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Title: 01/17/1991 - Chemical manipulation, production, multiple uses of chemicals in QC Labs | |
Record Type: Interpretation | Standard Number: 1910.1450; 1910.1200 |
January 17, 1991
Mr. Thomas Ozimek
Industrial Hygiene Supervisor
BASF Corporation
1609 Biddle Avenue
Wyandotte, Michigan 48192
Dear Mr. Ozimek:
This is in response to your letter of October 17, 1990, to OSHA's Region V Office, requesting interpretations on the Laboratory Standard, 29 CFR 1910.1450. Your letter has been forwarded to the National Office for response. We apologize for the delay.
Your questions and our answers are as follows:
If making secondary standards is part of the quality control of a production process, the Laboratory Standard would not be applicable. If blending operations result in a product, they would be considered as production processes and not be within the scope of the Laboratory Standard.
Your letter also addressed a concern that QC labs have limited coverage under 29 CFR 1910.1200, and no coverage under the laboratory standard. We are enclosing pages A-3 and A-4 of the updated Hazard Communication directive, CPL 2-2.38C for your information. The coverage of laboratories is limited under the Hazard Communication Standard (HCS) because it was expected that most laboratories would be covered by the Laboratory Standard. However, the directive does state that QC laboratories would generally be covered by the HCS. Please note that in the previous directive, there was no reference to limited coverage of QC labs under HCS as you had inferred. We hope we have adequately addressed your concerns. If we can be of further assistance, please do not hesitate to contact us. | Mix things up around the lab with automatic shakers from Safety Emporium. |
Patricia K. Clark, Director
Directorate of Compliance Programs
Enclosure
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20164&p_text_version=FALSE