Do you fall under the Laboratory standard or the HazCom standard?

If your facility has a laboratory, it’s easy to assume you fall under OSHA’s Laboratory standard at 29 CFR 1910.1450. However, this may not be the case. The Laboratory standard only applies in certain circumstances; instead, you may be covered by the Hazard Communication (HazCom) standard at 29 CFR 1910.1200.

How do you know?

OSHA says in a letter of interpretation that laboratories covered under the Laboratory standard are those that 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 available and in common use to minimize the potential for employee exposure to hazardous chemicals.

Making the determination

To help you make sense of the conditions outlined above and determine which standard is applicable, let’s take a closer look at some terms as they’re defined in the Laboratory standard at 1910.1450(b).

Hazardous chemical means any chemical which is classified as a health hazard or simple asphyxiant in accordance with the Hazard Communication standard (1910.1200).

Laboratory means a facility where the “laboratory use of hazardous chemicals” occurs. It’s a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.

Laboratory scale means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. “Laboratory scale” excludes those workplaces whose function is to produce commercial quantities of materials.

Laboratory use of hazardous chemicals means handling or use of such chemicals in which all of the following conditions are met:

(i) Chemical manipulations are carried out on a “laboratory scale;”

(ii) Multiple chemical procedures or chemicals are used;

(iii) The procedures involved are not part of a production process, nor in any way simulate a production process; and

(iv) “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

Protective laboratory practices and equipment means those laboratory procedures, practices and equipment accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals.

Other exclusions apply

The Laboratory standard does not apply to laboratory use of hazardous chemicals which provide no potential for employee exposure. Examples include the use of test media such as “dip and read” tests or commercially prepared pregnancy tests.

Laboratories considered quality control/quality assurance laboratories are classified as adjuncts of production operations and are covered under the HazCom standard rather than the Laboratory standard.

Final thoughts

Employers don’t necessarily fall under the Laboratory standard if they have a laboratory in their facility. OSHA’s “laboratory use of hazardous chemicals” definition can help you determine which standard is applicable to your workplace: 1910.1200 or 1910.1450.