Safety Tidbit 4.05 – Is it
a carcinogen?
Reference: OSHA Hazard Communication 1910.1200
National Toxicology Program (NTP)
International Agency for Research on Cancer (IARC)
I recently
asked the question “What are the two primary sources you should use to
determine if a substance you are working with is a carcinogen?” This was in
reference to OSHA’s Hazard Communication Standard. Many folks responded that
they would look on the Safety Data Sheet (SDS). Which made me feel good that
they both knew what an SDS was and that that information was in the
document. But when pushed further and I
asked how does the manufacturer of the chemical know to classify their chemical
as a carcinogen? We need to dig a little
deeper into the Hazard Communication Standard.
Appendix
A of the OSHA Hazard Communication Standard (1910.1200) is a mandatory appendix
to assist manufacturers with classifying the hazards of their chemicals. Section A.6 deals with Carcinogenicity. In
paragraph A.6.2.1 OSHA states “ For
the purpose of classification for carcinogenicity, substances are allocated to
one of two categories based on strength of evidence and additional weight of
evidence considerations. In certain instances, route-specific classification
may be warranted.”
So, the answer to my
question might be a) strength of evidence and b) weight of evidence.
OSHA goes on to define both items
but then says in A.6.2.5.1 “These factors
can be viewed as either increasing or decreasing the level of concern for human
carcinogenicity. The relative emphasis accorded to each factor depends upon the
amount and coherence of evidence bearing on each. Generally, there is a
requirement for more complete information to decrease than to increase the
level of concern. Additional considerations should be used in evaluating the
tumor findings and the other factors in a case-by-case manner.” In other
words, more information is better but how much is enough?
This is close but not quite what I
am looking for. Going back to my original question what two primary sources can
be used to determine if a substance is a carcinogen?” At the very end of the
section, OSHA says, in lieu of manufacturers doing their own testing to
determine if their chemical should be classified as a carcinogen they can use
two sources:
o National
Toxicology Program (NTP), "Report on Carcinogens" (latest edition);
o International
Agency for Research on Cancer (IARC) "Monographs on the Evaluation of
Carcinogenic Risks to Humans" (latest editions)
Hope this was helpful and thank you for
reading my Safety Tidbits! Comments and questions are always welcome. ~
BryanP.S. If you have an interesting safety or health question please let me know.
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