Ben, The way that we have interpreted this issue is that for all labs that utilize chemicals on lab scale and use OSHA standard 29 CFR 1910.1450 applies and only the Chemical Hygiene Plan would be implemented and lab employees would be trained on the Chemical Hygiene Plan. For all other departments that do not fall into the above category (e.g. Maintenance, Custodial staff) OSHA standard 29 CFR 1910.1200 would apply and a Hazardous Communication plan would be implemented and those employees would be trained on Hazardous Communication plan. This OSHA letter of interpretation may be helpful as it basically says that you can develop a comprehensive Chemical Hygiene plan to cover both standards. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETA TIONS&p_id 255 I hope this helps. Regards, Jason Jason Burrill Manager, Histology Charles River Laboratories 251 Ballardvale Street Wilmington, MA 01887 Ph: 781-222-6152 Fax: 978-988-8793 jason.burrill**At_Symbol_Here**crl.com **Please note new direct dial telephone number** -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Greene, Benjamin (WSTF-1333)[HON] Sent: Friday, December 07, 2007 11:15 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] Lab Standard versus Hazcom - not again 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 Is Hazcom not superseded by the lab standard (and if it is, how can the rules for laboratory workers under Hazcom be applied)?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 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES& p_id=933 OSHA 3111 "Hazard Communication Guidelines for Compliance". http://www.osha.gov/Publications/osha3111.html 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 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES& 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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