Standard Interpretations - Table of Contents|
| Standard Number:||1910.1450(a); 1910.1200(g); 1910.1200(f)(1)|
May 28, 1999
Ms. Maricela Carter
Baker Hughes; Baker Petrolite
3900 Essex Lane
Houston, TX 77027
Dear Ms. Carter,
We have received your September 15, 1998 letter to Richard Fairfax, Director, Occupational Safety and Health Administration (OSHA) Directorate of Compliance Programs (DCP), in which you asked questions regarding the classification of your laboratory under the Hazard Communication Standard (HCS), 29 CFR 1910.1200, or the Chemical Hygiene Standard, 29 CFR 1910.1450. Your inquiry can be summarized into two questions, which are outlined below.
- Do our laboratories (including quality assurance laboratories) fall under the Chemical Hygiene Standard (29 CFR 1910.1450) or the Hazard Communication Standard (29 CFR 1910.1200)?
The best way to approach this question is to provide you with further information to allow you to make this determination, as we are not familiar with your work processes. Laboratories considered quality control/quality assurance laboratories are classified as adjuncts of production operations and are not covered under the Laboratory Standard, but are covered under the HCS. For those laboratories covered under the Laboratory Standard, the requirements of the HCS are superseded, and the Laboratory Standard takes precedence. Laboratories covered under the Laboratory Standard are those which use or handle hazardous chemicals in which all of the following conditions are met:
- Chemical manipulations are carried out on a "laboratory scale",
- Multiple chemical procedures or chemicals are used,
- The procedures involved are not part of a production process, nor in any way simulate a production process, and
- Protective laboratory practices and equipment are