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Title: 09/25/1984 - Requirements for alternate warning methods, delays between filling and labeling a chemical container, and label identification of mixtures under HCS.
Record Type: InterpretationStandard Number: 1910.1200(c); 1910.1200(f)(4); 1910.1200(f)(5); 1910.1200(g)

ILPI Notes: This interpretation is based on and references the original HCS 1986 which, along with HCS 1994 is now obsolete. While some parts have been deleted or changed as indicated below, the conclusions of this interpretation appear consistent with the current regulation (HCS 2012).

September 25, 1984

Mr. Jim Wooldridge
Delta Solvents & Chemicals Company
610 Fisher Road
Longview, Texas 75604

Dear Mr. Wooldridge:

This is in response to your letter of July 23 to Gilbert J. Saulter, Regional Administrator, requesting clarifications of the Hazard Communication standard (29 CFR 1910.1200). Your questions are answered as follows:

  1. Must bulk chemical storage tanks and the plumbing be marked and labeled to show all hazards?

    Answer: The standard permits several alternative warning methods under 1910.1200(f)(5) [This is now paragraph 1910.1200(f)(7) under HCS 2012] as follows:

    (5) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraphs (f)(4) [current regulation: paragraphs (f)(6)] of this section to be on a label. [current regulation: The employer shall ensure t]he written materials shall be [are] readily accessible to the employees in their work area throughout each work shift.

    Appropriate hazard warnings are required for all hazardous chemicals present.

    NFPA sign kit
    NFPA signs and kits are available at Safety Emporium.
  2. When containers are filled for storage must they be labeled on the distribution property?

    Answer: Containers should be labeled as soon as practicable. A delay between filling and labeling is permissible. Bulk storage tanks from which filling is taking place must be labeled.

  3. Must the label identify all products in mixtures?

    Answer: Employers need not list all of a product's constituents individually on the label. This interpretation is evident when one reviews the definition of the terms "identity" and "common name" under section 29 CFR 1910.1200(c) [in context: HCS 1994 | current regulation: HCS 2012] of the standard. Essentially, a common name may appear on the label as long as the material safety data sheet (MSDS) is similarly identified.

  4. Must Material Safety Data Sheets identify all products and percentages in mixtures?

    Answer: The information required under 29 CFR 1910.1200(g) [in context: HCS 1994 | current regulation: HCS 2012] must be given only for the hazardous chemicals present within a product mixture, unless they are present in concentrations of less than 1.0 percent, and less than 0.1 percent for carcinogens. The standard does not require the listing of percentages of chemicals in mixtures. In the case of trade secrets or when specific information is unavailable, these facts must be explained on the MSDS; blanks are not permitted.

  5. Would signs posted in our drum filling area and storage area take the place of labels on our property?

    Answer: No, containers must be identified as soon as possible. Signs may be used in place of labels on stationary process equipment pursuant to paragraph (f)(5) [This is now paragraph 1910.1200(f)(7) under HCS 2012] of the standard. (See answer to question number 1.)

Please feel free to contact us if further assistance is needed.


John B. Miles, Jr., Director
Directorate of Field Operations

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