From: Eileen Mason <lnmsn8**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] Why are QC/Qa labs not covered by the Lab Standard?
Date: Thu, 4 Feb 2016 12:52:35 -0600
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAHoM=hsV1TZrpre6g0NwLY+Fk-hJgvJpVrP_=tKzX-U5nE5z8w**At_Symbol_Here**

Not only do QC labs support production, but typically the same tests are done in the same way every time using well-characterized materials.

The lab standard was primarily designed to address the hazards of small amounts of many chemicals, which are often poorly characterized. Consider the latest offering of that organic research lab: Eureka! a new compound! Not only has there been insufficient time for extensive testing, the sample size does not permit it. Because hazards may not be known, the lab standard requires medical consultations for exposure. This does not apply to production chemicals, since TSCA requires a certain amount of testing before a compound may be offered for sale.

Engineering controls used in production may be infeasible, due to the small amounts and variability of substances in use in laboratories. Hence the emphasis on hoods, glove boxes and other containment measures that can be applied to many materials..

Note that the lab standard does not relieve an employer from the requirements of HazCom and pertinent exposure limits, although the limited quantities in use may make many exposure limits meaningless.

Remember that employer practices must be AT LEAST as effective as OSHA standards. There is no prohibition against being MORE protective. OSHA regulations represent the MINIMUM legally acceptable practice.

On Thu, Feb 4, 2016 at 11:17 AM, James Wright <jhwright**At_Symbol_Here**> wrote:
UCLA was cited four times for non-compliance with the lab standard (Title 8 5191) in 2009 by Cal/OSHA.
Also this citation was discussed by Jyllian Kemsley ( ) because of one of the citations related to the previous CHO being deemed unqualified.

The best rationale I can think of that QC/QA could be argued as part of the production process. As part of the production process it does not meet the definition of laboratory use of hazardous chemicals.

James H. Wright, PhD
Chemical Safety Officer
The University of Chicago
Office of Research Safety
5730 S. Ellis Ave, Crerar Library Rm 018
Chicago, IL 60637
Phone: (773)702-5907

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of Stuart, Ralph
Sent: Thursday, February 04, 2016 10:28 AM
Subject: Re: [DCHAS-L] Why are QC/Qa labs not covered by the Lab Standard?

> >I do not understand the point of the distinction. The end result would be to bind QC/QA labs to the OSHA regulations for large production level quantities of chemicals.
I think that this is a distinction without a difference. As far as I can tell, OSHA has not cited anyone under the lab standard for at least 10 years, if ever (I've asked OSHA for an instance and they couldn't come up with one). As discussed at
even OSHA citations that involve lab operations use more generic standards such as the HazCom or PPE requirements rather than the lab standard, most likely for simplicity of the enforcement adminstration.

With this in mind, if you have a operation that meets the OSHA definition of lab scale and you feel that a Chemical Hygiene Plan approach will improve your safety program, I would write a CHP that addresses lab safety for your operations. This effort can only add value to a regulatory interaction with OSHA involving those operations. An example of such an operation could be an art studio that operates with small enough amounts of chemicals to be considered lab scale. I would note that I have seen many art studios that wouldn't meet that definition and/or have other hazards that wouldn't be included in a CHP (e.g. welding).

Thanks for any interesting question.

- Ralph

Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College


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