When quality control laboratories fall under the laboratory standard

OCT 11 1990

Mr. George C. Karpin
Toxicological and Environmental Coordinator
CONAP, Inc.
[Recipient address omitted]

Dear Mr. Karpin:

This is in response to your letter of September 12, regarding interpretation of the Occupational Safety and Health Administration's (OSHA) Laboratory Standard, 29 CFR 1910.1450.

Per telephone conversation with our staff member Ms. Li, you were informed that laboratories meeting the standard's definitions of "laboratory scale" and "laboratory use" are covered under the standard. Most quality control laboratories are not expected to meet the qualification for coverage under the standard. They are usually adjuncts of production operations which typically perform repetitive procedures for the purpose of assuring reliability of a product or a process. Laboratories that conduct research and development and related analytical work are subject to the requirements of the Laboratory Standard, regardless of whether or not they are used only for support of the manufacturing of CONAP products.

We hope we have adequately addressed your concerns. If you need further assistance, please do not hesitate to contact us again.

Sincerely,
Patricia K. Clark
Director Designate
Directorate of Compliance Programs