- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
U.S. Department of Labor
Occupational Safety and Health Administration
Washington, D.C. 20210
Reply to the Attention of:
JUL 5 1990
MEMORANDUM FOR: DAVID M. SMITH, Director Office of Health Compliance Assistance FROM: SHELDON WEINER, Director Office of Standards Analysis and Promulgation SUBJECT: Interpretation of Substances With High Acute Toxicity as Used in the Occupational Exposures to Hazardous Chemicals in the Laboratory Standard
Helen Li, Industrial Hygienist, has requested the following interpretation.
Although there is a basic difference between the Hazard Communication Standard and the Occupational Exposures to Hazardous Chemicals in the Laboratory Standard, the laboratory standard strives to be consistent with Hazard Communication Standard definitions.
The Hazard Communication Standard (HCS) delineates between "acute" and "chronic" on the basis of severity or duration of effects and states, "acute effects usually occur rapidly as a result of short-term exposures, and are of short duration." The HCS also defines explicitly the terms "highly toxic" and "toxic" as they relate to chemicals. The preamble discussion of the Chemical Hygiene Plan describes substances with "high acute toxicity" as highly toxic noncarcinogenic materials or highly volatile toxic materials such as hydrogen cyanide, hydrogen sulfide and nitrogen dioxide. The preamble also states that such substances may be fatal or cause damage to target organs as a result of a single exposure or exposures of short duration.
Therefore, the laboratory standard requirements for substances with "high acute toxicity" must include those substances defined in the HCS as highly toxic or toxic which may be fatal or cause damage to target organs as a result of a single exposure or exposures of short duration.
If there are any further questions regarding this issue, please contact Jennifer Courtney at 523-7166.