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Title: 01/03/1986 - Conformation of labeling requirements of the Hazard Communication Standard | |
Record Type: Interpretation | Standard Number: 1910.1200 |
January 3, 1986
Merike Kammar, Office Manager
Filo Chemical Incorporated
50 Broadway
New York, New York 10004-1698
Dear Mr. Kammar:
This is in response to your letter dated October 29, 1985, requesting confirmation of three items relating to the Hazard Communication Standard.
As you correctly stated, chemical manufacturers and importers must label containers of hazardous chemicals leaving their workplaces, and provide material safety data sheets with initial shipments by November 25, 1985. The requirements of the standard are not retroactive regarding material safety data sheets and labels.
Labels should be put on imported hazardous materials as soon as practicable. Where the shipping container is a tank truck, rail car, or the like, the appropriate label may be provided with the shipping papers rather than posted on the container. It should not take beyond the first stop after the material leaves the pier to affix these labels.
Technically, chemical manufacturers, importers, or distributors are required to label each container leaving the workplace. Your method of labeling the entire pallet containing the shrink wrapped bags is a technical deviation from 29 CFR 1910.1200(f)(1), but is acceptable as long as the following is performed:
| Communicate workplace hazards with handy labels from Safety Emporium. |
John B. Miles, Jr., Director
Directorate of Field Operations
October 29, 1985
Mr. Roy Gibbs Re: OSHA Hazard Communication - Final Rule Dear Mr. Gibbs: Like everyone else in our business we have run into problems interpreting this rule and putting it into practice. We have turned to your office for clarification and wish to confirm our understanding of the following points which were discussed with Mr. John Healy yesterday. If our understanding is not completely correct, please contact us. As explained to Mr. Healy we are importers and distributors. | These pallets are just one of many spill prevention products available at Safety Emporium. |
We have also asked Mr. Healy to send us a copy of the OSHA General Industry Standards.
Thank you.
Yours Very Truly,
Merike Kammer
Office Manager
Filo Chemical Incorporated
50 Broadway
New York, N.Y. 10004-1698
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19363&p_text_version=FALSE