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OSHA Hazard Communication Letters of Interpretation
What is the correct grouping/placement of the six required elements for labels
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; current small-container provisions supplement it
The grouping principle remains in paragraph (f)(3): the signal word, hazard statements and pictograms must be together. The letter does not require every label element to occupy one field of view, but all required information must still be legible and available on a compliant label.
The June 4, 2013 small-container accommodation predates the current small-container provisions. Where full labels, pull-out labels, fold-back labels or tags are not feasible, containers of 100 mL or less have specified reduced-label requirements. A narrower provision applies to containers of 3 mL or less when any label interferes with normal use; a product identifier is still required. The immediate outer package must bear the full label and storage instructions. A reference to an SDS or website alone is insufficient.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 27, 2014
Mr. Mark Kardon
The Penray Companies, Inc.
440 Denniston Court
Wheeling, Illinois 60090-4731
Dear Mr. Kardon:
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Thank you for your May 16, 2014, letter to the Occupational Health and Safety Administration's (OSHA) Directorate of Enforcement Programs with your question regarding OSHA's Hazard Communication standard (HCS 2012), 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], which was revised in March 2012. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. For clarification, your specific question is paraphrased below, followed by OSHA's response.
Background: In your letter, you stated that your company is converting your safety data sheets and product labels to comply with the formatting requirements specified in HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] . However, the exact placement of the six required elements for labels on shipping containers is not specified by the HCS 2012 paragraph 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS]. The only provision that specifies a location is paragraph 1910.1200(f)(3) [ILPI: Original HCS 2012 context · Current HCS], which requires that the elements provided under paragraphs (f)(1)(ii) signal word, (f)(1)(iii) hazard statement(s), and (f)(1)(iv) pictogram(s) be located "together " on the label.
You also provided two sample product containers with labels to see if they meet the requirements of HCS 2012 [ILPI: Original HCS 2012 context · Current HCS]. The format used for these labels included the required six elements, with grouping together of the signal word, hazard statement(s), and pictogram(s) on each product label. One sample container was a 12-ounce flattened bottle with a label on its front and a second label with additional information on the back of the bottle. The front label contained general product information, including the (f)(1)(i) product identifier, (f)(1)(ii) signal word, (f)(1)(iii) hazard statement(s), and (f)(1)(iv) pictogram(s), located together. The remainder of the required information for HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] , specifically the (f)(1)(v) precautionary statement(s), and (f)(1)(vi) name, address, and telephone number of the chemical manufacturer, importer, or other responsible party, was printed on the back label.
The other sample container was a 19-ounce cylindrical aerosol can with a single label around its entire circumference. The front view of the can's label contained general product information, along with a product identifier, signal word, hazard statement(s), and pictogram(s), located together. The remainder of the required information for HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] , specifically the precautionary statement(s), name, address, and telephone number of the chemical manufacturer, importer, or other responsible party, was printed on the remainder of the label and viewed as the can is rotated.
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Question: What is the correct grouping/placement of the six required elements for labels on shipping containers (product identifier, signal word, hazard statements, pictograms, precautionary statement, and name/address of the manufacturer), per 1910.1200(f) [ILPI: Original HCS 2012 context · Current HCS]? Must all six elements appear in the same field of view? Do our sample containers with updated labels comply with HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] ?
Response: OSHA's Hazard Communication standard at paragraph (f)(3) [ILPI: Original HCS 2012 context · Current HCS] specifies:
The chemical manufacturer, importer, or distributor shall ensure that the information provided under paragraphs (f)(1)(ii) through (iv) [ILPI: Original HCS 2012 context · Current HCS] of this section is located together on the label, tag, or mark.
Thus, HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] does not require all six elements in the same field of view, just the three elements: signal word, hazard statement(s), and pictogram(s). The sample labels which you provided satisfy the HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] requirement specified in 1910.1200(f)(3) [ILPI: Original HCS 2012 context · Current HCS] because each label has the (f)(1)(ii) signal word, (f)(1)(iii) hazard statement(s), and (f)(1)(iv) pictogram(s) grouped together in the same field of view.
For products that are sold in small sizes, the containers may be labeled using fold-back labels, pull-out labels, tags or other methods. Further, we refer you to OSHA's Letter of Interpretation to Dr. Robert L. Watters, Jr., dated June 4, 2013, which explains practical accommodations for manufacturers unable to use pull-out labels, fold-back labels, or tags containing the full HCS 2012-required information [ILPI: Original HCS 2012 context · Current HCS].
[ILPI note: At issuance: HCS 2012. The referenced 2013 letter is historical. Current small-container provisions now specify the conditional alternatives.]
Thank you for your interest in occupational safety and health. We hope this provides the clarification you were seeking. 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 www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.
Sincerely,
Thomas Galassi, Director
Directorate of Enforcement Programs
cc: Chicago Regional Administrator
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-27.