Ben,
The way that we have interpreted this issue is that for all labs that
utilize chemicals on lab scale and use OSHA standard 29 CFR 1910.1450
applies and only the Chemical Hygiene Plan would be implemented and lab
employees would be trained on the Chemical Hygiene Plan.  

For all other departments that do not fall into the above category (e.g.
Maintenance, Custodial staff) OSHA standard 29 CFR 1910.1200 would apply
and a Hazardous Communication plan would be implemented and those
employees would be trained on Hazardous Communication plan.

This OSHA letter of interpretation may be helpful as it basically says
that you can develop a comprehensive Chemical Hygiene plan to cover both
standards.
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETA
TIONS&p_id 255 

I hope this helps.

Regards,
Jason
 
Jason Burrill
Manager, Histology
Charles River Laboratories
251 Ballardvale Street
Wilmington, MA 01887
Ph: 781-222-6152
Fax: 978-988-8793
jason.burrill**At_Symbol_Here**crl.com 
**Please note new direct dial telephone number**

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Greene, Benjamin (WSTF-1333)[HON]
Sent: Friday, December 07, 2007 11:15 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Lab Standard versus Hazcom - not again

Dear Colleagues - In comparing the lab standard (1910.1450) with the
hazard communication standard (1910.1200), especially the specific
provisions for laboratory workers found under 1910.1200(b), I have a few
questions I wonder how others are handling (background is below):

Question 1.  How can Hazcom apply to labs when the lab standard
specifically states 

1910.1450(a)(2) Where this section applies, it shall supersede, for
laboratories, the requirements of all other OSHA health standards in 29
CFR part 1910, subpart Z, except as follows...

Question 2.  Is Hazcom not superseded by the lab standard (and if it is,
how can the rules for laboratory workers under Hazcom be applied)?

Question 3. Laboratory employees do not have to know the location and
availability of the written hazard communication program under
1910.1200(h)(2)(ii), but are they required to know the rest of
1910.1200(h)(2)(ii) "...including the required list(s) of hazardous
chemicals, and material safety data sheets required by this section"?
There appears to be a conflict between the preamble
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&
p_id=933 OSHA 3111 "Hazard Communication Guidelines for Compliance".
http://www.osha.gov/Publications/osha3111.html

1910.1200(b)(3)

This section applies to laboratories only as follows:

1910.1200(b)(3)(i)

Employers shall ensure that labels on incoming containers of hazardous
chemicals are not removed or defaced;

1910.1200(b)(3)(ii)

Employers shall maintain any material safety data sheets that are
received with incoming shipments of hazardous chemicals, and ensure that
they are readily accessible during each workshift to laboratory
employees when they are in their work areas;

1910.1200(b)(3)(iii)

Employers shall ensure that laboratory employees are provided
information and training in accordance with paragraph (h) of this
section, except for the location and availability of the written hazard
communication program under paragraph (h)(2)(iii) of this section; 

Ok.  

1910.1200 b(3)(i) is identical to 1910.1450(h)(1)(i)
1910.1200 b(3)(ii) is close but not verbatim and more stringent than
1910.1450(h)(i)(ii)
1910.1200 b(3)(iii) information and training requirements correlate well
with 1910.1450(f) information and training requirements

The preamble
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&
p_id=933 to 1910.1200 states: "Laboratory coverage. The current HCS
limits coverage of laboratories (paragraph (b)(3)), simply requiring
that labels be kept on containers that are received labeled; that
material safety data sheets which are received be kept, and employees be
given access to them; and that employees be trained in accordance with
paragraph (h) of the rule. Paragraph(h)(2)(iii) states, among other
things, that employees are to be informed of the location and
availability of the written hazard communication program. Since
laboratories are not required to have written hazard communication
programs, this part of the information and training program would not
apply to these types of facilities. Although this would appear to be
evident, OSHA has received a number of questions regarding this, so the
provision has been modified to clarify that the location and
availability of the written hazard communication program does not have
to be addressed in the laboratory training program. The location and
availability of material safety data sheets, which is also currently
addressed under paragraph (h)(2)(iii), would still have to be included
in the training program." 

By way of information, OSHA Publication 3111 "Hazard Communication
Guidelines for Compliance" states (regarding laboratories) "Employers do
not have to have written hazard communication programs and lists of
chemicals for these types of operations."

Previous post   |  Top of Page   |   Next post