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OSHA Hazard Communication Letters of Interpretation
The OSHA Hazard Communication Standard and how it applies in various industries.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Potential release during removal still matters; no blanket encased-product exemption
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains useful: foreseeable repair, removal or demolition can create exposure even when a hazardous material was previously enclosed. Manufacturing, installation and removal are different exposure situations.
Apply scope, foreseeable emergencies, the full article definition and current information and training requirements. The old statement that labels/SDSs may not be enforceable describes particular circumstances; it is not a general waiver for every repair or demolition chemical. Separate EPA PCB requirements and actual waste status also matter. OSHA marks its source corrected December 6, 2024. Historical enforcement context: 1990 CPL 2-2.38C. Current counterpart: current HCS inspection procedures.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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, 1992
Mr. Dan Bigler
Environmental Energy Group
1032 Shady Oaks Drive
Suite 203
Post Office Box 50764
Denton, Texas 76206
Dear Mr. Bigler:
This is in response to your second letter of October 26, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].
Previously, you had written to Charles Adkins from OSHA's Health Standards Office explaining the potential hazards involved with the removal of old electric light ballasts containing polychlorinated biphenyls (PCBs). Mr. Adkins informed you that electricians installing light ballasts would not be exposed to PCBs under "normal conditions of use," and therefore would not be covered by the Hazard Communication Standard (HCS).
In your second letter you state that you concur with OSHA's interpretation, but ask how HCS would apply to other industries.
As long as PCBs are encased so that they will not present a threat of exposure, workers do not need to be advised of the hazards of PCBs. If employees were exposed to PCB's during the construction of electric light ballasts at the manufacturer's facility, the HCS would apply. During the removal and disposal of old light ballasts, the HCS may apply if the employer determines there is a threat of hazard exposure. OSHA instruction CPL 2-2.38C ILPI note: Original: CPL 2-2.38C (1990). Current: HCS inspection guidance., dated October 22, 1990, states the following in paragraph K.3.c.:
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Apply current scope and article conditions to potential release during actual removal, damage and foreseeable emergencies. Enclosure alone does not establish a universal exemption, and separate EPA handling/disposal duties remain.]
In some cases, a hazardous chemical may be present for a long period of time without an employee exposure until repair or demolition activities are performed. By way of example, employers involved in work operations where jackhammers are being used to break up a sidewalk know that they are exposing their employees to a hazardous chemical (silica), even though they did not "bring" the hazard to the site. Even though other provisions of the standard may not be enforceable (MSDS and labels), the employer should still develop a hazard communication program to inform their employees "about the hazardous chemicals to which they are exposed." Employers may utilize their already existing hazard communication program to communicate information on these types of hazards to their employees, as per paragraph (e)(3) [ILPI: Original HCS 1987 context (PDF) · Current HCS].
Information regarding the hazards of PCBs and appropriate protective measures is readily available. Employers whose employees are involved in operations where PCB exposure may occur under normal conditions of use or in foreseeable emergencies, should obtain such information and include it in their hazard communication program.
Environmental Protection Agency (EPA) regulations under the Toxic Substance Control Act may also apply (please see 40 CFR Part 761 - PCBs Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions). You may contact the EPA TSCA hotline at the following number: 1-800-835-6700.
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1992-11-20-0.