Date: Fri, 7 Dec 2007 10:15:04 -0600
Reply-To: "Greene, Benjamin (WSTF-1333)[HON]" <benjamin.greene-1**At_Symbol_Here**NASA.GOV>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Greene, Benjamin (WSTF-1333)[HON]" <benjamin.greene-1**At_Symbol_Here**NASA.GOV>
Subject: Lab Standard versus Hazcom - not again
In-Reply-To: <20061017162205.xabzqz9hr8kk0kw0**At_Symbol_Here**>

Dear Colleagues - In comparing the lab standard (1910.1450) with the hazard communication standard (1910.1200), especially the specific provisions for laboratory workers found under 1910.1200(b), I have a few questions I wonder how others are handling (background is below): Question 1. How can Hazcom apply to labs when the lab standard specifically states 1910.1450(a)(2) Where this section applies, it shall supersede, for laboratories, the requirements of all other OSHA health standards in 29 CFR part 1910, subpart Z, except as follows... Question 2. Is Hazcom not superseded by the lab standard (and if it is, how can the rules for laboratory workers under Hazcom be applied)? Question 3. Laboratory employees do not have to know the location and availability of the written hazard communication program under 1910.1200(h)(2)(ii), but are they required to know the rest of 1910.1200(h)(2)(ii) "...including the required list(s) of hazardous chemicals, and material safety data sheets required by this section"? There appears to be a conflict between the preamble p_id=933 OSHA 3111 "Hazard Communication Guidelines for Compliance". 1910.1200(b)(3) This section applies to laboratories only as follows: 1910.1200(b)(3)(i) Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced; 1910.1200(b)(3)(ii) Employers shall maintain any material safety data sheets that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible during each workshift to laboratory employees when they are in their work areas; 1910.1200(b)(3)(iii) Employers shall ensure that laboratory employees are provided information and training in accordance with paragraph (h) of this section, except for the location and availability of the written hazard communication program under paragraph (h)(2)(iii) of this section; Ok. 1910.1200 b(3)(i) is identical to 1910.1450(h)(1)(i) 1910.1200 b(3)(ii) is close but not verbatim and more stringent than 1910.1450(h)(i)(ii) 1910.1200 b(3)(iii) information and training requirements correlate well with 1910.1450(f) information and training requirements The preamble p_id=933 to 1910.1200 states: "Laboratory coverage. The current HCS limits coverage of laboratories (paragraph (b)(3)), simply requiring that labels be kept on containers that are received labeled; that material safety data sheets which are received be kept, and employees be given access to them; and that employees be trained in accordance with paragraph (h) of the rule. Paragraph(h)(2)(iii) states, among other things, that employees are to be informed of the location and availability of the written hazard communication program. Since laboratories are not required to have written hazard communication programs, this part of the information and training program would not apply to these types of facilities. Although this would appear to be evident, OSHA has received a number of questions regarding this, so the provision has been modified to clarify that the location and availability of the written hazard communication program does not have to be addressed in the laboratory training program. The location and availability of material safety data sheets, which is also currently addressed under paragraph (h)(2)(iii), would still have to be included in the training program." By way of information, OSHA Publication 3111 "Hazard Communication Guidelines for Compliance" states (regarding laboratories) "Employers do not have to have written hazard communication programs and lists of chemicals for these types of operations."

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