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Avoiding unsupported target-organ warnings on labels

Summary An OSHA regional office asked whether a manufacturer could use the same broad list of target-organ hazards on every product in a line. OSHA said each listed hazard must be demonstrated by at least one valid positive study for the particular chemical. The guidance matters to chemical manufacturers designing hazard labels.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1988-06-27
Date issued
June 27, 1988
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication 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.

June 27, 1988

MEMORANDUM FOR: MICHAEL G. CONNORS
REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR
DIRECTORATE OF FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Overwarning on Hazard Labels

This is in response to your memorandum of May 18 on the above subject. Specifically, you wish to know whether it is acceptable under the Hazard Communication Standard (HCS) for a company to use the same comprehensive list of health hazard target organs on the warning labels for an entire line of products.

Acceptability in terms of compliance with the HCS will depend upon whether, in fact, each product possesses all of the listed hazards. Any target organ hazard which is not demonstrated by at least one valid positive study for the chemical which is so labeled is not an appropriate hazard warning.

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