> >I do not understand the point of the distinction. The end result would be to bind QC/QA labs to the OSHA regulations for large production level quantities of chemicals.
>
I think that this is a distinction without a difference. As far as I can tell, OSHA has not cited anyone under the lab standard for at least 10 years, if ever (I've asked OSHA for an instance and they couldn't come up with one). As discussed at
https://urldefense.proofpoint.com/v2/url?u=http-3A__cenblog.org_the-2Dsafety-2Dzone_2016_01_trimethylaluminum-2Dexplosion-2Dat-2Ddow-2Dfacility-2Din-2Dmassachusetts_&d=BQIFAg&c=lb62iw4YL4RFalcE2hQUQealT9-RXrryqt9KZX2qu2s&r=meWM1Buqv4IQ27AlK1OJRjcQl09S1Zta6YXKalY_Io0&m=wuNl3uYe9LIMs9oeFvmXKzS-SU2a0-FRVulm5vi1Sa4&s=9V3hZp63hxnjw48r5rZY47JdNbfcdXdeanGBaEwxGK4&e=
even OSHA citations that involve lab operations use more generic standards such as the HazCom or PPE requirements rather than the lab standard, most likely for simplicity of the enforcement adminstration.

With this in mind, if you have a operation that meets the OSHA definition of lab scale and you feel that a Chemical Hygiene Plan approach will improve your safety program, I would write a CHP that addresses lab safety for your operations. This effort can only add value to a regulatory interaction with OSHA involving those operations. An example of such an operation could be an art studio that operates with small enough amounts of chemicals to be considered lab scale. I would note that I have seen many art studios that wouldn't meet that definition and/or have other hazards that wouldn't be included in a CHP (e.g. welding).

Thanks for any interesting question.

- Ralph

Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College

ralph.stuart**At_Symbol_Here**keene.edu

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