MEMORANDUM FOR: JAMES W. STANLEY, REGIONAL ADMINISTRATOR
ATTENTION: ACTING ASSISTANT REGIONAL ADMINISTRATOR FOR TECHNICAL SUPPORT
THROUGH: LEO CAREY, DIRECTOR, DIRECTORATE OF FIELD PROGRAM
FROM: PATRICIA K. CLARK, ACTING DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Hazard Communication Standard (HCS) Labeling Requirements for Industrial Thermometers

This is in response to your memo of June 6, which forwarded a memo from the Manhattan Area Office requesting an interpretation of the Hazard Communication Standard as it applies to labeling requirements for industrial thermometers.

If industrial thermometers are expected to break during normal conditions of use, exposing employees to mercury, they are not considered articles for purposes of the HCS. Under the labeling provisions of the HCS each thermometer container would have to be labeled, tagged, or marked with the required label information.

These HazCom labels come in handy rolls of 500 at Safety Emporium.