Standard Interpretations - Table of Contents
• Standard Number: 1910.1200(c); 1910.1200(f)(4); 1910.1200(f)(5); 1910.1200(g)

September 25, 1984

Mr. Jim Wooldridge
Delta Solvents & Chemicals Company
610 Fisher Road
Longview, Texas 75604

Dear Mr. Wooldridge:

This is in response to your letter of July 23 to Gilbert J. Saulter, Regional Administrator, requesting clarifications of the Hazard Communication standard (29 CFR 1910.1200). Your questions are answered as follows:

1. Must bulk chemical storage tanks and the plumbing be marked and labeled to show all hazards?

Answer: The standard permits several alternative warning methods under 1910.1200(f)(5) as follows:

"(5) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraphs (f)(4) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.

Appropriate hazard warnings are required for all hazardous chemicals present.

2. When containers are filled for storage must they be labeled on the distribution property?

Answer: Containers should be labeled as soon as practicable. A delay between filling and labeling is permissible. Bulk storage tanks from which filling is taking place must be labeled.

3. Must the label identify all products in mixtures?

Answer: Employers need not list all of a product's constituents