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OSHA Hazard Communication Letters of Interpretation
The labeling elements required on the safety data sheet (SDS) under the Hazard Communication Standard (HCS 2012)
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent with the current HCS
The packaging-specific explanation remains useful: a common SDS must convey all applicable hazards and precautions, while handling instructions can explain differences between glass bottles and steel drums.
The current label-omission provision is C.2.4.9. The letter distinguishes label omissions from the SDS Section 2 precautionary information and the packaging explanation in Section 7. It is not general permission to omit precautions from the SDS or assume every glass-container operation has no static hazard.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
October 2, 2015
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Ms. Tammy L. Blakeslee, CIH
President
EnviroNet LLC
P.O. Box 386 M.O.,
Shrewsbury, MA 01545
Dear Ms. Blakeslee:
Thank you for your April 12, 2015, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). In your letter you requested guidance on the labeling elements [ILPI: Original HCS 2012 context · Current HCS] required on the safety data sheet (SDS) under the 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 herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased scenario and question are presented below, followed by our response.
Scenario: EnviroNet LLC needs to modify and omit the Globally Harmonized System (GHS) precautionary statements with certain packaged material because the statements are not appropriate. The product in question is flammable and sold in small glass bottles and 5-gallon steel drums. However, the precautionary statement referring to grounding and bonding applies only to the steel drums, and not to the glass bottles.
Accordingly, we have two sets of label elements [ILPI: Original HCS 2012 context · Current HCS] that need to be communicated on two different product labels with the only difference being the precautionary statements.
Question: We have a single SDS for this product. Is it acceptable to list the grounding and bonding precautionary statement in Section 2 of the SDS [ILPI: Original HCS 2012 context · Current HCS] even though it does not apply when the product is packaged in glass bottles?
Response: Yes, it is acceptable to list all precautionary statements on a single SDS even though some of the precautionary statements do not apply to the product when placed in glass containers. Paragraph 29 CFR 1910.1200(g)(2) [ILPI: Original HCS 2012 context · Current HCS] requires the SDS to include precautionary statements as outlined in Appendix D to §1910.1200 [ILPI: Original HCS 2012 context · Current HCS] - Safety Data Sheets (Mandatory). A statement that the grounding and bonding precautionary statement does not apply when the product is shipped in glass bottles may be added to Section 7 of the SDS [ILPI: Original HCS 2012 context · Current HCS], Handling and Storage.
[ILPI note: At issuance: HCS 2012. The current label-omission provision is C.2.4.9. Include applicable SDS precautions in Section 2 and explain packaging-specific handling in Section 7.]
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 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 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
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2015-10-02.