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OSHA Hazard Communication Letters of Interpretation
Standards that apply to cotton gins
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: HazCom coverage remains; use current agriculture incorporation and enforcement guidance
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Cotton ginning is treated as agriculture for OSHA coverage. HazCom remains one of the general-industry standards incorporated through 1928.21; the cotton-dust standard's exclusion is not a general exemption from chemical-hazard duties.
Consult current 1928.21, cotton-gin guarding requirements and current HCS coverage. For general-duty citations use the current Field Operations Manual, not the historical FIRM/FOM edition cited. SIC has been superseded by NAICS; industry coding alone does not decide which OSHA standards apply. The source is dated August 6, 2002 despite this file's legacy filename, and records a January 21, 2009 correction.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 6, 2002
MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
STATE DESIGNEES
FROM:
R. DAVIS LAYNE
Deputy Assistant Secretary
GARY VISSCHER
Deputy Assistant Secretary
SUBJECT: Cotton Gins
Questions have been raised as to which Occupational Safety and Health Administration (OSHA) standards are applicable to cotton gins. Under the Standard Industrial Classification (SIC) coding system, cotton ginning is under Agricultural Services and has the industry code of 0724. OSHA's long-standing position is that cotton ginning is an agricultural operation and not a general industry operation.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. SIC has been superseded by NAICS. The applicable agricultural standards and actual operations, not a code alone, determine OSHA coverage.]
OSHA's agricultural standards (Title 29, Code of Federal Regulation, Part 1928) specifically cover cotton gins in §1928.57, which deals with guarding of farm field equipment, farmstead equipment, and cotton gins. OSHA's cotton dust standard at §1910.1043(a)(2) specifically excludes cotton ginning from coverage.
The only standards that OSHA can apply to agricultural operations are the agriculture standards in 29 CFR Part 1928, and the few general industry standards referenced in §1928.21, which are also applicable to agricultural operations. The following general industry standards are referenced in §1928.21:
| Standard | Subject |
|---|---|
| 1910.111(a) & (b) | Storage & Handling of Anhydrous Ammonia |
| 1910.142 | Temporary Labor Camps |
| [1910.145(d)(10)] | Slow-Moving Vehicles |
| 1910.266 | Logging Operations |
| 1910.1027 | Cadmium |
| 1910.1200 [ILPI: Original HCS 1994 context · Current HCS] | Hazard Communication |
| 1910.1201 | Retention of DOT Markings, Placards & Labels |
If hazards are found at cotton ginning operations that are not covered by the above standards, consideration should be given as to the applicability of citing under OSHA's general duty clause (Sec. 5(a)(1) of the OSH Act). These may include hazards covered by general industry standards that are not referenced in §1928.21. When a general duty citation is issued, procedures in Paragraph C.2.c. of Chapter III of OSHA Instruction CPL 2.103, Field Inspection Reference Manual (FIRM) [correction 01/21/2009: OSHA Instruction CPL 02-00-148, Field Operations Manual (FOM)], are to be followed.
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2002-08-06.