Answer Library / Chemicals & HazCom OSHA letter · 2019-09-11

Can you combine or shorten precautionary statements on GHS chemical labels?

Quick answer

Yes. When a chemical has multiple hazard classifications with similar precautionary statements, the most stringent statement must appear on the label, and statements may be combined, reordered, or reworded to save space and improve readability (29 CFR 1910.1200, Appendix C, C.2.4.7).

A chemical product steward asked OSHA four questions about streamlining precautionary statements on Hazard Communication (HazCom 2012) labels, including whether similar statements like "Immediately call a poison center/doctor" and "Call a poison center/doctor if you feel unwell" can be consolidated into the more protective one.

OSHA said yes. Under Appendix C, C.2.4.7 of the Hazard Communication Standard, when a chemical carries multiple hazard classifications with similar precautionary statements, the most stringent statement must be included on the label. OSHA pointed to its Inspection Procedures for the Hazard Communication Standard (HCS 2012) guidance document for additional detail.

OSHA also confirmed that similarly worded statements "may be arranged to create an order of preference, or combined to save space and improve readability." That flexibility covers combining statements across hazard classes (for example, Acute Toxicity-Oral under C.4.1 with Skin Corrosion/Irritation under C.4.4) and stating a shared instruction like "If exposed: Immediately call a poison center or doctor" once, followed by route-specific precautions. The limit: all precautionary statements must still be listed, except as allowed under Appendix C sections C.2.4.5, C.2.4.6, and C.2.4.8.

29 CFR 1910.120029 CFR 1910.1200 Appendix C
Source: OSHA Standard Interpretation letter, 2019-09-11 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

Get answers like this in seconds — with the receipts

Canary AI answers safety & compliance questions from the actual standards and interpretation letters, cites the exact section, and drafts JHAs as clean PDFs. Free during the pilot.

Join the pilot →

Related answers

Can an SDS list physical and chemical properties for the concentrated chemical instead of the diluted mixture actually shipped?Chemicals & HazCom · OSHA letter 2018-07-24Did OSHA extend the HCS 2012 relabeling deadline for distributors of long shelf life agricultural chemicals?Chemicals & HazCom · OSHA letter 2018-07-30Are minimum risk pesticides, spray adjuvants, and fertilizers exempt from OSHA HazCom labeling?Chemicals & HazCom · OSHA letter 2018-07-30