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|Title: 10/11/1994 - Container labelling requirements.
|Record Type: Interpretation
|Standard Number: 1910.1200
October 11, 1994
Mr. Russell K. Snyder, General Manager
Asphalt Roofing Manufacturers Association
6000 Executive Boulevard Suite 201
Rockville, Maryland 20852-3803
Dear Mr. Snyder:
Thank you for your letter of August 15, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200, container labelling requirements. In your letter you were concerned about the proposed revision ANSI Z129.1-1994, American National Standard for Hazardous Industrial Chemicals - Precautionary Labeling and its compliance with the HCS. Your specific question is reiterated below.
"Would a liquid with a flashpoint of 101 degrees F, labelled as a flammable liquid, be in compliance with the HCS? Said another way: Is the use of the ANSI "flammable liquid" definition for hazard communication permitted by OSHA as an alternative to the one contained in the HCS? If so, is there a list of acceptable alternatives to other HCS definitions which we can obtain from OSHA?"
On February 9, 1994 OSHA published the modified final rule for the HCS that included a number of minor changes and technical amendments to further clarify the requirements and ensure full compliance. Section (c) of the HCS defines "flammable liquids" as:
Using flammable liquids? OSHA requires that you have store them in proper cabinets such as these available at Safety Emporium.
We hope this information is helpful. If you have any further questions please feel free to contact the Office of Health Compliance Assistance at (202) 219-8036.
John B. Miles, Jr., Director Directorate of Compliance Programs
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=21613&p_text_version=FALSE