| 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
HCS Labeling requirements regarding intra-plant and intercompany shipping
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent with the current HCS
The distinction remains useful: transfers within the described workplace may use workplace labeling, but shipments to a different workplace require shipped-container labels even when both facilities belong to the same company. Common ownership, trained drivers and a shared program do not create a shipping exemption.
The stationary-process-container alternative does not authorize unlabeled mobile shipments. DOT requirements are separate from the HCS.
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 3, 2018
Mr. David O. Rivers
R&S Compliance Group, LLC
2707 W. Price Ave
Tampa, Florida 33611
Dear Mr. Rivers:
Get your GHS-compliant labels and signs from Safety Emporium.
Thank you for your letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs, regarding labeling requirements under OSHA's 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 herein and may not be applicable to any situation not delineated within your original response. Your question is summarized below, followed by our reply.
Background: Your company has an internal communication method to communicate the identity of hazardous chemicals transported on company vehicles from one location to another location within the same building (intra-plant). This method uses words, pictures, and/or product identification number, NFPA, HMIS, or DOT identifiers. The company also uses this communication method when transporting hazardous chemicals from one company property to another company property (inter-company). The internal communications methods are included in the company's written hazardous communication plan, which covers multiple company properties. During transportation, the hazardous chemicals do not leave the custody of trained company personnel.
Question: Do the workplace labeling requirements in 29 CFR 1910.1200(f)(6) [ILPI: Original HCS 2012 context · Current HCS] and 29 CFR 1910.1200(f)(7) [ILPI: Original HCS 2012 context · Current HCS] apply when moving hazardous chemicals intra-plant and/or inter-company?
Reply: Workplace labeling in 29 CFR 1910.1200(f)(6) [ILPI: Original HCS 2012 context · Current HCS] and 29 CFR 1910.1200(f)(7) [ILPI: Original HCS 2012 context · Current HCS] applies to labeling hazardous chemicals that are used within the workplace. These paragraphs provide an alternative to labeling under 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS], labels on shipped containers. Paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS] permits hazardous chemical containers in the workplace to be labeled with product identifiers and words, pictures, symbols, or a combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with other information immediately available to employees under the hazard communication program [ILPI: Original HCS 2012 context · Current HCS], will provide employees with the specific information regarding the physical and health hazards of the hazardous chemicals. 29 CFR 1910.1200(f)(6)(ii) [ILPI: Original HCS 2012 context · Current HCS]. OSHA views hazardous chemicals that are transported within the same building intra-plant as being the same workplace, and accordingly, workplace labeling in paragraph (f)(6) [ILPI: Original HCS 2012 context · Current HCS] would be permitted.
DOT shipping signs and labels plus a host of safety and compliance posters are available at Safety Emporium.
However, as OSHA explained in the Valasek letter (enclosed), any container leaving the workplace is a "shipped container" and must comply with the labeling requirements in paragraph (f)(1) [ILPI: Original HCS 2012 context · Current HCS]. Therefore, hazardous chemicals that are transported between workplaces (i.e., from one company building/property to another company building/property), even if within the same company, must be labeled in accordance with 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS]. Paragraph (f)(7) [ILPI: Original HCS 2012 context · Current HCS] applies only to labeling individual stationary process containers of hazardous chemicals.
[ILPI note: At issuance: HCS 2012. Common ownership does not remove shipped-label requirements. The stationary-process-container provision is a different alternative.]
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,
Kimberly Stille, Acting Director
Directorate of Enforcement Programs
Enclosure (Interpretation of Pictograms for Labeling Under 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], Appendix Letter)
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2018-12-03.