08/11/1986 - Applicability of HCS standard to shipment of truck parts

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Title: 08/11/1986 - Applicability of HCS standard to shipment of truck parts.
Record Type: InterpretationStandard Number: 1910.1200
    August 11, 1986

    Mr. Davis Thekkanath Sr.
    Supervising Engineer
    Oshkosh Truck Corporation
    2307 Oregon Street
    Oshkosh, Wisconsin 54903

    Dear Mr. Thekkanath:

    This is in response to your letter of June 25 regarding the Hazard Communication Standard (HCS).

    The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. It is our interpretation that items such as a truck radiator, an engine, or a battery are not containers and therefore would not be required to be labeled. However, the containers that held such chemicals as ethylene glycol and battery acids would need to be labeled since they meet the definition of a "hazardous chemical" under the standard.

    If you have any further questions, please feel free to contact us again.

    Sincerely,

    John B. Miles, Jr., Director

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    June 25, 1986

    John B. Miles Jr., Director
    Directorate, Field Operations
    U.S. Department of Labor
    OSHA
    200 Constitution Ave. N.W.
    Washington, DC 20210

    Subject: 29 CFR Part 1910.1200 Hazard Communication

    Gentlemen:

    Oshkosh Truck Corporation is a manufacturer of heavy duty trucks. The trucks as shipped to our customers, have ethylene glycol solution in the radiator, lubricating oil in the engine transmission and axles, battery fluids in the battery, to name a few. Our question concerns the applicability of the subject requirements for the vehicle operation.

    Mr. Steve Simon, of your office, in a recent telephone conversation with the writer advised that the subject regulation is not applicable to items on the vehicle that are functional requirements for vehicle operation.

    We would therefore appreciate your confirming this in writing at you earliest.

    Sincerely,

    OSHKOSH TRUCK CORPORATION

    Davis Thekkanath Sr.
    Supervising Engineer


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