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OSHA Hazard Communication Letters of Interpretation
Clarification of OSHA's Hazard Communication Standard with regards to the carcinogenicity of wood dust
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Old softwood-only omission instruction is not current blanket guidance
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its need to communicate wood-dust cancer hazards remains useful, but the broad statement that softwood-only sheets need no cancer identification must not be used as current blanket clearance.
Under the current HCS, apply all relevant evidence, cancer criteria, SDS toxicology/carcinogen information and shipped-container label elements and Appendix C. NTP's wood-dust assessment identifies wood dust as a known human carcinogen; evaluate relevant material/exposure evidence rather than assuming softwood means noncarcinogenic. The 1995 wood-dust monograph was Volume 62, not the letter's Volume 25; see IARC's 1995 volume. No individual product classification is made here.
OSHA marks its matching original corrected 12/6/2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
October 11, 1995
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Bill Bremer, Director
Loss Control, Safety and Health
Tiber Products Manufacturers
951 East Third Avenue
Spokane, Washington 99202
Dear Mr. Bremer:
Your letter dated July 24, requesting clarification of the Hazard Communication Standard (HCS) (29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]) with regards to the carcinogenicity of wood dust has been forwarded to my office for response.
Paragraph (g)(2)(vii) [ILPI: Original HCS 1994 context · Current SDS cancer information; now SDS Section 11] of the Hazard Communication Standard requires that the carcinogenicity of hazardous chemicals be identified or reflected on the material safety data sheet (MSDS) for that product. Under paragraph (g)(2)(vii) [ILPI: Original HCS 1994 context · Current SDS cancer information; now SDS Section 11], if a chemicals has been identified on either the National Toxicology Program (NTP) - Annual Report On Carcinogens (latest edition), the International Agency for Research on Cancer (IARC) Monographs (latest editions) or by the Occupational Safety and Health Administration (OSHA), as a carcinogen it must be identified on the MSDS within three (3) months.
The IARC Monograph on Wood Dust (Volume 25, 1995; pages 35-215) has identified hardwood dust as a Group 1 carcinogen. The 1995 Monograph found a clear association between adenocarcinoma of the nasal cavities and paranasal sinuses and occupational exposure to hardwood dust. The report also indicated that there were two few studies to sufficiently evaluate the cancer risk attributable to the workplace exposure to softwood species. In the few studies that have been completed, the risk of cancer from exposure to soft woods appears to be elevated, however there is not enough evidence to make a final determination.
Consequently, the MSDS for hardwood species and those sheets for mixed species of hardwoods and soft woods must be identified as a carcinogen as required under 29 CFR 1910.1200(g)(2)(vii) [ILPI: Original HCS 1994 context · Current SDS cancer information; now SDS Section 11]. MSDSs for softwood species (not mixed with hardwoods) do not have to be identified as being carcinogenic.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Do not use this old sentence as a present blanket omission rule. Apply current classification criteria, SDS cancer information and NTP's wood-dust assessment to relevant evidence. Softwood-only does not itself establish no cancer hazard.]
We hope that this information will be of assistance to you. If you have any further questions please feel free to contact Richard Fairfax of OSHA's Office of Health Compliance Assistance on (202) 219-8036.
Sincerely,
John B. Miles, Jr., 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/1995-10-11-0.