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OSHA Hazard Communication Letters of Interpretation
Applicability of the Hazard Communication Standard to stevedores in the containerized shipping industry.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Sealed-container duties retained; training depends on actual tasks
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains consistent: sealed cargo does not eliminate all hazard communication duties. The limited sealed-container provisions require information and training sufficient to protect workers if a spill or leak occurs.
Apply current sealed-container provisions, including incoming-label preservation, SDS availability, and appropriate training. The current longshoring counterpart is 1918.1(b)(4), which applies 1910.1200; the letter's 1918.90 citation is historical. Workers opening containers or undertaking chemical handling/response need evaluation beyond the limited sealed-container situation. Evacuation-only training is not sufficient for workers assigned spill cleanup.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 17, 1988
Alan J. Kaplan, Director
Safety Engineer
Sea-Land Corporation
Post Office Box 800
Iselin, New Jersey 08830
Dear Mr. Kaplan:
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This is in response to your letter of June 15, concerning the training requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) as applied to stevedores. Your letter requests reconsideration of our previous correspondence to you of June 6, 1988.
The standard itself addresses the issue of sealed containers in section 29 CFR 1918.90(b)(4)(iii): "Employers shall ensure that employees are provided with information and training...to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container.." Although, as you state, stevedores may not directly handle individual sealed containers, the trailers, with their sealed cargo, would also be considered sealed containers and therefore covered by the limited provisions of the standard under paragraph (b)(4).
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). At issuance the letter cites the historical longshoring HCS incorporation at 1918.90. The current subject-specific provisions are 1910.1200(b)(4); current longshoring adoption is 1918.1(b)(4). The old citation should not be treated as proof that OSHA meant a different standard.]
Since the standard addresses the handling of hazardous chemicals in sealed containers, OSHA cannot exempt stevedores in the containerized shipping industry from the training requirements of the HCS. Employers can develop training programs to reflect the type of work performed. For example, if an employer's work practice procedures for leaks and spills is to evacuate the work area, then the employer's training program could just address the proper action to take, such as evacuation procedures, cleanup responsibility, etc.
Specific training is not required concerning the hazards of each chemical stevedores may encounter in a sealed container, provided that employees are aware of general precautions to take in the event of a spill or leak of the chemical. If an employer has employees who open sealed containers, then those employees would be covered by the more comprehensive provisions of the standard.
If we can be of further assistance, please feel free to contact us again.
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/1988-11-17.