11/10/1988 - Lift trucks or other machines found in the workplace are not containers for labeling requirements of the HCS

Interactive Learning Paradigms, Incorporated


The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995!
The history and philosophy behind this resource.
A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics.
Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term.
An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more.
A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers.
Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet.
Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources.
Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors
You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard
Commercial suppliers of SDS authoring and management software as well as cloud compliance services.
Commercial companies that will create SDS's for your specific needs as well as SDS translation companies.

Safety signs, banners, and scoreboards? Get yours at Safety Emporium!

XXXPrevNext
Title: 11/10/1988 - Lift trucks or other machines found in the workplace are not containers for labeling requirements of the HCS.
Record Type: InterpretationStandard Number: 1910.1200(f)

    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.

    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.

    We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.

    Dispenser

    Contain leaky drums with overpack containers from Safety Emporium.

    Sincerely,

    Themes J. Shepich, Director
    Directorate of Compliance Programs


The original official public domain version of this document is available from OSHA at XXXOSHAURL.