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OSHA Hazard Communication Letters of Interpretation
Labeling of Lead Chromate 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ILPI assessment: Historical no-cancer-label conclusion superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Do not rely on its conclusion that lead chromate need not be labeled as a carcinogen because human evidence was considered inadequate. Current hexavalent-chromium hazard-communication requirements expressly address cancer. Apply hazard classification, current carcinogenicity criteria, shipped-container label requirements and Appendix C, and SDS health-effect disclosures.
Lead chromate also requires attention to applicable lead hazard-communication provisions and the respective standards' scopes and conditions. A historical discussion of one cancer study is not a present-day exemption from communicating lead or chromium(VI) hazards.
OSHA archive notice: The matching OSHA page is marked as an archive document that may no longer represent OSHA policy and is provided for historical research.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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
June 1, 1987
MEMORANDUM FOR: FRANK L. STRASHIEM, Regional Administrator
FROM: LEO CAREY, DIRECTOR, Directorate of Field Operations
SUBJECT: Labeling of Lead Chromate Under the Hazard Communication Standard
Although Table I, page A-15 of CPL 2-2.38A CH-1, indicates that carcinogens listed in NTP need a carcinogen warning label, the table, as stated, is to be used as general guidance for assessing the MSDS and labeling information on carcinogens. The criteria for determining whether a carcinogen warning label is required is based on, as stated on page A-13 of CPL 2-2.38A CH-1, the existence of positive human evidence.
[ILPI note: This historical no-cancer-label rationale is superseded. Current counterparts: carcinogenicity criteria, chromium(VI) hazard communication, and lead hazard communication. OSHA marks this letter as archived. The cited 1986 CPL is historical; current enforcement counterpart: HCS inspection procedures.]
Presently, there are no studies which have indicated that lead chromate is a human carcinogen. Attached for your information is a memo prepared by Region II which provides additional support on this subject.
If you have any questions concerning this issue, please contact Gary Anderson, Acting Director, Office of Health Compliance Assistance on FTS 523-8036.
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-06-01.