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Target-organ and manufacturer details on shipped chemical labels

Summary An aerosol maker asked what information had to fit on small labels for products shipped to industrial users. OSHA said target-organ effects were required on shipped hazardous containers, though it had dropped that requirement for in-plant containers. It gave no minimum label size and said a shipped HMIS label also needed the manufacturer's name and address.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1986-11-10
Date issued
November 10, 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.

November 10, 1986

Mr. Lloyd T. Flanner
Vice President
Aerosol Systems, Inc.
[Recipient address omitted]

This is in response to your letter dated August 18 regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

The labeling requirements addressed in my June 3 memorandum to Regional Administrators has been changed. Target organ effects are no longer required for in-plant containers. Target organ effects, however, are still, and have always been, required for all shipped containers. Therefore, if you sell an aerosol product to manufacturing users, which contains a hazardous ingredient(s), the organs affected must appear on the label.

The HCS does not provide specifications for label size. However, the label must contain all of the labeling information required by the standard. If a HMIS label is to be used on a shipped container the target organ effects and the name and address of the chemical manufacturer must be added to the label.

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

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

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

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