There is no laboratory exemption written into 29 CFR 1910.119. The standard's exemptions are retail facilities, oil and gas well drilling and servicing, and normally unoccupied remote facilities. OSHA's position on labs is simpler than the name suggests: a true laboratory, in the sense of the lab standard (1910.1450), uses small, below-threshold quantities on a non-production basis, so it usually isn't covered. But a lab, research, or pilot operation that holds a threshold quantity of a highly hazardous chemical is covered, whatever it's called and whether or not it sells product.
What OSHA Has Said
Feb 11, 2003
R&D lab and pilot plant: not exempt, but a storage policy applied
A polymer R&D company with a small lab and an open-air pilot plant had more than 10,000 lb of flammable liquid only in connected atmospheric storage tanks. OSHA said the company had a PSM-covered process but was not required to comply, because of OSHA's May 12, 1997 enforcement policy: when coverage of a process that would otherwise qualify for the atmospheric storage exception is based partly or solely on flammable liquid in connected atmospheric tanks, compliance is not currently required. OSHA stressed that the lab setting and the noncommercial product had no bearing on coverage, and that laboratory and research facilities "are not exempt" when a process holds a threshold quantity.
Read OSHA Letter ↗
Sep 13, 1994 · Compliance directive
CPL 2-2.45A CH-1, Appendix B: labs and research operations
OSHA's PSM compliance directive answers the question directly, as quoted in the 2003 letter: "A laboratory or research operation involving at least the threshold quantity of one or more highly hazardous chemicals is subject to the PSM standard." The 2003 letter also cites a 1992 OSHA letter to the American Chemical Society explaining that a laboratory as defined in 1910.1450, using less than threshold quantities on a non-product basis, is not subject to PSM, while other processes at the same site still can be.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
Don't rely on a "lab exemption." Ask the same question OSHA asks of any operation: does a process, including connected or co-located storage, contain a threshold quantity of a highly hazardous chemical at any one time? If yes, it is covered whether it's a lab, a pilot plant, or a production unit. The 1997 stored-flammables enforcement policy can matter when the only reason you reach 10,000 lb is flammable liquid in connected atmospheric tanks, so evaluate that case carefully.
