W EEKLY EDITION MAY 1, 2019
C hem i c al Lab e li n g Do s and D on't s
Wh e n Y o u Use Y o u r Ow n Lab e ls, Make S u r e T h ey Ar e OS H A - Co m p lian t
B y Kar le e n K o s, P S AI E xe cu t ive Dir e ct o r
R e m e m b e r : OSHA establishes policies and procedures at the federal level. States are required to establish
their own plans, enforcement policies and procedures which are at lea st as effective — generally meaning "at
least as stringent" — as those set by OSHA. States have the option of adopting identical or different language
and requirements as long as they meet or exceed OSHA's requirements. So, keep in mind that regulations in
your state or county could be more rigorous than those described in this article. Always check them out and
comply with their requirements.
For more information, you can delve into OSHA's 124 - page d irective on HCS enforcement
here https://www.osha.gov/OshDoc/Directive_pdf/CPL_02 - 02 - 079.pdf and its advisory letter on secondary
labeling here https://www.osha.gov/laws - regs/standardinterpretations/2017 - 06 - 20 .
- KK
P AGE 12
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