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OSHA Hazard Communication Letters of Interpretation
Requirements for target organ effects on labels under the Hazard Communication standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical target-organ guidance insufficient for current shipped labels
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its discussion of adding target-organ warnings to HMIS labels does not describe all current shipped-container requirements. Apply six required shipped-label elements and Appendix C, including prescribed hazard statements and pictograms as applicable. HMIS may be part of a workplace alternative under paragraph (f)(6); it is not by itself a replacement for a shipped label.
Current small-container provisions provide specific conditions and alternatives. The historical statement that no minimum container size is specified should not be used to bypass those requirements or to assume every aerosol container qualifies. Current hazard classification must address the actual aerosol and its health and physical hazards.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 10, 1986
Mr. Lloyd T. Flanner
Vice President
Aerosol Systems, Inc.
9150 Valley View Road
Macedonia, Ohio 44056
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This is in response to your letter dated August 18 regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.
[ILPI note: At issuance: original 1983 rule (PDF). Current counterparts: shipped-label elements, Appendix C, workplace alternatives, and specific small-container provisions. The old HMIS additions alone are not a complete current shipped label.]
The labeling requirements addressed in my June 3 memorandum to Regional Administrators has been changed. Target organ effects are no longer required for in-plant containers. Target organ effects, however, are still, and have always been, required for all shipped containers. Therefore, if you sell an aerosol product to manufacturing users, which contains a hazardous ingredient(s), the organs affected must appear on the label.
The HCS does not provide specifications for label size. However, the label must contain all of the labeling information required by the standard. If a HMIS label is to be used on a shipped container the target organ effects and the name and address of the chemical manufacturer must be added to the label.
If you have any further questions please feel free to contact us again.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
August 18, 1986
John B. Miles, Jr.
Director
Directorate of Field Operations
U.S. Dept. of Labor
Occupational Safety & Health Administration
Washington, DC 20210
Dear Mr. Miles:
I just received a copy of your memo dated June 3, 1986, to the Regional Administrators on labeling requirements for the Hazard Communication Standard. In your memo you make reference to labeling for target organ effects in addition to the HMIS identification system.
Our company manufactures aerosol products for many marketers who sell these cans to manufacturers. The cans are labeled with many warnings and the 2 1/2 inches by 6 inch panel used for directions, warnings and other label copy is filled now.
Please advise if there is a minimum size that requires the complete OSHA labeling. These cans are less than 1/2 pints and contain many materials found in the household like anti-static agents, silicones, oils, glass cleaners etc., but we sold to industry.
I also note this change takes effect on August 23, 1986. In some cases over 50,000 to 75,000 cans are out in distribution which may be there for over a year without this new labeling.
I would appreciate an early response. Thank you for your help.
Very truly yours,
Lloyd T. Flanner
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-11-10.