| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
OSHA Hazard Communication Letters of Interpretation
Hazard Communication classifications
- Issued
- Record type
- Interpretation
- Historical HazCom standard
- HCS 2012
- Current HazCom standard
- HCS 2024, as amended
ILPI assessment: Manufacturer evaluation principle retained; apply current physical criteria
Its central HazCom principle remains consistent: the manufacturer/importer must evaluate the actual product and relevant evidence; the absence of visible free liquid does not by itself establish the correct classification. OSHA does not approve a product classification through this letter. It interprets HCS 2012.
Under the current HCS, apply hazard classification, anticipated-use evaluation, flammable-liquid and flammable-solid criteria, with the current physical-state definitions. Refer to OSHA's adopted criteria rather than assuming that the cited old GHS edition is the current U.S. rule. This assessment does not decide whether a particular present-day wipe belongs in one or both classes.
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.
December 14, 2015
Mr. Joe McCarthy
Dell Tech Laboratories
100 Collip Circle, Suite 220
London Ontario, Canada
N6G 4X8
Dear Mr. McCarthy:
Thank you for your March 25, 2015, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. Your question concerns flammable liquid and solid classifications 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 questions and our responses are below.
Store your solvents safely with flammable storage safety cabinets from Safety Emporium.
Background: Dell Tech Laboratories produces a towelette impregnated with a flammable liquid but there is no free flowing liquid in the container; the substrate of the towelette is not flammable.
Question 1: Should the impregnated towelette be classified and labeled as a flammable liquid or as a flammable solid under HCS 2012?
Response: The HCS places responsibility for hazard classification on the manufacturer or importer of the chemical. 29 CFR 1910.1200(b)(1) [ILPI: Original HCS 2012 context · Current HCS], (d)(1) [ILPI: Original HCS 2012 context · Current HCS; same paragraph number; classification requirements revised]. OSHA does not perform hazard classifications for manufacturers, since it is the manufacturer that is most familiar with a product's composition, the normal conditions of use (e.g., packaging, shipping, cutting, burning, heating, or any other processing), and the potential downstream exposures. OSHA also does not require testing. 1910.1200(d)(2) [ILPI: Original HCS 2012 context · Current HCS]. It is up to the manufacturer or importer to determine how best to use the relevant data and information to ascertain the hazard(s) associated with a chemical, and then to compare the information to the classification criteria to determine the appropriate hazard statement(s).
The HCS 2012 classifies a liquid as flammable if it has a flash point of not more than 93° C (199.4° F). See Appendix B of 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], Physical Criteria, Chapter B.6 [ILPI: Original HCS 2012 context · Current HCS], Flammable liquid. The classification criteria for flammable liquids are listed in Chapter B.6.2 [ILPI: Original HCS 2012 context · Current HCS], Classification Criteria. The HCS 2012 classifies a solid as flammable if it is a readily combustible solid, or which may cause or contribute to fire through friction. See Appendix B of 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], Physical Criteria, Chapter B.7 [ILPI: Original HCS 2012 context · Current HCS], Flammable solids. The classification criteria for flammable solids are listed in Chapter B.7.2 [ILPI: Original HCS 2012 context · Current HCS], Classification Criteria. Please also refer to the GHS, version 3, Chapters 2.6 and 2.7 for additional guidance on classifying flammable liquids and flammable solids, respectively. Following these criteria can help determine if your product is a flammable liquid, flammable solid, or both under HCS 2012.
[ILPI note: Original HCS 2012 context · Current HCS. Apply current classification, B.6 liquids and B.7 solids to the actual formulation and form. This is guidance on the evaluation process, not OSHA approval of an individual wipe product.]
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 assure 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 Directorate of Enforcement Programs at (202) 693-2100.
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/2015-12-14-0.