edited by
MALCOLM M. RENFREW University of Idaho MOSCOW, Idaho 83843
Academic Experiences with OSHA Raymond L. Schmidt University of New Orleans New Orleans, Louisiana 70122
INTRODUCTION Colleges and universities will have to consider the OSHA standards in all areas of the campus. At a time when there are serious pressures on many institutions from declining enrollment and stand-still budgets, the cloud of more federal standards and the investment of time and effort to insure compliance to OSHA have generated great anxiety, largely propagated by rumors and fear of these standards. There is concern over possihle inappropriate application of vaguely worded and difficult to interpret regulations which may require the expenditure of exorbitant amounts of money. Of particular interest to chemists is the effect of these standards on laboratory instrudional programs and research activities, essential parts of education in the physical sciences. To quantify the level of OSHA-type inspections which have occurred in colleges and universities and to better highlight the major problem areas, a brief letter survey was conducted during the late spring of 1976. The initial survey was mailed to 687 chemistry department chairmen throughout the United States, including the 211 PhD granting institutions listed in the 1975ACS Directory of Graduate Research and 476 institutions offering only an undergraduate major in chemistry or graduate work a t the MS level. Ninety-two department chairmen responded. About a month after this survey was mailed, an excellent special report entitled "Chemical Lab Safety and the Impact of OSHA," was published by Howard J. Sanders in Chemical and Engineering News (May 24, 1976). The Sanders report provides an excellent supplement to the information gathered in our studv but does not attemut to quan~lfvrhr lmrl d O S H A - t ) p e inspecrwns, the rcuncmm Impart u i complinnrt, rsr the implirarmna car OSHA rryulal:ms the program of research and instruction in academic laboratories.
Paper g resented as part of the Symposium on Chemical Educator, OSHA and Liability at the 172nd American Chemical Society National Meeting, August 29-September 3, 1976, San Francisco, California
LEVEL OF OSHA-TYPE INSPECTIONS As a first stage of our study, we considered the level and scope of OSHA-type inspections which have occurred in academic institutions with the results shown in Table 1. PhD granting departments have been more heavily investigated, presumably because of their larger research activity. Roughly one in six departments whose primary mission is undergraduate instruction has been inspected contrasting with one out of four PhD-granting institutions. Clearly, OSHA-type inspections are being made on a number of college campuses. Table 1.
Level of OSHA-Type Inspectiom
Total number of institutions inspected (19/92) Ph.D. granting departments (12/47i Undergraduate 17/45] departments
20.7% 25.5%
15.6%
Inspecting Olgonirotion Federal or State-level OSHA (invited 3) State DeDartment of Labor insurance company Campus Health and Safety Office Outride Consulting Firm Visiting Committee
9
1 2 4 2 1
The level of anxiety among department chairmen is indeed very high; only three responses indicated a favorable feeling about OSHA. Better than half the institutions have requested an inspection either directly from OSHA, or by using outside individuals familiar wkh the standards, as a matter of self-preservation. Other inspections appear to have been initiated from the outside directly or as a result of some reported problem by an employee or student to the official OSHA organizational office.
PROBLEM AREAS IN ACADEMIC LABORATORIES The major deficiencies are shown in Table 2 in the approximate order that a given problem was cited. Faulty electrical wiring and missing belt guards are probably the most cited shortcomings, and there is little (Continued on page AI46J
Volume 54, Number3, March 1977 / A145
Safety
. ..
Table 2. Safety Problems i n Academic Laboratories I.
difference between an industrial-manufacturing operation and a laboratory in this regard. The eost of correcting the common electrical faults and belt guards will of course vary from academic department to department depending on the level of operation. The per item cost of three-prong plugs for Variaes, p H meters, and other apparatus is small, but there are usually hundreds of such items in any department. The cost of conversion mounts rapidly, not counting the staff time required to make the necessary changes. At the California Institute of Technology correcting ungrounded electrical equipment
unguarded Beit and Pulley aisemblles. saw blades and Duffer wheels. Improper Storage of Bulk Chemicals
-. Lt
-.""..."",,, c*"ek."n*
Design of shelves. air hsndlina ryst&, fire equibment 2. Ungrounded bulk solvent drums 6. Laboratolies-Research and Instructional 1. Excessive voiumes of solvents 2. Lack o f metal safety cans and metal cabinets 3. Lack of explosion proof refrigerators C. Carcinogenic Compounds Inadequate Ventilation and Exhaust Hood Flow Velocity Lack of Eyewash and Safetv Showel Facilities Lerr Major Problem Areas A. waste disposal 6. Storage and use o f gas cylinders C. Poor houlekeeping practicer D. Inadequate safety rignr E. Inadequate shields for individual experiments F. Blockage of escape router between rerearch areas 1.
