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Who regulates my product: OSHA or CPSC?

A majority of commercially available products are regulated by one of two main federal agencies: the Occupational Safety and Health Administration (OSHA) and the Consumer Product Safety Commission (CPSC) but which regulations should your product use for labeling?

Well, it’s based on what it’s used for!

For products used in a workplace environment that will be used by employees to perform their jobs the labeling will be regulated by OSHA (29 CFR 1910.1200(a)). For example: an HVAC Technician using a specialty chemical coil cleaning product is legally required to use an OSHA compliant label with appropriate pictograms, hazard statements, and signal word.

(OSHA Label Sample)

If your product is intended to be used in the dwelling of a home by a person not using the chemical in a professional capacity then the product labeling will be regulated by the CPSC (16 CFR 1500). The Consumer Product Safety Commission claims jurisdiction over any “hazardous substance, whether or not packaged, that under any customary or reasonably foreseeable condition of purchase, storage, or use may be brought into or around a house, apartment, or other place where people dwell, or in or around any related building or shed including, but not limited to, a garage, carport, barn, or storage shed”

Determining if your product should be labeled for OSHA or CPSC regulations can be tricky and might require professional guidance but the rule of thumb is that if your product is meant for a workplace environment then it needs an OSHA label but if your product is meant for an “every day consumer” then the product needs to be a CPSC label. 

If your product seems like it might be applicable to both then you would need two different labels to satisfy both requirements. The distinction between OSHA and CPSC jurisdiction is largely determined by who is using the product. Employees need OSHA compliant labeling and consumers need CPSC compliant labeling. 

Cogwork Consulting Group has the professional know-how to assist you in ensuring that your product is compliant with the CPSC and OSHA. Don’t make the costly mistake of having your product classified as misbranded and out-of-compliance by letting us handle all of your compliance needs.