Steven,

Without all of the information one cannot make a sound decision.

The Laboratory Standard supersedes all Subpart Z requirements with the exceptions as listed in 1450(a)(2). The incorporation of GHS into the Lab Standard may have rendered that 2008 letter moot, but I would have to know the situation to which you’re operating. Note that simple asphyxiants are mentioned under the definition of “hazardous chemical” in the lab standard.

You need to follow requirements of Hazard Communication (29CFR1910.1200) or the Laboratory Standard (29CFR1910.1450), but not both.

Harry

Hello all:  Our Compliance Coordinator and I were working on a question concerning proper compressed gas storage and ran across the following quote from an OSHA interpretation in 2008.  While this pertains to a compressed gas question the comment implies that chemicals which are not listed as hazardous are not covered by the lab standard.  How can that be?  The implications of this is that all chemicals in a lab would have to be classified as either under the standard or not.  Does anyone have thoughts on this. 

“You stated in your letter that you are using these cylinders in a laboratory environment. OSHA's laboratory standard, =A71910.1450, Occupational exposure to hazardous chemicals in laboratories, defines "hazardous chemical" as one that has been established to produce acute or chronic health effects in exposed employees. While methane is an asphyxiant, it does not produce the acute or chronic health effects described in 1910.1200 Appendix A to which the lab standard refers. However, methane does present an explosion or flammability hazard. Therefore, OSHA's Hazard communication standard, =A71910.1200, would apply.”

Steven S. Funck, MS, CSMM

Natural Sciences Laboratory Program Manager

Messiah College

One College Ave.

Suite 3049

Mechanicsburg, PA 17055

Phone:  (717) 796-1800 (ext. 2079)

Fax: (717) 691-6046

SFunck**At_Symbol_Here**messiah.edu