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.

June 10, 1983

Mr. John D. Hopkins
Section Staff Executive
National Electrical
Manufacturers Association
2101 L Street, N. W. - Suite 300
Washington, D. C. 20037

Dear Mr. Hopkins:

This is in response to your letter of May 23, 1983, addressed to Mr. Barry White, requesting an evaluation of NEMA's "Mr. Ouch" Labeling System.

NEMA's "Mr. Ouch" Labeling System does not violate OSHA's requirements. However, these labels can only be used in addition to, not in place of, any danger, caution, or safety instruction signs required by OSHA standards. For example, signs for transformers are addressed in section 1910.303(h)(2)(ii), section 1910.305(j)(5)(ii)m and section 1926.402(d)(3). These signs must meet the requirements of section 1926.200 of the standards for construction, as appropriate.

I hope this information is helpful to you. If I may be of further assistance, please feel free to contact me.

Sincerely,

Bruce Hillenbrand
Acting Director, Federal Compliance
and State Programs