Industrial hygiene in Tempe: where the lab exemption ends

Tempe combines light industry, research and manufacturing tied to the semiconductor trade, along with a large research presence around Arizona State University.

Our field is industrial hygiene, the discipline behind workplace air monitoring and noise surveys.

Tempe's mix raises a question that people often get wrong: where does the laboratory exemption end?

The lab question

Two sets of rules give laboratories their own treatment.

• OSHA's laboratory standard. This standard covers the use of hazardous chemicals in laboratories, and it works differently from OSHA's substance-specific standards.
• The Toxics Release Inventory (TRI). This is the annual report on toxic chemical releases that goes to EPA, and its rules exempt laboratory work that a technically qualified person supervises.

Both exemptions are narrower than people assume. The TRI exemption says outright that it does not cover:

• Specialty chemical production
• Pilot plant scale manufacture
• Work done outside the lab

Some sites run a true research laboratory next to a scale-up or pilot operation, and they often treat both as exempt when only one is.

If you are moving a process from the lab bench to a pilot line and then to production, the boundary of the exemption moves with it. That transition is exactly when nobody checks where the boundary is.

→ Do you have to file a Form R?

What we do for Tempe companies

We work in four fields here:

• Tier II chemical inventory reporting (due March 1)
• Form R / TRI reporting (due July 1)
• Air monitoring surveys and noise surveys
• ISO consulting for environmental management (ISO 14001) and for occupational health and safety (ISO 45001)

Practical notes

Most Tempe sites get their air permits from the Maricopa County Air Quality Department, not from ADEQ, the Arizona Department of Environmental Quality. For many Valley plants, the permit that counts is a county permit. We do not handle air permits, but it helps to know who issues yours.

If your plant files a Form R, you also owe Arizona a Toxic Data Report through myDEQ, due the same July 1, plus a pollution prevention plan. myDEQ is the state's online system.

→ Arizona's pollution prevention plan and Toxic Data Report · Where we work