I think this discussion misses the point a bit. I have seen numerous research laboratories that use drums to feed or collect products from hoods. Not terribly common certainly but not that uncommon. I do not think the size of the container(s) have any relevance to is it or is it not a laboratory.

The question I thought I read was is an organization that does large volumes of commercial tests in a laboratory setting a laboratory. (Think a lab that runs thousands of Covid tests each day or hundreds of ASTM tests a day.) No research is done. To me these are still laboratories as the work is done in a laboratory setting.

I agree the OSHA definition is a bit weak on what od but I suspect that we would all recognize the operation as a laboratory and so I would always follow and apply the lab standard.

My view for what it is worth.

Richard Palluzi

PE, CSP,FAIChE

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www.linkedin.com/in/richardppalluzillc/

Richard P Palluzi LLC

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