Hazard communication for chromium-containing respirator cartridges

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 6, 1992

MEMORANDUM FOR: R. DAVIS LAYNE
REGIONAL ADMINISTRATOR

THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Acid Gas Cartridges Containing Hexavalent Chromium and the Hazard Communication Standard

This is in response to your memorandum of February 5, regarding the applicability of the Hazard Communication Standard to acid gas respirator cartridges containing hexavalent chromium. We apologize for the delay in this response.

At issue is whether manufacturers of these types of respirator cartridges would have to warn of the (cancer) hazard of exposure to the hexavalent chromium (Cr(VI)) present in these types of cartridges. After carefully reviewing the background information attached to your memo, it was learned that NIOSH found no exposure to particulate Cr(VI) possible after testing several commercially available MSHA/NIOSH certified cartridges. Since no exposure is expected under normal conditions of use, and since, even under abnormal "test" conditions simulated by NIOSH no chromium was detected, the cartridges can be considered to be articles as defined under the HCS and would not be covered under the requirements of the standard. Further, since manufacturers have been notified by NIOSH that acid gas cartridges containing hexavalent chromium would not be approved by NIOSH after September 1, 1990, no new manufacturing of the cartridges can be anticipated, and, therefore, any requirement of the chemical manufacturer to transmit MSDSs and labels to downstream users warning of the potential hazard would not apply. Chemical manufacturers must transmit "significant information" only with the next shipment of hazardous chemicals within three months after they become aware of the new information (29 CFR 1910.1200(g)(5)).

We hope this has been responsive to your inquiry. Feel free to contact Melody Sands of my staff if you have any further questions.

[Regional request and NIOSH attachments reproduced on OSHA page; omitted here.]