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OSHA Hazard Communication Letters of Interpretation
Chemical manipulation, production, multiple uses of chemicals in QC Labs
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Functional scope distinction retained; no blanket QC or environmental exemption
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom distinction remains useful: production/QC work is not automatically laboratory use, and excluding an operation from the Laboratory Standard does not remove other employee-protection duties.
Apply all current laboratory-use and laboratory-scale conditions and scope. Environmental analysis may qualify when it is not used to control production and all other conditions are met. Making a small blend or analytical standard is not decided solely by its name; the role of the operation matters. Read the old broad production examples with those definitions, not as an automatic exclusion of all research.
Current laboratory HazCom limits are not a blanket reduction for production QC labs. Use the current HCS, current HCS inspection procedures, and where applicable the Laboratory Standard's Chemical Hygiene Plan/training duties. The original historical directive is original CPL 2-2.38C (October 22, 1990). Current enforcement counterpart: current HCS inspection procedures.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 17, 1991
Mr. Thomas Ozimek
Industrial Hygiene Supervisor
BASF Corporation
1609 Biddle Avenue
Wyandotte, Michigan 48192
Dear Mr. Ozimek:
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This is in response to your letter of October 17, 1990, to OSHA's Region V Office, requesting interpretations on the Laboratory Standard, 29 CFR 1910.1450 [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard]. Your letter has been forwarded to the National Office for response. We apologize for the delay.
Your questions and our answers are as follows:
- Does 29 CFR 1910.1450 [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard] cover quality control laboratories where these facilities support the production process through sample analysis? NOTE: See attached interpretation from Avenel area office.
The preamble to the standard indicates that most quality control (QC) laboratories are not expected to qualify for coverage under the Laboratory Standard, since they are usually adjuncts of production operations which typically perform repetitive procedures for the purpose for assuring reliability of a product or a process. This response does not contradict the letter from OSHA's Avenel Area Office.
- If samples are taken during different phases of the production process to verify quality control of the process, would these labs be covered under 1910.1450 or under 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]?
These labs assuring quality control of the production process would not be covered under 1910.1450 [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard] but would be covered under other general industry standards including 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: Laboratory Standard scope/definitions and applicable HCS duties. Production QC is not automatically entitled to the limited laboratory provisions.]
- Are environmental labs performing analysis on samples for compliance under EPA regulations covered by the Lab Standard?
Yes. Most if not all of these laboratories are not conducting quality control of production processes but are monitoring emissions for environmental control purposes; therefore, they are not exempted from the Laboratory Standard. Such operations would only be considered quality control of production if the result of the monitoring is used as a source of information for process control adjustment.
If making secondary standards is part of the quality control of a production process, the Laboratory Standard would not be applicable. If blending operations result in a product, they would be considered as production processes and not be within the scope of the Laboratory Standard.
- Request specific clarifications of the following conditions defined under "laboratory use of hazardous chemicals," including: chemical manipulations, production versus non-production, and multiple use of chemicals.
Chemical manipulation simply means the use of chemicals. Production means an operation where a product is produced. Examples of production facilities are refineries, utility- generating companies, manufacturing plants. Multiple use of chemicals (the actual wording in the standard is "multiple chemical procedures or chemicals are used") means using chemicals in laboratory procedures.
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Your letter also addressed a concern that QC labs have limited coverage under 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS], and no coverage under the laboratory standard. We are enclosing pages A-3 and A-4 of the updated Hazard Communication directive, CPL 2-2.38C for your information. The coverage of laboratories is limited under the Hazard Communication Standard (HCS) because it was expected that most laboratories would be covered by the Laboratory Standard. However, the directive does state that QC laboratories would generally be covered by the HCS. Please note that in the previous directive, there was no reference to limited coverage of QC labs under HCS as you had inferred.
We hope we have adequately addressed your concerns. If we can be of further assistance, please do not hesitate to contact us.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
Enclosure
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1991-01-17-0.