Revising MSDSs to Reflect New IARC Classification for TiO2
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.