her interpretation of this regulation, after discussion with your office, is the following:
Your assistance in this matter will be greatly appreciated. If you need to discuss this matter in greater detail please contact our Safety Officer, Linda Richison at FTS 463-6346/6347 or Commercial (209) 946-6346/6347 (Fax 463-6214).
John W. Boyan
Western Distribution Center (9FS)
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=20121&p_text_version=FALSE