| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
OSHA Hazard Communication Letters of Interpretation
IARC occupational listings and boot and shoe manufacturing
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Industry listing distinction retained; chemical-list limitation obsolete
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its distinction between an industry/process listing and classification of a particular chemical remains useful. An IARC listing of an occupation does not automatically classify every product used in that occupation. However, the statement that only chemicals specifically listed by IARC/NTP or regulated by OSHA are subject to the HCS is not a complete current coverage rule.
Under the current HCS, hazard classification follows all relevant available evidence and the applicable health/physical criteria; carcinogenicity criteria are one part of that evaluation. A chemical may be hazardous without appearing on one of those lists. The 1986 CPL appendix mentioned below is historical and has not independently been verified; use current HCS inspection procedures for current enforcement context.
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 24, 1987
Mr. Ralph Mosely
Mosely and Associates, Inc.
Post Office Box 150302
Nashville, Tennessee 37215
Dear Mr. Mosely:
This is in response to your letter dated May 11, regarding the International Agency for Research on Carcinogens (IARC) listing of boot and shoe manufacturing and repair as an occupation causally associated with cancer in humans.
[ILPI note: At issuance: 1910.1200, original 1983 rule (PDF). Current counterparts: classification from all relevant evidence and carcinogenicity criteria. An occupation listing does not classify every product, but the limitation to specifically listed chemicals below is not a complete current coverage rule. The cited 1986 CPL is historical; current enforcement counterpart: HCS inspection procedures.]
The Hazard Communication Standard (HCS) states that "chemical manufacturers, importers, and employers evaluating chemicals shall treat the following sources as establishing that a chemical is a carcinogen or potential carcinogen for hazard communication purposes:
- "National Toxicology Program (NTP) Annual Report On Carcinogens (latest edition);
- International Agency for Research on Cancer (IARC) Monographs (latest edition);
- 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration [OSHA]."
Since IARC lists boot and shoe manufacturers in Supplement 4, OSHA included it (Table 1 Appendix D of CPL 2-2.38A CH-2) in the group of industrial processes and occupational exposures causally associated with cancer in humans. This was for informational purposes to alert our field people that carcinogenic chemicals may be found in this industry. As indicated in Note 2 under Table 1 "these are processes on occupational exposures and are not specific chemicals." In addition Note 2 states that "the labeling requirements of the HCS will not usually apply unless a specific chemical from the process has been identified elsewhere by IARC, NTP or OSHA as a hazardous chemical." (Underlining added.) Therefore, from a compliance standpoint, only those chemicals which are specifically listed by IARC or NTP or regulated by OSHA would be subject to the requirements of the HCS.
OSHA Instruction CPL 2-2.28A provides only general guidance to our compliance officers to assist them in making HCS inspections. Appendix D was added to the Instruction in order to make the IARC and NTP lists more accessible to them in the field.
Since the inclusion of industries in our guidelines does not enhance or significantly contribute toward increasing the efficiency of our enforcement program, they will be removed from the directive during the next general revision.
I hope I have fully addressed your concerns. If I can be of further assistance please feel free to contact me 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/1987-06-24.