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OSHA Hazard Communication Letters of Interpretation
"Laboratory setting" and subsequent requirements for Hazwoper.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Actual release and task determine response coverage; laboratory rules may also apply
This letter compares the obsolete 1987 HCS with HAZWOPER. Its central HazCom point remains useful: incidental spill cleanup is not automatically emergency response, but workers still need applicable hazard information, training and protective equipment. A laboratory label or waste permit alone does not settle coverage.
Use current release definitions, covered TSD operations, and emergency response with their exact scope conditions. For qualifying laboratory use, consider Laboratory Standard scope and training as well as applicable laboratory HazCom duties. The original does not make a definitive finding about the described site; neither does this comparison. California workplaces also require review of current Cal/OSHA coverage.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
November 15, 1990
Mr. Donald F. Bates
Head, Environmental Health & Safety
HUGHES Santa Barbara Research Center
75 Coromar Drive
Goleta, California 93117
Dear Mr. Bates:
This in an update to our response to your inquiry requesting interpretation of OSHA's final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120 [ILPI: Original 1989 HAZWOPER context (PDF) · Current HAZWOPER]).
Your letter does not provide sufficient facts upon which to render a determinative answer to your questions whether your "laboratory setting" is covered under the emergency response section of the standard.
If your "laboratory setting" is not within the confines of the treatment, storage and disposal (TSD) operations and deals with incidental release of hazardous substances, it is not considered to be an emergency response within the scope of 29 CFR 1910.120 [ILPI: Original 1989 HAZWOPER context (PDF) · Current HAZWOPER]. Such employees, however, must have the proper equipment and training under other OSHA standards such as the Hazard Communication Standard (29 CFR 1910.1200) [ILPI: Original HCS 1987 context (PDF) · Current HCS] to handle this type of incident. If the release poses an emergency then you must comply with the training provision of the standard (29 CFR 1910.120(q) [ILPI: Original 1989 HAZWOPER context (PDF) · Current HAZWOPER]). When determining whether a situation constitutes an emergency the key factor which must be considered on a case-by-case basis is the actual or estimated exposure or degree of danger to responders, other workers, neighbors, etc. In order to determine this, other factors such as the size of the spill, the material spilled, and the location of the incident (e.g., confined space) play a significant role.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: emergency/incidental definition, TSD scope, and response duties. Evaluate the actual operation and release; no uniform spill-volume or laboratory-name exemption is established.]
If the laboratory setting is within the confines of the TSD operations then the training provisions of (p) apply.
The State of California has administered its own occupational safety and health program since 1973, under the provisions of the Occupational Safety and Health Act of 1970. As part of that program, the State is responsible for the enforcement of occupational safety and health standards in the State of California, subject to monitoring by the Federal Occupational Safety and Health Administration (OSHA).
I hope that this helps in your concern.
Sincerely,
Gerard F. Scannell
Assistant Secretary
August 3, 1990
Mr. Gerald F. Scannell
Assistant Secretary of Labor
Occupational Safety and Health
Department of Health Services
200 Constitution Ave., N.W.
Washington, D.C. 20001
Dear Mr. Scannell:
I am writing to get an interpretation of 1910.120 [ILPI: Original 1989 HAZWOPER context (PDF) · Current HAZWOPER] to a work situation which I have. My need is brought about (besides my wishes to abide by the regulations) because two different vendors of training have told me two ifferent things. One vendor has told me that I needed the 8 hour training while another has told me that I needed the 24 hour training. I believe the regulations could be interpreted that training under 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS] is the applicable training.
This guide to safer laboratories and maker spaces is just one of many lab and safety items available at Safety Emporium.
The work situation is this. The work is performed in a laboratory setting within a fume hood. The workers use a 4% solution of Bromine in the job they are doing and when they are through they reduce the Bromine to the Bromide by the use of Sodium Thiosulfate. They do occasionally overfill the container they put this mixture in and are expected to clean it up.
What may complicate things is that we are permitted as a TSD facility. We permitted ourselves as a TSD facility to allow us the latitude to store hazardous waste for more than 90 days and to cover the "treatment" noted above.
We would appreciate your response as to which training is appropriate based upon the scenario presented. We would like an answer by early September.
Thanking you in advance for your efforts in responding to my dilemma.
Sincerely,
SANTA BARBARA RESEARCH CENTER
Donald F. Bates,
Head Environmental Health & Safety
DFB/dm
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1990-11-15.