Carcinogenicity entries on material safety data sheets

May 28, 1986

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS

FROM: JOHN B. MILES, JR., DIRECTOR, DIRECTORATE OF FIELD OPERATIONS

SUBJECT: Indication of Carcinogenicity on Material Safety Data Sheets

Attached for your information is a copy of an interpretation made for the State of Kentucky regarding the indication of carcinogenicity on material safety data sheets. Please inform all State and Area Offices in your Region of this interpretation.

May 21, 1986

Mr. Guy Schoolfield
Branch Manager
Occupational Safety and
Health Program
Commonwealth of Kentucky
Labor Cabinet
[Recipient address omitted]

Dear Mr. Schoolfield:

This is in response to your letter dated April 29 to Mr. Charlie Anderson of our Atlanta Regional Office regarding the Hazard Communication Standard (HCS).

First, it appears from reading your letter to Mr. Anderson that you may be under the misconception that an OSHA 174 is a required form. It is not a required form, nor is any material safety data sheet format required by the HCS.

Secondly, the standard specifies the minimum amount of information that is required on the material safety data sheet, such as physical and chemical characteristics. This type of information must always appear on the material safety data sheet. However, with carcinogens the standard requires that the material safety data sheet must state "whether" a chemical is a carcinogen, and not "whether or not" it is a carcinogen. Only when the condition is affirmative must this indication appear. A section for carcinogenicity would not even have to appear on a material safety data sheet if a chemical was not a carcinogen. However, if a space for carcinogenicity does appear on the material safety data sheet being used, then that area has to be addressed and no blank spaces are permitted; see 29 CFR 1910.1200(g)(3). If a chemical is not a carcinogen then phrases such as "no information found" or "not applicable" would have to be used in the space provided for carcinogenicity.

Concerning your question regarding compressed air, it is applicable under the standard's definitions for compressed gas and physical hazards.

If you have any further questions, please feel free to contact our office.

Sincerely,

John B. Miles, Jr., Director
Directorate of Field Operations

[A May 7 regional request memorandum and related materials reproduced on the OSHA page are omitted here.]