Revising MSDSs to Reflect New IARC Classification for TiO2
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.