From: "Gregory, Elizabeth" <egregory**At_Symbol_Here**BROCKPORT.EDU>
Subject: Re: [DCHAS-L] [NAOSMM] OSHA LAB Standard applicability
Date: Wed, 30 Mar 2016 18:11:26 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: uu3jcbsy8ufjv0h27vybfxu5.1459361602128**At_Symbol_Here**

I'm on vacation so I'm not looking up the regs, but I think that they are right in that if a chemical doesn't meet the OSHA definition of hazardous, we don't have to adhere to the lab standard rules for it.

That being said, we also don't have to NOT adhere to them. Best, easiest bet is to treat them all as if they did fall under it.

Sent from my Verizon Wireless 4G LTE smartphone

-------- Original message --------
From: "Funck, Steven" <sfunck**At_Symbol_Here**>
Date: 03/30/2016 1:52 PM (GMT-05:00)
To: naosmm**At_Symbol_Here**, DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Cc: "Fink, Donna" <dfink**At_Symbol_Here**>
Subject: [NAOSMM] OSHA LAB Standard applicability

Hello all:  Our Compliance Coordinator and I were working on a question concerning proper compressed gas storage and ran across the following quote from an OSHA interpretation in 2008.  While this pertains to a compressed gas question the comment implies that chemicals which are not listed as hazardous are not covered by the lab standard.  How can that be?  The implications of this is that all chemicals in a lab would have to be classified as either under the standard or not.  Does anyone have thoughts on this. 


"You stated in your letter that you are using these cylinders in a laboratory environment. OSHA's laboratory standard, =A71910.1450, Occupational exposure to hazardous chemicals in laboratories, defines "hazardous chemical" as one that has been established to produce acute or chronic health effects in exposed employees. While methane is an asphyxiant, it does not produce the acute or chronic health effects described in 1910.1200 Appendix A to which the lab standard refers. However, methane does present an explosion or flammability hazard. Therefore, OSHA's Hazard communication standard, =A71910.1200, would apply."


Steven S. Funck, MS, CSMM

Natural Sciences Laboratory Program Manager

Messiah College

One College Ave.

Suite 3049

Mechanicsburg, PA 17055


Phone:  (717) 796-1800 (ext. 2079)

Fax: (717) 691-6046



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