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OSHA Hazard Communication Letters of Interpretation
Container labelling requirements.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Old 100°F distinction and enforcement rationale are superseded
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its 100°F flammable/combustible distinction and the resulting historical de-minimis rationale are not current HCS classification or label guidance.
Under the current HCS, use Appendix B.6 flammable-liquid categories, shipped-container label elements and Appendix C and actual flash-point/initial-boiling-point data. A 101°F flash point falls within the modern flammable-liquid range; do not retain the old combustible-only conclusion. De minimis is an enforcement concept, not permission to replace current mandatory criteria with an old ANSI definition. Other fire/transport standards can use different classifications; identify the applicable rule.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
October 11, 1994
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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 [ILPI: Original HCS 1994 context · Current HCS], 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 [ILPI: Original HCS 1994 context · Current HCS] defines "flammable liquids" as:
[ILPI note: At issuance: HCS 1994, pre-GHS archive. This old definition is superseded. Current Appendix B.6 classifies flammable liquids by modern criteria; the old 100°F boundary and letter's de-minimis conclusion do not decide current labeling.]
"Liquid, flammable means any liquid (chemical) having a flash point below 100 degrees F (37.8 degrees C), except any mixture having components with flashpoints of 100 degrees F or higher, the total of which make up 99 percent or more of the total volume of the mixture."
OSHA, the National Fire Protection Association (NFPA), the Department of Transportation have similar definitions for "flammable liquid." If industry were to use the proposed ANSI flammable liquid definition, then chemicals labeled as flammable according to the proposed ANSI standard would be labelled as combustible under the NFPA and OSHA's HCS. Therefore, using the proposed ANSI definition would be considered a technical violation of the HCS and classified as de minimis. A de minimis violation is a violation of a standard that has no direct bearing on employee safety and health.
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.
Sincerely,
John B. Miles, Jr., 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/1994-10-11-1.