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OSHA Hazard Communication Letters of Interpretation
Letter to Diesel Fuel Manufacturers
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Diesel-exhaust hazard disclosure remains required
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains consistent: diesel fuel SDSs must communicate the hazards of diesel exhaust associated with combustion, including carcinogenicity. The 1988 study dates and deadline in the attachment are historical, not present update dates.
The current inspection guidance on by-products expressly retains diesel-fuel SDS communication of exhaust carcinogenicity. Use known/anticipated-use evaluation, current evidence-based classification, SDS updates, and toxicological information. Modern classification replaces the old general one-positive-study description; the letter is not permission to wait for that 1988 bulletin before disclosing current hazards.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
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APR 4 1990
MEMORANDUM TO: REGIONAL ADMINISTRATORS
FROM: PATRICIA K. CLARK, DIRECTOR DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS
THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS
SUBJECT: Letter to Diesel Fuel Manufacturers
In accordance with then Acting Assistant Secretary Alan C. McMillan's testimony before the House Education and Labor Subcommittee on Health and Safety in August, 1989, the Occupational Safety and Health Administration (OSHA) recently mailed a letter to 240 diesel fuel manufacturers. This letter informs diesel fuel manufacturers of their obligation under OSHA's Hazard Communication Standard [ILPI: Original HCS 1987 context (PDF) · Current HCS] to include information regarding the potential carcinogenicity of diesel exhaust on their diesel fuel material safety data sheets. A copy of this letter is attached for your information.
Attachment
MAR 14 1990
Dear Diesel Fuel Manufacturer:
The purpose of this letter is to provide diesel manufacturers with information regarding the Hazard Communication Standard [ILPI: Original HCS 1987 context (PDF) · Current HCS]'s (HCS) requirement to include the hazards of diesel fuel exhaust on material safety data sheets (MSDS) for diesel fuel. The Occupational Safety and Health Administration (OSHA) is hereby alerting you that under the HCS requirements, recent information regarding the potential carcinogenicity of diesel exhaust must be included on the diesel fuel MSDS.
The HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] requires manufacturers to perform a hazard determination for the chemicals they produce. As part of the evaluation, the manufacturer must anticipate the intended uses of the product, and consider the potential physical and health hazards to which employees may be exposed as a result of those uses. 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 a sufficient basis for a hazard determination and must be reported on the MSDS.
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Diesel fuel exhaust is produced as a result of combustion, which is a normal condition of use for diesel fuel. Any health or physical hazards associated with the exhaust must therefore be included on the MSDS. In addition to respiratory irritation and reversible pulmonary effects of exposure to diesel exhaust, in August, 1988, the National Institute for Occupational Safety and Health (NIOSH) released Current Intelligence Bulletin 50, Carcinogenic Effects of Exposure to Diesel Exhaust, which summarizes recent studies on the potential carcinogenicity of diesel exhaust. NIOSH concluded in this bulletin that the toxicologic and epidemiologic findings suggest a "potential occupational carcinogenic hazard exists in human exposure to diesel exhaust." Under the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] requirement to examine all relevant data when performing the hazard determination, these studies which indicate the potential carcinogenicity of diesel exhaust must be included as part of the overall evaluation and the carcinogenic hazards must be noted on the MSDS. Manufacturers, importers or employers may also report the results of other scientifically valid studies which tend to refute the findings of hazard. However, the positive data must always be reported.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: diesel-exhaust carcinogenicity on diesel-fuel SDSs, with anticipated-use classification and current update duties. The old bulletin deadline is historical.]
Therefore, your diesel fuel MSDS must reflect the potential carcinogenicity of diesel exhaust. As with all OSHA standards, actions not consistent with the provisions of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] are subject to OSHA review and citation. The provisions of the HCS regarding updating MSDS to reflect new information require such data to have been added within 3 months after publication of the NIOSH CIB (which would have been by the end of November, 1988).
We hope this information is helpful to you in your efforts to provide safe and healthful workplaces in the United States. For further information regarding this notice, please feel free to contact the Hazard Communication Coordinator in the OSHA Regional Office closest to you.
Sincerely
Gerard F. Scannell Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1990-04-04-0.