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OSHA Hazard Communication Letters of Interpretation
Application of the HCS to Borax Powered Hand Soap.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; consumer-product exemption depends on actual use
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central HazCom conclusion remains consistent with the current HCS: a qualifying consumer product may be exempt when workplace use results in exposure comparable to normal consumer use. Under current paragraph (b)(6)(ix), the employer must show use for the intended purpose and exposure duration and frequency no greater than reasonably experienced by consumers.
Hand soap or consumer packaging does not by itself establish the exemption. Frequent production use can fall outside it; assess actual tasks and exposure before concluding that labels, SDSs, or training are unnecessary. The separate personal-use cosmetics exemption may also be relevant when its conditions are met. See the SDS FAQ discussion of consumer products for practical context.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
June 30, 1986
Richard H. Schwank
President, PSP, Inc.
Peacher-Schwank Plastics, Inc.
10109 Two Notch Road
Columbia, South Carolina 29206
Dear Mr. Schwank:
President Reagan has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of May 21, concerning the application of the Hazard Communication Standard (HCS), 29 CFR 1910.1200 to Borax Powered Hand Soap.
Finished consumer products such as hand soap are exempt from the requirements of the Hazard Communication Standard. This exemption would apply as long as the product was used as it would be by a typical consumer. However, if a manufacturer purchases a product--such as cans of spray paint intended for short, one-application consumer use--and uses it in production operations, then a material safety data sheet must be provided.
[ILPI note: Current counterpart: consumer-product exemption, requiring intended use and exposure duration/frequency no greater than normal consumer exposure. See the SDS FAQ explanation; consumer packaging alone is not enough.]
The HCS is the result of over 10 years of rule-making activity. Considerable research, combined with intense public comment, have shaped the standard into what we feel is a workable and meaningful document.
We hope this information satisfies your concerns. Please feel free to contact me again if further assistance can be provided.
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/1986-06-30.