- Standard Number:1910.1200(d)(4)
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 http://www.osha.gov.
August 5, 1986
Mr. Michael Lafond
BETZ Laboratories, Inc.
The Water and Energy Management Company
Trevose, Pennsylvania 19047
Dear Mr. Lafond:
This is an update to our response of June 19 to your letter of June 4 requesting an interpretation on whether sodium and potassium salts of chromate and dichromate are considered carcinogenic in accordance with the Hazard Communication Standard's (HCS) requirements for labeling material safety data sheets, and training.
As you correctly mention in your letter the HCS lists three sources to be used in determining whether a chemical is a carcinogen or potential carcinogen: the National Toxicology Program's "Annual Report on Carcinogens," International Agency for Research on Cancer (IARC) "Monographs," and 29 CFR 1910 Subpart Z, Toxic and Hazardous Substances. After reviewing the above sources, particularly IARC Monograph Volume 23, it appears that sodium and potassium salts of chromate and dichromate would not be considered carcinogens as defined by the HCS.
However, for health hazards, any evidence which is statistically significant and which is based on at least one positive study conducted in accordance with established scientific principles would need to be reported on the material safety data sheet. Therefore, if there are any studies which indicate that sodium and potassium salts of chromate and dichromate may be carcinogenic, the results, although not conclusive for establishing carcinogenicity, would need to be reported on the material safety data sheet.
If you have any questions, please feel free to contact us again.
John A. Pendergrass