edited bv

safety tips TIM CH~MPION

Johnson C. Smith University Charlotte, NC 28216

Occupational Exposure to Hazardous Chemicals in Laboratories Understanding the OSHA Laboratory Standard

James A. Kaufman Laboratory Safety Workshop, Curry College, Milton, MA 021 86

OSHA's Health and Safety Standards; Occupational Ex- posures to Hazardous Chemicals in Laboratories (29CFR1910.1450) was published in the Federal Register on January 31,1990 (pp 33004333). This landmark legis- lation affects almost all public and private laboratories. For nearly 10 years, there have been discussions focused on the difference between laboratories and other workpla- ces and the need for different safety requirements. The OSHA Laboratory Standard addresses these differences.

The Lab Standard applies to all private sector employers whose laboratories use hazardous chemicals as defmed in the Federal Hazard Communication Standard (29CFR 1910.1200). These new laboratory regulations will be eas- ier and less time-consuming to comply with than the Haz- ard Communication Standard they replace. Public sector employers are covered only in those states where the state has developed a "State Plan" to enforce workplace safety regulations. Municipal and state employers in states with- out state OSHA plans, like Massachusetts, are not cov- ered. See the table below for the list of "State Plan States". Check with your State for additional specific require- ments.

The primary goal of these regulations is to insure that laboratory workers are informed about the hazards of chemicals in their workplace and protected from exposures in excess of allowed levels. To achieve this, the law re- quires that employers appoint a Chemical Hygiene Officer to develop and implement a Chemical Hygiene Plan (CHP).

Students are not covered by the OSHALaboratory Stan- dard unless they are institution employees. Teaching as- sistants and research assistants are likely to be considered employees by OSHA. Students are pn)te&d for a diflerent rea;inn. Colleees and Umvcr.iities are ethirallv and lceallv - - "

bound to protect their students. Academic institutions have $1 soc&tally-imposed duty ofcare owed to the student. Therefore. the standard of care taken to omtect students must be a t least as stringent a s that take; for employees. In practice, a greater standard of care should be observed because students have had less training.

I n March of 1991, OSHA increased the penalties for vio- lations by a factor of seven. The maximum fine for a seri- ous, willful violation is now $70,000.

The OSHA Laboratory Standard consists of 12 parts, A through L. These parts are outlined and briefly discussed below.

A. Scope and Application

Covers all employers engaged in the "laboratory use" of chemicals on a "laboratory scale", e.g., work performed by one person using standard laboratory safety equipment, with multiple chemicals and procedures, not as part of a pro- duction operation. Supersedes almost all other OSHA health standards in 29CFR1910, subpart Z.

6. Definitions

The most important of these is that of the Chemical Hy- giene Officer-a person who, by reason of training or expe-

State Plan Participants

The Occupational Safety and Health Act (29CRF1910) provides lor individual State to adopt and enforce their own regulations as long as they are at least as stringent as the Federal standard and the coverage is extended to public employees. The list below indicates whether or not States have adopted such Dlans.

Alabama no Louisiana no Ohio

Alaska yes Maine no Oklahoma

Arizona yes Maryland yes Oregon

Arkansas no Massachusettsno Pennsylvania

California yes

Colorado no

Connecticut yes

Delaware no

Florida no

Georgia no

Hawaii yes

Idaho no

iilinois no

Indiana yes

Iowa yes

Kansas no

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Navada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

Kentucky yes North Dakota no

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

Volume 69 Number 11 November 1992 911

rience, is capable of developing and implementing a chem- ical hygiene plan.

C. Permissible Exposure Limits 'Do not exceed the permissible exposure limits (PEL'S) speci-

fied in 29CFR1910, subpart Z. Creates no new exposure levels.

D. Employee Exposure Determination Emnlovers must measureem~loveeermamre ifthe actionlevel . " . . or PELis routmely exceded and a mun~toringstandardrxisLs. There are only nine applwnhlt. auhsranres: nqlonitnle. )nor- gnnic arsenic, asbestos, 1.2-aihromoJ-chlomprop~nc, rrhyl- ene oxide, formaldehyde, lead, and vinyl chloride.

