11/10/1992 - Employee "Right to Know" chemical labeling

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Title: 11/10/1992 - Employee "Right to Know" chemical labeling.
Record Type: InterpretationStandard Number: 1910.1200

    November 10, 1992

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

    Dear Congressman Bliley:

    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. 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)). 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.

    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.

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    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

    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.

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

    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


The original official public domain version of this document is available from OSHA at XXXOSHAURL.