Date: Fri, 7 Dec 2007 11:50:53 -0500
Reply-To: Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Organization: WC Environmental, LLC
Subject: Re: Lab Standard versus Hazcom - not again
Comments: To: "Greene, Benjamin (WSTF-1333)[HON]"
In-Reply-To: <B9066CFAE511644CB27FB33279A6DAE47E6C0B**At_Symbol_Here**>

Ben -


There are several instances where all the requirements of the Hazard
Communication Standard can apply to a laboratory - for instance, when 
manufactures chemicals or is a quality control lab.   The strict 
of a laboratory has been clarified/ interpreted many times by OSHA.    
are also labs that may have to comply with both standards due to the 
of their operations.


The laboratory standard does not supercede all requirements of the 
communication standard.  Laboratories still must protect employees to 
limits and protect from eye & skin exposures.   It also requires 
whenever an individual standard requires monitoring.   Other than those
requirements, though, the Lab Standard DOES supercede the Hazard
Communication Standard for laboratories.  The main differences in my 
between the two standards are how information & training must be 
When you reference 1910.1200(b) - that=92s a pretty big section - 
most of it
has to do with MSDS management and employee information.  Those aspects 
clearly supplanted by the Lab Standard.  (Of course, if you don=92t have 
Chemical Hygiene Plan, then you don=92t qualify for ANY of the 
conditions for
alternate compliance presented under the Lab Standard.)  In effect, a 
becomes your regulations - the policies and procedures your employer 
employees need to follow.


As to why the Hazard Communication Standard repeatedly references lab
workers - 1910.1200 pre-dates 1910.1450 by a number of years, and 
was never amended to remove laboratory references.


Hope this helps=85.


Russ Phifer


Russ Phifer

WC Environmental, LLC

PO Box 1718, 1085C Andrew Drive

West Chester, PA  19380

610-696-9220x12/ fax 610-344-7519



P Please consider your environmental responsibility before printing this
e-mail or any other document


-----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

p_id=933 OSHA 3111 "Hazard Communication Guidelines for Compliance".





This section applies to laboratories only as follows:




Employers shall ensure that labels on incoming containers of hazardous

chemicals are not removed or defaced;




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;




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; 




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


1910.1200 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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