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OSHA Hazard Communication Letters of Interpretation
Interpretation for treated wood products in regards to paragraphs (f)(2)(i)-(iii) of the HCS
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Exposure to treatment chemicals still limits the exception
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main conclusion remains consistent: the solid-material labeling exception does not automatically cover treatment chemicals available to employees during handling or transit.
Under the current HCS, the relevant exception is (f)(4), formerly(f)(2). It does not waive chemical warnings for separately available treatment chemicals. Apply wood-product coverage, shipped-container label elements and Appendix C and SDS transmission to the actual product and shipment. Do not infer that every wood product is uncured; the finding depends on the described exposure situation. See downstream context.
OSHA marks its matching original corrected 6/2/2005.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 17, 1994
Keep informed about workplace hazards with proper labeling techniques and safety posters available from Safety Emporium.
Mr. Martin Wikstrom Manager, Government Affairs
American Wood Preservers Institute
Tysons International Building Suite 150
Vienna, VA 22182
Dear Mr. Wikstrom:
Thank you for your letter of August 1, concerning the Occupational Health and Safety Administration's (OSHA's) final Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], recently published in the Federal Register on February 9, 1994.
You requested an interpretation for treated wood products in regards to paragraphs (f)(2)(i)-(iii) of the HCS [ILPI: Original HCS 1994 context · Current HCS; solid-material exception now (f)(4)]. It is OSHA's understanding that treated lumber is not completely cured at the time of its initial distribution. Therefore, the hazardous chemical will, to a varying degree, leach out of the treated lumber and be available for exposure to employees.
Based on the information that you have provided us, OSHA concludes that labels must be provided on each shipment of treated wood. Please bear in mind that ultimate compliance with the OSHA regulations will be determined by the local OSHA Area Office serving your geographical area. The standard's requirement is stated specifically in paragraph (f)(2)(iii) [ILPI: Original HCS 1994 context · Current HCS; solid-material exception now (f)(4)], which is provided below:
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Current counterpart: solid-material exception. The exception does not extend to hazardous treatment chemicals available during handling/transit; modern shipped-label elements also apply.]
"(iii) This exception to requiring labels on every container of hazardous chemicals is only for solid material itself, and does not apply to hazardous chemicals used in conjunction with, or known to be present with the material and to which employees handling the items in transit may be exposed (for example, cutting fluids or pesticides in grains)."
The HCS necessitates a "downstream flow of information" which means that producers of hazardous chemicals have the primary responsibility for generating and disseminating information, while the users must obtain the information and transmit it to their employees.
We hope this information is helpful. If you have any further questions, please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Ruth E. McCully, Director Office of Health Compliance Assistance
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-11-17.