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Vehicle components as hazard communication containers

Summary A truck manufacturer asked whether chemical-label rules applied to vehicle components that held operating fluids. OSHA said a radiator, engine or battery was not itself a container requiring a hazard label under the rule. Containers holding chemicals such as ethylene glycol or battery acid did require labels.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1986-08-11
Date issued
August 11, 1986
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication Chemical Labeling
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

August 11, 1986

Mr. Davis Thekkanath Sr.
Supervising Engineer
Oshkosh Truck Corporation
[Recipient address omitted]
Dear Mr. Thekkanath:

This is in response to your letter of June 25 regarding the Hazard Communication Standard (HCS).

The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. It is our interpretation that items such as a truck radiator, an engine, or a battery are not containers and therefore would not be required to be labeled. However, the containers that held such chemicals as ethylene glycol and battery acids would need to be labeled since they meet the definition of a "hazardous chemical" under the standard.

If you have any further questions, please feel free to contact us again.

Sincerely,
John B. Miles, Jr., Director

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

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