LABELING OF HAZARDOUS CHEMICALS FOR BULK SHIPMENTS
The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) and the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) are responsible for enforcing distinct and separate safety standards that address appropriate labeling of chemical hazards in transportation (PHMSA) and in the workplace1 (OSHA). PHMSA’s labeling requirements are contained in the U.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) and apply to transportation2 of hazardous materials in commerce. OSHA’s labeling requirements are specific to the workplace and are found in the Hazard Communication Standard (HCS 2012), 29 CFR § 1910.1200. For the purposes of this memorandum, labeling also includes DOT placarding, signs, and other markings. PHMSA and OSHA are aware of a number of questions from stakeholders concerning the labeling required by each agency. The purpose of this memorandum is to provide clarity on the general applicability of, and overall relationship between, DOT’s labeling requirements under the HMR and OSHA’s labeling requirements for bulk shipments under the HCS 2012.