29 CFR 1910.1200, the HazCom Standard covers labels in Paragraph (f), Labels and other forms of warning: http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(f)

Appendix C, Allocation of Label Elements: http://www.ilpi.com/msds/osha/1910_1200_APP_C.html

Table C.4.9. (Carcinogenicity): http://www.ilpi.com/msds/osha/1910_1200_APP_C.html#table_C.4.9 states

Note: If a Category 2 carcinogen ingredient is present in the mixture at a concentration between 0.1% and 1%, information is required on the SDS for a product; however, a label warning is optional. If a Category 2 carcinogen ingredient is present in the mixture at a concentration of > 1%, both an SDS and a label is required and the information must be included on each.

The same information is found in Appendix A, Health Hazard Criteria. Paragraph A6.3, the Classification Criteria for Mixtures http://www.ilpi.com/msds/osha/1910_1200_APP_A.html#A.6.3

The toxicity determinations are independent of the carcinogenicity, so whether the acute toxicity skull and crossbones pictogram needs to appear is determined by those (per the classification procedures in Appendix A and label requirements in Appendix C for each type - oral, dermal etc.).

Best wishes,

Rob Toreki

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On Feb 10, 2022, at 11:08 AM, Monique Wilhelm <mwilhelm**At_Symbol_Here**UMICH.EDU> wrote:

Hi Everyone,

QUESTION: Is the toxic hazard and pictogram required on these labels?

I thought I read somewhere that a label for a mixture does not have to include the hazard of any component less than 1% but cannot easily find it right now. I know carcinogens designations occur at a much lower concentration, 0.001%. So, is the 1% rule true? Does anyone know of this guideline?

My institution uses ChemWatch Gold FFX for SDS and labeling info. Being a biochemist who always made her own solutions, when I looked up TBE info, I looked up each component. Boric acid is listed as a reproductive poison health hazard on its SDS. But, the researcher just looked up TBE buffer and it was listed as non-hazardous. The boric acid is at 0.5% when at 1x concentration, but is often made at 10x concentration and later diluted down. Is it still considered hazardous at these concentrations and require the toxic hazard and pictogram on these labels?

Thank you,

_________________________________________________________

Monique Wilhelm

Lab Manager

CAS, Department of Natural Sciences | The University of Michigan-Flint

303 E. Kearsley St | Room 572 MSB | Flint, MI | 48502-1950

NEW EMAIL ADDRESS: mwilhelm**At_Symbol_Here**umich.edu

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