.Periodic monitoring requirements are those in these nine published standards. Termination of monitoring allowed a s per the published standards.

Not i fy employee of monitoring results within 15 days of re- ceiving such information.

E. Chemical Hygiene Plan Develop and implement a written plan to protect workers'

health from hazardous chemicals in laboratories. Make the plan easily accessible to employees. The employer

must decide the best way to do this. Giving each employee a copy or placing a copy in each lab are two possibilities.

Include information to:

descrihe standard operating pnwdures, e g. , wear pro- tective equipment. durl't work aloe, wash hands before leaving the lab, etc. define employer's criteria for determining and im- plementing control measures , e.g., chemical splash goggles should he worn when handling ehemi- cals known to be hazardous to the eves. chemicals whose hazard to eyes are unknown, or &e&icals hotter than fin 'C. ~~~~~~~ ~ ~ - ~

maintain proper functioning of fume hwds and other protective equipment. The responsible parties should he clearly designated for each item of equipment. provide employee information and training. Although annual training is not required, employees must he able to answer questions posed by an OSHA inspector. An- nual refreshers are a mod idea. provide eriwrln for p r m approval of ~pceilicd nrtivilica ur procedures. Each employer must deode what is ap- propriate for its organization. provide far medical consultation and examination. designate persons responsible for implementation of the CHP. This really should be a t the front of the CHP right after the institutional safety policy statement. provide employee protection from particularly hazard- ous substances: highly toxic substances, select carcino- gens, and reproductive toxins.

F. Employee Information and Training . . - Apprise workers of hazards ofchcrnicnls in thc workplace and

thr content* of the OSHA Lab Standard. Provide trnining and inforrnatmn at time of initial cmplny-

ment and when the nature of hazards change. Information requirements:

Contents of the Standard and Aooendices. Location and availability of ~o;~'cHP. PEES and Threshold Limit Values (TLV's). Signs and symptoms of exposure. Location and availability of reference material.

Daining requirements:

Methods and observations to detert presrnre or release of hnmrdous chemicals. Phvsicnl and chrmical health hazards in the work area. ~ h k i e a l hazards indude reactivitv. flammabilitv. hieh .. ., - pressure, explosivity, etc. Protective measures including emergency pmcedures, work practices, and protective equipment. Details of the employer's Chemical Hygiene Plan.

G. Medical Consultation and Medical Examinations Prumde opportunities for mrdicnl attention and follow-up ex-

nrninatior~s durmg re~wlar working hnum. Muit be performed hy liccnaed physician. . . Provide information to physician concerning the nature of the

work and the exposure. Must obtain physician's written opinion.

H. Hazard Identification Maintain and do not deface existing labels. Maintain and make available material safety data sheets

(MSDS's) received. For departments with lots of old chem- icals, it's still a good idea to obtain MSDS's for these chemicals. Whenever anyone uses a chemical, they should have access to current safety information.

Chemicals developed in the lab:

For use within the company, treat as particularly haz- ardous substances. For external use treat a s per Federal Hazard Commu- nication Standard.

I. Use of Respirators When needed, they must be provided by the employer a t no

cost to the employee. Comply with 29CFR1910.134 Respiratory Protection.

J. Recordkeeping Establish and maintain records of employee exposure moni-

toring, medical consultation, and examinations. Keep, transfer, and make records available in accordance

with 29CFR1910.20 Access to Employee Exposure and Medical Records.

K. Dates Effective May 1,1990 Develop and implement Chemical Hygiene Plan by January

31,1991

L. Appendices Appendix A-National Research Council's nomandatory rec-

ommendations on Chemical Hygiene in Laboratories Appendix B-Nonmandatory References. Includes Laboratory

Safely Guidelines by this author.'

'Copies of Laboratory Safely Guidelrnes are availab e from Ka~f- man & Assoc~ates (I01 Oan Street. We lesley MA 02186 617.237- 1335). Please encose a stamped ($0.521, self-addressed 9 in. x 12 in. envelope.

912 Journal of Chemical Education