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OSHA Hazard Communication Letters of Interpretation
Precautionary statements in Hazard Communication standard
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; precautionary-statement provisions renumbered
The consolidation principles remain useful: reduce repetition without losing required precautions. The most-stringent-statement provision is now C.2.4.8 and the inappropriate-statement omission provision is now C.2.4.9. Their historical numbers in this letter were C.2.4.7 and C.2.4.8.
Current C.2.4.7 separately permits specified minor textual variations; it is not unrestricted permission to weaken precautions. Combining and consolidating statements must still convey the required information. The 2015 inspection directive is historical; the current HCS inspection guidance is provided separately.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 11, 2019
Mr. Travis Willard
Product Steward
Ascend Performance Materials
1010 Travis Street, Suite 900
Houston, Texas 77002
Dear Mr. Willard:
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Thank you for your letter to the Occupational Safety and Health Administration 's (OSHA) Directorate of Enforcement Programs. You requested clarification on precautionary statements 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 herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased questions and our responses are below.
Question 1: When the precautionary statements, “Immediately call a poison center/doctor” and “Call a poison center/doctor/…./if you feel unwell,” appears on a label, is it acceptable to only use the more protective statement, “Immediately call a poison center/doctor” per Appendix C.2.4.7 [ILPI: Original HCS 2012 context · Current HCS; most-stringent provision now C.2.4.8]?
Response: Yes, where a chemical is classified for a number of hazards, and the precautionary statements are similar, the most stringent must be included on the label. See Appendix C, C.2.4.7 of the HCS [ILPI: Original HCS 2012 context · Current HCS; most-stringent provision now C.2.4.8]. For more information on the use of precautionary statements, please refer to the Hazard communication directive, Inspection Procedures for the Hazard Communication Standard (HCS 2012), dated July 9, 2015, found at https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-02-079.PDF [ILPI: Original 2015 HCS 2012 directive · Current HCS inspection guidance]
[ILPI note: At issuance: HCS 2012. This provision is now C.2.4.8; omission is governed by C.2.4.9. Current C.2.4.7 addresses minor textual variations.]
Question 2: When precautionary statements are similarly worded, is it permissible to omit irrelevant word(s) or rearrange and reword?
Response: Yes, precautionary statements may be arranged to create an order of preference, or combined to save space and improve readability. However, all precautionary statements must be listed except as otherwise noted in Appendix C, C.2.4.5, C.2.4.6, and C.2.4.8 [ILPI: Original HCS 2012 context · Current HCS].
Question 3. Is it permissible to use a precautionary statement that essentially combines the precautionary statements from the C.4.1 [ILPI: Original HCS 2012 context · Current HCS], Acute Toxicity-Oral precautionary statements, with C.4.4 [ILPI: Original HCS 2012 context · Current HCS]., Skin Corrosion/Irritation, precautionary statements?
Response: Please see response to question 2.
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Question 4. Where exposure by multiple routes requires the precautionary statement, “If exposed: Immediately call a poison center or doctor. Get medical attention immediately,” is it acceptable, on both the label and SDS, to state this precautionary statement only once, and then follow it with each of the individual exposure route precaution statements?
Response: Please see response to question 2.
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 www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Sincerely,
Patrick J. Kapust, Acting 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/2019-09-11.