Imported chemical labels and shrink-wrapped stock

January 3, 1986
Merike Kammer, Office Manager
Filo Chemical Incorporated
[Recipient address omitted]
Dear Mr. Kammer:
This is in response to your letter dated October 29, 1985, requesting confirmation of three items relating to the Hazard Communication Standard.
As you correctly stated, chemical manufacturers and importers must label containers of hazardous chemicals leaving their workplaces, and provide material safety data sheets with initial shipments by November 25, 1985. The requirements of the standard are not retroactive regarding material safety data sheets and labels.
Labels should be put on imported hazardous materials as soon as practicable. Where the shipping container is a tank truck, rail car, or the like, the appropriate label may be provided with the shipping papers rather than posted on the container. It should not take beyond the first stop after the material leaves the pier to affix these labels.
Technically, chemical manufacturers, importers, or distributors are required to label each container leaving the workplace. Your method of labeling the entire pallet containing the shrink wrapped bags is a technical deviation from 29 CFR 1910.1200(f)(1), but is acceptable as long as the following is performed:

a. One label is placed on the outside of the pallet.
b. Individual labels are provided for each of the individual bags sold to your customer.
c. A determination is made that the customer did put these labels on.
d. This procedure is limited to your present stock. All future stock should be properly labeled.

If you have any further questions concerning the above please contact [the Office of General Industry Enforcement at (202) 693-1850].
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

[Requester letter reproduced on OSHA page; omitted here.]