From: Allen Niemi <anniemi**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] OSHA LAB Standard applicability
Date: Wed, 30 Mar 2016 14:47:01 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAN0bzO5vy-m0M35KdR=CiV2Qm-zVwVuoTnrpwngTSH1kKRBxiQ**At_Symbol_Here**

The lab standard requires written SOPs but the hazcom standard does not. This interpretation seems to imply that one does not need to address hazards other than acute or chronic health effects (and asphyxiation) in an SOP. That does not make any sense to me. I would expect ALL hazards related to a procedure to be addressed in the SOP, including compressed gas hazards.


On Wed, Mar 30, 2016 at 1:52 PM, Funck, Steven <sfunck**At_Symbol_Here**> wrote:

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


Allen Niemi, PhD
Occupational Safety and Health Services
Room 322 Lakeshore Center
Michigan Technological University
Phone: 906-487-2118
Fax: 906-487-3048

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