Clarification on combining hazard statements on labels under the hazard communication standard

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,

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. 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?

Response: Yes. HCS 2012 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 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.

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 http://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