Standard Interpretations - Table of Contents|
| Standard Number:||1910.1200; 1910.1200(b)(6)(ix); 1910.1200(f)(1)(i)|
. . . IARC published Monograph No. 44, entitled, "Alcohol Drinking," in which the carcinogenicity of ethanol was determined based on chronic exposure to ethanol through human consumption. Manufacturers and importers must consider this information in performing the hazard determination of a product which contains ethanol. The MSDS would have to list ethanol as a hazardous ingredient along with the findings published in the IARC monograph. However, under normal conditions of use or in a foreseeable emergency, ingestion should not be a route of exposure; therefore, the product would not be listed as a carcinogen on the label.Therefore, if ingestion is the only route of exposure by which the nitrate/nitrite is capable of demonstrating its carcinogenic properties, and there is never a time where it is expected that the nitrate in your client's product would be ingested, then the IARC Group 2A classification would not be required to be on the cartridge label. However, the cancer hazards would still be required by the HCS to be listed on the material safety data sheet (MSDS) for the ink product.
. . . Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended. . .If your client demonstrates that their ink cartridge is a consumer product, as defined in the standard, then the HCS would not apply. Please remember however, that there are other agencies and entities that have standards and regulations for labeling. At a minimum, the Consumer Products Safety Commission (CPSC) and the Department of Transportation (DOT) should be contacted to ensure that their standards are followed by your client.
Minnesota Department of Labor and IndustryThank you for your interest in occupational safety and health. We hope you find this information helpful. 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.
Minnesota OSHA (MNOSHA)
443 Lafayette Road North
St. Paul, Minnesota 55155-4307
Phone: (651) 284-5050
|Standard Interpretations - Table of Contents|