Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

June 1, 1987

  Regional Administrator
  Directorate of Field Operations
SUBJECT: Labeling of Lead Chromate Under the Hazard Communication

Although Table I, page A-15 of CPL 2-2.38A CH-1, indicates that carcinogens listed in NTP need a carcinogen warning label, the table, as stated, is to be used as general guidance for assessing the MSDS and labeling information on carcinogens. The criteria for determining whether a carcinogen warning label is required is based on, as stated on page A-13 of CPL 2-2.38A CH-1, the existence of positive human evidence.

Presently, there are no studies which have indicated that lead chromate is a human carcinogen. Attached for your information is a memo prepared by Region II which provides additional support on this subject.

If you have any questions concerning this issue, please contact Gary Anderson, Acting Director, Office of Health Compliance Assistance on FTS 523-8036.