Fiberglass product labels for workplace and consumer use

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 29, 1997

Robert Horowitz, President
Victims of Fiberglass
[Recipient address omitted]
Dear Mr. Horowitz:

This is in response to your letters of February 19, addressed to John B. Miles, Jr., Director, Directorate of Compliance Programs and to John Martonik, former Deputy Director, Directorate of Health Standards Programs on August 30, 1996, for the Occupational Safety and Health Administration (OSHA), regarding OSHA's Hazard Communication Standard (HCS) requirements for labeling an Owens Corning Fiberglass Corporation product trade named Miraflex. Please accept my apologies for the delay in responding to your previous letters.

Your letters indicate concern as to whether a cancer warning is required on the label for Miraflex products. The labeling requirements for specific products may vary depending upon end use. Products which are utilized by employees in the workplace rather than consumers are generally required to comply with 29 CFR 1910.1200. When these products contain fiberglass material, they may be required to include a warning of cancer on the label and disclose information relating to this hazard on the material safety data sheet. However, products which are considered to be consumer products, i.e. sold over the counter in retail establishments, are subject to labeling requirements of the Consumer Product Safety Act (15 U.S.C. 2051 et. seq.)(CPS Act) and, therefore, specifically exempt from the labeling requirements of OSHA's Hazard Communication Standard pursuant to 29 CFR 1910.1200(b)(5)(v). OSHA contacted Owens Corning World Headquarters and was informed that the vast majority of Miraflex is sold as a consumer product, trade named PinkPlus, to retailers for use by home owners in do-it-yourself projects. For the specific label carcinogen warning requirements under the CPS Act, I suggest you contact the Consumer Product Safety Commission. Owens Corning also provided a photocopy of a product safety and health information sheet for Miraflex PinkPlus which does contain information about cancer. This sheet is available to employers who utilize PinkPlus in a workplace setting.

I hope this clarifies OSHA's position on the requirements of the hazard communication standard with regard to fiberglass products.

Sincerely,

Stephen Mallinger, Acting Director
Office of Health Compliance Assistance

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