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Labels for hazardous chemicals moved between company plants

Summary A company asked whether chemicals sent from one of its plants to another require hazard labels. OSHA said hazardous chemicals moved between company facilities must be labeled, regardless of whether the plants are in the same state. The normal exceptions for stationary process containers and immediate-use portable containers remain limited to those circumstances.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-02-16
Date issued
February 16, 1989
Status
Active
Status last verified October 10, 2026

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February 16, 1989

Ms. Judy Peterson
Manager, Research and Standards Development
Corporate Safety and Health Administration
Boeing Support Services
[Recipient address omitted]
Dear Ms. Peterson:

This is in response to your letter of September 28, 1988, addressed to Ms. Jennifer Silk, regarding the requirements for the labeling of chemicals leaving the workplace under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard 29 CFR 1910.1200. Please accept our apology for the delay in response.

Hazardous chemicals transported to another plant of the same company whether across State lines or within the State are required to be labeled by the employer. 1910.1200(f)(5) requires the employer to label all chemicals in the workplace with the identity of the hazardous chemicals and appropriate hazard warnings. The two exceptions to this provision are when alternative methods are used to identify stationary process containers and when hazardous chemicals are transferred to portable containers for the immediate use of the employee that performed the transfer.

We hope this information is helpful to you. Please contact us again if further assistance is needed.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance

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