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Nov 10, 1992 - Employee "Right to Know" chemical labeling. Nov 10, 1992 - Employee "Right to Know" chemical labeling.

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OSHA Hazard Communication Letters of Interpretation

Employee "Right to Know" chemical labeling.

Issued: November 10, 1992
Record type: Interpretation
Historical standard: 1910.1200, 1987 expanded rule (PDF)
Current standard: HCS 2024, as amended

ILPI assessment: Food-use status does not resolve occupational classification; old automatic tests superseded

This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom distinction remains useful: a food-use determination is not a finding that workplace inhalation, handling or other exposures are harmless. However, the old mandatory-source and universal 0.1% explanation is not the complete current classification/disclosure test.

Apply hazard classification, all relevant evidence, carcinogenicity criteria and ingredient disclosure. Use the current product SDS for actual duties and evaluate applicable exemptions on their terms. Food-use status does not establish safety for every occupational exposure route. The attached constituent's chart is not OSHA's classification finding.

Last reviewed: October 27, 2026.

Related interpretations

The hazard communication standard requirements for food or food additives. (January 24, 1990)
Food and food additives can present occupational hazards, including combustible dust, and are not automatically outside the HCS.
Requirements for labeling of food additives and intermediate chemicals under the revised Hazard Communication Standard (HCS 2012) (May 26, 2015)
FDA labeling coverage does not automatically remove applicable SDS, classification or training duties.
The HCS does not apply to food items in a retail establishment (April 7, 1998)
Its retail-food conclusion remains consistent for food sold, used or prepared in a retail establishment.
Letter requesting that OSHA exempt animal feed ingredients from the requirements of 29 CFR 1910.1200, the Hazard Communication Standard. (September 18, 1995)
FDA regulation or paperwork volume does not create a blanket HCS exemption for feed ingredients.

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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.

November 10, 1992

The Honorable Thomas J. Bliley, Jr.
U.S. House of Representatives
Washington, D.C. 20515

Dear Congressman Bliley:

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This is in response to your letter of September 2, on behalf of your constituent Mr. N. Lee Brown, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. Mr. Brown pointed out what seemed to be discrepancies in describing the hazards of the chemical acetaldehyde.

The Hazard Communication Standard requires chemical manufacturers or importers to consider a chemical carcinogenic if the International Agency for Research on Cancer (IARC), National Toxicology Program (NTP) or OSHA designates the chemical as a carcinogen or potential carcinogen (please see 29 CFR 1910.1200(d)(4) [ILPI: Original HCS 1987 context (PDF) · Current HCS; current evidence and hazard-specific criteria apply]). If the chemical is a carcinogen and in concentrations of 0.1% or more the health hazard must be explained in the material safety data sheet (MSDS). We see no conflicting information, since the document which Mr. Brown enclosed stated that both NTP and IARC classify acetaldehyde as a carcinogen.

[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: evidence evaluation, cancer criteria and mixture ingredient disclosure. The old automatic-source/threshold shorthand and food-use comparison do not replace the modern criteria.]

Mr. Brown also noted that the Food and Drug Administration (FDA) recognizes acetaldehyde as safe "for use as a flavoring," and that this conflicting information makes a judgment call difficult. When there is conflicting information that would affect employee safety and health, employers should take the more conservative approach to ensure that the work place is hazard free. In this case, however, OSHA gives solid guidance in its Hazard Communication Standard on which chemicals to label carcinogenic. FDA classification is not required by the HCS; however, if Mr. Brown is interested in the FDA's studies we suggest that he contact the FDA to request their studies on the health effects of acetaldehyde as a flavoring and preservative in consumer products.

We hope this information is helpful. If you have any further questions please feel free to contact us at (202) 219-8036.

Sincerely,

Roger A. Clark,
Director
Directorate of Compliance Programs

September 2, 1992

Secretary Lynn Martin
Department of Labor
200 Constitution Avenue, NW
Washington, D.C. 20210

Dear Secretary Martin:

A constituent brought to my attention his peculiar difficulty in attempting to comply with OSHA "Right to Know" regulations. Enclosed you will find a copy of his complaint and my response.

His frustrations with current methods of chemical hazards classifications seem to illustrate a larger need for reform. I urge you to investigate this matter and respond at your earliest convenience. Thank you.

Sincerely,

Thomas J. Bliley, Jr.
Member of Congress

Enclosure

July 28, 1992

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The Honorable Thomas J. Bliley, Jr.
4914 Fitzhugh Avenue
Richmond, Virginia 23230

Dear Tom:

In compliance with OSHA "Right to Know" regulations we review the work place hazards of chemicals used at our facilities.

Attached are meting notes used to describe the hazards of the chemical acetaldehyde. These notes point out the confusion that exists in specifying hazards under our Nation's current chemical hazards management system.

As our employees learn from page three of the guideline, acetaldehyde may be:

"Reasonably expected to be a carcinogen"

National Toxicology Progress
""Possibly carcinogen to Humans"

The Food and Drug Administration
""Generally recognized as Safe"

The Food and Drug Administration

In short, a difficult judgement for the employee or management to make. I encourage you and the Congress to seek out common methods and policies for use in determining such critical definition to our employees and to the procedure management uses to insure the health of its workers.

Yours truly,

N. Lee Brown
Director Fibers Engineering

This hypermarked and content-enhanced page is copyright by ILPI, all rights reserved. Unauthorized duplication or posting on other web sites is expressly prohibited. For questions, comments and concerns, please contact us at our SDS email address.

The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1992-11-10.