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OSHA Hazard Communication Letters of Interpretation
Clarification of the label requirements of the OSHA Hazard Communication Standard (HCS).
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Container-specific warning principle retained; paragraph numbers changed
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central conclusion remains consistent: a shelf or cabinet label is not automatically a substitute for the required information on movable chemical containers. Existing compliant labels should be preserved, and the immediate-use exception is limited to its actual conditions.
Under the current HCS, use workplace label information, stationary-process alternatives, immediate-use exception, and label preservation. The quoted paragraph numbers below are historical: old (f)(5)/(6)/(7) correspond to present (f)(6)/(7)/(8) for these subjects. Immediate use means control and use by the transferring employee within that work shift; ordinary storage in a drawer does not qualify.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 11, 1989
Mr. Karson L. Carpenter
Health Career Learning Systems, Inc.
17187 North Laurel Park Drive
Suite 343
Livonia, Michigan 48152
Dear Mr. Carpenter:
Safety Emporium carries NFPA signs and labels like these ones. Plus a whole lot more!
This is in response to your letter of June 9, addressed to Alan McMillan, Acting Assistant Secretary, requesting a clarification of the label requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.
Under the HCS, the manufacturer, importer, or distributor is required to label each container of hazardous chemicals. Therefore, each container of hazardous chemicals received should have existing labels that comply with the requirements of the rule, and your clients would not be required to relabel the containers, shelves or doors. If the hazardous chemicals are transferred into unmarked containers, these containers must be labeled with the required information, unless the container into which the chemical is transferred is intended for the immediate use of the employee who performed the transfer. As stated in paragraph (f)(7) of the rule, "The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer."
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This quoted exception is now paragraph (f)(8); apply the full immediate-use definition. The next paragraph's stationary-process alternative is now (f)(7), with workplace information under (f)(6).]
Section 29 CFR 1910.1200(f)(6) states the following: "The employer may use signs, placards, process sheets, batch tickets, operating procedures, or such written materials in lieu of affixing labels to individual stationary process containers,...." As stated in your letter, your clients store various types of chemicals in containers on shelves or in cabinets and drawers; however, these containers are not considered stationary (not capable of being moved) process containers. Therefore, each container must convey the information outlined in section (f)(5).
We hope this information is helpful to you in implementing your hazard communication program. If we can be of further assistance to you, please do not hesitate to contact us.
Sincerely,
Patricia K. Clark, Acting 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/1989-07-11.