What about OSHA hazard communication (HazCom) labeling for intra-plant and inter-company shipping?

The in-house (or workplace) labeling requirements found at 29 CFR 1910.1200(f)(6) apply to labeling hazardous chemicals that are used within the workplace. This provision provides an alternative to the shipped container labels under 1910.1200(f)(1). The question is do the in-house labeling requirements apply when moving hazardous chemicals intra-plant and/or inter-company?

OSHA explains that the agency views hazardous chemicals that are transported within the same building intra-plant as being the same workplace, and accordingly, in-house workplace labeling in paragraph (f)(6) would be permitted. However, any container leaving the workplace is considered a shipped container and must comply with the labeling requirements in paragraph (f)(1). Thus, hazardous chemicals that are transported between workplaces (i.e., from one company building/property to another company building/property), even if within the same company, must be labeled per paragraph (f)(1). Source 12/3/2018 OSHA letter of interpretation.