OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 5, 1986

Mr. Lawrence Schweinsburg
Lieutenant
Fiscal Affairs Division
The Prince George's County Government
3415 N. Forestedge Road
Forestville, Maryland 20747

Dear Mr. Schweinsburg:

This is in response to your inquiry concerning a fingerprint powder called Sirchie Silk Black.

Sirchie Silk Black has been investigated by the National Institute for Occupational Safety and Health (NIOSH). According to NIOSH's findings, Sirchie Silk Black contains polynuclear aromatic hydrocarbons (PNA's). PNA's are a group of organic compounds that are suspect human carcinogens. Because of this suspicion, NIOSH recommends that Sirchie Silk Black be substituted by a product that does not contain PNA's.

The Occupational Safety and Health Administration (OSHA) does not have regulations that apply to the specific PNA's included in their product. However, OSHA does have a standard that regulates employee exposure to carbon black. The current OSHA standard for carbon black is 3.5 milligrams per cubic meter of air (mg/m3) averaged over an 8-hour workday. Please be aware that carbon black may contain PNA's. Since OSHA does not have standards that regulate specific PNA's nor an official policy concerning PNA's I suggest that you are on the side of safety and follow NIOSH's recommendations i.e., substitute Sirchie Silk Black with another powder without PNA's.

I have enclosed a copy of NIOSH's report for your use. I hope this information is useful to you.

Sincerely,

Richard D. Edsell
Director
Office of Science and Technology Assessment

May 13, 1986

Occupational Safety and
Health Administration
200 Constitution Avenue N.W.
Washington, D.C. 20001

Dear Sirs:

We are in receipt of a report from the Department of Commerce (N.T.I.S. July, 1983, P.B.8S-102895) which advises that two types of fingerprint powder manufactured by the Sirchie Company contain PNA's which are known carcinogens. This Department uses one of these two types of powder, which is called Sirchie Silk Black.

I have been advised that further research subsequent to this report has indicated that routine use of this fingerprint powder in fact presents no health dangers and that it will not be necessary to permanently discontinue its use. It would be greatly appreciated if you could advise OSHA's position on the use of this product.

Sincerely,

Lawrence Schweinsburg
Lieutenant
Fiscal Affairs Division