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OSHA Hazard Communication Letters of Interpretation
Requirements for fingerprint powders containing carbon black under the Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical no-cancer-label rationale superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its conclusion that carbon black needs no cancer warning cannot be carried forward from the evidence available in 1986. IARC subsequently evaluated carbon black as possibly carcinogenic to humans (Group 2B), based on sufficient animal evidence and inadequate human evidence; see IARC classifications and IARC Volume 93. Absence of positive human studies does not establish that a substance is noncarcinogenic under the current HCS.
Under the current HCS, hazard classification must follow paragraph (d) and current carcinogenicity criteria, considering the actual product, composition, exposure routes, and available evidence. Apply shipped-container label requirements and Appendix C and SDS Section 11. This comparison does not classify every fingerprint-powder formulation or establish that all such mixtures have identical hazards.
OSHA source correction: OSHA marks its matching page “Corrected 6/1/2005” and updates the office/contact information. Historical contact details are preserved below; use the local-office directory in “About this ILPI assessment” for present inquiries.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
July 2, 1986
Mr. James W. Gocke
Vice President and General Counsel
SIRCHIE Finger Print Laboratories
Post Office Box 30576
Raleigh, North Carolina 27622
Dear Mr. Gocke:
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Your letters dated April 22 and May 5 have been forwarded to our office for response. Mr. Anderson, Assistant Regional Administrator in Region IV, has informed us of your concern regarding the health hazards of your fingerprint powders containing carbon black.
[ILPI note: The standard citations below refer to the original 1983 HCS. Current counterparts: classification, carcinogenicity criteria, shipped labels, and SDS Section 11. The later IARC evaluation makes the historical no-cancer-label conclusion unsuitable for current reliance; see the assessment above.]
The Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) requires chemical manufacturers and importers to evaluate chemicals produced in their workplace or imported by them to determine if they are hazardous. Any chemical for which OSHA has a permissible exposure limit (PEL) or the American Conference of Governmental Industrial Hygienist (ACGIH) has a threshold limit value (TLV) is automatically considered hazardous as part of the standards floor of chemicals.
Also, the following sources establish that a chemical is a carcinogen or potential carcinogen for hazard communication purposes:
- National Toxicology Program (NTP), Annual Report on Carcinogen (latest editions);
- International Agency for Research on Cancer (IARC) Monographic (latest editions); or
- Those substances regulated as carcinogens under 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substance, Occupational Safety and Health Administration.
In addition, for health hazards, evidence which is statistically significant and which is based on at least one positive study conducted in accordance with established scientific principles is sufficient for a notation to appear on the material safety data sheet.
Carbon black does have an OSHA PEL and is also listed by ACGIH. It is therefore automatically considered a "hazardous chemical" under the HCS and any associated health and/or physical hazard would have to be reported on the material safety data sheet.
According to IARC the available data on carbon blacks are inadequate to permit an evaluation of their carcinogenicity to experimental animals. However, there is sufficient evidence that solvent (benzene) extracts in most of the carbon blacks tested are carcinogenic to experimental animals. A chemical manufacturer or importer would have to indicate the results of such studies on the material safety data sheet. A cancer warning on the product's label would not be required since the available epidemiological data provides inadequate evidence to evaluate the carcinogenicity to humans of carbon blacks.
[ILPI note: This no-cancer-warning conclusion predates IARC's later Group 2B evaluation of carbon black. Current Appendix A.6 does not require positive human evidence before a carcinogenicity classification can apply. See the ILPI assessment above.]
If you have any further question please contact the Office of Health Compliance at (202) 523-8036.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
May 9, 1986
MEMORANDUM FOR: JOHN B. MILES, DIRECTOR, Directorate of Field Operations
ATTN: DAVE SMITH, DIRECTOR, Office of Health Compliance Assistance
FROM: ALAN C. McMILLAN, Regional Administrator
SUBJECT: Sirchie Fingerprint Laboratories' Request for OSHA's Position Regarding Health Effects of Fingerprint Powder Containing Carbon Black
We have received the enclosed letters and package of information from James W. Gocke of Sirchie Fingerprint Laboratories. Mr. Gocke has requested an official OSHA interpretation of the health hazards of fingerprint powder containing carbon black (specifically whether or not carbon black is considered to be a suspect carcinogen).
Information is the IARC Monograph, Volume 3, page 23, indicates that: "The reported inability to induce cancer in mice by feeding carbon black... or by applying it to the skin... was overcome by administering solvent extracts by injection or by skin painting."
The monograph indicates that carbon black of the furnace - black type contains several polycyclic aromatic hydrocarbons (PAH). IARC Volume 33, page 77, indicates that, "The available epidemiological studies on workers in the carbon-black industry are largely uninformative". Regarding an evaluation of experimental animal carcinogenicity, the data on carbon blacks are inadequate. Volume 33 does state, however, that there is sufficient evidence that solvent (benzene) extracts of most of the carbon blacks tested are carcinogenic to experimental animals.
Exhibit G in the attachments, a study done by the Carbon Black Industry Committee for Environmental Health, presents evidence that the carbon black itself is not carcinogenic, and that the PAH's absorbed to carbon black are not biologically active.
Please also note that Exhibit I in the attachments is a letter from Thorne Auchter dated July, 1983, which states that the designation of "suspect carcinogen" for carbon black was removed from the 1983 draft of the IHFOM (currently the Technical Manual).
We have informed Mr. Gocke that we have forwarded his letters to your office. We would appreciate your responding to Mr. Gocke directly and sending us a copy of your reply. If you have any questions, contact Charlie Anderson, ARA for Technical Support (FTS 257-2281).
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-07-02.