Colden’s Favorite OSHA Letters of Interpretation (LOI): Who’s In and Who’s Out for Laboratories: I have a lab onsite; do I need a chemical hygiene plan (CHP)?

Many facilities have lab areas, but only certain types of operations are required to have an OSHA chemical hygiene plan (CHP). In 29 CFR 1910.1450 OSHA defines the “laboratory use of hazardous chemicals” to include the handling or use of hazardous chemicals where all of the following conditions are met: 1) chemical manipulations are carried out on a “laboratory scale” 2) multiple chemical procedures or chemicals are used 3) the procedures involved are not part of a production process, nor in any way simulate a production process, and 4) “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals. The definition of “laboratory scale” specifically excludes those workplaces whose function it is to produce commercial quantities of materials. Lab operations such as quality control, which support production operations, are not considered to fall under the scope of a CHP.