Additional details on monitoring and substance specific standards and 
how they apply to the Lab Standard.

_Section a_ of the Lab Standard states that the provisions of "substance 
specific standards" (e.g., benzene) do not apply in labs, except to 
prohibit skin and eye contact and to limit employee exposure to the 
specific permissible exposure limits.  In other words, the employer must 
implement controls such as work practices, PPE (eye protection, gloves) 
and engineering controls (fume hoods), to prevent eye and skin contact 
and to limit exposure via inhalation.

Air monitoring is /not /required unless there is /reason to believe/ 
that the action level (normally 1/2 the PEL) could be exceeded. This is 
stated in _Section d _of the Lab Standard.

_Section a_ of the Lab Standard also states that if the action level for 
that substance is /routinely exceeded,/ then the full blown air 
monitoring and medical surveillance requirements of the applicable 
standard apply.

So the approach used in labs is more risk based than in industrial 
environments.

Hope this helps.

Larry

Russ Phifer wrote:
> 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’s 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’t have a
> Chemical Hygiene Plan, then you don’t 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….
>
>  
>
> 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."
>
>  
>
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>  
>
>
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