New report on carcinogens may affect employer Hazard Communication Programs

The U.S. Department of Health and Human Services recently released the National Toxicology Program's (NTP) 12th Report on Carcinogens (RoC), one of the two cancer lists referenced in OSHA's Hazard Communication Standard (HCS). As a result, employers that manufacture, distribute, or use any of the eight chemicals with new or updated listings in the 12th RoC need to determine if the changes have any impact on their existing hazard communications programs. The 12th RoC added two substances--formaldehyde and aristolochic acids--to its list of known human carcinogens, and six substances--captafol, cobalt-tungsten carbide (in powder or hard metal form), certain inhalable glass wool fibers, o-nitrotoluene, riddelliine (a botanical, not be confused with the drug Ritalin) and styrene--to its list of chemicals and biological agents that are reasonably anticipated to be human carcinogens. For chemicals like styrene and formaldehyde, which are already listed as carcinogens by the NTP or other organizations, the impact of the listings in the 12th RoC is likely to be minimal because many of the HCS requirements have already been triggered by the previous listings.

Chemicals listed in the RoC are considered carcinogens under OSHA's Hazard Communication Standard. Therefore, manufacturers and importers of a chemical or a product containing a chemical listed in the RoC must list the chemical on Material Safety Data Sheets (MSDSs) if it is present at a concentration of 0.1% or greater when the product has not been tested as a whole, and they must include warning information about cancer in the MSDS. Chemicals listed on the RoC that are present at less than 0.1% must also be listed if they could be released from the product in concentrations that could present a health risk to workers. The MSDS must also indicate that the NTP lists the chemical as a carcinogen.

Employers that use chemicals with new or updated cancer listings in the RoC or products that contain these chemicals should review incoming MSDSs for new information and must train workers about any new chemical or product hazards. Employers must also look at how the chemical or product is used in their workplaces and make sure that the precautions and protective equipment they require are sufficient to protect workers from anticipated exposures.

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