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OSHA Hazard Communication Letters of Interpretation
Review and comment on generic labels and consumer information sheets for chromated copper arsenate (CCA) pressure-treated lumber.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: No OSHA approval implied; current hazards and EPA use restrictions also matter
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main HazCom conclusions remain useful: OSHA does not preapprove labels, and a consumer information sheet does not replace the supplier's required SDS or complete hazard evaluation.
Under the current HCS, apply hazard classification, wood-product exemption and its limits, shipped-container label elements and Appendix C and SDS transmission. Chemically treated wood is not automatically exempt as ordinary lumber. Evaluate anticipated dust and relevant additives. EPA's CCA resource describes later restrictions on most residential uses; this letter does not approve a current treatment/use. EPCRA reporting remains separate from workplace HCS obligations.
OSHA marks its source “Reviewed; consistent with current policy” dated February 14, 2008. That dated review is not a new approval of a current product or label.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 31, 1994
Mr. Mike Sessa
Hickson Timber Protection
3941 Bonsal Road
Conley, Georgia 30027
Dear Mr. Sessa:
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Thank you for your letter of June 30, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]. Your inquiry requested review and comment on generic labels and consumer information sheets for chromated copper arsenate (CCA) pressure-treated lumber.
The HCS does not require manufacturers to obtain prior OSHA approval of their product labeling. Likewise, it is not the responsibility of OSHA to evaluate the consumer information sheet for CCA pressure-treated wood. Further, OSHA's evaluation of the proposed label for CCA pressure-treated wood would compromise the responsibility of the manufacturer to complete all hazard determinations for this product. Under the HCS, the manufacturers of CCA pressure-treated lumber are responsible for chemical hazard information (Material Safety Data Sheets, labels, etc.) to be transmitted to downstream employers.
In our conversations, it is OSHA's understanding that the hazard evaluation for CCA pressure-treated lumber has not been completed. Therefore, the proposed label for CCA pressure-treated wood may not provide employees with the appropriate hazard warning information. For example, any chemical additives present in the wood which represent a health hazard must be included on the MSDSs and/or label as appropriate.
Additionally, the consumer information sheet is not required by the HCS. For clarification, the Emergency Planning and Community Right-to-Know Act (EPCRA) provides that owners or operators of facilities must submit information in the form of material safety data sheets (MSDSs), as required by the Occupational Safety and Health Act, or emergency and hazardous chemical forms about the hazardous substance at their facilities to the local emergency planning committee, the state emergency response commission, and the local fire department. In turn, this information may be restructured into information/fact sheets for interested community residents.
Further, EPCRA requires facility to government reporting, with annual inventory updates. The statute does not mandate facility to consumer reporting. On a federal level, consumer information sheets cannot substitute for the emergency and hazardous chemical forms, nor can they be used by the manufacturer to substitute for an MSDS under 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS].
[ILPI note: At issuance: HCS 1994, pre-GHS archive. A consumer sheet is not a substitute for a required current SDS. Apply SDS requirements and actual wood-product coverage; EPA treatment/use and reporting requirements are separate.]
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,
Ruth McCully, Director Office of Health Compliance Assistance
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-08-31.