One of my clients had a lab with a walk-in hood that used 55-gallon drums as feed containers for the test apparatus in the hood.  A drum can be handled by a single person and they applied the Lab Standard to the entire lab.  I read the regulation to allow real employer flexibility, as long as you clearly define parameters in the documentation.

NL

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

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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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