Document Qg2nd06aNYDjzNGD9K78zx2no
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TO: Safety Directors
Interoffice Communication
FROM: DATE:
SU6J:
Tom Grumbles July 12, 1985
OSHA HAZARD COMMUNICATION STANDARD: BULK CONTAINER LABELING
It has been resolved that bulk containers (railcars, tank trucks, etc.) will be labeled in addition to DOT placarding and marking requirements- In summary, this decision is based on product liability concerns, evolving industry practice, and continued uncertainty regarding OSHA's stance on this issue.
We are currently investigating how best to do this but the label will basically be a reduction of the drum labels, minus the empty drum warning, in a tag or tag/envelope format similar to the VCM warning tags currently used. Operationally, this will probably be applied by the loader at the same time the container seals are placed.
Details to follow.
Thomas G. Grumbles ajo/007 cc Plant Managers
VVV 000016820