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OSHA Hazard Communication Letters of Interpretation
Letter to Lawrence N. Curcio from Thomas Shepich concerning requirements of the HCS on labeling of IARC category 2B carcinogens
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Blanket exclusion of Group 2B cancer labels is superseded
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Do not use its general statement that IARC Group 2B chemicals need no cancer label as a current rule. Positive human evidence is not a universal prerequisite for current cancer classification or labeling; animal evidence can support a carcinogenicity classification.
Under the current HCS, apply hazard classification under Appendix A.6 and shipped-container label elements and Appendix C. IARC groups and HCS hazard categories are not interchangeable labels. For mixtures, use the applicable concentration limits and C.4.9 labeling provisions, including the Category 2 ingredient rule distinguishing 0.1%–1% from concentrations of at least 1%. The assessment does not assign one HCS category to every IARC Group 2B chemical.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 14, 1988
Lawrence N. Curcio, Ph.D.
Exxon Company, U.S.A.
Marketing Technical Services
Post Office Box 2180
Dear Mr. Curcio:
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
Your letter of April 8 to Mr. Leo Carey has been forwarded to me for response. You have asked for clarification of an apparent inconsistency in guidance provided to our compliance officers regarding requirements for labeling International Agency for Research on Cancer (IARC) category 2B carcinogens.
While all hazards covered by Hazard Communication Standard (HCS) must be listed in the Material Safety Data Sheet, selection of hazards to be highlighted on the label will involve some assessment of the weight of the evidence regarding each hazard listed on the data sheet. If valid studies include positive evidence of human carcinogenicity, OSHA requires hazard warnings of carcinogenicity on the label.
IARC's summary classification of a chemical's carcinogenic risk as a category 2B is reserved for cases where there is sufficient evidence to classify substance as an animal carcinogen but inadequate data to classify it as a human carcinogen. In general, carcinogen labeling would not be required for chemicals in this category. Of course, if sufficient evidence of human carcinogenicity has become available subsequent to the publication of the IARC summary evaluation, carcinogen warnings on labels will be appropriate and required.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This general exclusion is not current. Apply current carcinogenicity criteria and C.4.9 labels; human evidence is not always necessary. IARC groups must not simply be substituted for HCS categories.]
We hope this information will be helpful to you. If we can be of further assistance, please feel free to contact us again.
Sincerely,
Thomas J. Shepich, 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/1988-06-14.