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Lead chromate labeling under hazard communication rules

Summary A regional administrator asked how OSHA’s hazard communication guidance applied to lead chromate labels. OSHA said the table listing carcinogens was general guidance and that the warning-label criterion in its instruction depended on positive human evidence; it said no studies then indicated lead chromate was a human carcinogen. OSHA now archives the memorandum as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1987-06-01
Date issued
June 1, 1987
Status
Archived by the agency
OSHA archives this document and says it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication Chemical Hazards
Source
View the official document

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 1, 1987

MEMORANDUM FOR: FRANK L. STRASHIEM
Regional Administrator
FROM: LEO CAREY, DIRECTOR
Directorate of Field Operations
SUBJECT: Labeling of Lead Chromate Under the Hazard Communication Standard

Although Table I, page A-15 of CPL 2-2.38A CH-1, indicates that carcinogens listed in NTP need a carcinogen warning label, the table, as stated, is to be used as general guidance for assessing the MSDS and labeling information on carcinogens. The criteria for determining whether a carcinogen warning label is required is based on, as stated on page A-13 of CPL 2-2.38A CH-1, the existence of positive human evidence.

Presently, there are no studies which have indicated that lead chromate is a human carcinogen. Attached for your information is a memo prepared by Region II which provides additional support on this subject.

If you have any questions concerning this issue, please contact Gary Anderson, Acting Director, Office of Health Compliance Assistance on FTS 523-8036.

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