| 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
Whether labels and material safety data sheets (MSDS) must be provided to downstream manufacturers and processors for orlon or orlon blend yarns.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Downstream release matters; cancer classification and label rules updated
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central principle remains useful: yarn is not automatically exempt when normal downstream processing can release hazardous chemicals. Its old cancer-list/label discussion and historical DMF evaluation are not the current classification system.
Under the current HCS, use hazard classification, carcinogenicity criteria, mixture rules, shipped-container label elements and Appendix C, and SDS toxicological information. IARC's 2018 DMF evaluation identifies Group 2A, rather than the letter's historical Group 2B. Current acrylonitrile hazard communication expressly addresses multiple hazards and HCS compliance; it is not limited to the old cancer-only label description. This review does not establish a particular present yarn formulation's classification.
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 31, 1989
Patrick R. Tyson, Esquire
Constangy, Brooks and Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557
Dear Mr. Tyson:
Safety Emporium carries NFPA signs and labels like these ones. Plus a whole lot more!
This is in response to your letter of August 1, in which you requested an interpretation on the issue of whether labels and material safety data sheets (MSDS) must be provided to downstream manufacturers and processors for orlon or orlon blend yarns.
As you know, the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS], requires all shipped containers of hazardous chemicals to be labeled with the following information: the identity of the hazardous chemical(s); appropriate hazard warnings; and the name and address of the chemical manufacturer, importer or other responsible party. In addition, chemical manufacturers and importers must obtain or develop a MSDS for each hazardous chemical they produce or import. One of the areas which must be addressed on the MSDS is whether the hazardous chemical is regulated by OSHA as a carcinogen, or is listed in the National Toxicology Program (NTP) Annual Report On Carcinogens, or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs.
You specifically requested an interpretation on whether the potential cancer hazards of dimethylformamide (DMF) and acrylonitrile (AN) would have to be addressed on the labels and MSDS for orlon and orlon blend yarns sent to downstream manufacturers or processors. In reviewing the MSDS and additional information forwarded with your inquiry on "orlon" products from Dupont, it appears that there is a potential for exposure to AN and DMF under their normal conditions of use in downstream processing operations. Since DMF is an IARC listed group 2B carcinogen, that health hazard information must be reflected on the MSDS. In addition, if there is a valid scientific study indicating positive human evidence of carcinogenicity, then the label must contain hazard warning(s) on carcinogenicity. It should also be noted that the chemical manufacturer is free to report any negative findings as well, as long as the positive findings by IARC are included.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The DMF Group 2B statement is historical; IARC's 2018 evaluation is Group 2A. Apply current cancer criteria, mixture rules, and shipped-container label elements and Appendix C.]
AN is regulated by OSHA as a carcinogen in a substance-specific standard at 29 CFR 1910.1045. That standard contains its own labeling requirements. However, to the extent that 1910.1045(p) applies in this situation, the labeling requirement of that substance specific standard addresses only carcinogenicity and does not require the reporting of other hazards, such as acute or chronic health effects or potential physical hazards.
I hope that this information answers your concerns with regard to this matter. If I can be of further assistance, please feel free to contact me again.
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/1989-08-31-0.