Document K7vjo2XXbkoGX0mV4XQ12Ex0

TO: Bill McClain Interoffice Communication FROM: DATE: Tom Grumbles January __29.^-1985 SUBJ: 'OSHA HAZARD COMMUNICATION STANDARD; LABELING REQUIREMENTS The subject standard 29 CFR 1910,1200 requires that containers leaving a plant be labeled with the chemical identity, appropriate hazard warning and name and address of the responsible party (1910.1200(f) (i)). This section (attached) further states that this be done in a manner which does not conflict with DOT regulations. My question is if a bulk container (greater than 110 gallons) is labeled or placarded in accordance with the DOT classification scheme, is additional labeling required to comply with the OSHA standard? The DOT classification scheme deals predominately with physical hazards (i.e., flammable, corrosive) and except for the Poison A and B classification do not deal with health hazards as defined by the OSHA standard. In most cases there is no specific chemical identity on the container. Also, DOT is very specific as to how materials must be classed and identified for transportation purposes. Please let me know when we can discuss this issue. Your prompt attention to this matter is requested as the compliance date for this labeling requirement is November 25, and it would require significant effort to assure a system was in place to comply with any additional labeling requirements for tank trucks and railcars. Thomas G. Grumbles ajo/006 Attachment VVV 000016027 TO: Fayetta Tasby Roscoe Cooley Interoffice Communication FROM: DATE: SUBJ: Tom Grumbles January 28, 1985 VIS1AORDER ENTRY OF HAZARDOUS MATERIALS: MULTIPLE PRODUCT LISTING It has come to our attention that when multiple product listings are entered on a Bill of Lading, the potential exists for an incorrect hazardous material description or no description to be printed on the Bill of Lading. This could result in non-compliance with DOT regulations and significant monetary fines. The problem is a result of the "logic" COEDS uses to determine the need for and which specific hazardous materials description is printed when multiple products are listed on the Bill of Lading. We are reviewing the options for fixing this system problem, however, in the interim I am asking that any multiple product listings routinely used be reviewed by me to assure the proper hazardous materials description is being used. Your cooperation in this matter is appreciated. Thomas G. Grumbles ajo/006 cc C. Williams F. Thomas B. Tuzinkiewicz T. Randolph VVV 00001602a