Page 56 - OHS, September 2024

HAZCOM
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
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 Sys- tem of Classification and Labeling of Chemicals (GHS). The stan- dard 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 haz- ardous 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 stan- dard was first issued is deciding when the HAZCOM standard ap- plies and when the laboratory standard applies for some specific operations. Most industrial facilities have quality control (QC) lab- oratories, 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 con- tainers 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.
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 lab- oratory standard? The table below compares the major require- ments of each standard.
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 cov- ered 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. How- ever, 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.
Gregory Boothe, Ph.D., CIH, CSP currently serves as the academic program director of the master’s in occupational safety and health and doctorate in OSH programs at Columbia Southern University. He has more than 40 years of experience in health and safety in- cludes military service in the U.S. Air
Force. He holds a Ph.D in public health epidemiology from Walden University in 2010, an master’s with a double major in toxicology and industrial hygiene from the University of Arizona in 1989, and a bachelor’s. in biology from Lubbock Christian University in 1977.
REFERENCES
• tinyurl.com/2s3kr3b3 • tinyurl.com/kbdpej6r • tinyurl.com/mr4ywkau • tinyurl.com/4kbbxcns
54 Occupational Health & Safety | SEPTEMBER 2024
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