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Title: 07/08/2004 - Hazard Communication: classification of uninterruptible power source batteries and office chemicals as "consumer products".
Record Type: InterpretationStandard Number: 1910.1200; 1910.1200(c)

July 8, 2004

Ms. Elaine B. Enfonde
Senior Environmental Scientist
Nixon Peabody, LLP
Clinton Square
P.O. Box 31051
Rochester, New York 14603-1051

Dear Ms. Enfonde:

Thank you for your February 3, 2004 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Please be aware that this response may not be applicable to any question or scenario not delineated within your original correspondence. You specifically requested a written confirmation of your interpretation of 29 CFR 1910.1200, the Hazard Communication standard's (HCS) classification of [Uninterruptible Power Supply (UPS)] batteries and its applicability to office employees. Your statements are paraphrased below, followed by our responses.

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Statement: Nixon Peabody, LLP, uses sealed batteries, known as Uninterruptible Power Supply (UPS) batteries as backup emergency power for computers and telephone systems. It is our belief that these batteries, which are used solely in an office context and are handled by contractors, are either articles or consumer items, as is defined in 29 CFR 1910.1200(c) and are, therefore, exempt from the requirements of the HCS, as either articles or consumer items.

Statement: A review of our firm's and clients present use and storage practices for office chemicals such as white-out, adhesive, copier chemicals, and cleaning agents, established that the offices use only small quantities of these chemicals.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs


The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2004-07-08.