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OSHA Hazard Communication Letters of Interpretation
The hazard warning labels attached to shipments of solder.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Hazard warnings remain appropriate; lead unit error needs correction
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains useful: lead-containing solder and hazardous flux require meaningful hazard information. The letter does not establish the classification of every solder or flux formulation, or extend OSHA jurisdiction to every overseas workplace.
Under the current HCS, use hazard classification, shipped-container label elements and Appendix C, and current SDS content. Evaluate the actual formulation and anticipated uses; see the fume explanation. The separate general-industry lead permissible exposure limit is 50 µg/m³ as an 8-hour average, not 50 mg/m³. The parenthetical unit error also appears in OSHA's original and is retained below with an explicit correction. Lead-standard monitoring and other duties have their own triggers; they do not all begin only above the permissible limit.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 11, 1989
Mr. Carl Seymour
Administrator and Credit Manager
Borde Communications
Valsayn Road, CUREPE
Post Office Box 897
Port-of-Spain
TRINIDAD
Dear Mr. Seymour:
Welding fumes are also a respiratory hazard. Remind your employees with safety banners from Safety Emporium.
This is in response to your letter of January 12, addressed to the National Bureau of Standards, regarding the hazard warning labels attached to a shipment of solder your company received. The National Institute of Standards and Technology (formerly the National Bureau of Standards) forwarded your letter to the Occupational Safety and Health Administration (OSHA). Please accept our apology for the long delay in this response to you.
In your letter, you mention that for a number of years you have been purchasing solder products from the United States but that recently, shipments of the solder materials have contained warning labels that indicated that the inhalation of solder fumes "could be harmful and could lead to birth defects, etc." On November 25, 1985, OSHA's Hazard Communication Standard (HCS) [ILPI: Original HCS 1983 context (PDF) · Current HCS] became effective. The standard requires that chemical manufacturers and importers assess the hazards of the chemicals and products they sell. The HCS has recently been expanded to include all workers exposed to hazardous substances in all industrial sectors, not just those in the manufacturing sector covered under the original standard.
Under the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS], manufacturers of chemicals or materials that may create a hazardous exposure during their use are to provide hazard information through warning labels affixed to all containers of their products and through the provision of material safety data sheets (MSDSs) to all downstream recipients or users of their products. The labels must include the identity of the chemical hazardous substance, appropriate hazard warnings and the name and address of the manufacturer, importer or responsible party. Chemical distributors must also adhere to the labeling requirements of the standard, and must ensure that MSDSs are provided to employees. In addition, the standard requires that employers develop and implement a written hazard communication program and communicate hazard information to their employees through formal training programs. The HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] incorporates a "downstream flow of information" which means that producers of chemicals have the primary responsibility for generating and disseminating information, while users of chemicals must obtain the information and transmit it to their own employees.
OSHA's Hazard Communication Standard was promulgated to ensure that all employers receive the information they need to inform and train their employees properly on the hazardous substances they work with and to help design and put in place employee protection programs. It also provides necessary hazard information to employees, so they can participate in and support the protective measures in place at their workplaces.
Since November of 1985, therefore, manufacturers of hazardous substances in the United States have had to comply with the Agency's HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] as described above, and this is why shipments of solder you have been receiving from the U.S. have contained the warning labels you mentioned in your letter. With regard to your specific question on whether or not "standards exist for solder" and "if solder is in fact harmful" to one's health, OSHA has enforced, since 1981, its standard for occupational exposure to inorganic lead. Solder contains, as you indicated in attachments to your letter, a large percentage of lead. During soldering operations, personnel risk being exposed to lead fume. OSHA's current standard for occupational exposure to lead during soldering operations is set at 50 micrograms lead per cubic meter of air (50mg/m3), measured as an 8-hour time weighted average exposure (e.g., employee exposure to lead in air, measured and averaged over an 8-hour work day). OSHA's Lead Standard sets requirements for the provision of environmental (workplace) monitoring, recordkeeping, employee education and training, medical surveillance, medical removal protection, hygiene facilities and other requirements that must be met by employers if their employee's exposure to lead exceeds the specified limits.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The parenthetical “50mg/m3” in the original is a unit error. The current general-industry lead limit is 50 µg/m³ (0.05 mg/m³) as an 8-hour average; the action level is 30 µg/m³. Other lead-standard obligations have their own conditions.]
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In your letter, you also inquire as to the "harmful side effects experienced for the inhalation of solder flux fumes." "Solder flux" generally refers to a substance applied in soldering and brazing operations to portions of a surface to be joined and which acts, with the application of heat, to prevent oxide formation and to facilitate the flow of solder. Fluxes may contain hydrazine salts and/or other harmful or toxic compounds, exposure to which may in themselves represent a health hazard, depending again on the duration and amount (or dose) of the exposure. Information on the chemical composition of any solder flux compounds that you may be using should be obtainable from the labels on the MSDS that comes with the fluxes, if manufactured in the United States. In order for you to know if these or any other types of harmful exposures are occurring in your workplace, you may wish to have a competent occupational health professional, such as an industrial hygienist, perform a survey of your workplace and develop an occupational health program for your employees. We are unable to tell you what harmful exposures, if any, are occurring or could occur at your worksite; such an evaluation can only be made after an on-site safety and health survey has been performed. In the interest of safety and health survey has been performed the safety and health of yourself and your employees, you may want to arrange for such an evaluation to take place. The results of an on-site safety and health survey would enable you to develop a safety and health program specific to your worksite and give you necessary information to provide a safe and healthful workplace, free from recognized hazards and preventative of potential occupational safety and health risks.
For your further reference, a copy of OSHA's Lead and Hazard Communication standards [ILPI: Original HCS 1987 context (PDF) · Current HCS] are enclosed along with a copy of other OSHA publications that may be helpful to you.
Sincerely,
Patricia K. Clark, Acting Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-07-11-0.