Looks like specific amounts were specifically considered and rejected. Maybe this will help?
Sammye

From the Final Rule 55 FR 3300.

The final standard revises the definition slightly to eliminate the requirement that containers be manipulated manually. Several commenters (see Exs. 8-112 and 10-2) pointed out that laboratory work frequently involves automated procedures. It was not OSHA's intention to exclude such operations from coverage. Other comments (Exs. 4-45, 8-50, and 8-64) suggested that the definition be amended to allow for non-routine tasks such as assistance from co-workers in handling 5-gallon drums and gas cylinders used in laboratory operations. As pointed out in the preamble to the proposed standard at 51 FR at 26673, the intent of the definition is not to exclude the use of facilitative mechanical aids when needed (and similarly would not preclude the assistance of co-workers when necessary).

A definition of �??laboratory scale�?? is included in the proposed standard. The purpose of this definition is to focus on the magnitude of the operations which are covered. OSHA rejected the option to specify quantity limits as criteria for �??laboratory scale,�?? realizing that any limit specified would be arbitrary. However, the concept of quantity is
certainly relevant. Therefore, the most reasonable approach is to define laboratory scale in relation to the size of containers used in reactions, transfers and other operations and, in general terms, to the quantity of materials handled. Consequently, �??laboratory scale�?? refers to work in which the containers used are designed to be easily and safely manipulated by a single individual. The definition is not intended to exclude the use of facilitative mechanical aids such as dollies which are often used m the transfer of gas cylinders. However, the intent is to exclude those reactions, transfers and other operations which normally can only be accomplished through the use of mechanical aids.
Moreover, quantities which are clearly related to production processes should place the workplace under the General Industry Standards.

All

Sorry.� Maybe I wasn�??t clear.� � My questions is more around what size/volume(s) can you really no longer apply the lab standard.� � It would also relate to type of processes.� � � For example, a �??laboratory�?? that is not �??production�?? but using 5, 10 or larger gallon containers�?|�?|.that still can be manipulated by a single person�?|.

An example could be a lab making clinical batches�?|.etc.� � � � The folks in the larger volume �??lab�?? would be scientist with equal expertise and experience to a normal (smaller quantity) research �??lab�??.

Thanks

�

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Kolodziej, Christopher
Sent: Friday, January 7, 2022 11:53 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Lab Standard vs HazCom

�

CAUTION!� Please do not click links or open attachments unless you recognize the sender,� this email is from an External Sender (outside Boehringer-Ingelheim)

Ralph, I think you�??re correct in terms of the rationale for the Lab Standard, even if they�??re not fully expressed in its text. Fred Malaby wrote a bit about how the ideas of laboratory researchers as experts, and the transient nature of their work, contributed to its development in his 2016 reflection on the history of the Lab Standard (https://doi.org/10.1016/j.jchas.2015.10.015). I also think that the condition that �??Multiple chemical procedures or chemicals are used�?? at least points in the direction of changing processes.

�

As for Bill�??s original question regarding specific volume or weight cutoffs, I�??m not aware that any regulatory agency has ever published anything definitive, and I don�??t expect they have any interest in doing so. In my mind, 5 gal is a good rule of thumb, but I can easily imagine exceptions to that in both directions.

�

�

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

�

Mobile: (310) 261-8611

Book a virtual appointment

�

-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ralph Stuart
Sent: Friday, January 7, 2022 7:19 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Lab Standard vs HazCom

�

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

>

This is a more interesting question than I thought. I had thought another piece of the definition of a laboratory included changing chemical processes and an educated workforce. Evidently, I moved the idea that the lab workforce has special chemical safety expertise from the definition of the CHO to that of the lab as a whole in my mind.

�

Anyway, I can imagine writing the CHP for the lab in a way that includes the lab staff's chemical safety expertise into this boundary you are exploring.

�

- Ralph

�

Ralph Stuart, CIH, CCHO

ralph**At_Symbol_Here**rstuartcih.org

�

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