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OSHA Hazard Communication Letters of Interpretation
Labeling of small containers in the laboratory
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; laboratory coverage determines the answer
First establish whether the operation actually qualifies under the Laboratory Standard. The absence of a specific secondary-container label rule there does not remove the need for a protective Chemical Hygiene Plan, training and incoming-label protections. Production and quality-control operations may instead have full HazCom duties; see the November 10, 2014 laboratory letter.
Outside that laboratory coverage, workplace labels must identify the product and communicate hazards through the permitted system. The current small-container shipped-label alternatives are conditional and do not create a general exemption for every small workplace bottle.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 3, 2015
Mr. Sumit K. Ghosh
Motorola Mobility, LLC
222 Merchandise Mart Plaza, Suite 1800
Chicago, Illinois 60654
Dear Mr. Ghosh:
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Thank you for your April 27, 2015, letter to the Occupational Safety and Health Administration (OSHA) Directorate of Enforcement Programs, and subsequent telephone conversation with a member of my staff. Your letter requested clarification of OSHA's Hazard Communication standard (HCS 2012), 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS], with regard to labeling of small containers in the workplace. 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.
Scenario: Your company is not a manufacturer, importer, or distributor of hazardous chemicals. Hazardous chemicals are used in your company's lab and facility. The lab you've described supports production as well as research and development. Different sizes of containers of hazardous chemicals are used. The larger 16-ounce bottles of hazardous chemicals are dispensed into four 4-ounce bottles. The primary bottles are properly labeled [ILPI: Original HCS 2012 context · Current HCS]; however, you state that due to the small size of the 4-ounce bottles, applying all of the HCS 2012 information is impossible.
Question: What is a reasonable solution for labeling the small 4-ounce bottles of hazardous chemicals?
Response: OSHA's Laboratory standard, 29 CFR 1910.1450, covers laboratories meeting the criteria of "laboratory use" and "laboratory scale" but excludes procedures that are part of a production process. See 1910.1450(b) (definition of "Laboratory use of hazardous chemicals"). Research and academic laboratories meeting these criteria are covered by the Laboratory standard and are not covered under the HCS 2012 [ILPI: Original HCS 2012 context · Current HCS].
The Laboratory standard requires that labels on incoming containers of hazardous chemicals not be removed or defaced, per paragraph 1910.1450(h)(1)(i), but does not have a specific labeling requirement for secondary containers of hazardous chemicals in a covered laboratory. The Laboratory standard allows laboratories flexibility in tailoring their written Chemical Hygiene Plan (CHP) and standard operating procedures to be protective of employees in laboratories. See 29 CFR 1910.1450(e). In addition, 1910.1450(f)(4), Training, requires the employer to train employees regarding the physical and health hazards of chemicals in the work area, the measures employees can take to protect themselves from these hazards, and the employer's CHP.
[ILPI note: At issuance: HCS 2012. This answer depends on Laboratory Standard coverage. Otherwise, apply workplace labeling; current small-container shipping provisions address a different issue.]
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On January 22, 2013, OSHA published an updated Appendix A (non-mandatory) to 1910.1450 to assist employers in developing an appropriate CHP. The non-mandatory recommendations were based on the National Research Council's (NRC) 2011 edition of "Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards," and include recommendations for labeling secondary containers. Appendix A to 1910.1450 can be found on OSHA's website at https://www.osha.gov.
If your facility or a non-laboratory portion of your facility is not covered by the Laboratory standard, the HCS 2012 paragraph 1910.1200(f)(6) [ILPI: Original HCS 2012 context · Current HCS], Workplace labeling, provides employers with flexibility when labeling hazardous chemicals in the workplace. Employers can provide either all of the required information that is on the label from the chemical manufacturer or the product identifier and words, pictures, symbols or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals. See 1910.1200(f)(6)(i) [ILPI: Original HCS 2012 context · Current HCS] and (ii) [ILPI: Original HCS 2012 context · Current HCS]. In addition, employers are required to train their employees on workplace labeling systems as well as labels received on shipped containers which comply with the HCS 2012 per paragraph 1910.1200(h)(3)(iv) [ILPI: Original HCS 2012 context · Current HCS].
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/2015-09-03.