Formaldehyde cancer warnings before final rulemaking

August 7, 1987

Mr. John F. Murray
President
The Formaldehyde Institute, Inc.
[Recipient address omitted]
Dear Mr. Murray:

This is in response to your letter regarding cancer warning labels for formaldehyde and products containing formaldehyde.

Although the Occupational Safety and Health Administration (OSHA) is conducting rulemaking with regards to formaldehyde and a final rule is due Fall 1987, it would be inappropriate to stay enforcement activities at this time for labeling requirements under the Hazard Communication Standard. The Hazard Communication Standard requires employers to evaluate the chemicals they produce and the information concerning their hazards be transmitted to affected employers and employees within the manufacturing sector.

Presently, there are several valid, positive studies indicating human carcinogenicity. Accordingly, label warnings stating the carcinogenic potential of formaldehyde is required under the Hazard Communication Standard and therefore is not, as you state, an ad hoc enforcement action by the Agency.

In addition, enforcement of labeling requirements under the Hazard Communication Standard will not prejudge the pending rulemaking. OSHA presently does not expect any final rule for formaldehyde to significantly change the information already required on existing labels.

If I can be of further assistance, please feel free to contact me again.

Sincerely,
John A. Pendergrass
Assistant Secretary