Page 57 - OHS, September 2024

HCS (29 CFR 1910.1200)
The Laboratory Standard (29 CFR 1910.1450)
Hazard determination by manufacturers or importer
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.
Written Hazard Communication Program
Written Chemical Hygiene Plan (CHP) which does not have the exact same elements as the Hazard Communication Program.
No requirement for a designated HCP officer, though that task is typically assigned to the safety officer.
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.
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.
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.
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.
Laboratory must maintain all SDSs provided by suppliers with incoming hazardous chemicals and make sure they are readily available to workers.
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.
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.
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.
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.
The HCS does not specifically discuss work practices like ventilation systems.
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.
The HCS does not discuss designated areas. Some chemical- specific standards require designated areas when exposures exceed a designated level.
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.
Respirator use is required when exposure exceeds a PEL, in accordance with the respiratory protection standard, 29 CFR 1910.134.
Respirator use is required when exposure exceeds a PEL, in accordance with the respiratory protection standard, 29 CFR 1910.134.
The HCS does not contain any requirements for medical surveillance. Some of the chemical-specific standards contain requirements for medical surveillance.
The laboratory standard includes requirements for the employer to provide medical consultations and examinations under specified conditions.
The regulation has five mandatory appendices and one advisory appendix
The regulation has two non-mandatory appendices.
Must comply with chemical-specific standards and OSH PELs published in 29 CFR 1910.1000.
Must comply with chemical-specific standards and OSH PELs published in 29 CFR 1910.1000.
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