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OSHA Hazard Communication Letters of Interpretation
Requirements for alternate warning methods, delays between filling and labeling a chemical container, and label identification of mixtures under HCS.
- Issued
- Record type
- Interpretation
- Historical standard references
- 1910.1200(c), (f)(4), (f)(5) and (g), original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Partly consistent; mixture SDS advice superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Under the current HCS, its distinction between stationary-process-container warnings and ordinary container labels remains broadly relevant (Questions 1 and 5), as does the use of a consistent product identifier rather than a complete ingredient list on a label (Question 3). However, the statement in Question 4 that mixture percentages need not be listed is superseded by current SDS requirements. The delay permitted in Question 2 should not be treated as general permission for unlabeled storage.
Current counterparts are workplace labeling, paragraph (f)(6), stationary process containers, paragraph (f)(7), and Appendix D, Section 3. The latter requires specified ingredient identities and concentrations or permitted ranges, including applicable trade-secret provisions in paragraph (i); the old blanket concentration cut-offs are not a substitute for the current disclosure criteria.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 25, 1984
Mr. Jim Wooldridge
Delta Solvents & Chemicals Company
610 Fisher Road
Longview, Texas 75604
Dear Mr. Wooldridge:
This is in response to your letter of July 23 to Gilbert J. Saulter, Regional Administrator, requesting clarifications of the Hazard Communication standard (29 CFR 1910.1200). Your questions are answered as follows:
- Must bulk chemical storage tanks and the plumbing be marked and labeled to show all hazards?
Answer: The standard permits several alternative warning methods under 1910.1200(f)(5) [ILPI note: Current counterpart: paragraph (f)(7), HCS 2024.] as follows:
(5) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraphs (f)(4) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.
[ILPI comparison: Current paragraph (f)(7) refers to paragraph (f)(6) for label information and assigns the employer responsibility for ensuring access to the written materials. The quoted 1983 wording above is preserved.]
Appropriate hazard warnings are required for all hazardous chemicals present.
- When containers are filled for storage must they be labeled on the distribution property?
Answer: Containers should be labeled as soon as practicable. A delay between filling and labeling is permissible. Bulk storage tanks from which filling is taking place must be labeled.
[ILPI note: Apply current workplace labeling requirements and any specific exception, such as immediate-use portable containers. This historical answer alone does not establish an acceptable delay for a particular operation.]
- Must the label identify all products in mixtures?
Answer: Employers need not list all of a product's constituents individually on the label. This interpretation is evident when one reviews the definition of the terms "identity" and "common name" under section 29 CFR 1910.1200(c) [ILPI note: Current counterpart: HCS 2024 product identifier definition (amended).] of the standard. Essentially, a common name may appear on the label as long as the material safety data sheet (MSDS) is similarly identified.
- Must Material Safety Data Sheets identify all products and percentages in mixtures?
Answer: The information required under 29 CFR 1910.1200(g) [ILPI note: Current counterpart: HCS 2024 SDS Section 3 requirements (supersedes the percentage advice below).] must be given only for the hazardous chemicals present within a product mixture, unless they are present in concentrations of less than 1.0 percent, and less than 0.1 percent for carcinogens. The standard does not require the listing of percentages of chemicals in mixtures. In the case of trade secrets or when specific information is unavailable, these facts must be explained on the MSDS; blanks are not permitted.
[ILPI note: Superseded in part. Current Appendix D, Section 3 requires specified health-hazard ingredient identities and concentrations, or permitted ranges. Ingredients posing a health risk below a cut-off may also require disclosure. Trade-secret claims have specific conditions; the historical statement that percentages are not required should not be followed.]
- Would signs posted in our drum filling area and storage area take the place of labels on our property?
Answer: No, containers must be identified as soon as possible. Signs may be used in place of labels on stationary process equipment pursuant to paragraph (f)(5) [ILPI note: Current counterpart: paragraph (f)(7), HCS 2024.] of the standard. (See answer to question number 1.)
Please feel free to contact us if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1984-09-25.