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OSHA Hazard Communication Letters of Interpretation
Applicability of the HCS to crystalline silica, when bound in a polymeric compound and silicone rubber elastomers.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Exposure analysis retained; universal ingredient thresholds superseded
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its need to consider cutting, grinding, and other potential releases remains useful. Binding a hazardous ingredient into a product does not automatically remove HazCom duties, and absence of a measured exposure in one test does not establish absence of every anticipated exposure.
Under the current HCS, use hazard classification, known or reasonably anticipated uses, mixture procedures, and the complete article definition as applicable. The old 1%/0.1% shorthand is not a universal modern rule. See the article FAQ, cancer criteria, and SDS ingredient disclosure. Separate respirable-crystalline-silica requirements may also apply.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 8, 1989
Mr. D. A. Polsinelli
Product Regulatory Specialist
Product Regulatory Operation
Silcone Products Division, General Electric Company
Waterford, New York 12188
Dear Mr. Polsinelli:
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This is in response to your letter of August 22, 1988, concerning coverage of hazardous chemicals physically bound in a material under the Hazard Communication Standard (HCS) 29 CFR 1910.1200. Please accept my apology for the delay in response.
Your specific question concerned whether crystalline silica, when bound in a polymeric compound and silicone rubber elastomers used to fabricate rubber articles, is covered by the HCS. If a hazardous chemical is present in a mixture in reportable quantities (i.e., 0.1 percent for carcinogens and 1.0 percent for other health hazards), it is covered by the standard unless the mixture has been tested as a whole or the material is bound in such a way that employees can not be exposed.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: mixture classification, anticipated-use evaluation, and ingredient disclosure. The old universal concentration shorthand does not replace hazard-specific criteria; evaluate potential releases as well as measured exposure.]
The standard defines exposure as including potential as well as measurable exposure, and applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. If there is no exposure either under normal conditions of use or in a foreseeable emergency, then the chemical is not covered by the standard. However, if under normal conditions of use an action, such a cutting or grinding, is performed on the product that could release the crystalline silica, then the product would be covered by the HCS and the presence of silica must be indicated on the material safety data sheet.
We hope this information is helpful to you. Please feel free to contact us again if further assistance is needed.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-02-08.