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OSHA Hazard Communication Letters of Interpretation
Use of multiple countries' information on labels of hazardous chemicals
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent with the current HCS
Other countries’ information can supplement a U.S. label only without contradicting, casting doubt on or obscuring the required HCS information. Use C.3.1 and C.3.2; a separate box does not automatically cure conflicting classifications.
A metal alloy’s shipped form does not by itself settle classification. Current paragraph (d)(1) expressly includes known or reasonably anticipated downstream processing, including relevant welding or grinding hazards.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 10, 2015
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Ms. Tammy L. Blakeslee, President
EnviroNet LLC
P.O. Box 386 M.O.
Shrewsbury, Massachusetts 01545
Dear Ms. Blakeslee:
Thank you for your October 24, 2014, letter to the Occupational Safety and Health Administration (OSHA). Your letter was referred to OSHA's Directorate of Enforcement Programs for an interpretation of OSHA's Hazard Communication standard (HCS 2012, 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS]. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to issues not delineated within your original correspondence. Your paraphrased questions and our responses are below.
Scenario: Your company has a chemical that is packaged in pre-printed bags, which are made to stock and then shipped around the world. In order to reduce relabeling and repackaging, you would like the chemical label to include the chemical hazard classifications for the United States (U.S.), European Union (E.U.), and China in clearly marked separate boxes.
Question 1: Is it acceptable to have other countries' hazard classifications in addition to the U.S. HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] classification, on a chemical product label?
Response: The HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party. 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS]. The HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] does not prohibit a manufacturer or importer from adding supplemental information to a label, as long as it does not lead to unnecessarily wide variation or undermine the required label information. Section C.3.1 [ILPI: Original HCS 2012 context · Current HCS] of Appendix C to HCS 2012 explains that supplementary information may only be added to a label if it provides further detail and does not contradict or cast doubt on the validity of the required information. Therefore, if the other countries have hazard classification information that contradicts or casts doubt on the HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] information, it is not permitted to be on the label. You may wish to review OSHA's January 31, 2013, letter of interpretation (enclosed) to Ms. Erin McVeigh on this subject.
Question 2: A metal alloy is not hazardous in its shipped form, but may release a hazardous chemical when processed downstream . In classifying a metal alloy, must the classifier evaluate the hazards related to processing?
Response: Yes. A manufacturer or importer must consider the hazards of a chemical during normal conditions of use or in a foreseeable emergency. 29 CFR 1910.1200(b)(2) [ILPI: Original HCS 2012 context · Current HCS]. The hazards related to normal processing (e.g. welding, grinding) must be considered in conducting the hazard classification. You may wish to review two past letters of interpretation on this subject: OSHA's March 11, 1986, letter (enclosed) to The Honorable John H. Chafee, and the November 16, 1994, letter (enclosed) to Ms. Sheila Loftus.
[ILPI note: At issuance: HCS 2012. Under current paragraph (d)(1), known or reasonably anticipated downstream processing hazards are part of classification.]
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Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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.
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
Enclosures
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2015-02-10-1.