Carcinogen determinations for cobalt compounds

February 2, 1994

Angela M. Mack
Product Safety Information Coordinator
UOP
[Recipient address omitted]
Dear Ms. Mack:

Thank you for your letter of October 5 concerning the requirements under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. Specifically, you inquired about section 1910.1200(d)(4)(ii) regarding hazard determination for carcinogenic compounds, in particular cobalt phthalocyanine sulfonate compounds.

Your question has been addressed in OSHA's compliance directive, Inspection Procedures for the Hazard Communication Standard (CPL 2-2.38C). This directive states the following: "For purposes of compliance with the MSDS and labeling requirements, the IARC monograph's summary evaluation for the chemical can generally be relied upon but it may be necessary to review the actual evaluations. In some cases, a group of compounds may be listed in the summary as carcinogenic but closer examination of the appropriate monograph will reveal that IARC had data to support the carcinogenicity of only certain compounds. Those compounds are the only ones covered by the HCS."

Under the Hazard Communication Standard chemical manufacturers have the responsibility to "identify and consider" all available scientific evidence for the chemicals they produce or import to determine if they are hazardous. In general, if an IARC monograph does not address a specific chemical or group of chemicals, the results of the monograph would not apply. However, it is your duty as the chemical manufacturer to evaluate all other scientific evidence and available studies to determine if any other evidence exists that may indicate a carcinogenic health hazard is associated with exposure to the cobalt phthalocyanine sulfonate compounds. The fact that your product was not addressed in the IARC monograph does not relieve you of the mandate to look elsewhere for other statistically significant evidence that carcinogenic or other health effects may result from employee exposure to cobalt phthalocyanine sulfonate compounds.

We hope this information is helpful. If you have any further questions please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]