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OSHA Hazard Communication Letters of Interpretation
Listing and disclosing Benzene as a human carcinogen on the label and SDS
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent with the current HCS
The main mixture-classification advice remains useful: carcinogenicity mixture criteria and hazard communication govern the required information. The letter identifies the 0.1% threshold for the Category 1 benzene example and also addresses evidence of hazards below that concentration.
The health-hazard pictogram communicates carcinogenicity; a skull-and-crossbones is not a generic cancer symbol. Apply current carcinogenicity label elements and ingredient disclosure, while evaluating other hazards. Classification and SDS disclosure are separate from compliance with the benzene exposure standard.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 24, 2017
Dr. Burton Z. Davidson, Ph.D, P.E.
31 Chandler Ct.
Monroe Township, New Jersey 08831
Dear Dr. Davidson:
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Thank you for your letter to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs. Your letter requested clarification on labeling and safety data sheet (SDS) requirements for solvents containing benzene under the Hazard Communication Standard [ILPI: Original HCS 2012 context · Current HCS] (HCS), 29 CFR 1910.1200. This letter constitutes OSHA 's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. We have combined and paraphrased your questions into one question below, followed by our response.
Question: For chemical solvents that contain benzene as a known trace contaminant, what are the requirements for listing and disclosing benzene as a human carcinogen on the product 's label and SDS?
Response: The HCS [ILPI: Original HCS 2012 context · Current HCS] requires manufacturers or importers of hazardous chemicals to ensure that each container of hazardous chemical leaving the workplace is labeled, tagged, or marked in accordance with 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS]. In addition, each hazardous chemical must have an SDS as required by 29 CFR 1910.1200(g)(1) [ILPI: Original HCS 2012 context · Current HCS].
Manufacturers, importers, and distributers are responsible for classifying hazardous chemicals. To determine if a mixture containing benzene is classified as a carcinogen, please refer to Appendix A.6.3 of the HCS [ILPI: Original HCS 2012 context · Current HCS], Classification Criteria for Mixtures. A mixture is classified as a carcinogen when at least one ingredient in the mixture is a Category 1 or Category 2 carcinogen and is present in the mixture at a concentration of greater than or equal to 0.1%. Because benzene is a Category 1 carcinogen (i.e., a known or presumed human carcinogen), a mixture containing benzene at a concentration greater than or equal to 0.1% would be classified as a Category 1 carcinogen and require appropriate hazard information on the product 's label and SDS. In addition, if benzene is present in the mixture at a concentration below 0.1%, but there is evidence that it presents a health hazard at that lower concentration, the mixture shall be assumed to present the same hazard, and have the appropriate label and SDS. For more information on classifying carcinogens, please consult OSHA 's Hazard Classification Guidance, available at https://www.osha.gov/Publications/OSHA3844.pdf.
[ILPI note: At issuance: HCS 2012. Use current mixture criteria and SDS Section 3; the numeric cutoff does not authorize ignoring evidence of a health risk below it.]
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Also note, mixtures containing benzene might be classified as other types of health or physical hazards in addition to carcinogenicity. Where this is the case, the product 's label and SDS would need to contain appropriate hazard information about those hazards as well.
The requirements for labels on shipped containers of hazardous chemicals are found in 29 CFR 1910.1200(f)(1) [ILPI: Original HCS 2012 context · Current HCS]. Labels must include the product identifier; signal word; hazard statement(s); pictogram(s); precautionary statement(s); and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. Please consult 29 CFR 1910.1200 Appendix C.4.9 [ILPI: Original HCS 2012 context · Current HCS], Carcinogenicity, to learn the appropriate hazard category, signal word, hazard statement, precautionary statements, and pictogram for mixtures classified as carcinogens. The pictogram for carcinogens is the “health hazard” pictogram depicting a human head and shoulders, not the skull-and-crossbones.
Benzene must be disclosed on the SDS as a carcinogenic ingredient if it meets the above mentioned criteria. Please see 29 CFR 1910.1200 Appendix D [ILPI: Original HCS 2012 context · Current HCS] for information about the different sections of an SDS and what is required in each section. The sections of the SDS that would include information on benzene are Section 2 - Hazard(s) identification, Section 3 - Composition/information on ingredients, Section 7 - Handling and storage, Section 8 - Exposure controls/personal protection, Section 9 - Physical and chemical properties, Section 10- Stability and reactivity, and Section 11 - Toxicological information.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA 's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA 's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA 's website at https://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement Programs at (202) 693-2190.
Sincerely,
Amanda Edens, Acting Director
Directorate of Enforcement Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2017-07-24.