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OSHA Hazard Communication Letters of Interpretation
Photographic chemicals, SDS access and exposure concerns
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: SDS-access principle remains; no pregnancy-safety determination is made
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains useful: employees need information for the actual photographic products they use. This short referral letter does not determine whether a particular C-41 process is safe during pregnancy.
Under the current HCS, use immediate SDS access (FAQ), hazard identification, exposure controls and toxicological information, including relevant reproductive-toxicity criteria. Required sheets must be readily accessible during the shift, not only after a delayed formal request. Actual formulations, tasks and exposures need assessment; an SDS alone does not diagnose an illness or establish individual safety. Current workplace-investigation resource: NIOSH Health Hazard Evaluations.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
January 31, 1995
Mary Wright
P.O. Box 1606
Van, Texas 75790
Dear Mrs. Wright,
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This is in response to your December 10, 1994, letter requesting the Occupational Safety and Health Administration (OSHA) to provide you literature concerning the harmfulness of photographic chemicals used in the C-41 color processing procedure.
OSHA does not have any specific technical information concerning photographic chemicals. We are providing you with a copy of the Hazard Communication (HAZCOM) Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], that covers an employee's right to information concerning the hazards of chemicals in the workplace.
The purpose of the HAZCOM standard is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. Under the HAZCOM standard, the manufacturer or importer of a chemical is required to develop a material safety data sheet (MSDS) for documenting a chemical's hazardous properties. The information on the hazards of a chemical is transmitted to the employer and employees through the use of MSDSs. Under this standard, the employer is required to maintain the MSDSs in the workplace and provide upon request, by an employee, MSDSs of chemicals that an employee may be exposed to in the workplace.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Read this with current immediate SDS access (FAQ): the sheet must be readily accessible during each shift without barriers, not merely supplied after a delayed request. A product sheet is an information source, not an individual pregnancy-safety finding.]
For technical information specific to the hazards in the photographic processing industry, you should contact the National Institute of Occupational Safety and Health (NIOSH), Hazard Evaluations and Technical Assistance Branch in Cincinnati, Ohio. You can call their Technical Information and Hazard Evaluation Requests line at 1-800-35-NIOSH(6-4674) for that information.
Thank you for your interest in learning more about protecting your safety and health in the workplace.
Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance
To whom it may concern,
I recently discovered that my husband and I are going to have a baby. Naturally, I want to take all of the necessary precautions for our baby's prenatal care. I work for a photo lab in Tyler, Texas. I am surrounded by various photographic chemicals. I wanted to find out if these chemicals (mostly for color processing, C-41) will be harmful to our unborn baby during the remaining seven months of my pregnancy.
I would appreciate any literature that you may be able to send me on this subject. Thank you for your time.
Sincerely,
Mary Wright
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1995-01-31.