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OSHA Hazard Communication Letters of Interpretation
Standards applicable to the process of wrapping meat in plastic.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Foreseeable hazardous-release principle generally retained
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its central conclusion remains sound: a plastic film is not automatically exempt when normal wrapping use releases hazardous chemicals. Apply current article definition and known or reasonably anticipated uses, including the actual heating process, decomposition products, and exposure conditions. See the article FAQ.
Obtain an accurate current SDS when required and evaluate the actual airborne contaminants against applicable air-contaminant limits or substance-specific standards. The product's food-contact purpose does not by itself establish an exemption for an industrial wrapping film. Hazard communication and exposure-control requirements address different parts of protecting the workers.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 23, 1987
Mr. Donn S. Dutton
High, Stack, Lazenby, & Palahach
Attorneys at Law
3929 Ponce De Leon Boulevard
Coral Gables, Florida 33134
Dear Mr. Dutton:
This is in response to your inquiry of October 28, concerning your client, Ms. Barbara Prince.
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The Occupational Safety and Health Administration (OSHA) may have some air contaminant standards that are applicable to the process of wrapping meats in plastic. Before it can be established whether OSHA does, the air contaminants released would have to be identified.
After you identify the air contaminants, consult 29 CFR 1910, Subpart Z, to see if there are standards for any of them. Moreover, if the plastic wrapping material releases hazardous substances during the wrapping process, the hazard communication standard, 29 CFR 1910.1200 applies. One of its requirements is that the manufacturer of the plastic wrapping material must provide a Material Safety Data Sheet for it. Therefore, you may want to contact the manufacturers of the plastic wrapping materials.
[ILPI note: Current counterparts: article definition, anticipated-use evaluation, and SDS duties. Current air-contaminant requirements and any substance-specific rules need a separate exposure assessment. At issuance: 1910.1200, 1987 expanded rule (PDF).]
We appreciate the opportunity to assist you in this matter.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-11-23.