Ben - There are several instances where all the requirements of the Hazard Communication Standard can apply to a laboratory - for instance, when it manufactures chemicals or is a quality control lab. The strict definition of a laboratory has been clarified/ interpreted many times by OSHA. There are also labs that may have to comply with both standards due to the nature of their operations. The laboratory standard does not supercede all requirements of the hazard communication standard. Laboratories still must protect employees to PEL limits and protect from eye & skin exposures. It also requires monitoring whenever an individual standard requires monitoring. Other than those requirements, though, the Lab Standard DOES supercede the Hazard Communication Standard for laboratories. The main differences in my mind between the two standards are how information & training must be provided. When you reference 1910.1200(b) - that=92s a pretty big section - most of it has to do with MSDS management and employee information. Those aspects are clearly supplanted by the Lab Standard. (Of course, if you don=92t have a Chemical Hygiene Plan, then you don=92t qualify for ANY of the conditions for alternate compliance presented under the Lab Standard.) In effect, a CHP becomes your regulations - the policies and procedures your employer and employees need to follow. As to why the Hazard Communication Standard repeatedly references lab workers - 1910.1200 pre-dates 1910.1450 by a number of years, and 1910.1200 was never amended to remove laboratory references. Hope this helps=85. Russ Phifer Russ Phifer WC Environmental, LLC PO Box 1718, 1085C Andrew Drive West Chester, PA 19380 610-696-9220x12/ fax 610-344-7519 HYPERLINK "mailto:rphifer**At_Symbol_Here**wcenvironmental.com"rphifer**At_Symbol_Here**wcenvironmental.com P Please consider your environmental responsibility before printing this e-mail or any other document -----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." No virus found in this incoming message. Checked by AVG Free Edition. Version: 7.5.503 / Virus Database: 269.16.17/1176 - Release Date: 12/6/2007 11:15 PM No virus found in this outgoing message. Checked by AVG Free Edition. Version: 7.5.503 / Virus Database: 269.16.17/1176 - Release Date: 12/6/2007 11:15 PM
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