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OSHA Hazard Communication Letters of Interpretation
HCS 2012 pictograms for aerosol air fresheners
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Aerosol/gas-cylinder advice superseded by current criteria
The letter’s conclusion that an aerosol can also require classification as a gas under pressure does not reflect the current HCS aerosol criteria.
HCS 2024 changed the aerosol criteria. Current Appendix B.3.1 covers three aerosol categories; Note 2 to Table B.3.1 excludes additional classification under the gases-under-pressure class. Use current aerosol label elements in C.4.16 rather than automatically adding a gas-cylinder pictogram solely because an aerosol is pressurized. Other applicable hazards still require evaluation.
This ILPI comparison does not assert that OSHA has formally withdrawn the letter. Its historical wording and original HCS 2012 links are retained so readers can see the change.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 2, 2015
Mr. Juan Salazar
Industrias Salcom, S.A. DE C.V.
Calle 2 # 10540 Parque Industrial El Salto
El Salto Jalisco, Mexico CP45680
Dear Mr. Salazar:
Thank you for your October 17, 2014, letter to the Occupational Safety and Health Administration (OSHA). Your letter has been referred to OSHA's Directorate of Enforcement Programs for an answer to your specific question regarding guidance on the correct pictograms to display under 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 any questions not delineated within your original correspondence. Your question is paraphrased below, followed by our response.
Background: Your company manufactures aerosol air fresheners. In your letter, you referred to 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], Appendix B [ILPI: Original HCS 2012 context · Current HCS], Physical Hazard Criteria, and Appendix C [ILPI: Original HCS 2012 context · Current HCS], Allocation of Label Elements. Your question refers specifically to Table B.3.1 [ILPI: Original HCS 2012 context · Current HCS], Criteria for Flammable Aerosols, Table B.5.1 [ILPI: Original HCS 2012 context · Current HCS], Criteria for Gases Under Pressure, and Section C.4.16 [ILPI: Original HCS 2012 context · Current HCS], Flammable Aerosols. Table B.3.1 [ILPI: Original HCS 2012 context · Current HCS; aerosol criteria reorganized in HCS 2024] contains information used to classify the two categories of flammable aerosols. Table B.5.1 [ILPI: Original HCS 2012 context · Current HCS] contains information for the categories of gases under pressure. Section C.4.16 [ILPI: Original HCS 2012 context · Current HCS] provides information to be displayed on the product label for flammable aerosols.
Question: For a Category 1 flammable aerosol, is the gas cylinder pictogram required on the product label along with the flame pictogram, knowing that an aerosol has pressurized gas in its container that serves as propellant to deliver its product?
Response: Section C.4.16 of Appendix C of 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS] requires a flame pictogram on the product label of all flammable aerosols. A gas cylinder pictogram may also be required on the product label if the flammable aerosol is considered a gas under pressure, as defined under section B.5.1 [ILPI: Original HCS 2012 context · Current HCS] of Appendix B of 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS]. Section B.5.1 [ILPI: Original HCS 2012 context · Current HCS] states:
[ILPI note: At issuance: HCS 2012. Under current Table B.3.1, Note 2, aerosols are not additionally classified as gases under pressure. Use current aerosol label elements rather than this historical conclusion.]
Gases under pressure are gases which are contained in a receptacle at a pressure of 200 kPA (29 psi) (gauge) or more, which are liquefied or liquefied and refrigerated.
Although Section C.4.16 [ILPI: Original HCS 2012 context · Current HCS] recognizes that flammable aerosols are contained within a pressurized container, the gas cylinder pictogram is only required on the product label if the conditions mentioned in Section B.5.1 [ILPI: Original HCS 2012 context · Current HCS] are met. To clarify, Table B.5.1 of 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS] provides the criteria for classifying gases under pressure. If the flammable aerosol also meets the criteria in Table B.5.1 [ILPI: Original HCS 2012 context · Current HCS], then the chemical would be classified both as a flammable aerosol and a gas under pressure. The appropriate hazard information for both the gases under pressure and flammable aerosols hazard classes and categories would be required on the label and safety data sheet (SDS).
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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. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at 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 Progams
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2015-07-02-1.