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|Title: 05/15/1993 - Fire extinguisher requirements of Hazard Communication Standard.
|Record Type: Interpretation
|Standard Number: 1910.1200
May 15, 1993
Mr. John L. Dowell III
7512 Connelley Drive
Hanover, MD 21076
Dear Mr. Dowell:
Thank you for your letter of February 11, requesting interpretation of the labeling requirement specified in the Hazard Communication Standard (29 CFR 1910.1200(f)) as it pertains to fire extinguishers. Your three questions are answered below in the order they were presented in the letter.
Question No. 1: Does Subpart Z apply to fire extinguishers?
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Roger A. Clark, Director
Directorate of Compliance Programs
February 11, 1993
Mr. Roger Clark
Director of Compliance Program
200 Constitution Avenue, NW
Washington, DC 20210
Dear Mr. Clark:
Within the fire suppression industry, there appears to be some confusion on HMIS requirements for fire extinguishers.
Safety Emporium.com carries hundreds of extinguisher signs and accessories!
The National Fire Protection Association 1990 Pamphlet 10, Section 1-7, requires content identification under the HMIS system for extinguishers manufactured after July 1, 1991.
More recently, we were made aware of the attached customer memo which indicates that OSHA requires labels on all extinguishers.
The referenced Subpart Z appears to have been taken from CFR-29 1910.1200(f). Our interpretation is that this section applies to process containers in a manufacturing setting and not to fire extinguishers.
Not wishing to rely on our interpretation, we would greatly appreciate it if you would state OSHA's position on the following:
The answers to the above questions will enable us to be in proper compliance as well as competitively price our service.
Very truly yours,
John L. Dowell III
The OSHA Hazard Communication Standard affects ALL businesses that produce, use, store or distribute ANY hazardous substance.
The Hazardous Materials Identification System (HMIS) is a TOTAL Right-to-Know compliance system. It includes the contents product name as it appears on the manufacturer's Material Safety Data Sheet (MSDS). It's easy to use and easy for your employees to understand. When used properly, it will help you fulfill the requirements of OSHA'S Hazard Communication Standard and various state Right-to-Know regulations.
Underwriters Laboratories (UL) listed fire extinguishers manufactured after July 1, 1991 include the HMIS information on the label.
Fireline Corporation, in order to help keep you in compliance with this law, will be attaching the correct HMIS label on your fire extinguishers that were manufactured prior to July 1, 1991 for a nominal fee of $1.10 each.
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(f) Labels and other forms of warning
(6) The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee who performs the transfer.
4605 Hollins Ferry Rd.
Baltimore, Maryland 21227
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=21121&p_text_version=FALSE