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OSHA Hazard Communication Letters of Interpretation
Hexavalent chromium in photocopier toners.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical concentration finding is not a current exemption or exposure limit
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Do not use its 0.003% finding as a general current permission to omit chromium(VI) hazards from an SDS, or assume that an old absence-of-evidence conclusion establishes the safety of today's product. Current hazard classification, mixture procedures, carcinogenicity criteria, and SDS ingredient-disclosure rules must be applied to actual composition and relevant evidence. This comparison does not conclude that every product at that concentration must receive the same classification.
For chromium(VI), use the current 5 µg/m³ eight-hour TWA PEL where that standard applies, together with its scope, exposure-assessment, control, and chromium(VI) hazard communication provisions. The 0.5 and 1 mg/m³ values quoted at the end must not be used as the current chromium(VI) PEL; chromium metal and different oxidation states require distinctions. The employer's exposure duties are not eliminated merely because an SDS was not received.
OSHA archive notice: OSHA marks its matching page as an archive document that may no longer represent agency policy and is provided for historical research. The related August 25, 1987 letter was an interim investigation response. This archive notice and ILPI's current comparison do not themselves 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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 16, 1988
Mr. Desmond Bond
Desmond Bond, Inc.
Energy & Environment
Post Office Box 470
Chantilly, Virginia 22021
Dear Mr. Bond:
This is in further response to your letter of December 18, 1987, regarding hexavalent chromium in photocopier toners.
As we mentioned in our November 24, 1987, letter, an analysis of the photocopier toner indicated that hexavalent chromium was present at .003 percent and therefore did not, under the Hazard Communication Standard, have to be reported on a material safety data sheet. In addition, we asked you if you had evidence that a health hazard existed or if an Occupational Safety and Health Administration's (OSHA) permissible exposure limit could be exceeded where toner chromium concentration is .003 percent.
[ILPI note: This concentration-specific 1988 conclusion is not a blanket current omission rule. Historical HCS: 1910.1200, 1987 expanded rule (PDF). Apply current mixture procedures, carcinogenicity criteria, and ingredient-disclosure rules to the actual material and evidence; OSHA marks this letter as archived.]
Like you, OSHA is concerned about employee exposure to chromium. The evidence you presented in your letter, however, is not sufficient to support that a permissible exposure limit would be exceeded or that a health hazard exists at a chromium concentration of .003 percent. Additional support such as actual sampling data and animal and/or human studies demonstrating a carcinogenic effect (at a .003 percent concentration) would be needed before OSHA could require manufacturers to inform employees of the carcinogenic risk of chromium at a .003 percent concentration. Our review of the current scientific literature indicates that such evidence does not exist at this time.
In addition, present scientific evidence indicates that only hexavalent chromium is carcinogenic. Therefore, when evaluating the effects of chromium or its compounds only chromium in the hexavalent state would be considered carcinogenic.
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You state that your client is concerned that his employees might be exposed to chromium. Under the Occupational Safety and Health Act of 1970 each employer is responsible for the safety and health of his or her employees. It would, therefore, be your clients responsibility to ensure that his employees are not being exposed above the permissible exposure limit (0.5 mg/m3 for soluble chromic or chromous salts as chromium and 1 mg/m(3) for metal and insoluble salts). This responsibility applies even though an employer may not have received a material safety data sheet.
[ILPI note: For chromium(VI), the current PEL is 5 µg/m³ as an eight-hour TWA where that standard applies. Do not use the quoted form-specific chromium values as the chromium(VI) limit. See its scope and the assessment above.]
If I can be of further assistance, please feel free to contact me again.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-02-16.