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OSHA Hazard Communication Letters of Interpretation
Regarding warning labels under OSHA's Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Old label acceptance does not establish current classification or label compliance
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its review of a particular 1991 label is not approval of that wording for present use. The old possible-cancer warning is neither a complete modern shipped label nor a current classification of all fiberglass wool.
Under the current HCS, use hazard classification, carcinogenicity criteria and shipped-container label elements and Appendix C. OSHA's later fiber-specific IARC summary and NTP's assessment of certain inhalable glass wool fibers distinguish fiber types and evidence; neither every glass fiber nor every product should receive a blanket cancer conclusion. Group 3 does not mean harmless, and irritation/other hazards still require evaluation. The statement about no pending enforcement action describes the situation in 1991.
OSHA archive notice: OSHA marks its matching original as an archive document that may no longer represent agency policy and is retained for historical research. This notice does not by itself establish formal withdrawal.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 28, 1991
Get your GHS-compliant labels and signs from Safety Emporium.
Mr. Thomas R. Hays
Director, Environmental Law
Owens-Corning Fiberglass Corporation
Fiberglass Tower
Toledo, Ohio 43659
Dear Mr. Hays:
Thank you for your letter of May 30, regarding the warning labels of Owens-Corning Fiberglass products under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. Your letter forwarded for our review a copy of a "new" label intended for use by Owens-Corning for products that contain fiberglass wool.
The label you forwarded contains the following hazard warning: "Contains fiberglass wool. Possible cancer hazard. To avoid this possible cancer hazard, minimize breathing fiberglass wool dust." In addition, the warning: "May cause irritation to skin, eyes and respiratory tract" also appears on the label.
This specific language serves to provide employees with appropriate hazard warning information for this particular product. The label appears to meet the intent of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] and would therefore be in compliance with the requirements of OSHA's Hazard Communication Standard. We might add that OSHA has no enforcement action pending against your company in this matter.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is a historical review of the submitted label, not present approval. Current shipped-label elements and fiber-specific classification must be evaluated using current evidence.]
We hope this information is helpful to you and appreciate your patience for the delay of this response. Please feel free to contact us again if we can be of further assistance.
Sincerely,
Patricia K. Clark, 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/1991-06-28.