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OSHA Hazard Communication Letters of Interpretation
Reporting threshold for non-carcinogenic mixtures on MSDSs.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Old automatic-source restriction and universal 1% threshold are superseded
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). The claim that a chemical cannot count as a carcinogen until one of three listed bodies validates it is not the current HCS classification approach. Nor is 1% a universal current reporting threshold for every unlisted chemical or mixture.
Apply all relevant evidence, carcinogenicity criteria, mixture classification and SDS ingredient disclosure. These are related but distinct decisions, with hazard-specific cutoffs and circumstances requiring disclosure below a nominal cutoff. Adequate evidence cannot simply be ignored while awaiting a particular organization's listing.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 11, 1998
Mr. Lance Edwards, CIH
Director of Health & Safety Affairs
Directorate of Environmental, Industry,
and International Affairs
1500 Rhode Island Avenue, NW
Washington, DC 20005
Dear Mr. Edwards:
This is in response to your letter of July 9, addressed to Mr. Charles Jeffress, Assistant Secretary, Occupational Safety and Health Administration (OSHA). Your letter requested information regarding the reporting threshold for certain hazardous chemicals under the Hazard Communication Standard (HCS), 29 CFR 1910.1200. [ILPI: Original HCS 1994 context · Current HCS] Please excuse this delay in responding.
Specifically, you requested information on the reporting threshold for chemicals for which evidence of carcinogenicity exists, even though these chemicals have not been established as a carcinogen (or potential carcinogen) by the three sources listed in paragraph (d)(4) of the standard [ILPI: Original HCS 1994 context · Current HCS; current evidence and hazard-specific criteria apply].
Under the HCS, a chemical is not considered a carcinogen or potential carcinogen unless it is listed as such by the International Agency for Research on Cancer, the National Toxicology Program, or is regulated as a carcinogen by OSHA. The reporting threshold for non-carcinogenic mixtures which have not been tested as a whole to determine their health hazards is one percent. Therefore, until one of the above-mentioned groups validates the carcinogenic findings, the reporting threshold on the material safety data sheets (MSDSs) is one percent.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. This historical source-list restriction is superseded by current all-evidence and hazard-specific classification. Current AppendixA.6, mixture criteria and SDSSection 3 replace the universal 1% shortcut.]
Please be aware, however, that even though the chemical is not considered a carcinogen for the purposes of the HCS, the results of any study conducted in accordance with scientific principles which shows statistical significance of a health effect must be discussed on the MSDS.
We hope this information will be helpful, and should you need further assistance, please do not hesitate to contact OSHA's Office of Health Compliance Assistance at (202)219-8036[correction 12/6/2024 the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Richard E. Fairfax
Acting 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/1998-11-11.