There are few epidemiologic data available to address the question of potential carcinogenic effects of hydrogen chloride (HCl) exposure on humans. An opportunity arose to augment a nominal HCl exposure classification that had been done earlier for a nested case-control study of lung cancer among a cohort of chemical manufacturing employees. Working from first-hand knowledge of the relevant chemical processes and limited HCl monitoring data, a certified industrial hygienist estimated average exposures for each of the job assignments of 308 lung cancer cases and 616 comparison workers. The risk of lung cancer was then analyzed in relation to several measures of HCl exposure, including duration, a cumulative exposure score, highest average exposure, and latency. None showed evidence of an association between HCl exposure and lung cancer. This is consistent with the limited rodent bioassay data, which also failed to find a tumorigenic response from HCl. Thus, even at high level occupational exposures (up to 3000 micrograms/m3 for several years) there is no evidence that HCl is a human carcinogen.