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.

August 8, 1990

Mr. Thomas M. Snyder, C.I.H. Supervisor, Industrial Hygiene Deere & Company John Deere Road Moline, Illinois 61265-8098

Dear Mr. Snyder:

This is in response to your letter of April 11, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Laboratory Standard, 29 CFR 1910.1450. We apologize for the delay in response.

You stated your laboratories use various hazardous chemicals to perform routine, standardized tests which monitor and support production processes. Examples of your activities are metal analyses on steel and cast iron samples, concentration measurements of coolants for machining, and waste water analyses.

Your first question asks whether these labs must comply with 29 CFR 1910.1450. The answer is no. Since they are routine, standardized tests which monitor and support production processes and therefore can be considered as quality control, they are not covered under the standard.

Question 2 concerns non-routine, non-production-related tests to be performed using the laboratory's sophisticated analytical instruments. You asked whether this occurrence would initiate and require compliance with 29 CFR 1910.1450. The answer is yes.

If you need further assistance, please feel free to contact us again.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

April 11, 1990

Mr. Charles Adkins, Director Directorate of Health Standards USDOL/OSHA Room N3718 Washington, D.C. 20210

SUBJ: Occupational Exposure to Hazardous Chemicals in Laboratories

Dear Mr. Adkins:

Deere & Company is a manufacturer of agricultural, industrial,and consumer products. We have manufacturing facilities in several states with the Corporate Headquarters in Moline, Illinois. All of our factories have laboratory operations. They have asked me to request your interpretation regarding who must comply with 29 CFR 1910.1450.

Our laboratories use various hazardous chemicals to perform routine, standardized tests which monitor and support production processes. The following examples illustrate our activities: metals analyses on steel and cast iron samples; concentration measurements of coolants for machining; and waste water analyses.

Question 1: In consideration of the described activities, must these labs comply with 29 CFR 1910.1450?

Question 2: Many of our labs possess sophisticated analytical tools. The opportunity exists for a non-routine, non-production related test to be performed. Would this occurrence initiate and require continued compliance with 29 CFR 1910.1450?

We appreciate your consideration of these questions. If you wish to discuss this further, please contact me at (309) 765-2775.

Thomas M. Snyder, C.I.H. Supervisor, Industrial Hygiene

cc: John Martonik, Deputy Director - Directorate Health Standards