Mar 17, 1986 - Application of the Hazard Communication Standard to lift trucksMar 17, 1986 - Application of the Hazard Communication Standard to lift trucks
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Mr. Kevin C. Donaghue Rollins Burdick Hunter of Oregon, Inc. Pacwest Center, Suite 600 1211 S. W. Fifth Avenue Portland, Oregon 97204-3799
Dear Mr. Donaghue:
Thank you for your letter dated November 11, 1985, addressed to Mr. Carl Halgren, in regard to the Hazard Communication Standard. Please accept my apology for the delay in response. The overwhelming number of letters and telephone calls regarding the Hazard Communication Standard has caused unavoidable delays in responding to the public's concerns.
OSHA considers lift trucks to be machines and not containers. Containers are required to be labeled according to the standard. Labeling vehicle components seems to be impractical and would be cumbersome.
Labeling of vehicle components is not necessary. Lift trucks do not meet the current definition of an "article" because of potential exposures to carbon monoxide and physical hazards of petroleum fuel products. The "article" definition was one of the issues upon which OSHA requested comment in the November 27, 1985, publication of the Federal Register. Comments were accepted until February 25, 1986.
If we can be of further assistance please contact our Office of Health Compliance Assistance at (202) 523-8036.
Sincerely,
John B. Miles, Jr., Director Directorate of Field Operations
MEMORANDUM FOR: ROY GIBBS, Industrial Hygienist , Hazard Communication Health Compliance Assistance
THROUGH: JOHN B. MILES, JR., Director, Director of Field Operations
FROM: JAMES W. LAKE, Regional Administrator Region X
SUBJECT: Request for Hazard Communication Interpretation
Based on a December 13, 1985, telephone conversation with Joseph Hopkins of your office, I am forwarding a request for an interpretation regarding lift trucks and the hazard communication standard.
The requester, Mr. Kevin C. Donaghue, has been notified that his questions have been referred to your office and that a response will be forthcoming. I would appreciate a copy of your response.
Occupational Safety and Health Administration 909 First Avenue Seattle, Washington 98174 December 13, 1985
I recently had a meeting with Hyster Company concerning the Hazard Communication Standard. During our meeting several items were discussed including the Standards inevitable expansion. There were three questions which Hyster Company would appreciate a written response from OSHA:
Does Hyster Company have to label all radiators (antifreeze), brake lines (brake fluid), gasoline, propane, diesel tanks (fuel), crank case (various oils), etc.?
Are they exempt from having to comply with items one and two because lift trucks are considered articles?
I appreciate you considering these questions and am looking forward to your reply.
Sincerely,
KEVIN C. DONAGHUE Loss Control Consultant Rollins Burdick Hunter of Oregon, Inc. Pacwest Center, Suite 600, 1211 S.W. Fifth Avenue Portland, Oregon 97204-3799 Telephone 503-224-9700
