WASHINGTON - The International Agency for Research on Cancer's (IARC) recent reclassification of titanium dioxide (TiO2) from a Group 3 to a Group 2B carcinogen has prompted the NPCA to reiterate previously obtained guidance received from the Occupational Safety and Health Administration (OSHA). When IARC changed the cancer classification of formaldehyde from a Group 2B to a Group 1, NPCA contacted OSHA for guidance on hazard communication responsibilities. OSHA reconfirmed that the "90-day clock" for amending Material Safety Data Sheets (MSDSs) under the Hazard Communication Standard (HCS, 29 CFR 1910.1200), which starts upon becoming "newly aware" of a change of a chemical's reclassification, does not start until the actual publication of the complete IARC monograph. In the case of TiO2, the IARC monograph (No. 93) has not yet been published, nor is it anticipated that it will be published in the immediate future.

OSHA does not require that chemicals designated as IARC Group 3 Carcinogens (as IARC did with TiO2 in 1989) be identified as such on labels or MSDSs. However, IARC's recent reclassification of TiO2 to a Group 2B, while not requiring labeling changes, will require a change to the MSDS of materials containing TiO2.

OSHA specifically advised NPCA that the monograph must be published in order to trigger the requirement to revise an MSDS to reflect that new classification since the IARC listing itself doesn't provide all relevant information, such as any constraints on the reclassification determination. OSHA advised that this "is particularly true for monographs that cover multiple compounds of a single chemical, for example."

Additionally, OSHA repeated that it does not require that those preparing an MSDS list the specific IARC designation on the MSDS, only whether or not the substance is a carcinogen; so unless you are specifying the precise IARC numeric designation, your MSDS need not be changed.

See http://monographs.iarc.fr/ENG/ Meetings/index1.php for more information.

NPCA members are invited to contact Skip Edwards at sedwards@ paint.org or Allen Irish at airish@ paint.org for more information.