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Hazard Communication and Occupational Exposure to Hazardous Chemicals in Laboratories Standards
Even some operations that might not seem to be supporting production have been identified by OSHA as falling under the HCS and not the laboratory standard. For example, since electrical power generation stations produce electricity, if they have water treatment laboratories conducting quality assurance monitoring for process control, the QA laboratories are covered by the HCS standard, not the laboratory standard. However, if a laboratory is conducting testing to determine compliance with discharge limits established by the Environmental Protection Agency (EPA), they would be covered by the laboratory standard, not the HCS.
Laboratories that only use chemically impregnated test media with the results compared to a chart based on color changes are also not covered by the laboratory standard. An example would be a laboratory that uses pH strips to monitor the pH of water discharges.
What are the main differences between the HCS and the laboratory standard? The table below compares the major requirements of each standard.
Major Requirements of HCS and Laboratory Standards
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HCS (29 CFR 1910.1200)
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The Laboratory Standard (29 CFR 1910.1450)
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Hazard determination by manufacturers or importer
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Some requirements for hazard determinations. Chemicals produced for the use of the laboratory must be evaluated to determine if they are hazardous. Chemicals with unknown composition produced as a byproduct must be assumed to be hazardous. The laboratory is required to identify the hazardous chemicals that might be present.
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Written Hazard Communication Program
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Written Chemical Hygiene Plan (CHP) which does not have the exact same elements as the Hazard Communication Program.
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No requirement for a designated HCP officer, though that task is typically assigned to the safety officer.
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Must designate personnel responsible for implementing the CHP. This is typically the chemical hygiene officer. May require a Chemical Hygiene committee, depending on the complexity of the CHP.
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Container labels, tags or markers. Required for portable containers unless chemicals are transferred from a labeled container and intended for immediate use of the employee performing the transfer.
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Must ensure the labels on incoming chemical containers are not removed or defaced. Labels are not required on secondary containers but are recommended by OSHA.
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Safety Data Sheets (SDS) must be provided by manufacturers and importers for each hazardous chemical they manufacture or import. Employers are required to have an SDS in the workplace for each hazardous chemical they use.
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Laboratory must maintain all SDSs provided by suppliers with incoming hazardous chemicals and make sure they are readily available to workers.
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Employee information and training is required for hazardous chemicals used in their work area.
Specific topics are required for the training.
Annual refresher training is not required by federal OSHA but is required by some State OSHA programs.
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Employee information and training is required for hazardous chemicals used in their work area.
Specific topics are required for the training.
Frequency of refresher training is left up to the employer.
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The HCS does not specifically require air sampling to evaluate the risks associated with exposures. 29 CFR 1910.134 requires some sampling and some chemical specific standards require initial and on-going sampling. The HCS requires the employer to inform employees of the methods and observations that can be used to detect chemical exposures in the workplace.
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The laboratory standard requires initial monitoring for any chemical regulated by a chemical-specific standard if there is reason to believe an exposure may routinely exceed an established action level or PEL. Periodic testing is required in accordance with the chemical-specific standard.
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The HCS does not specifically discuss work practices like ventilation systems.
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Appendix A to the laboratory standard, which is non-mandatory, discusses laboratory ventilation systems. The laboratory standard requires fume hoods and other protective equipment to be functioning properly and measures taken to ensure the systems are functioning properly.
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The HCS does not discuss designated areas. Some chemical-specific standards require designated areas when exposures exceed a designated level.
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The laboratory standard requires additional protective measures for “particularly hazardous substances.” The requirements include designated areas, the use of fume hoods or glove boxes, procedures to safely remove any generated waste, and decontamination procedures.
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Respirator use is required when exposure exceeds a PEL, in accordance with the respiratory protection standard, 29 CFR 1910.134.
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Respirator use is required when exposure exceeds a PEL, in accordance with the respiratory protection standard, 29 CFR 1910.134.
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The HCS does not contain any requirements for medical surveillance. Some of the chemical-specific standards contain requirements for medical surveillance.
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The laboratory standard includes requirements for the employer to provide medical consultations and examinations under specified conditions.
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The regulation has five mandatory appendices and one advisory appendix
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The regulation has two non-mandatory appendices.
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Must comply with chemical-specific standards and OSH PELs published in 29 CFR 1910.1000.
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Must comply with chemical-specific standards and OSH PELs published in 29 CFR 1910.1000.
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As the table shows, the two standards are very similar but there are some significant differences.
Developing an Effective Hazard Communication Program
What are the options for a location that has a QC laboratory covered by the HCS and also has an R&D laboratory that is covered by the laboratory standard? The employer could develop a hazard communication program for the QC laboratory and a separate CHP for the R & D laboratory.
It is also possible to develop one program that will satisfy both the HCS and the laboratory standard. By studying the table, it’s clear that having a hazard communication program that meets all of the requirements of 29 CFR 1910.1200 would not guarantee the ability to meet all the requirements of 29 CFR 1910.1450. However, if you developed a program that meets all of the requirements of 29 CFR 1910.1450, it’s possible to meet all the requirements of 29 CFR 1910.1200, with the proper training program.
OSHA issued a letter of interpretation in 1991 that stated that if all requirements of the laboratory standard were met, compliance with the HCS would also be achieved. This would allow a location with laboratories covered by both standards to comply with both standards more easily and efficiently.
This article originally appeared in the September 2024 issue of Occupational Health & Safety.
About the Author
Greg Boothe, Ph.D., CIH, CSP® is the faculty lead for occupational safety and health at Columbia Southern University. He is a founding member and past president of the Middle Tennessee section of AIHA and a professional member of the Middle Tennessee section of ASSP. Dr. Boothe has more than 35 years of experience in OSH.