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OSHA Hazard Communication Letters of Interpretation
Health effects of prolonged exposure to paint related materials.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Product identification remains useful; the letter does not establish medical causation
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main HazCom point remains useful: accurate identification of the paints, coatings and solvents used is essential to obtaining relevant hazard information. The historical literature search is not a diagnosis or a finding that a particular exposure caused an individual's condition.
Use the sheets relevant to the actual products and exposure dates, toxicological information and employee exposure/medical-record access. A current reformulation's SDS may not describe earlier exposures. Retention and workplace access are separate duties; consult appropriate occupational-health expertise to assess actual records and exposures. Current workplace-investigation resource: NIOSH Health Hazard Evaluations. The old TDC contact details and unprovided abstracts are historical.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
April 4, 1995
Ms. Debra Horn
HC15 Box 2140
Smithville, Oklahoma 74957
Dear Ms. Horn:
This is in response to your letter of January 26, requesting information or literature regarding the health effects of prolonged exposure to paint related materials.
There are many different formulas for paints, industrial coatings, primers, sealers, etc., and consequently, there are many different chemicals used to produce them. Therefore, the Occupational Safety and Health Administration (OSHA), Technical Data Center (TDC), did a wide ranging search for any technical literature that may associate brain, nerve, or kidney damage with exposures occurring during painting operations. We have enclosed the abstracts of the literature the TDC located.
Also, please be aware that the OSHA Hazard Communication Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS] (copy enclosed), requires the manufacturer OR importer of a hazardous paint to conduct a hazard determination and to prepare a material safety data sheet (MSDS) for the paint and to provide the MSDS to employers who use the paint. If your husband or his employer(s) know the identities of paints that were used, the MSDSs for them may be helpful to you.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Seek the product/version relevant to the actual exposure dates and applicable exposure records. SDSs can assist evaluation but do not by themselves establish individual medical causation or substitute for an occupational-health assessment.]
We hope you find the information helpful. Should you require additional information, please contact the OSHA TDC at (202) 219-7500.
Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance
Enclosures
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January 26, 1995
Debra Horn HC15
Box 2140
Smithville, OK 74957
I need information and or literature regarding prolonged exposure to paint (hazardous) related materials such as solvents, lacquers, ceramic tile primer concrete sealer, etc. too many to list.
My husband was a painter for 20 years. He has done just about all types of painting from industrial steel, high rise, auto you name it, he's done it.
He now has a lot of health problems. Brain, nerve and kidney damage. He has not worked for about 4 years, due to this and has been on nerve medication for 5 years. His condition is getting worse. Do not have money to see doctors. He has applied for disability and we need more facts about prolong exposure to hazardous paint materials and their side effects.
Thank-you,
Debra Horn
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1995-04-04.