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OSHA Hazard Communication Letters of Interpretation
Labeling provisions.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Old label specifications are superseded; no OSHA endorsement implied
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its principle that warnings must communicate real hazards remains useful, as does the distinction between informal review and OSHA approval. However, the old three-item shipped-label list and proposed ANSI wording are not current labeling specifications.
Under the current HCS, apply hazard classification, shipped-container label elements and Appendix C and current flammable-liquid criteria. Signal words and hazard/precautionary statements now have defined functions; the old grouping of these terms should not be used as a modern glossary. The 1994 draft ANSI review does not authorize replacing mandatory hazard statements with discretionary language. The 1994 rulemaking was published that day but took effect March 11; modern requirements arise from later revisions as well.
OSHA marks its matching original corrected 12/6/2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 9, 1994
Mr. Morton L. Mullins
Vice President-Regulatory Affairs
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C. 20037
Dear Mr. Mullins:
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Thank you for your letter of December 1, 1993, addressed to Mr. Joseph A. Dear, Assistant Secretary of Labor, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS], labeling provisions. Specifically your letter requested that OSHA review section 5.2 of the draft revision ANSI Z129.1 for consistency with OSHA's position on target organ labeling, as well as consider harmonizing several terms used to characterize flammability.
As you know the HCS requires that a chemical shipping label must contain the identity of the chemical, an appropriate hazard warning, and the name and address of the responsible party. The agency's position stated in the current compliance directive (CPL 2-2.38C) [ILPI note: Original: CPL 2-2.38C (October 22, 1990). Current counterpart: CPL 02-02-079.] is:
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This historical label list is obsolete. Current shipped-container label elements and Appendix C supplies the required elements; an old ANSI review or old target-organ warning alone does not establish compliance.]
Precautionary statements such as "caution", "danger" or "harmful if inhaled" are not hazard warnings. The definition of hazard warning states that the hazard warning must be included on the label and must specifically convey the hazards of the chemical. OSHA has consistently maintained that this includes target organ effects."
You mentioned the sixth Circuit Court of Appeals decision in the matter of L. Martin v. American Cyanamid which was decided on September 15, 1993. This decision upheld OSHA's long standing interpretation that the agency's HCS requires manufacturers, distributors and importers of hazardous chemicals to list target organ effects on container labels of hazardous substances shipped to downstream users
In terms of section 5.2 of the draft revision ANSI Z129.1, the target organ labeling instruction in this document is consistent with OSHA's position as stated above and further elaborated in CPL 2-2.38C [ILPI note: Original: CPL 2-2.38C (October 22, 1990). Current counterpart: CPL 02-02-079.]. However, the use of the phrase "Based on Animal Data" in section 5.2.1 and 5.2.2 is not recommended on the label. Significant scientific and technical expertise is required to evaluate and interpret animal data. The use of this proposed labeling information could diminish the impact of the warning label on employees who typically do not have this expertise to make judgements on animal exposure compared to human exposure.
Regarding the Agency's review of the proposed ANSI Standard as a matter of policy, OSHA does not approve materials developed by the private sector. OSHA staff have informally reviewed a number of materials at the request of the organizations preparing them, and have pointed out to them any inaccuracies or inconsistencies. However, in no case have these informal agency actions served as an endorsement or approval of such materials.
We are aware of the differences in the definition of flammability and combustibility between OSHA and the Department of Transportation. The agency is reviewing this issue and is deciding on our course of action. We appreciate your assistance in further clarifying this issue.
We hope this information is helpful. If you have any further questions please contact us at (202) 219-8036.
Sincerely,
H. Berrien Zettler, Deputy 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/1994-02-09.