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OSHA Hazard Communication Letters of Interpretation
Requirements for spill containment mats under retail displays of lawn and garden chemicals within stores.
- Issued
- Record type
- Interpretation
- Historical HazCom standard
- HCS 1994
- Current HazCom standard
- HCS 2024, as amended
ILPI assessment: Narrow mat conclusion retained; spill-control duties remain
The narrow HazCom-related conclusion remains useful: this letter does not identify a universal federal OSHA requirement for mats in front of every retail chemical display. It does not waive necessary spill prevention, safe storage, training or protective measures for actual hazards.
Use ready SDS access and effective information and training for covered chemicals. Distinguish an incidental release from an emergency response and apply the appropriate HAZWOPER requirements when employees are assigned emergency response. The favorable facts about small-spill kits and outside contractors are case-specific; environmental, fire-code or State Plan rules can impose separate duties.
OSHA source notice: [Corrected 4/18/03]
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 1, 1995
Ms. Lori L. Herron
Risk Management Department
Frank's Nursery & Crafts
6501 East Nevada
Detroit, Michigan 48234
Dear Ms. Herron:
Train your employees to respond to emergencies with colorful workplace safety posters from Safety Emporium.
This letter is a response to your letter of January 27, regarding the Federal Occupational Safety and Health Administration (OSHA) requirements for spill containment mats under retail displays of lawn and garden chemicals within your stores. In a subsequent telephone conversation you stated that your employees are trained to handle small spills of a single product in accordance with the Material Safety Data Sheet (MSDS) for that product, using spill kits available in your stores. You also stated that large spills and mixed chemical spills are handled by an outside contractor and asked whether your stores could eliminate spill containment mats now used under in-store displays of pesticides, fertilizers, pool chemicals, and similar products.
Federal OSHA does not specifically require the use of spill containment mats in front of the shelving displaying chemicals for sale in stores. We understand you have addressed pertinent emergency response requirements through your program for small incidental as well as large chemical spills.
[ILPI note: Original HCS 1994 context · Current HCS. This is a narrow conclusion about the stated retail-display facts. It is not a waiver of actual spill-control measures, effective information and training, or emergency-response requirements. The following January 1995 letter is the requester's account, not an additional OSHA ruling.]
We hope this response provides useful clarification. If you have additional questions, please contact [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Ruth McCully, Director
[Directorate of Enforcement Programs]
[ILPI note: The following is enclosed incoming correspondence. Its requests, claims and proposals are the correspondent's, not additional OSHA interpretations.]
January 27, 1995
USDOL-OSHA
200 Constitutional Avenue
Room N-36377
Washington, DC 20210
RE: USE OF SPILL MATS WHERE CHEMICALS ARE DISPLAYED FOR SALE IN RETAIL BUSINESS
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Dear Sirs:
I am requesting a formal opinion on whether or not spill mats are an OSHA requirement in the following scenario:
Frank's Nursery & Crafts, Inc., is a retailer that sells crafts, lawn & garden products and pet supplies in approximately 17 states east of the Mississippi. We are not a manufacturer. During certain times of the year, we do sell common lawn and garden chemicals such as pesticides, fertilizers and pool chemicals. The liquid chemicals that Frank's sells are packaged in plastic containers usually containing not more than a gallon of 1 product each.
Frank's Nursery & Crafts, Inc., does have a Hazardous Communication program in place and spill kits are located at each facility.
What I am questioning is whether or not there is a Federal OSHA regulation that would require the placement of spill containment mats in front of the shelving displaying chemicals for sale in our stores.
Thank you for your courtesy.
Sincerely,
Lori L. Herron
Administrator
Risk Management Department
[Corrected 4/18/03]
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1995-05-01.