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OSHA Hazard Communication Letters of Interpretation
Hazard Communication Standard (HCS) Labeling Requirements for Industrial Thermometers
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Article analysis remains useful; current label elements apply
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: thermometers expected to break during normal use and expose employees to mercury cannot simply be treated as exempt articles.
Under the current HCS, apply the complete article definition and article exemption, considering the actual conditions of use and release. See the article FAQ and mercury resource. Nonexempt products require the applicable shipped-container label elements and Appendix C or workplace labeling, along with SDSs and effective training; container labeling alone is not the entire current duty.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 17, 1989
MEMORANDUM FOR: JAMES W. STANLEY, REGIONAL ADMINISTRATOR
ATTENTION: ACTING ASSISTANT REGIONAL ADMINISTRATOR FOR TECHNICAL SUPPORT
THROUGH: LEO CAREY, DIRECTOR, DIRECTORATE OF FIELD PROGRAM
FROM: PATRICIA K. CLARK, ACTING DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS
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SUBJECT: Hazard Communication Standard (HCS) [ILPI: Original HCS 1987 context (PDF) · Current HCS] Labeling Requirements for Industrial Thermometers
This is in response to your memo of June 6, which forwarded a memo from the Manhattan Area Office requesting an interpretation of the Hazard Communication Standard [ILPI: Original HCS 1987 context (PDF) · Current HCS] as it applies to labeling requirements for industrial thermometers.
If industrial thermometers are expected to break during normal conditions of use, exposing employees to mercury, they are not considered articles for purposes of the HCS. Under the labeling provisions of the HCS each thermometer container would have to be labeled, tagged, or marked with the required label information.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Apply the complete current article definition and distinguish shipped from workplace label requirements. The original release/exposure reasoning is not a blanket exemption for all thermometers.]
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-07-17.