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OSHA Hazard Communication Letters of Interpretation
Hazard determination; labeling of solid materials.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Article and solid-label exceptions remain conditional; modern classification applies
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its distinction between an exempt article and a nonexempt solid material remains useful. Lack of a release during shipment does not establish article status when normal use involves grinding or other hazardous releases.
Apply all conditions of complete article definition (FAQ), anticipated-use evaluation, mixture classification and current solid-material label exception(formerly(f)(2)). The few-molecules description must not be separated from the no-physical-hazard-or-health-risk condition. No mandatory new testing does not mean no evidence evaluation; testing a mixture as a whole is not a universal substitute for all modern hazard-specific criteria. See dust and classification.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
December 1, 1998
Mr. J. J. Wherry
Grinding Wheel Institute
30200 Detroit Road
Cleveland, Ohio 44145-1967
Dear Mr. Wherry:
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We have received your letter of August 6, addressed to Mr. John B. Miles Jr., Director, Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP), in which you asked questions regarding labeling under the Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]. Thank you for your inquiry. For clarity, your questions are paraphrased below.
- What tests or exposure scenarios are required to establish a standard of proof for the article exemption?
- When testing "as a whole" for hazard determination, what are the full range of tests required to establish the presence or absence of a hazard?
- Grinding wheels, superabrasive products, and sandpaper do not create an exposure during shipment. Are these items subject to labeling provisions under paragraph (f)(1) [ILPI: Original HCS 1994 context · Current HCS; modern shipped-label elements apply] or paragraph (f)(2) [ILPI: Original HCS 1994 context · Current HCS; solid-material exception now (f)(4)] of the standard?
The HCS does not require testing to determine the presence of a hazardous chemical. The rule covers chemicals which are "known to be present." The release of a very small quantity (that is, a few molecules or trace amounts) of a hazardous chemical is not covered by the rule. For instance, one may assume that an item, such as newly varnished furniture, emits chemicals. This, however, would not be covered under the HCS.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. The complete article definition also requires no physical hazard or health risk under normal use. Evaluate anticipated grinding/sanding releases; the nonexempt solid-material labeling provision is now (f)(4).]
This definition of the article exemption has not changed since the standard was originally published in 1983. In 1994, the definition was amended to provide clarification. Further guidance is provided on page 31865 of the Federal Register, Volume 52, Number 163, published on Monday, August 24, 1987.
There is no pre-set list of testing requirements. Manufacturers may test a mixture "as a whole" or may rely on tests which have been scientifically conducted. The purpose of the hazard determination is to provide known information for the elements listed under paragraph (g) of the standard [ILPI: Original HCS 1994 context · Current HCS]. It is the manufacturer's prerogative to "test as a whole" for any or none of these elements.
Labeling requirements for items which are solid materials, but do not classify as articles, are described in paragraph (f)(2) of the standard [ILPI: Original HCS 1994 context · Current HCS; solid-material exception now (f)(4)].
We hope that this information is helpful. Please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 693-2190 if further guidance is needed.
Sincerely,
Richard E. Fairfax
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/1998-12-01.