The "Hazard Communication" (29 C.F.R. l9l0.l200) standard requires chemical manufacturers and importers to assess the hazards of chemicals which they produce or import, and the manufacturing sector to provide information to their employees concerning hazardous chemicals by means of hazard communications programs including; container labels, material safety data sheets, training, and access to written records. Employers were required to comply with all provisions of the standard including initial training for all current employees by May 25, l986.

The criteria for determining whether a substance is a "Hazardous Chemical" is divided into two categories i.e.; physical hazards criteria and health hazards criteria.

OSHA defines a "Physical Hazard" as a "chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophonic, unstable (reactive) or water-reactive." Cottonseed oil in any of its forms does not meet the criteria set forth for the determination of a physical hazard.

We have reviewed several of the "Information Sources" listed in Appendix C of 29 CFR l9l0.1200 and can find nothing that indicates that cottonseed oil is a health hazard. One source listed cottonseed oil as "combustible." OSHA defines a combustible liquid as follows: Any liquid having a flashpoint at or above l00^oF, but below 200^oF except any mixture having components with flashpoints of 200^oF, or higher, the total volume of which make up 99 percent or more of the total volume of the mixture. Since cottonseed oil has a flash point of 486^oF and since OSHA does not consider it to be a mixture, the definition of "Combustible Liquid" can not be construed in such a way as to include cottonseed oil.

The standard defines a "Health Hazard" as a "chemical for which there is statistically significant evidence based on at least one study conducted by established scientific principles that acute or chronic health effects may occur in exposed employees". The term "Health Hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Appendix A of the standard provides complete definitions and explanations of the scope of health hazards. We are not aware of any statistically significant evidence that would indicate that cottonseed oil meets any of the criteria for a health hazard.

Upon consulting with the OSHA regional office in Atlanta, we learned that OSHA does not expect manufacturers to conduct lengthy tests on their products and such tests are not a requirement of the regulation. Appendix B of 29 CFR l9l0.l200 states that; "Hazard evaluation is a process which relies heavily on the professional judgement of the evaluator..." It would be impractical, if not impossible, for us to review all the literature looking for a health effect that may be related to exposure to cottonseed oil. In our search of the published literature, we have found nothing that indicates that workers exposed to cottonseed oil are at risk.

It is our opinion that cottonseed oil does not meet any of the criteria set forth to define a "Hazardous Chemical." A comprehensive hazard communication program including container labeling and other forms of warning, material safety data sheets and employee training are not required for cottonseed oil.

Sincerely yours,

Ben Morgan
Executive Vice President