Hazard evaluation for products with methylene chloride

March 12, 1986

Mr. Loren Anderson, CIH
International Business Machines, Corp.
[Recipient address omitted]
Dear Mr. Anderson:

This letter is in reference to our previous telephone conversation on March 12 regarding hazard evaluation.

Hazard evaluation is a process which relies heavily on the professional judgment of the evaluator. Employers evaluating chemicals shall describe in writing the procedures they used to determine the hazards of the chemical they evaluate. If a determination has been made that a hazard does not exist, then the labeling and material safety data sheet requirements will not apply.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
March 7, 1986

Loren Anderson, CIH
International Business Machines, Corp.
[Recipient address omitted]

Dear Mr. Anderson:

Thank you for your letter dated January 28 in regards to the Hazard Communication Standard. Please accept my apology for the delay in response. The overwhelming number of letters and telephone calls regarding the Hazard Communication Standard has caused unavoidable delays in responding to the public's concerns.

Methylene chloride has been shown through established scientific studies to be a suspect carcinogen. However, since the chemical is not listed as a carcinogen by IARC or the NTP, labeling is not listed as a carcinogen by IARC or the NTP, labeling requirements are not necessary.

Material safety data sheets are required to be prepared if the chemical has been determined to be a health hazard and comprises 1% or greater of the composition, except that chemicals identified as carcinogens shall be listed if the concentrations are 0.1 % or greater.

The material safety data sheet must provide a health hazard description of the chemical based on the positive studies of carcinogenicity for methylene chloride. The material safety data sheet must state the studies have indicated that it is a suspect carcinogen.

If we may be of further assistance on this matter please feel free to contact our office at (202)523-8036.

Sincerely,
John B. Miles, Jr., Director
Directorate of Filed Operations

[Requester letter reproduced on OSHA page; omitted here.]