04/30/1986 - Labeling requirements for containers of polyvinyl chloride.

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OSHA Hazard Communication Letters of Interpretation

Mr. Peter A. Susser
Keller and Heckman
1150 17th Street, N.W.
Washington, D.C. 20036

This is in response to your letter of February 26, regarding the hazard of polyvinyl chloride. We apologize for the delay in responding to your inquiry.

The vinyl chloride standard controls the labeling that polyvinyl chloride must bear with respect to information on carcinogenicity. Provision 29 CFR 1910.1017 (1)(4) requires that containers of polyvinyl chloride shall be labeled as containing vinyl chloride. Moreover, the provision requires that the label state that polyvinyl chloride is a cancer-suspect agent. Such labeling, however, is not required for "fabricated products." A "fabricated product" is described at 29 CFR 1910.1017 (b)(6) as "...a product made wholly or partly from polyvinyl chloride, and which does not require further processing at temperatures, and for times, sufficient to cause mass melting of the polyvinyl chloride resulting in the release of vinyl chloride." Consequently, polyvinyl chloride resin that has not yet been processed into film, or sheeting, or has not yet undergone final molding or extrusion, must be labeled in accordance with 29 CFR 1910.1017 (1)(4); whereas the film, sheeting, final molded products, and final extruded products do not.

[ILPI note: The fixed legend discussed here is historical. Current counterpart: 1910.1017(l), including HCS compliance and the separate requirements for contaminated waste. The historical citations link to the 1974 rule issue (PDF); this is not a substitute for all subsequent amendments. The local text prints numeral 1 in some references where the paragraph is letter l.]

Whenever labeling according to 29 CFR 1910.1017 (1)(4) applies for a polyvinyl chloride product, then the provisions of the Hazard Communication Standard, 29 CFR 1910.1200, also apply, subject to the limits on scope and applicability found in the standard.

We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.

On behalf of the Vinyl Institute, a division of The Society of the Plastics Industry, Inc., we request an official interpretation of OSHA's Hazard Communication Standard, 29 C.F.R. 1910.1200. (*).

Our concern focuses upon the status of polyvinyl chloride (PVC) as a carcinogen or potential carcinogen under the Standard. PVC is not a carcinogen. However, confusion may be created due to the characterization of existing scientific evidence in a document referenced in the Standard.

As you know, Section (d) of the Standard requires chemical manufacturers and importers to evaluate the hazards of their chemical products. It further states, at subsection (4), that those evaluating chemicals must treat the following sources as establishing that a given chemical is a carcinogen or potential carcinogen for purposes of the Standard:

Polyvinyl chloride, or PVC, is produced from vinyl chloride monomer through a chemical reaction called polymerization. While vinyl chloride monomer is a regulated hazardous material, it is transformed through polymerization into a white granular powder, PVC, which is nonhazardous. Polymerization is a "one way reaction"; thus, PVC powder does not revert back to vinyl chloride. PVC is widely used in a large number of commercial products, including water pipe, floor and wall coverings, vinyl siding, upholstery, records and wrapping films.

PVC is not listed as a carcinogen or potential carcinogen by NTP in its most recent Annual Report On Carcinogens. Similarly, PVC is not included among those substances regulated by OSHA and listed in 29 C.F.R. Subpart Z. We believe that confusion concerning the carcinogen or potential carcinogen status of PVC under the Standard may stem from a listing in the NIOSH Registry, which characterizes an IARC study of PVC in the following fashion:

However, IARC Volume 19, does not report a conclusion that PVC is a carcinogen or potential carcinogen. The referenced IARC study is one of a series which focused on evidence generated from various subcutaneous implementation tests. These tests produced local tumors when particles of a correct size were used. Such results are not accepted as sufficient evidence of carcinogenicity by either the scientific community or various Federal agencies. 29 C.F.R. 1910.44 (b)(ii). In addition, it is important to note that IARC's summary of substances classified as Group I or Group II does not include PVC, accordingly, we believe that PVC is not covered by the Standard. See OSHA Instruction CPL 2-2.38, p. C-2. Rather, there is an error in the NIOSH Registry in characterizing the IARC studies.

[ILPI note: This is the correspondent's position, not a blanket exemption. Current hazard classification follows paragraph (d) and Appendix A.6; absence from an old list does not establish the absence of every hazard.]

We would be most appreciative if you could confirm, at your earliest convenience, that polyvinyl chloride (PVC) is not a carcinogen or potential carcinogen under the Hazard Communication Standard. If this discussion raises any question, or if we can provide further information, please do not hesitate to contact us at any time.

*SPI, the major national trade association of the plastics industry, is a corporation organized under the Not-for-Profit Corporation Law of the State of New York. Its 1,600 member companies and individuals and 49 operating units include those who supply raw materials; and engineer or construct molds or similar accessory equipment for the plastics industry. The majority of SPI members are the processors and converters of plastic resins into end products which represent 75% of the dollar volume sale of plastics in this country.

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OSHA Hazard Communication Letters of Interpretation