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OSHA Hazard Communication Letters of Interpretation
Definitions of target organs and chemical hazards
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Target-organ concept retained; definitions and appendix functions changed
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. The explanation of target organs remains useful. Question 2's suggested data-source appendix and Question 3's definitions are historical, however, and should not be used as a complete current classification method.
Under the current HCS, hazard classification follows paragraph (d), Appendix A health criteria, and Appendix B physical criteria. A.8/A.9 address specific target-organ toxicity where applicable. Original Appendix B concerned hazard determination and original Appendix C listed information sources; today's Appendix C concerns label elements. The same appendix letter does not imply the same subject across editions.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 17, 1987
Mr. Frank L. Pellegrini
Law Offices
A Professional Corporation
Suite 400, Chouteau Center
133 South Eleventh Street
St. Louis, Missouri 63102
Dear Mr. Pellegrini:
This is in response to your letter of July 21 concerning the Hazard Communication Standard, 29 CFR 1910.1200 .
[ILPI note: At issuance: 1910.1200, original 1983 rule (PDF). Current counterparts: classification, Appendix A health criteria, and Appendix B physical criteria. The original Appendix B concerned hazard determination and original Appendix C supplied data sources; current Appendix C instead governs label elements.]
Your questions and our responses are as follow:
Question 1: Define target organs.
Answer:As defined in Casarett and Doull'e Toxicology, the Basic Science of Poisons, Most chemicals that produce systemic toxicity do not cause a similar degree of toxicity in all organs but usually produce the major toxicity to one or two organs. These are referred to as target organs of toxicity for that chemical.
Appendix A of the Hazard Communication Standard provides a target organ categorization of effects chemicals which have been found to cause such effects. The examples given are presented to illustrate the range and diversity of effects and hazards but are not intended to be all-inclusive.
Question 2: After defining same, please advise where a manufacturer can obtain a list of target organs versus hazardous chemicals.
Answer: As stated in our June 29 letter, Appendix C of the standard provides a list of available data sources which can be used to determine the target organ effects of chemicals.
[ILPI note: The original Appendix C was a data-source list. Current Appendix C has a different function (label elements); evaluate current evidence under paragraph (d) and the relevant health/physical criteria.]
Question 3: Define hazards of chemicals.
Answer: The Hazard Communication Standard defines "hazardous chemical" to mean any chemical which is a physical or a health hazard.
"Physical hazard" means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.
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"Health hazard" means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Appendix A provides further definitions and explanations of the scope of health hazards covered and Appendix B describes the criteria to be used to determine whether or not a chemical is to be considered hazardous for purposes of the standard.
If I can be of further assistance, please feel free to contact me again.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Assistance
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-09-17-0.