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OSHA Hazard Communication Letters of Interpretation
Lift trucks or other machines found in the workplace are not containers for labeling requirements of the HCS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Vehicle distinction retained; process containers still need hazard identification
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its distinction between vehicle operating systems and process containers remains useful. Current container definition excludes piping systems and engines, fuel tanks, or other operating systems in a vehicle. This does not exempt the hazardous chemicals themselves from other applicable HCS duties.
Do not generalize the letter's broad machine-components language to every chemical vessel in any machine. Assess actual equipment and containers. The current alternative for stationary process containers is paragraph (f)(7), referring to the workplace information in paragraph (f)(6); it requires identification and readily accessible written materials during each shift. SDS access and current information and training requirements still matter where exposure is possible.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 10, 1988
Ms. Katherine S. Davis
Project Industrial Hygienist
International Paper
Suite 212
6075 The Corners Parkway
Norcross, Georgia 30092
Dear Ms. Davis:
This is in response to your letter of October 25, regarding clarification of the Hazard Communication Standard (HCS) 29 CFR 1910.1200 container labeling requirements.
The term container as defined in 29 CFR 1910.1200(c) means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank or the like that contains a hazardous chemical. The definition specifically states that pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle are not considered to be containers. Therefore lift trucks would not be considered a container for purposes of the HCS and would not require labeling regarding hazardous chemicals used to operate them. This does not exempt such chemicals from coverage by the rule; it simply eliminates the need to label once they are placed in the vehicle.
Other machines found in the workplace that may contain hazardous chemicals do not fall under the definition of container, therefore the machine components would not have to be labeled according to the HCS. If there is the potential for exposure to the hazardous chemicals associated with these machines, the article definition would also not apply and these chemicals would be covered by the rule. Again, the need to label the machine components once the hazardous chemicals are in place is eliminated.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The explicit current definition excludes vehicle operating systems, not every chemical vessel built into any machine. Apply the actual container definition and stationary-process alternatives with required workplace information.]
Process equipment however, which incorporates containers as defined by the HCS, such as mixers and blenders, must be labeled according to the rule. The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(5) of the standard.
[ILPI note: This alternative is now paragraph (f)(7), referring to workplace label information. Written materials must identify the containers and remain readily accessible during each shift.]
We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.
Sincerely,
Themes 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/1988-11-10.