Lift trucks and hazard communication labels

March 17, 1986

Mr. Kevin C. Donaghue
Rollins Burdick Hunter of Oregon, Inc.
[Recipient address omitted]
Dear Mr. Donaghue:

Thank you for your letter dated November 11, 1985, addressed to Mr. Carl Halgren, in regard to the Hazard Communication Standard. Please accept my apology for the delay in response. The overwhelming number of letters and telephone calls regarding the Hazard Communication Standard has caused unavoidable delays in responding to the public's concerns.

OSHA considers lift trucks to be machines and not containers. Containers are required to be labeled according to the standard. Labeling vehicle components seems to be impractical and would be cumbersome.

Material safety data sheets do not have to be provided for lift trucks. However, material safety data sheets are required for the gasoline and other fuels used by the lift trucks. Employees should be aware of the potential for exposure to carbon monoxide and associated physical hazards of petroleum fuel products such as fire and explosion.

Labeling of vehicle components is not necessary. Lift trucks do not meet the current definition of an "article" because of potential exposures to carbon monoxide and physical hazards of petroleum fuel products. The "article" definition was one of the issues upon which OSHA requested comment in the November 27, 1985, publication of the Federal Register. Comments were accepted until February 25, 1986.

If we can be of further assistance please contact our Office of Health Compliance Assistance at (202) 523-8036.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

[The regional forwarding memorandum and requester letter reproduced on OSHA's page are omitted here.]