Response: OSHA's Laboratory standard, 29 CFR 1910.1450, covers laboratories meeting the criteria of "laboratory use" and "laboratory scale" but excludes procedures that are part of a production process. See 1910.1450(b) (definition of "Laboratory use of hazardous chemicals"). Research and academic laboratories meeting these criteria are covered by the Laboratory standard and are not covered under the HCS 2012.

The Laboratory standard requires that labels on incoming containers of hazardous chemicals not be removed or defaced, per paragraph 1910.1450(h)(1)(i), but does not have a specific labeling requirement for secondary containers of hazardous chemicals in a covered laboratory. The Laboratory standard allows laboratories flexibility in tailoring their written Chemical Hygiene Plan (CHP) and standard operating procedures to be protective of employees in laboratories. See 29 CFR 1910.1450(e). In addition, 1910.1450(f)(4), Training, requires the employer to train employees regarding the physical and health hazards of chemicals in the work area, the measures employees can take to protect themselves from these hazards, and the employer's CHP.

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On January 22, 2013, OSHA published an updated Appendix A (non-mandatory) to 1910.1450 to assist employers in developing an appropriate CHP. The non-mandatory recommendations were based on the National Research Council's (NRC) 2011 edition of "Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards," and include recommendations for labeling secondary containers. Appendix A to 1910.1450 can be found on OSHA's website at http://www.osha.gov.

If your facility or a non-laboratory portion of your facility is not covered by the Laboratory standard, the HCS 2012 paragraph 1910.1200(f)(6), Workplace labeling, provides employers with flexibility when labeling hazardous chemicals in the workplace. Employers can provide either all of the required information that is on the label from the chemical manufacturer or the product identifier and words, pictures, symbols or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals. See 1910.1200(f)(6)(i) and (ii). In addition, employers are required to train their employees on workplace labeling systems as well as labels received on shipped containers which comply with the HCS 2012 per paragraph 1910.1200(h)(3)(iv).