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Chemical Hygiene Standard v. Hazard Communication

In 1987 OSHA created the Hazard Communication (HC) standard [1], which required all industries to take measures ensuring employee safety regarding hazardous chemicals.

But the standard failed to take into account the number of chemicals present in laboratories, which store hundreds of chemicals, often in small quantities. In some cases, the standard forced these labs to have as many as 900 MSDS forms on hand.

So, OSHA went back and made and exception for labs by creating the Chemical Hygiene Standard (CHS) [2] in 1990. This standard contained most of the same material in the HC standard, but was designed specifically for labs to eliminate unnecessary documentation. Special consideration is given for chemicals in kit form.  They don’t need to be listed on the chemical inventory, and you don’t need an MSDS for them. In addition, any reagent that has leas than 1% of a hazardous chemical in it also does not need to be listed.

Many labs will play it safe and just do an MSDS for all chemicals to avoid an OSHA fine, but the important thing to remember is that CHS takes precedence over the HC standard for all labs. It’s not a matter of choosing between the two, so it’s important that your employees are trained on CHS, since it’s a requirement from both OSHA and the College of American Pathologists (CAP). That’s where a lot of labs get cited.

But abiding by CHS isn’t such a bad thing, since it was created specifically to cut labs a break in terms of paperwork. It might be a good idea to bring in the New Year by making sure your lab is in compliance.

Gile has a Chemical Hygiene Training DVD, which addresses CHS specifically. To purchase it, click here [3].