Rotating solvent labels on one machine

October 20, 1999

James M. Kuszaj, Ph.D.
[Recipient address omitted]

Dear Dr. Kuszaj:

We are in receipt of your letter of March 22, 1999 regarding labeling provisions under the Hazard Communication Standard (HCS), 29 CFR 1910.1200. You described a labeling system used by your client and asked if this system meets the requirements of the HCS. This letter follows up on a phone conversation you had with a member of my staff. Please excuse this delay in providing these written comments.

The labeling system you described is designed for four different solvents with similar hazards. These solvents are used rotationally in one piece of equipment. You have proposed to label the equipment permanently with the manufacturer's name and the products' appropriate hazard warnings, including target organ effects. The solvent identity would be adhered to the equipment using stick-on labels. Differences in health effects that the solvents present (such as carcinogenicity) would be printed on the stick-on label.

The labeling requirements of the HCS include the identity of the hazardous chemical(s); appropriate hazard warnings; and the name and address of the chemical manufacturer, importer, or other responsible party. The labeling system you have proposed appears to meet these requirements.

Thank you for your interest in occupational safety and health. If you require further information, you may contact the Office of Health Compliance Assistance at 202-693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs