Hazard Communication and Occupational Exposure to Hazardous Chemicals in Laboratories Standards
OSHA's Hazard Communication and Laboratory Standards outlines their differences, similarities and how to effectively comply with both.
- By Gregory Boothe
- Sep 10, 2024
In 1983, OSHA issued the Hazard Communication Standard (29 CFR 1910.1200) to protect workers from exposure to the hazards of all chemicals in their workplace.
The standard, commonly called the HAZCOM standard, or HCS, codified the use of material safety data sheets (MSDSs) and the labeling of chemical containers. The HAZCOM standard was updated in 1994 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The standard was updated again this year to align with the latest version of GHS.
OSHA also issued the Occupational Exposure to Hazardous Chemicals in Laboratories in 1990. This standard was designed to protect workers who were exposed to the laboratory use of hazardous chemicals and is commonly called the laboratory standard.
Though there are some differences between the two standards, they were issued to be consistent with each other.
One challenge that has been present since the laboratory standard was first issued is deciding when the HAZCOM standard applies and when the laboratory standard applies for some specific operations. Most industrial facilities have quality control (QC) laboratories, making it unclear at times which standard covers these particular operations.
Defining Laboratory Standards
Applying laboratory standards to a specific laboratory operation requires an understanding of three definitions contained within the standard. A “laboratory” is defined as a location where the “laboratory use of hazardous chemicals” occurs, and a “laboratory scale” is defined as work with hazardous chemicals where the containers used for the chemicals are designed to be easily and safely manipulated by one person. Work that is designed to produce commercial quantities of hazardous materials is not considered laboratory-scale operations.
Operations must meet all of the requirements in the laboratory standard including:
- The chemical manipulation of chemicals on a “laboratory scale.”
- Multiple chemical procedures or chemicals are used.
- The procedures are not part of a production process, nor do they simulate a production process.
- Protective laboratory practices and equipment are available and are in common use.
While the definitions may seem to be fairly straightforward, there are some operations that may be more difficult to place under either the laboratory standard or the HAZCOM standard. For example, an industrial facility may have a QC laboratory that performs analyses of production materials to ensure quality standards are met, and a separate research and development laboratory in the same location. The QC laboratory would be covered by the HAZCOM standard, but the research and development (R&D) portion of the laboratory would be covered by the laboratory standard because the activities of the R&D laboratory are not part of the production process, nor do they simulate the production process.
This article originally appeared in the September 2024 issue of Occupational Health & Safety.