05/06/1991 - Regarding labeling requirements of the OSHA's Hazard Communication Standard

Interactive Learning Paradigms, Incorporated

	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!

XXXPrevNext

Title: 05/06/1991 - Regarding labeling requirements of the OSHA's Hazard Communication Standard.
Record Type: Interpretation	Standard Number: 1910.1200

May 6, 1991

Mr. Richard W. Munson
Chairman
Victims of Fiberglass
Meadow Vista, California 95722

Dear Mr. Munson:

This is in further response to your letters of February 15, addressed to both myself and Mr. Roderick DeArment, Deputy Secretary of Labor, regarding the labeling requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. As I mentioned in my interim response to you of March 13, Mr. DeArment had provided me with a copy of your letter to him and asked that I respond to you directly. We are also in receipt of your letter and supporting documentation to OSHA's Columbus, Ohio, Area Director, Mr. James E. Vaughan, of January 9. This letter will also respond to the similar concerns you raised in that correspondence.

OSHA's policy regarding the labeling of hazardous chemicals for carcinogenic effects is discussed at length in the Agency's Compliance Instruction for the Hazard Communication Standard, CPL 2-2.38C ("Inspection Procedures for the Hazard Communication Standard," October 22, 1990, copy enclosed). As you have correctly stated in your letter to us, the existence of positive human evidence, based on one valid study conducted in accordance with established scientific principles indicating carcinogenic effects in humans triggers the requirement that the label contain an appropriate carcinogen hazard warning. It is the responsibility of the chemical manufacturer or importer of a product to identify and evaluate all relevant scientific data when conducting a hazard determination.
A review of the available scientific literature for health effects associated with exposure to fibrous glass products was conducted by our Directorate of Health Standards Programs. Several epidemiological studies of fibrous glass production workers were found which showed a statistically significant increase in respiratory tract cancer. Therefore, appropriate hazard warnings on fibrous glass products would have to indicate that fibrous glass may cause lung cancer in humans.
Communicate workplace hazards with handy labels from Safety Emporium.
A copy of this letter to you will be sent to each of OSHA's Regional Offices and included on OSHA's Computerized Information System (OCIS), the Standards Interpretation File, so that our compliance staff will be informed of and have access to this interpretation regarding the requirement of chemical manufacturers and importers, under the HCS, to positively label fibrous glass products with a carcinogen warning label. If, upon inspection, an OSHA Compliance Officer becomes aware of incorrectly labeled fibrous glass products being used in the workplace, according to OSHA referral procedures, the chemical manufacturer will be contacted and asked to correct the hazard. Referral procedures for the abatement of incorrect labels are set forth in section X.7.a.(7) of the enclosed OSHA Instruction for your information and reference.

We hope this response sufficiently addresses the concerns you raised. Please feel free to contact us again if we can be of further assistance.

Sincerely,

Gerard F. Scannell
Assistant Secretary

This hypermarked and content-enhanced page is copyright by ILPI, all rights reserved. Unauthorized duplication or posting on other web sites is expressly prohibited. For questions, comments and concerns, please contact us at our SDS email address.

The original official public domain version of this document is available from OSHA at XXXOSHAURL.