cost . . %7nn0 . ! I major worr) ii I l l ? hulk itoragcufflnmm d A w l w m s in vtwkn.cms and e x w w v e a m w u t s in thr i n s t r u r t ~ ~ m and al rei~nrrh Inhcjr.l~urws.Ycrr l e u chemical ,locknwmi C.NW rluir t u l h e 0511.4 standnrds,nnd man" institutions have hegun, or are planning, the construction of completely new stockroom facilities. One chairman, of a campus located in a heavily populated downtown area, wrote the "Chemistry Stores, whieh was previously in the Chemistry Building, has had to be rehoused same five miles away, and the total cost for removing all of the Stores areas (which includes more than purely chemical stores, but it was the problem of flammability of liquids, etc., which dictated this move) was somewhat in excess of $1 million. This was without regard to the fact that we now have very serious delays in obtaining simple chemicals and apparatus in the Chemistry
Improper Electrical Wiring A. ungrounded equipment (3-wire Pl"911 Overloaded circuits rexcerrive
IV.
V. VI.
Department, and the effects are not even yet fully apparent." Almost universal concern was expressed about the use. handline. -. and storaee of "hnmrdous materials." esneciallv * the sixteen presently highly regulated carcinogens (the famous "14 carcinogens" specified in 1974, plus asbestos fibers and vinyl chloride). In ~~~
~
~
~ - ~~.~~~ . ~
~
~
addition, OSHA and the National Institute for Occuoational Safetv and Health (NIOSH) are imprbving the stambards on over 400 more common hazardous chemicals and periodically issue a "Criteria Document" which details the proposed handling and maximum allowable atmospheric concentration of these regulated chemicals. The OSHA-NIOSH project is reportedly scheduled for eompletian sometime in late 1977. After seeing the OSHA standards far working with the carcinogens, academic chemists greatly fear what the future holds in the restricted use of common solvents such as benzene, toluene, eyclohexane, and carbon tetrachloride. Dr. J. W. lrvinefrom M.LT. notes that "the shadow an the wall is getting darker, and it would not take a very long list of regulated compounds to put us out of business." Dr. Charles Knobler of 1J.C.L.A. indicates that "the L herni;try f:rulty feel I here arc iw more than ~ n prrsenr t fourteen r\ llich can. should, and pronohly utll r,c added 10 the OSHA lirt i n the months to come. If this occurs we expect to experience substantial and eventually insurmountable problems in conducting and maintaining a vigorous and meaningful research environment."
based on a successful appeal of a decision to the Third Circuit U.S. Court of Appeal. The appealed decision was won not on the contents of the regulations but on the method by whieh the reeulatians were oromuleated. Standards uu t h r r n n i n < ~ c nwill i ctrralnl) reappear inn more leaally bindins firrtu i n the near future. A few institutions have mustered the courage and financial resources to construct a special carcinogen handling room complete with independent ventilation systems, shower facilities. and a medical surveillance
projection is $35,000 for a single lab plus the eost of the medical monitoring and record keeping. The chairman of one of the more respected graduate departments estimates "the cost of soaee to handle such noxious foot of finished laboratory. 1 know of no legislative body that is prepared ta consider such a floor cast in a legislative appropriation."
