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Mercury thermometer labels under hazard communication

Summary An OSHA regional office asked whether industrial thermometers require hazard labels under the Hazard Communication Standard. OSHA said thermometers expected to break in normal use and expose employees to mercury are not exempt articles, so each container needs the required hazard label information. The guidance matters to manufacturers and employers using industrial thermometers.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-07-17
Date issued
July 17, 1989
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication Mercury
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.

July 17, 1989

MEMORANDUM FOR: JAMES W. STANLEY
REGIONAL ADMINISTRATOR

ATTENTION: ACTING ASSISTANT REGIONAL ADMINISTRATOR FOR TECHNICAL SUPPORT

THROUGH: LEO CAREY, DIRECTOR
DIRECTORATE OF FIELD PROGRAM

FROM: PATRICIA K. CLARK, ACTING DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Hazard Communication Standard (HCS) Labeling Requirements for Industrial Thermometers

This is in response to your memo of June 6, which forwarded a memo from the Manhattan Area Office requesting an interpretation of the Hazard Communication Standard as it applies to labeling requirements for industrial thermometers.

If industrial thermometers are expected to break during normal conditions of use, exposing employees to mercury, they are not considered articles for purposes of the HCS. Under the labeling provisions of the HCS each thermometer container would have to be labeled, tagged, or marked with the required label information.

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