Meeting labeling requirements of the hazard communication standard for slag wool

April 1, 1993

Mr. Charles A. Jones
Director, Environmental Affairs and Safety
Sloss Industries Corporation
[Recipient address omitted]
Dear Mr. Jones:

This is in further response to your letter of December 1, to the Occupational Safety and Health Administration (OSHA) Area Director, John Hall. Your letter was forwarded to Federal OSHA's Office of Health Compliance Assistance for response.

Your letter to John Hall requested clarification on the labeling requirements of the Hazard Communication Standard (HCS), 29 CFR 1910.1200. You indicated that a label is currently attached to bales of your slag wool, and this has caused problems when your customers process the slag wool. They have reported that the labels become "entrained" in the final product.

The proposed alternative labeling method described in your letter is satisfactory and meets the intent of the standard. You proposed to:

1. Utilize signs in the facility to convey the information to our employees;

2. Post signs conveying information inside the rail cars which are used to ship these bales;

3. Transmit a label and a material safety data sheet with each shipment;

4. Post a sign in areas where bales are accumulated and consumed.

However, we disagree with the rational you offered for implementing them. The alternative labeling methods which you cited, 29 CFR 1910.1200 (f)(2) and (f)(6), do not apply to your unique situation. Paragraph (f)(2) discusses labeling requirements for solid metals, such as a steel beam or a metal casting, and does not apply to bales of slag wool. Paragraph (f)(6) also does not apply because it specifically addresses "stationary process containers."

The alternative means of providing a hazard warning that you propose to implement is appropriate because bales do not meet the HCS's definition of a container. Even though the twine or wire that secure the bales are not containers as defined under the standard, and do not lend themselves to standard labeling methods, chemical hazards must still be conveyed.

The purpose for labels under the Hazard Communication standard is clear. Labels provide an immediate warning of the hazards that employees may be exposed to and, through the chemical identity, labels provide a link to more detailed information available through MSDSs and other sources. Labels must contain the identity of the chemical, and appropriate hazard warning, and the name and address of the responsible party. Employers must ensure that the hazards of slag wool are presented to employees by alerting them to potential hazards before exposure could occur.

We hope this information is helpful. If you have any further questions please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs

[Attached correspondence reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]