Chemical hygiene plan within existing workplace manuals

September 7, 1990

Mr. William E. Clark
Supervisor of Safety
and Health
Williams Pipe Line Company
[Recipient address omitted]
Dear Mr. Clark:

This is in response to your letter of July 2, regarding the Chemical Hygiene Plan (CHP) under the Occupational Safety and Health Administration's (OSHA) Laboratory Standard, 29 CFR 1910.1450. Your letter proposed to incorporate the CHP into your current Hazard Communication and/or other related manuals.

As Mr. Brown of OSHA's Oklahoma City area office indicated to you, this situation would be sufficient as long as ALL information in 29 CFR 1910.1450 is covered, easily identified and readily accessible. Please note the requirement for a Chemical Hygiene Officer or a Committee to implement the CHP.

We are sending copies of this interpretation to all of our Regional Offices. Among the states you mentioned in your letter, Iowa and Minnesota are not within Federal OSHA's jurisdiction but are state-plan states which handle their own health and safety programs. Their standards are at least as effective as Federal OSHA's but can be stricter. We suggest that you contact them for their interpretation on the subject. Their addresses and phone numbers are as follows:

Iowa Division of Labor Services
1000 E. Grand Avenue
Des Moines, Iowa 50319
[(515) 281-6432]
Minnesota Department of Labor and Industry
443 Lafayette Road
St. Paul, Minnesota 55155
[(651) 296-2342]

If you need further assistance, please do not hesitate to contact us.

Sincerely,

Patricia K. Clark
Director Designate
Directorate of Compliance Programs

[Regional forwarding memoranda and the request letter reproduced on OSHA page; omitted here.]