Crystalline silica considered a carcinogen under the HCS.

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.

September 20, 1988

Mr. Theodore L. Garrett
Covington and Burling
Post Office Box 7566
Washington, D.C. 20044

Dear Mr. Garrett:

This is in further response to your letter of May 23 which petitioned the Occupational Safety and Health Administration (OSHA) to clarify or amend the Hazard Communication Standard (HCS) with regard to its applicability to crystalline silica.

Exemption of hazardous waste samples sent to a laboratory for analysis from the Hazard Communication Standard.

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.

August 17, 1988

Lawrence B. Maglin, CSM, CSSP LBM
Safety Consultants
90 Perkins Avenue South
Hamilton, Massachusetts 01982

Dear Mr. Maglin:

This is in reply to your letter concerning the hazardous waste exemption of the Hazard Communication Standard as applied to samples of the waste sent to a laboratory for analysis.

Enforcement of the Hazard Communication Standard

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.

July 18, 1988

Copies of MSDSs and the written hazard communication program must be provided to an employee representative.

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.

June 30, 1988

Mr. Richard D. Montgomery
Director Safety and Security
Fruehauf Corporation
10900 Harper Avenue
Detroit, Michigan 48213

Dear Mr. Montgomery:

This is in response to your letter of May 27. You have raised two specific questions

Question 1:

Is an employer expected to provide, at no cost, a copy of all material safety data sheets to a representative of his/her employees?

Answer:

Letter to Lawrence N. Curcio from Thomas Shepich concerning requirements of the HCS on labeling of IARC category 2B carcinogens

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.

June 14, 1988

Lawrence N. Curcio, Ph.D.
Exxon Company, U.S.A.
Marketing Technical Services
Post Office Box 2180

Dear Mr. Curcio:

Your letter of April 8 to Mr. Leo Carey has been forwarded to me for response. You have asked for clarification of an apparent inconsistency in guidance provided to our compliance officers regarding requirements for labeling International Agency for Research on Cancer (IARC) category 2B carcinogens.

Clarification of Material Safety Data Sheet Requirements Under the Hazard Communication Standard.

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.

Jun 10 1988

 

Carcinogen status of titanium dioxide relative to OSHA Standards

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.

November 19, 1997

Mr. Douglas C. Markley
North American Refractories Co.
500 Halle Building
1228 Euclid Avenue
Cleveland, Ohio 44115-1809

Dear Mr. Markley:

This is in response to your letter of October 15, requesting information about the carcinogen status of titanium dioxide
(TiO2) relative to Occupational Safety and Health Administration (OSHA) standards.

Material Safety Data Sheets (MSDSs).

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.

November 19, 1997

Mr. Mark B. Vandenbusch
Environmental Analyst
Wisconsin Public Service Corporation
700 North Adams Street
Post Office Box 19002
Green Bay, Wisconsin 54307-9002

Dear Mr. Vandenbusch:

The coverage of the Hazard Communications Standard (HCS) to crude oil, natural gas, and natural gas condensate.

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.

February 16, 1996

Laurence R. Durio, CIH
Durio Consulting Services
8762 Quarters Lake Road
Baton Rouge, Louisiana 70809

Dear Mr. Durio:

Office workers routinely performing short clean up procedures using chemicals covered by the HCS.

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.

May 16, 1988

Mr. Gregory M. Leitner
Law Offices
Leitner, Warner, Moffitt, Williams,
Dooley, Carpenter & Napolitan
Third Floor Pioneer Building
Chattanooga, Tennessee 37402

Dear Mr. Leitner:

This is in response to your letter of March 22, addressed to Mr. Steven Simon of my staff, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.