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Title: 05/28/1999 - Applicability of the Laboratory Standard; MSDS and labeling requirements. | |
Record Type: Interpretation | Standard Number: 1910.1450(a); 1910.1200(g); 1910.1200(f)(1) |
May 28, 1999
Ms. Maricela Carter
Baker Hughes; Baker Petrolite
Safety Programs
3900 Essex Lane
Houston, TX 77027
Dear Ms. Carter,
We have received your September 15, 1998 letter to Richard Fairfax, Director, Occupational Safety and Health Administration (OSHA) Directorate of Compliance Programs (DCP), in which you asked questions regarding the classification of your laboratory under the Hazard Communication Standard (HCS), 29 CFR 1910.1200, or the Chemical Hygiene Standard, 29 CFR 1910.1450. Your inquiry can be summarized into two questions, which are outlined below.
The best way to approach this question is to provide you with further information to allow you to make this determination, as we are not familiar with your work processes. Laboratories considered quality control/quality assurance laboratories are classified as adjuncts of production operations and are not covered under the Laboratory Standard, but are covered under the HCS. For those laboratories covered under the Laboratory Standard, the requirements of the HCS are superseded, and the Laboratory Standard takes precedence. Laboratories covered under the Laboratory Standard are those which use or handle hazardous chemicals in which all of the following conditions are met:
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The Laboratory Standard does not apply to laboratory use of hazardous chemicals which provide no potential for employee exposure. Examples of these would be the use of test media such as "dip and read" tests or commercially prepared pregnancy tests.
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Sincerely,
Richard Fairfax
Director
Directorate of Compliance Programs
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=22745&p_text_version=FALSE