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OSHA Hazard Communication Letters of Interpretation
National Paint and Coatings Association's (NPCA) Health Effects Labeling Approach
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Professional judgment retained; blanket rejection of cutoffs superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its warning that a trade-association guide does not guarantee compliance remains sound. However, the blanket statement that numerical thresholds or cutoffs are incompatible with the HCS is not current: modern hazard classification includes hazard-specific criteria, cut-off values/concentration limits, and mixture procedures.
Use all relevant evidence, Appendix A/Appendix B, and current shipped-label elements and Appendix C. Professional judgment remains important within those rules. OSHA's favorable 1987 comments on this particular historical guide do not establish that it supplies all current criteria or label elements.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 10, 1987
Mr. J. Andrew Doyle
Counsel National Paint & Coatings Association
1500 Rhode Island Avenue, N.W.
Washington, D.C. 20005
Dear Mr. Doyle:
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Thank you for the opportunity to review and comment on the National Paint and Coatings Association's (NPCA) Health Effects Labeling Approach (Advance Supplement to Volume II May 7, 1987).
The guidance provided in the labeling guide should serve as a practical tool for professionals responsible for hazard determination under the Hazard Communication Standard. When used in conjunction with the Hazard Communication Standard the manual will greatly assist employers in making proper compliance decisions. However, the use of the "Approach" may not guarantee that an employer will always be in compliance with the standard. Compliance officers will judge the adequacy of an employer's hazard determination decisions based on the scientific facts and the standard's requirements on a case by case basis.
The need for professional judgment relative to the Hazard Communication Standard is established by the very nature of the regulation. Accordingly, the application of specifications or cut-offs is incompatible with the performance orientation of the standard. For this reason, the concept of a numerical threshold for determining labeling obligations is not consistent with the intent of the Hazard Communication Standard. Professionals will generally agree that some threshold level is necessary, but they will rarely agree on the level for a single chemical. We are pleased to see the NPCA agrees with this concept. The Agency supports the use of the "Approach" and believes that when NPCA members use it correctly and in conjunction with the Hazard Communication Standard compliance will be achieved.
[ILPI note: Current counterparts: classification, health/physical criteria, and mixture procedures. Unlike this historical blanket statement, today's HCS uses hazard-specific numerical criteria and concentration limits. At issuance: 1910.1200, original 1983 rule (PDF).]
Once Again, thank you for permitting us to review your work. Please feel free to call on us again.
Sincerely,
Frank White
Deputy Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-09-10.