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OSHA Hazard Communication Letters of Interpretation
Establishing carcinogenicity of sodium and potassium salts of chromate and dichromate.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical no-cancer-warning conclusion superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Do not rely on its conclusion that these chromate/dichromate salts need no carcinogenicity label because convincing human evidence was lacking. Current OSHA requirements expressly address cancer hazards of hexavalent chromium: see 1910.1026(l)(1). Apply current hazard classification, current carcinogenicity criteria, shipped-container label requirements and Appendix C, and SDS health-effect disclosures.
The chromium(VI) standard has its own scope and conditions; determine its applicability to the actual operation separately. The 1986 discussion is not a present-day exemption for these compounds, and inadequate human evidence alone does not remove a carcinogenicity hazard.
OSHA archive notice: The matching OSHA page is marked as an archive document that may no longer represent OSHA policy and is provided for historical research. That notice is separate from the current-requirements comparison above.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 5, 1986
Mr. Michael Lafond
BETZ Laboratories, Inc.
The Water and Energy Management Company
Somerton Road
Trevose, Pennsylvania 19047
Dear Mr. Lafond:
This is an update to our response of June 19 to your letter of June 4 requesting an interpretation on whether sodium and potassium salts of chromate and dichromate are considered carcinogenic in accordance with the Hazard Communication Standard's (HCS) requirements for labeling material safety data sheets, and training.
[ILPI note: Historical no-cancer-warning conclusion superseded. Current counterparts: carcinogenicity criteria and chromium(VI) hazard communication. OSHA also marks this letter as archived; see the assessment above.]
As you correctly mention in your letter the HCS lists three sources to be used in determining whether a chemical is a carcinogen or potential carcinogen: the National Toxicology Program's Annual Report On Carcinogens," International Agency for Research on Cancer (IARC) "Monographs," and 29 CFR 1910 Subpart Z, Toxic and Hazardous Substances. After reviewing the above sources, particularly IARC Monograph Volume 23, it appears that sodium and potassium salts of chromate and dichromate would not be considered carcinogens as defined by the HCS.
However, for health hazards, any evidence which is statistically significant and which is based on at least one positive study conducted in accordance with established scientific principles would need to be reported on the material safety data sheet. Therefore, if there are any studies which indicate that sodium and potassium salts of chromate and dichromate may be carcinogenic, the results, although not conclusive for establishing carcinogenicity, would need to be reported on the material safety data sheet.
If you have any questions, please feel free to contact us again.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-08-05.