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OSHA Hazard Communication Letters of Interpretation
Laboratory Standard's application in testing building products
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Research versus production distinction remains task-specific
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom distinction remains useful: research that qualifies as laboratory use differs from production or production-QC work, and a facility can contain more than one kind of operation. The original expressly declines a definitive site-specific determination.
Use current scope and laboratory-use/scale definitions, including all four laboratory-use conditions. Whether raw-material evaluation is research or part of production depends on the actual activity; the old example is not a categorical exemption for every small batch. Apply limited laboratory HazCom provisions where appropriate and full applicable HazCom duties for production/QC operations. No current coverage decision about the named facility is made here.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
January 16, 1991
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Mr. Norbert Kaleta
Group Manager
Gold Bond Building Products
Research Center
1650 Military Road
Buffalo, New York 14217
Dear Mr. Kaleta:
This is in response to your letter of November 27, 1990, regarding 29 CFR 1910.1450 [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard], commonly known as the Laboratory Standard. You stated in your letter that it is your interpretation that only your Analytical Laboratory meets the criteria of 29 CFR 1910.1450 while the other labs, Paper, Gypsum and Joint Compound are used to "simulate as production process" on a laboratory scale and are regulated under 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. In these labs current raw materials or proposed raw materials are evaluated for suitability on a lab scale. A product is formulated and tested for the appropriate characteristics.
Given the above information from your letter, we cannot provide you a definitive answer on the applicability of the Laboratory Standard [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard] to your facilities. If some of these laboratory functions are integral part of research and do not proceed onto production, these operations would be covered by the Laboratory Standard. In other words, laboratories that meet the definition of "laboratory scale" and "laboratory use" would be within the scope of the standard. Laboratories that are part of the production process or performing quality control of production would be covered by other appropriate general industry standards including 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. For example, evaluating the suitability of raw materials may be considered research. Once raw materials are selected and will be incorporated into the formulation of a product, the laboratory activities would be considered part of the production process and therefore not be within the scope of the Laboratory Standard.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: scope and all definition conditions. Assess the actual research/production activity; the original does not determine this facility's coverage conclusively.]
If we can be of further assistance, please do not hesitate to contact us.
Sincerely,
Patricia K. Clark, 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/1991-01-16.