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OSHA Hazard Communication Letters of Interpretation
Employee exposure to hazardous chemicals while working around small sensors.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Exposure during construction, removal or disposal remains important
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains useful: a sealed sensor's ordinary use and work that opens, damages or removes it can present different exposure situations. A small amount or an enclosed chemical does not automatically establish an article exemption.
Under the current HCS, apply complete article definition (FAQ), scope, potential exposure and current information and training requirements. The old repair/demolition guidance is not a universal waiver of labels or SDSs whenever maintenance is involved; duties depend actual roles and circumstances. The original enforcement context is CPL 2-2.38C (1990); current counterpart current HCS inspection procedures. OSHA marks its matching source corrected December 6, 2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 31, 1993
Ms. Denese A. Deeds, CIH
Senior Consultant
Industrial Health & Safety Consultants, Inc.
915 Bridgeport Avenue
Shelton, CT 06484
Dear Ms. Deeds:
We have all kinds of first aid signs, posters and labels at Safety Emporium.
This is in response to your letter of June 21, to Mr. John Miles concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. Mr. Miles forwarded your inquiry to the Office of Health Compliance Assistance for response. Please accept our apologies for the delay in responding to your letter.
You explain that employees working with or around small sensors which contain small amounts of a corrosive chemical would not be exposed to the hazardous chemicals under "normal conditions of use." OSHA agrees that these sensors would be considered articles as long as employees were not exposed to the hazardous chemicals, and, therefore, would not be covered by the Hazard Communication Standard (HCS).
If employees were exposed to the hazardous chemicals contained in the sensors during the construction of scientific instruments, or during the removal and disposal of old sensors, the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] would apply. It is the employer's responsibility to determine if there is a threat of exposure to hazardous chemicals. OSHA instruction CPL 2-2.38C ILPI note: Original: CPL 2-2.38C (1990). Current: HCS inspection guidance., dated October 22 1990, states the following in paragraph K.3.c.:
In some cases, a hazardous chemical may be present for a long period of time without an employee exposure until repair or demolition activities are performed. By way of example, employers involved in work operations where jackhammers are being used to break up a sidewalk know that they are exposing their employees to a hazardous chemical (silica), even though they did not "bring" the hazard to the site. Even though other provisions of the standard may not be enforceable (MSDS and labels), the employer should still develop a hazard communication program to inform their employees "about the hazardous chemicals to which they are exposed." Employers may utilize their already existing hazard communication program to communicate information on these types of hazards to their employees, as per paragraph (e)(3) [ILPI: Original HCS 1987 context (PDF) · Current HCS].
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: scope, complete article definition (FAQ) and HCS inspection guidance. The repair/demolition example is not a general label/SDS exemption for all maintenance chemicals.]
If there is potential for employee exposure, employers are required to include information regarding the hazards of the corrosive materials in the sensors in their hazard communication program.
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Roger A. Clark, 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/1993-08-31.