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Title: 06/14/1993 - Labeling requirements of hazardous chemicals. | |
Record Type: Interpretation | Standard Number: 1910.1200 |
June 14, 1993
The Honorable Jim Slattery
U.S. House of Representatives
Washington, D.C. 20515
Dear Congressman Slattery:
Thank you for your letter of April 28, on behalf of your constituent Ms. Barbara Dietrich, addressed to the Occupational Safety and Health Administration (OSHA), on the labeling requirements of hazardous chemicals under OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200. In her correspondence Ms. Dietrich provided the following suggestion for reducing health care costs:
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The HCS allows the employer to use an alternative labeling method as long as the written Hazard Communication Program adequately addresses the issue. Examples of alternative labeling methods are the Hazard Material Information System (HMIS), National Fire Protection Association (NFPA), and American National Standard Institute (ANSI) systems. Ms. Dietrich's letter indicates that the office is using an alternative labeling method that includes a rating system and that this system is burdensome. The standard does not require employers to use hazardous chemical rating systems. Again, if the incoming container is already labeled by the chemical manufacturer, importer, or other responsible party, then the employer is not required to affix his own label. If the container does require labeling by the employer, then either the alternative labeling method or a label containing the chemical identity and an appropriate hazard warning shall be used.
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We welcome any further comments that Ms. Dietrich may have concerning the HCS or occupational safety and health issues in general.
Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs
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=21155&p_text_version=FALSE