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OSHA Hazard Communication Letters of Interpretation

OSHA-recognized chemicals as carcinogens or potential carcinogens for Hazard Communication purposes

Issued
Record type
Interpretation
Historical standard
HCS 1994, pre-GHS archive
Current standard
HCS 2024, as amended

ILPI assessment: PEL tables are not a cancer list; old automatic-list and mixture rules are obsolete

This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). The distinction remains useful: Tables Z-1, Z-2 and Z-3 are exposure-limit tables, not a complete list of carcinogens. The letter's dated list of substance-specific standards and its old paragraph (d)(4)/(d)(5) framework are not a complete current classification method.

Under the current HCS, evaluate all relevant evidence using paragraph (d) and Appendix A.6. Distinguish classification of a mixture from SDS ingredient disclosure: category-specific thresholds and required disclosure are not interchangeable. The old blanket 0.1% assumption must not replace the current criteria; nor does the absence of a substance from this 2003 list demonstrate absence of a carcinogenic hazard.

Last reviewed: .

Related interpretations
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.

October 16, 2003

Mr. Philip W. Crawford
Director
Gibbons, Del Deo, Dolan, Griffinger, and Vecchione
One Riverfront Plaza
Newark, NJ 07102-5496

Dear Mr. Crawford:

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Thank you for your June 25 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. You have a question regarding one of the provisions set forth in 29 CFR 1910.1200(d)(4) [ILPI: Original HCS 1994 context · Current HCS; current evidence and hazard-specific criteria apply], OSHA's Hazard Communication Standard. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. Our reply to your paraphrased question is provided below.

Question: Please clarify 29 CFR 1910.1200(d)(4)(iii) [ILPI: Original HCS 1994 context · Current HCS; current evidence and hazard-specific criteria apply] which relates that chemical manufacturers, importers, and employers evaluating chemicals shall treat 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, as one source establishing that a chemical is a carcinogen or potential carcinogen for hazard communication purposes. Are the Tables Z-1, Z-2, and Z-3 intended to be lists of chemicals that OSHA recognizes as carcinogens or potential carcinogens for hazard communication purposes?

Reply: No. Tables Z-1, Z-2, and Z-3 are not intended to be lists of chemicals that OSHA recognizes as carcinogens or potential carcinogens for hazard communication purposes. When designating Subpart Z as one source establishing that a chemical is a carcinogen or potential carcinogen for hazard communication purposes, OSHA has under consideration certain substances in 29 CFR Part 1910, Subpart Z that are regulated by detailed, substance-specific standards. With the exception of 1,3-butadiene and coke oven emissions, one can identify those substances that OSHA regulates as carcinogens or potential carcinogens by referring to the section of the substance-specific standards that covers the labeling of containers. The current list of substances that OSHA regulates as carcinogens or potential carcinogens follows:

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In addition, in your letter, you stated, "Pursuant to 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], chemical manufacturers are obligated to list a product as containing a carcinogenic substance if a constituent element makes up more than 0.8 percent of the product…" Please be advised that 1910.1200(d)(5)(ii) [ILPI: Original HCS 1994 context · Current HCS; old procedure superseded by classification criteria] requires that a mixture, "shall be assumed to present a carcinogenic hazard if it contains a component in concentrations of 0.1 percent or greater, which is considered to be a carcinogenic under (d)(4) of this section [ILPI: Original HCS 1994 context · Current HCS; current evidence and hazard-specific criteria apply]."

[ILPI note: At issuance: HCS 1994, pre-GHS archive. The 0.1% statement quotes the pre-GHS mixture rule. Current Appendix A.6 distinguishes carcinogenicity categories and mixture thresholds, while SDS ingredient disclosure has separate requirements. Apply the current criteria, not this historical shortcut.]

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs

The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2003-10-16.