ECONOMIC IMPACT AND COST OF OSHA COMPLIANCE
chairmen were not sufficiently aware of the OSHA requirements to venture an order of magnitude guess of the costs involved, and to appreciate the meaning of the term "full OSHA compliance." Most were, however, very concerned and described the economic impact on their department or institutions with phrases ranging from "tremendous," "severe," and "staggering" to "devastating," "castastrophie," and "disastrous". In terms of a dollar value the numbers range from 10" to 107dollars.There appears to be a correlation between thuse inslilutiune which have
A146 / Journal of Chemical Education
ables affect the estimates such as size of the campus, age of buildings, and previous campus attitude and commitment to safety programs. In alimited number of cases, relatively serious objective attempts have been made to arrive a t a rough figure for the campus-wide cost of OSHA compliance. The average figure appears to be in the range of $260 to $500 per enrolled student. For a campus of 10,000 students the cost would range between 2.5 and 5 million dollars, while for a campus of 40,000, the total cost could reach 20 million dollars. These cost estimates should cover OSHA related problems in all areas of a campus, but probably one third to one half of the maney would be required in the science and engineering areas. Using 1974 enrollment figures nationwide, this calculates to 2.5-5.0 billion dollars that public and private higher education would have to pay to comply with OSHA. These are initial costs to bring institutions up to present standards, and do not include the added manpower, record keeping, utility, and personnel services cost, such as providing annual medical examinations and special monitoring examinations for people working in the special carcinogenic laboratories. Additional staff will be needed t o sustain and continually monitor OSHA compliance and to keep track of the paper work; a few departments already report staff additions for these purposes. The initial cost and those far maintaining a campus within OSHA standards must be added onto the already staggering and steadily increasing cost of higher education. Pubhe institutions must rely on special legislative appropriations and current operating funds; while private institutions would attempt to work through their Boards of Trustees. The prospects far such special funding is not great, but without these additional monies restriction of laboratory courses and the abolition of research would be the only way to comply. One institution reports being able to make a number of much needed improvemenb funded mainly from OSHA money.
AFFECTED AREAS OF RESEARCH Table 3 summarizes the areas of research now governed in some manner by the present OSHA standards. The experiences thus far with the 14 carcinogens has precipitated a great deal of uneasiness about the future and the prospects of an even larger list of regulated compounds is almost certain. Almost every area of research would be affected because of the difficulties of obtaining many Table 3. Affected Areas of Research
I. Ure of regulated carcinogenic CompoundP About 80% of organicchemical research a. synthesis and/or reactions of novel compounds of unknown toxicities b. Aikyiating agents c. suspect solvents (CCi,. c,H,, etc.) 3. organometallic chemistry 4. Organ oberyllium chemistry 5. High pressure experiments 6. Large vacuum apparatus 7. Gel permeation chromatography 8 . PhotochemiCBi inveltigationr 9. Laser laboratories 10. Biologically hazardous materials 11. sciected areas of Diochernicai. Physical and analytical research
2.
(Continued on page A1481 Volume 54. Number 3, March 1977 / A147
Safety
...
chemicals. Synthetic organic research programs would be mast heavily hit. One of the leading authorities in the area of organabervllium chemistrv, reoorts that it is imoossible rocomply $bith lwr)~lliumitandardi that are irnpuwl un industry; t h u he has lwrn ftnred tudisrontinur urgunobcryllium re~earrh.
.
OSHA IN THE INSTRUCTIONAL LABORATORIES Just what the OSHA standards mean in the instructional laborataries of colleges and universities is not very clear. A number of resoondants indicate ereat difficultv in wading, inrerpr~ring,nnd npplyrng the pre5-t standards ro thr instrucrlonnl slruotam. Thew i, a drlinitr nerd tor rhe academ~c community to define a good set of guidelines and regulations which could pre-empt the vague OSHA standards. There is a surprising lack of published material about the standards and solutions to soecific instructional problems from an OSHA viewpoint. More than one institution, however, has
come under scrutiny for insufficient ventilation in instructional labs because of student com~laints.A number of chairmen reoort
extend and rearrange duct systems with a net result of very little, probably not sufficient, improvement in air flaw. One chairman reports "Our new (occupied January, 1973) chemistry building has been inspected for compliance. The results are that the research labs can be made to meet OSHA standards with relatively simple modifications to the hoods. The instructional labs are something else again. In these, the students work under
timates t h i t it will take 1.7 millia~dollars to lrriny the canopy 11, od%in our insrrurrlunnl lab, up to 0Stl.4 srnndmds. and nn odditlr.nai Sltit),UvJpcv Jenr t o pav rhe addrd electrical costs." All chemistry laboratories get more smelly than we would like but the best most people can do is make a subiective value iudement ,. ns rcr whether the vapor ronctntrati
