Are environmental labs performing analysis on samples for compliance under EPA regulations covered by the Lab Standard?
Yes. Most if not all of these laboratories are not conducting quality control of production processes but are monitoring emissions for environmental control purposes; therefore, they are not exempted from the Laboratory Standard. Such operations would only be considered quality control of production if the result of the monitoring is used as a source of information for process control adjustment. If making secondary standards is part of the quality control of a production process, the Laboratory Standard would not be applicable. If blending operations result in a product, they would be considered as production processes and not be within the scope of the Laboratory Standard. • Request specific clarifications of the following conditions defined under “laboratory use of hazardous chemicals,” including: chemical manipulations, production versus non-production, and multiple use of chemicals. Chemical manipulation simply means the use of chemicals. Production means an operation where a prod
