Quality control and nonroutine tests under the laboratory standard

August 8, 1990

Mr. Thomas M. Snyder, C.I.H., Supervisor, Industrial Hygiene, Deere & Company
[Recipient address omitted]
Dear Mr. Snyder:

This is in response to your letter of April 11, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Laboratory Standard, 29 CFR 1910.1450. We apologize for the delay in response.

You stated your laboratories use various hazardous chemicals to perform routine, standardized tests which monitor and support production processes. Examples of your activities are metal analyses on steel and cast iron samples, concentration measurements of coolants for machining, and waste water analyses.

Your first question asks whether these labs must comply with 29 CFR 1910.1450. The answer is no. Since they are routine, standardized tests which monitor and support production processes and therefore can be considered as quality control, they are not covered under the standard.

Question 2 concerns non-routine, non-production-related tests to be performed using the laboratory's sophisticated analytical instruments. You asked whether this occurrence would initiate and require compliance with 29 CFR 1910.1450. The answer is yes.

If you need further assistance, please feel free to contact us again.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]