| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
OSHA Hazard Communication Letters of Interpretation
Cancer warning labels for formaldehyde and products containing formaldehyde
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Cancer communication remains required; pending-rule discussion historical
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its conclusion that formaldehyde cancer hazards must be communicated remains relevant. The reference to a rule expected in fall 1987 is historical, not a current pending decision. Use current formaldehyde hazard-communication provisions and their coverage/labeling conditions.
Current hazard classification and carcinogenicity criteria do not require positive human evidence before animal evidence can matter. Apply current shipped-label elements and Appendix C and SDS health-effect disclosures. The manufacturing-only scope described below has been replaced by the broader current HCS scope.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
August 7, 1987
Mr. John F. Murray
President
The Formaldehyde Institute, Inc.
1330 Connecticut Avenue, N.W., #300
Washington, D.C. 20036
Dear Mr. Murray:
This is in response to your letter regarding cancer warning labels for formaldehyde and products containing formaldehyde.
[ILPI note: At issuance: 1910.1200, original 1983 rule (PDF). Current counterparts: formaldehyde hazard communication, carcinogenicity criteria, and shipped labels. The pending 1987 rulemaking and manufacturing-only scope are historical. The “final rule” links below identify the rule subsequently published December 4, 1987, not a rule already in effect on this letter's date. Use current paragraph (m) for today's formaldehyde hazard communication.]
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
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-08-07.