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OSHA Hazard Communication Letters of Interpretation
MSDS and labeling requirements for copper or aluminum wire or metal products.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; article definition and coverage updated
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central HazCom conclusion remains consistent with the current HCS: downstream melting or other processing that can release hazardous substances must be considered, and an article exemption depends on the actual product and use.
Use the current article definition and articles exemption, including the shape/end-use criteria, very-small-release limits, and absence of a physical hazard or health risk. A metal product is not exempt merely because it is solid. See the SDS FAQ discussion of articles. The definition reproduced in the letter is historical and has changed.
Under the current HCS, evaluate hazards associated with known or reasonably anticipated uses, including changes in physical form and reaction products. Non-exempt solid metals have a separate labeling provision; SDS distribution duties still apply. The current scope extends beyond manufacturing workplaces.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
March 11, 1986
The Honorable John H. Chafee
United States Senate
Washington, D.C. 20510
Dear Senator Chafee:
This fire extinguisher bracket forklift mount is one of many forklift safety items you'll find at from Safety Emporium.
This is in response to your letter dated February 20 on behalf of your constituent, Mr. Bruce C. Ferguson of Ferguson Perforating and Wire Company, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
The HCS relies on the downstream flow of information on hazardous chemicals from the manufacturer to the user. If the copper, aluminum, or any other hazardous components in the materials Mr. Ferguson's company uses can be released in his customers' operations, then he would be required to provide Material Safety Data Sheets to his manufacturing customers and to label shipments. For example, if such products are melted in downstream production operations, they are likely to release hazardous substances.
[ILPI note: Current counterparts: classification for anticipated uses, solid-metal labeling, and SDS distribution. Coverage now extends beyond manufacturing.]
It is possible, however, that the completed product may be considered an "article." An "article" means a manufactured item: (1) which is formed to a specific shape or design during manufacture (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. Any product which meets the definition of an "article," would be exempt from the requirements of the Standard.
[ILPI note: The definition above is historical. Apply the current article definition and exemption.]
If you or your constituent have any further questions, please feel free to contact our Office of Health Compliance Assistance at (202) 523-8036.
Sincerely,
Patrick R. Tyson
Acting Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-03-11.