Carbon black in fingerprint powder safety data sheets

July 2, 1986
Mr. James W. Gocke
Vice President and General Counsel
SIRCHIE Finger Print Laboratories
[Recipient address omitted]
Dear Mr. Gocke:
Your letters dated April 22 and May 5 have been forwarded to our office for response. Mr. Anderson, Assistant Regional Administrator in Region IV, has informed us of your concern regarding the health hazards of your fingerprint powders containing carbon black.
The Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) requires chemical manufacturers and importers to evaluate chemicals produced in their workplace or imported by them to determine if they are hazardous. Any chemical for which OSHA has a permissible exposure limit (PEL) or the American Conference of Governmental Industrial Hygienist (ACGIH) has a threshold limit value (TLV) is automatically considered hazardous as part of the standards floor of chemicals.
Also, the following sources establish that a chemical is a carcinogen or potential carcinogen for hazard communication purposes:

i. National Toxicology Program (NTP), Annual Report on Carcinogen (latest editions);
ii. International Agency for Research on Cancer (IARC) Monographic (latest editions; or
iii. Those substances regulated as carcinogens under 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substance, Occupational Safety and Health Administration.

In addition, for health hazards, evidence which is statistically significant and which is based on at least one positive study conducted in accordance with established scientific principles is sufficient for a notation to appear on the material safety data sheet.
Carbon black does have an OSHA PEL and is also listed by ACGIH. It is therefore automatically considered a "hazardous chemical" under the HCS and any associated health and/or physical hazard would have to be reported on the material safety data sheet.
According to IARC the available data on carbon blacks are inadequate to permit an evaluation of their carcinogenicity to experimental animals. However, there is sufficient evidence that solvent (benzene) extracts in most of the carbon blacks tested are carcinogenic to experimental animals. A chemical manufacturer or importer would have to indicate the results of such studies on the material safety data sheet. A cancer warning on the product's label would not be required since the available epidemiological data provides inadequate evidence to evaluate the carcinogenicity to humans of carbon blacks.
If you have any further question please contact the [Office of Health Enforcement at (202) 693-2190].
Sincerely,
John B. Miles, Jr., Director
[Directorate of Enforcement Programs]
[Corrected 6/1/2005]

------------------------------------------------------------------------

[A May 9 regional request memorandum and related materials reproduced on the OSHA page are omitted here.]