First, the clarification letter from which that was taken was from 2008 (prior to implementation of HazCom 2012), so some of the regulations have changed. According to what I found, under HazCom 2012, cylinders of compressed gas are considered containers, physical hazards, and hazardous chemicals.
Here are my sources (all from OSHA’s documents):
1) According to this document about OSHA’s HazCom 2012 (https://www..osha.gov/dsg/hazcom/HCSFinalRegTxt.html) cylinders of compressed gas are considered under the definition of a “physical hazard”.
2) According to this document from OSHA (https://www.osha..gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf):
Gas cylinders are considered containers under GHS (p. 18 of the document, p. 23 of the pdf)
3) According to this document from OSHA (https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
“Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.”
Sarah Schlereth, MA, ALAT
Biology Lab Materials Manager
St. Louis College of Pharmacy
4588 Parkview Place
St. Louis, MO 63110
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
One College Ave.
Mechanicsburg, PA 17055
Phone: (717) 796-1800 (ext. 2079)
Fax: (717) 691-6046
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