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OSHA Hazard Communication Letters of Interpretation
Labeling outer containers of chemical cleaning products while in storage.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; storage accommodation is conditional
The letter permits specified outer-box or shrink-wrap workplace labeling during sealed warehouse storage. It does not replace individual shipped-container labels when the product is sent onward or the stated opening/unwrapping conditions occur.
Under sealed-container duties, workers still need access to received SDSs and information/training for potential spills or leaks. The workplace-label alternative is a complete information system, not merely a mark on an unrelated pallet.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 5, 2017
DEP/OHE/DM/27674
Mr. William Balek
Director of Legislative and Environmental Services
International Sanitary Supply Association (ISSA)
3300 Dundee Road
Northbrook, Illinois 60062-2303
Dear Mr. Balek:
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Thank you for your letter to the Occupational Safety and Health Administration 's (OSHA 's) Directorate of Enforcement Programs (DEP). Your letter requests guidance on labeling containers as required by the Hazard Communication Standard [ILPI: Original HCS 2012 context · Current HCS] (HCS), 29 CFR 1910.1200. This letter constitutes OSHA 's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within your original correspondence. Your questions have been paraphrased below, followed by our reply.
Background: ISSA is a non-profit trade association that represents manufacturers of chemical cleaning products. Many of these manufacturers produce private label products which are sold under a distributor 's proprietary label and trade name. These manufacturers commonly produce private label chemicals in advance for sale which are containerized and packaged as four one- gallon containers in one box or 12 quart containers in one box. Once these chemicals are packaged, they are often palletized and shrink-wrapped for storage awaiting purchase. Once orders have been received, ISSA manufacturers ensure that all chemical containers are labeled compliant to HCS [ILPI: Original HCS 2012 context · Current HCS].
Question 1: Can manufacturers and distributors of chemical cleaning products achieve HCS [ILPI: Original HCS 2012 context · Current HCS] compliance by labeling only the outer box containing the chemical cleaning products while in storage?
Response: Paragraph 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS] requires manufacturers (and importers and distributors) to ensure that each shipped container leaving the workplace is labeled, tagged, or marked in accordance with paragraphs (f)(1)(i) [ILPI: Original HCS 2012 context · Current HCS]-(vi). Sealed containers of chemical cleaning products that are boxed, but are temporarily stored at a manufacturer 's or third party warehouse, may be labeled in accordance with paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS]. For this type of operation, if the unlabeled individual containers are kept in a sealed box with an HCS [ILPI: Original HCS 2012 context · Current HCS]-compliant label (i.e., in accordance with paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS]) while in the warehouse, there is no requirement to affix an HCS-compliant label to each individual container. However, once the outer box is opened even while in the warehouse, then an HCS-compliant label must be affixed to each individual container of chemical cleaning product in accordance with paragraph (f)(1) [ILPI: Original HCS 2012 context · Current HCS].
[ILPI note: At issuance: HCS 2012. The storage accommodation depends on keeping the specified packages sealed. Apply warehouse duties and outgoing shipped-label requirements; opening the package changes the labeling situation.]
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In addition, the HCS [ILPI: Original HCS 2012 context · Current HCS] requirements of 29 CFR 1910.1200(b)(4) [ILPI: Original HCS 2012 context · Current HCS] would apply for a warehouse operation. Paragraph (b)(4) [ILPI: Original HCS 2012 context · Current HCS] applies to work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use (e.g., warehousing). During warehousing operations, employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced, maintain copies of any safety data sheets (SDSs) that are received with incoming shipments of hazardous chemicals and have the SDSs readily available upon employee request and during each work shift to employees when they are in their work area(s). Employers must also ensure that employees are provided with information and training (1910.1200(b)(4)(i) [ILPI: Original HCS 2012 context · Current HCS]-(iii)).
Question 2: Is an HCS [ILPI: Original HCS 2012 context · Current HCS] label placed only on the outside of a shrink-wrapped pallet containing multiple boxes with inner containers HCS-compliant while in storage?
Response: Applying an HCS [ILPI: Original HCS 2012 context · Current HCS] label in accordance with paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS] to the outside of a shrink-wrapped pallet of chemical cleaning product while in storage (e.g., warehouse) is acceptable under the HCS. However, once the pallet is unwrapped in the warehouse each individual box containing chemical cleaning product must have an affixed HCS-compliant label in accordance with paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS].
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 http://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
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-05.