OSHA 1910.1007
3'-Dichlorobenzidine requirements
Subpart Z
Questions & Answers
Under 1910.1007, does the listing of 3,'-Dichlorobenzidine itself state the detailed employer obligations (for example, exposure limits or controls)?
No. The 1910.1007 listing identifies 3,'-Dichlorobenzidine (and its salts) as a named substance, but the listing itself does not lay out the full compliance procedures or controls; you must consult the related carcinogen requirements in 1910.1003 and other applicable parts of 29 CFR part 1910 to determine specific employer obligations.
Under 1910.1007, does the standard cover the salts of 3,'-Dichlorobenzidine as well as the base compound?
Yes. The title of 1910.1007 explicitly covers "3,'-Dichlorobenzidine (and its salts)," so both the base compound and its salts are included in the listing described in 1910.1007. Employers should treat salts of this chemical as within the scope of the listing and consult 1910.1003 for applicable carcinogen requirements.
Under 1910.1007, how does a workplace determine whether the chemical inventories or operations bring them under OSHA’s carcinogen requirements for 3,'-Dichlorobenzidine?
You must identify whether workplace processes involve 3,'-Dichlorobenzidine (or its salts); if they do, the substance is a listed carcinogen under 1910.1007 and you should follow the carcinogen-related provisions referenced in 1910.1003. The listing itself signals that follow-up actions and any specific procedures are defined in the broader carcinogen regulation at 1910.1003.
Under 1910.1007, does the listing of 3,'-Dichlorobenzidine mean employers must automatically adopt medical surveillance, exposure monitoring, or other programs?
Not automatically from 1910.1007 alone; the listing notifies you the substance is a named carcinogen, and employers must then review the requirements in 1910.1003 and other applicable 29 CFR 1910 standards to determine which specific programs (for example, monitoring, medical surveillance, training, or controls) apply to their operations. The 1910.1007 listing is the trigger to consult those detailed requirements in 1910.1003.
Under 1910.1007, where can employers and safety professionals read the authoritative OSHA regulatory text that lists 3,'-Dichlorobenzidine?
The authoritative OSHA regulation listing 3,'-Dichlorobenzidine (and its salts) appears at 1910.1007. For the broader set of carcinogen obligations and cross-references, consult 1910.1003 and the rest of 29 CFR part 1910.
Under 1910.1007, does the standard identify how many carcinogens are covered in the related section noted as "See 1910.1003, 13 carcinogens"?
Under 1910.1007, if an employer has questions about how the listing applies to a specific work task, can OSHA Letters of Interpretation change the employer’s legal duties for 3,'-Dichlorobenzidine?
No—OSHA Letters of Interpretation clarify how OSHA interprets and applies standards but do not create new legal obligations beyond the regulations themselves. OSHA’s letters explain application and may be persuasive guidance, but employers’ duties remain defined by the regulations such as 1910.1007 and the related carcinogen rules in 1910.1003; see an example of that principle in OSHA’s Asbestos remediation protocols letter of interpretation.
Under 1910.1007, if a workplace uses 3,'-Dichlorobenzidine in combination with other hazardous processes, where should compliance officers look for overlapping requirements?
Start with the listing at 1910.1007 and then review the carcinogen-specific provisions in 1910.1003; then check other applicable parts of 29 CFR part 1910 for standards that may impose additional controls or programs relevant to the other hazardous processes present.
Under 1910.1007, does OSHA’s listing of 3,'-Dichlorobenzidine affect state-plan states differently than federal OSHA?
No—the listing under 1910.1007 reflects federal OSHA’s codification; State-plan states must have standards and enforcement programs at least as effective as federal OSHA, but they may adopt different or more stringent requirements. Employers in a State-plan state should check their State’s OSHA plan in addition to the federal references in 1910.1007 and 1910.1003.
Under 1910.1007, if a safety manager finds a material labeled as "dichlorobenzidine" without the prefix or exact naming, should they assume it’s covered by the listing?
You should treat substances identified as 3,'-Dichlorobenzidine or chemically equivalent names and their salts as within the scope of the listing at 1910.1007 until confirmed otherwise, and then consult the carcinogen provisions in 1910.1003 for required actions. When in doubt, confirm the chemical identity (for example, via manufacturer documentation or a qualified chemist) and apply the listed standard and related OSHA requirements.