Visibility of hazard labels on shrink-wrapped pallet bags

July 2, 1986

Mr. Frank J. Karasinski
Safety & Loss Prevention Manager
FMC Corporation
[Recipient address omitted]
Dear Mr. Karasinski:

This is in response to your letter of May 29 concerning the labeling requirements of the Hazard Communication Standard (HCS), 29 CFR 190.1200.

Your letter raises questions about the visibility of labels on shipments of palletized bags. The purpose of a label is to provide an immediate visual warning to employees before a potential exposure to the products contents occur. Additionally the label identity serves as a point of cross reference with the material safety data sheet.

The standard's intent is met as long as the placement of the label permits it to be seen before employees are potentially exposed to the hazardous chemical. If for instance the product is flammable or shock sensitive then the label warnings must be visible before handling, so that special care if necessary, can be taken. On the other hand, for a product that only presents a toxicity hazard when a bag is opened then a label that is visible when the bag is readied for opening is acceptable.

As you can see proper placement of labels is dependent on a product characteristics and the ways and means employees may be exposed to them. Labeling therefore must be considered on a case by case basis. Obviously however, the more visible a label the better the chance that it will he effective.

We hope the above information will assist you in your HCS compliance activities. Please contact us again if further assistance is needed.

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

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