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OSHA Hazard Communication Letters of Interpretation
Regarding labeling requirements of the 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: Blanket historical cancer-label conclusions need current fiber-specific review
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its requirement to evaluate relevant cancer evidence remains valid, but its broad 1991 conclusion that fibrous-glass products must indicate lung cancer in humans should not be applied to all modern fibers or products.
Under the current HCS, apply hazard classification, all relevant evidence and carcinogenicity criteria. OSHA's later fiber-specific IARC summary distinguishes insulation glass wool/continuous filaments from refractory ceramic and certain special-purpose fibers; NTP's assessment of certain inhalable glass wool fibers also distinguishes fiber types and biopersistence. Group 3 is not a finding of harmlessness. Irritation and other hazards still require evaluation. Current shipped labels follow shipped-container label elements and Appendix C. This review does not classify a particular product.
OSHA archive notice: OSHA marks its matching original as an archive document that may no longer represent agency policy and is retained for historical research.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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 6, 1991
Mr. Richard W. Munson
Chairman
Victims of Fiberglass
Meadow Vista, California 95722
Dear Mr. Munson:
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This is in further response to your letters of February 15, addressed to both myself and Mr. Roderick DeArment, Deputy Secretary of Labor, regarding the labeling requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. As I mentioned in my interim response to you of March 13, Mr. DeArment had provided me with a copy of your letter to him and asked that I respond to you directly. We are also in receipt of your letter and supporting documentation to OSHA's Columbus, Ohio, Area Director, Mr. James E. Vaughan, of January 9. This letter will also respond to the similar concerns you raised in that correspondence.
OSHA's policy regarding the labeling of hazardous chemicals for carcinogenic effects is discussed at length in the Agency's Compliance Instruction for the Hazard Communication Standard, CPL 2-2.38C [ILPI note: Original: CPL 2-2.38C (October 22, 1990). Current counterpart: CPL 02-02-079.] ("Inspection Procedures for the Hazard Communication Standard," October 22, 1990, copy enclosed). As you have correctly stated in your letter to us, the existence of positive human evidence, based on one valid study conducted in accordance with established scientific principles indicating carcinogenic effects in humans triggers the requirement that the label contain an appropriate carcinogen hazard warning. It is the responsibility of the chemical manufacturer or importer of a product to identify and evaluate all relevant scientific data when conducting a hazard determination.
A review of the available scientific literature for health effects associated with exposure to fibrous glass products was conducted by our Directorate of Health Standards Programs. Several epidemiological studies of fibrous glass production workers were found which showed a statistically significant increase in respiratory tract cancer. Therefore, appropriate hazard warnings on fibrous glass products would have to indicate that fibrous glass may cause lung cancer in humans.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This blanket historical cancer-warning conclusion is not a substitute for modern classification using all relevant fiber-specific evidence. See OSHA's later fiber-specific IARC summary and NTP's assessment of certain inhalable glass wool fibers. OSHA archives this letter.]
A copy of this letter to you will be sent to each of OSHA's Regional Offices and included on OSHA's Computerized Information System (OCIS), the Standards Interpretation File, so that our compliance staff will be informed of and have access to this interpretation regarding the requirement of chemical manufacturers and importers, under the HCS, to positively label fibrous glass products with a carcinogen warning label. If, upon inspection, an OSHA Compliance Officer becomes aware of incorrectly labeled fibrous glass products being used in the workplace, according to OSHA referral procedures, the chemical manufacturer will be contacted and asked to correct the hazard. Referral procedures for the abatement of incorrect labels are set forth in section X.7.a.(7) of the enclosed OSHA Instruction for your information and reference.
We hope this response sufficiently addresses the concerns you raised. Please feel free to contact us again if we can be of further assistance.
Sincerely,
Gerard F. Scannell
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1991-05-06-0.