Response: OSHA exempts products from HCS labeling when they are subject to a consumer product safety standard or labeling requirements of the Consumer Product Safety Act and the Federal Hazardous Substance Act. See 29 CFR 1910.1200(b)(5)(v). Generally, if a label meets the exemptions described in this paragraph of the HCS, then the employer must follow CPSC's label requirements.

Response: Any questions PLZ may have with regards to the CPSC label requirements, other than the exceptions stated in HCS 2012, must be addressed to the CPSC. OSHA cannot make requirements on label information under the regulatory responsibility of the CPSC or other agencies. OSHA reminds PLZ that the full hazard statement of "Extremely flammable aerosol" must be used on HCS 2012 labels, unless the product is exempt from HCS labeling because it is subject to another federal agency's labeling requirements as provided in 29 CFR 1910.1200(b)(5). No abbreviations or omissions are permitted, unless the chemical manufacturer, importer, or responsible party can demonstrate that all or part of the hazard statement is inappropriate to a specific substance or mixture (see Appendix C.2.2.2 of 1910.1200). The CPSC can be contacted at:

U.S. Consumer Product Safety Commission (CPSC)
4330 East West Highway
Bethesda, MD 20814
Phone: (301) 504-7923
Fax: (301) 504-0124 and (301) 504-0025

Response: Although flammability testing is allowed, OSHA does not require testing. However, should testing be conducted, the HCS identifies scientifically-validated test methods for the flammable aerosol hazard classification. See Appendix B.3.3 of the HCS. It is up to the manufacturer or importer to determine how best to use the relevant data and information to ascertain the hazard(s) associated with a chemical, and then to compare the information to the classification criteria to determine the appropriate hazard statement(s). If the aerosol is classified to meet HCS 2012 requirements, please use the data mentioned in the standard, such as heat of combustion and flammable components (see Appendix B.3 Flammable Aerosols). Flame extension and flash point data are not needed to determine the classification for flammable aerosols. Please also refer to the GHS version 3 for additional guidance on classifying physical hazards, Chapter 2.3.