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OSHA Hazard Communication Letters of Interpretation
Hazard Communications Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Fire-hazard communication remains; modern classification and SDS sections apply
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its central conclusion remains useful: applicable spontaneous-heating/fire hazards and safe handling of contaminated materials must be communicated. It does not establish one classification for every formulation containing linseed oil.
Under the current HCS, assess the actual product under hazard classification, including self-heating criteria as applicable, then use shipped-container label elements and Appendix C. Relevant SDS content includes fire hazards, handling/storage and stability/reactivity. Disposal information has its heading in Section 13, whose content OSHA does not enforce; applicable fire, waste and other safety duties remain separate. An SDS should not omit known safe-handling precautions simply because disposal also falls under another agency.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 28, 1996
Mr. Richard F. Andree, CSP, PE, Ph.D.
326 Greenlawn Road
Greenlawn, New York 11740
Dear Dr. Andree:
Thank you for your letter of December 18, 1995, addressed to the Assistant Secretary of Labor, referring to the Hazard Communications Standard (29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]). Your letter was forwarded to the Directorate of Technical Support (DTS), Office of Science and Technology Assessment (OSTA) for response. I apologize for the delay in the response, caused by a heavier than normal workload after the Federal Government shutdown.
I will attempt to answer each question in the order they were presented:
Is it required to have the hazard of autoignition / spontaneous combustion identified on the label of products containing Linseed Oil?
According to 29 CFR 1910.1200(f)(1)(i) thru (iii) [ILPI: Original HCS 1994 context · Current HCS; modern shipped-label elements apply], labels and other forms of warning: the chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with certain information. In the case of linseed oil and products containing linseed oil, the hazard of autoignition / spontaneous combustion should be included in this information.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Use product-specific current classification and mandatory label elements, not only the old three-item label summary. Safe handling/storage and contaminated-material fire precautions belong in the relevant current SDS sections.]
Is it required to document in the MSDS of products containing Linseed Oil that the hazard of autoignition / spontaneous combustion exists?
According to 29 CFR 1910.1200(g) [ILPI: Original HCS 1994 context · Current HCS] Material Safety Data Sheets (MSDS), it is required that ingredients of all chemicals which have been determined to present a physical hazard when present in the mixture be documented. The MSDS should also contain physical and chemical characteristics of the hazardous chemicals. It must list the physical hazards of the hazardous chemical including potential for fire, explosion, and reactibility.
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Is it required to document in the MSDS of products containing Linseed Oil appropriate safety instructions for the disposal of material contamination with Linseed Oil?
According to 29 CFR 1910.1200(g) [ILPI: Original HCS 1994 context · Current HCS], any generally applicable precautions for safe handling and use, which are known to the chemical manufacturer, importer or employer preparing the MSDS should be documented. Documentation should also include appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks. Other documentation calls for the listing of control measures known to the manufacturer such as engineering, work practices, or the use of personal protective equipment.
A copy of the standards cited in this letter is enclosed. We hope that the above information is of assistance to you. If we may be of further assistance, please do not hesitate to contact Mac Arthur Cheeks of OSTA at (202) 219-7056 or write again.
Sincerely,
Stephen Mallinger
Acting Director
Directorate of Technical Support
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1996-02-28.