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OSHA Hazard Communication Letters of Interpretation
Hazard Communication Standard requirements for castings
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; assess downstream use and current article criteria
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central HazCom conclusion remains consistent with the current HCS: welding, cutting, sanding, or similar downstream processing that releases hazardous dusts or fumes can prevent a casting from qualifying for the article exemption and can require an SDS.
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.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 20, 1986
The Honorable Carl Levin
United States Senate
Washington, D.C. 20510
Dear Senator Levin:
This is in response to your letter dated February 6 on behalf of your constituent, Mr. Don Birtwistle of Great Lakes Castings Corporation, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
Under normal circumstances, a casting would be considered an "article" under the HCS and would be exempt from the provisions of the standard. However, if the casting is going to another manufacturing facility where it will be used in such a way as to release a hazardous chemical, information will have to be provided to the manufacturing purchaser of the product in accordance with the standard. The HCS requires manufacturers of such products to make determinations as to whether the casting is exempt based upon its "normal conditions of use." Welding, burning, cutting, gouging, sanding and other operations will release metal dusts or fumes which are considered hazardous chemicals. Castings undergoing these types of processes must have a material safety data sheet to inform the user of the hazards associated with exposure to metal dusts and fumes.
[ILPI note: Current counterparts: article definition, classification for anticipated uses, solid-metal labeling, and SDS distribution. There is no automatic casting exemption, and coverage now extends beyond manufacturing.]
If we may be of further assistance please feel free to contact us again.
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/1986-03-20.