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OSHA Hazard Communication Letters of Interpretation
Evaluation of labeling system which was designed to meet the requirements of the HCS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Workplace alternatives retained; shipped-label information expanded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its recognition of alternative workplace labeling systems remains consistent with workplace-label alternatives, provided the system supplies the required information and works with accessible hazard information and employee training. A supplier's or consultant's label system does not eliminate the employer's responsibility to make its program effective.
The letter's shipped-label summary predates the six required shipped-label elements and Appendix C. A chemical name, general warning, and manufacturer details alone are not a complete current shipped label. Distinguish workplace rating systems from current hazard classification and prescribed shipped-label elements.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 4, 1987
Mr. Peter E. Kelly
Director of Safety and
Health
Timber Products Manufacturers
951 East Third Avenue
Spokane, Washington 99202
Dear Mr. Kelly:
Keep informed about workplace hazards with proper labeling techniques and safety posters available from Safety Emporium.
This is in response to your letter of April 14 regarding your company's labeling system which was designed to meet the requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard.
[ILPI note: At issuance: original 1983 rule (PDF). Current counterparts: workplace alternatives and six shipped-label elements with Appendix C. The historical shipped-label summary is incomplete under the current HCS.]
The Hazard Communication Standard requires employers to label each container of hazardous chemicals in the workplace with the following information:
In addition, if containers of hazardous chemicals are shipped, the name and address of the chemical manufacturer, importer, or other responsible party must also appear on the label.
The standard's preamble also recognizes the existence of the numerous labeling systems that are currently in use in industry. The intent of the standard is to permit the use of these systems as long as the employer's entire Hazard Communication Program (HCP) is effective. In assessing an employer's compliance with the standard, an OSHA compliance officer will evaluate the effectiveness of the employer's inplant labeling system through a review of the employer's material safety data sheets and training program. An effective program would be one that ensures that employees are aware of the hazardous effects of the chemicals they may be exposed to as well as meeting the other basic requirements of the standard. Hazard warnings used as part of inplant labeling systems, in combination with the HCP, are deemed to be effective when they promote safe handling and use of hazardous chemicals in the workplace.
From the label decal enclosed with your letter it appears that the chemical identity and health hazard warnings appear, in addition to a numerical hazard rating system. As long as the hazard warnings and/or ratings are correctly selected it appears your labeling system would meet the inplant labeling requirements of the Hazard Communication Standard. Please note that for shipped containers your labeling system could not rely on a numerical rating system and would have to be supplemented with the appropriate hazard warning(s) in a narrative form and include the target organ effect as well as the physical hazards of the chemicals.
If you have any further questions, please feel free to contact us again.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-05-04-0.