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Exemption for research laboratories and medical facilities under 311 and 312

Are research laboratories and medical facilities exempt from reporting under Sections 311 and 312?

Research laboratories and medical facilities are not exempt from reporting requirements under Sections 311 and 312, rather, Section 311(c)(4) of Title III excludes from the definition of hazardous chemical:  "Any substance to the extent it is used in a research laboratory or a hospital or other medical facility under the direct supervision of a technically qualified individual."  The exclusion applies to research laboratories as well as quality control laboratory operations located within manufacturing facilities.  Laboratories that produce chemical specialty products or full scale pilot plant operations are considered to be part of the manufacturing facility and therefore would not be a "research laboratory."

With respect to hospitals or medical facilities, the exemption applies only to hazardous chemicals that are used at the facility for medical purposes under the supervision of a "technically qualified individual."  Veterinary facilities are included.