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OSHA Hazard Communication Letters of Interpretation
Exemption of hazardous waste samples sent to a laboratory for analysis from the Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Conditional RCRA hazardous-waste exclusion generally retained
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its conditional HazCom conclusion remains consistent with the current hazardous-waste exclusion: the waste must be defined as hazardous under the cited RCRA framework and be subject to EPA regulations under that Act.
A sample is not exempt merely because it is called waste or goes to a laboratory. The manifest and disposal-preparation facts below belong to the letter's particular case. The HCS exclusion does not remove applicable EPA, transport, laboratory, or HAZWOPER requirements; determine their scope separately. This assessment does not decide a particular sample's current EPA regulatory status.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 17, 1988
Lawrence B. Maglin, CSM, CSSP LBM
Safety Consultants
90 Perkins Avenue South
Hamilton, Massachusetts 01982
Dear Mr. Maglin:
This is in reply to your letter concerning the hazardous waste exemption of the Hazard Communication Standard as applied to samples of the waste sent to a laboratory for analysis.
Since the laboratory analysis is part of the preparation for the disposal of the chemicals and the waste manifest accompanies the sample bottles to the laboratory, it would, therefore, still be considered hazardous waste. Such samples would be exempted from coverage under the Hazard Communication Standard, if the waste is defined as a hazardous waste by the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, when subject to regulations issued under that Act by the Environmental Protection Agency.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: conditional hazardous-waste exclusion. Verify both the RCRA definition and applicable EPA regulation; a laboratory destination or manifest alone is not a universal HCS exemption.]
Please contact this office if we can be of further assistance.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-08-17.