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OSHA Hazard Communication Letters of Interpretation
Manufacturer's name and address on the label of a chemical product under HCS 2012
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; current U.S. contact details apply
A website alone does not replace the required name, address and telephone information. A recognizable trade name can identify the responsible party if the label and SDS consistently identify the same entity. Current paragraph (f)(1)(vi) and SDS Section 1 expressly require a U.S. address and U.S. telephone number; the letter does not establish a blanket prohibition on mailing addresses.
OSHA marks this letter corrected July 14, 2014. See also the August 31, 2009 mailing-address letter.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
March 22, 2013
Mr. Dennis Morikawa
Morgan, Lewis & Bockius LLC
1701 Market Street
Philadelphia, PA 19103-2921
Dear Mr. Morikawa:
Thank you for your March 4, 2013, email to the Occupational Safety and Health Administration (OSHA) Directorate of Enforcement Programs. We apologize for the delay in responding to your earlier inquiry. Your questions concern specific sections of the labeling requirements under the revised Hazard Communication standard (HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] ), 29 CFR 1910.1200. This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence.Your paraphrased questions and our responses are below.
Question 1: Can the web address for the company be used instead of a physical or mailing address on the required HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] label?
[ILPI note: At issuance: HCS 2012. Current label contact information and SDS Section 1 require U.S. address and telephone details. A website may supplement, but cannot replace, those details.]
Response: No. While the web address for your company may provide contact information, many small businesses do not have ready access to the internet. Therefore, the address required by 29 CFR 1910.1200(f)(1)(vi) [ILPI: Original HCS 2012 context · Current HCS] is the physical or mailing address for the manufacturer, importer or distributor. The web address for your company may be included on the label as supplemental information. It may serve as an additional manner to request and transmit information for those businesses that have internet access, but it cannot replace the physical or mailing address. Please see the August 31, 2009, letter to Ms. Peggy Haase concerning mailing addresses versus physical addresses, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27206.
Question 2: Must the legal name of the company (e.g., Airgas USA, LLC) be used on the HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] label or can the trade name (e.g., Airgas) be used instead?
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Response: OSHA's requirement at [29 CFR 1910.1200(f)(1)(vi) [ILPI: Original HCS 2012 context · Current HCS]] to include the name of the manufacturer, importer or distributor on the label and safety data sheet serves to ensure that downstream users know whom to contact if they have any questions. If the trade name of the company is recognizable to downstream users, then that name can be used on the label and safety data sheet (SDS). OSHA expects that the same company name (e.g., Airgas) would be used on the label and SDS. If it is difficult to associate the trade name on the label and the full legal company name on the SDS, it may potentially create confusion. This would not be compliant.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements, but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Sincerely,
Thomas Galassi, Director
Directorate of Enforcement Programs
Enclosure
[Corrected on 7/14/2014]
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2013-03-22.