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OSHA Hazard Communication Letters of Interpretation
Clarification on combining hazard statements on labels under the hazard communication standard
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent with the current HCS
The described combination remains consistent with current C.2.2.1: related hazard statements may be combined when every required hazard remains clear. A combined skin-burn/eye-damage statement can avoid redundant eye-damage wording.
This is not general permission to shorten away hazards or replace required hazard statements with informal warnings. Apply the relevant current hazard classifications and label elements.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 10, 2014
Mr. Robert D. Colau
North America Regulatory Manager
SAP America, Inc.
3999 West Chester Pike
Newtown Square, Pennsylvania 19073
Dear Mr. Colau,
If your workplace uses corrosive materials, OSHA requires an ANSI-compliant eyewash like this one from Safety Emporium.
Thank you for your letter dated September 19, 2014, to the Occupational Safety and Health Administration's (OSHA), Directorate of Enforcement Programs. You requested clarification on combining hazard statements pertaining to skin corrosion and eye damage with regards to OSHA's Hazard Communication standard (HCS 2012), 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS]. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to issues not delineated within your original correspondence. Your paraphrased question and our response are below.
Question: When the hazard statement, “Causes severe skin burns and eye damage,” appears on a label, is it acceptable to omit the hazard statement, “Causes serious eye damage” per Appendix C.2.2.1 of HCS 2012 [ILPI: Original HCS 2012 context · Current HCS]?
Response: Yes. HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] allows chemical manufacturers and importers to combine hazard statements where the information is related and the combination can shorten the text required on the label. Appendix C.2.2.1 [ILPI: Original HCS 2012 context · Current HCS] states, Hazard statements may be combined where appropriate to reduce the information on the label and improve readability, as long as all of the hazards are conveyed as required.
Since the hazard statement, Causes severe skin burns and eye damage,
includes eye damage,
it is acceptable to omit the second hazard statement.
[ILPI note: At issuance: HCS 2012. Current C.2.2.1 permits combination only when all required hazards are conveyed.]
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,
Thomas Galassi, 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/2014-11-10.