There are some situations where the specific target organ effect is not known. Where this is the case, the more general warning statement would be permitted. For example, if a chemical causes lung damage if inhaled, then the appropriate warning should be that the chemical causes lung damage if inhaled . OSHA's requirement that manufacturers specifically state the target organ effects on labels of hazardous substances is nowhere to be found in the formal OSHA regulations. OSHA claims that this rule is a logical interpretation of its formal labeling regulations.
Some reasonable people disagree.
As you know, OSHA is enforcing this interpretation and it has cited seversl companies for violating this standard. On at least four occasions, cited companies have challenged the labeling requirement alleging that it is invalid because the proper rulemaking procedures were not followed. Unfortunately, each of those citations was settled with OSHA before the issue of the validity of the regulations was decided. As it stands now, OSHA requires the labels to state the hazards of the chemical, including target organ effects. I would imagine that this regulation will be challenged again and I will keep you informed of any favorable developments.