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1in the Chemical laboratory Edited by N O R M A N V. STEERE, 1 4 0 Melbourne Ave., S:E. Minneapolis, Minn. 554 1 4
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as it Relates to the Working Chemist Sle~henSichak'. Technical Coordinator, Scholl Incorporated, 213 West Schiller, Chicago, 111. 606 10
When the Williams-Steiger Occupational Safety and Health Act (OSHA) was passed in late 1970, the declared congressional purpose and policy of the act was "to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources."
COVERAGE The provisions of this law apply to every employer engaged in a business affecting commerce. The law applies in all 50 states, the District of Columbia, Puerto Rim, the Virgin Islands, American Samoa, Guam, the trust territory of the Pacific Islands, Wake Island, the Outer Continental Shelf Lands, Johnston Island, and the Canal Zone. Although Federal, State, and local government tmpluyrrq w r e sprcificallv rxrludrd from cuwragr hy the law, on Septemher 28, 1971 I'rrsid~nr Fwd signed Executive order 11807 extending OSHA coverage t o all employees of the Federal Government, both military and civilian. As State governments begin enforcing State OSHA laws State and municipal governments will come under OSHA provisions.
DUTIES OF EMPLOYER AND EMPLOYEES
Labor and in an agency, the Occupational Safety and Health Review Commission, a quasi-judicial board appointed by the President. A 12-member National Advisory Committee advises, consults and makes recommendations. Research and related functions are vested in the Secretary of Health, Education, and Welfare whose functions will, for the most part, be carried out by the National Institute for Occupational Safety and Health (NIOSH). Promulgation and enforcement of job safety and health standards are the responsibilities of the Secretary of Labor. Inspections are made by compliance officers located in 10 OSHA regional offices (Region I-Boston; II-New York City; IIIPhiladelphia; IV-Atlanta; V-Chicago, VIDallas; VII-Kansas City; VIII-Denver; IXSan Francisco; and X-Seattle).
OCCUPATIONAL SAFETY AND HEALTH STANDARDS In general, job safety and health standards consist of rules for avoidance of hazards which have been proven by research and experience t o be harmful t o personal safety and health. They constitute an extensive cornoilation of wisdom which sometunes applir* to all employew an example 01' rhii w d d I,? tiw protpctrcm rtandard5. A great many standards, however, apply only to workers while engaged in specific types . . of work, such as handlina .compressed gases. There are literally thousands of OSHA standards in existence today. To give you a feel for the form that these standards take, a few examples are cited: "Aisles and passageways shall be kept clear and in good repair, with no ohstruction across or in aisles that could create a hazard." "The number of fire extinguishers needed t o oroteet a ~ r o ~ e r shall t v be determined as prescribed herein, considering the area and arrangement of the building or occupancy, the severity of the hazard, the anticipated classes of fires, and the distances to be traveled to reach extinguishers." "The Bhour time-weighted average airborne concentration of asbestos fibers to which an employee may he exposed shall not exceed five fibers longer than 5 micrometers, per cubic centimeter of air, as determined by the method prescribed in paragraph (el of ~
Each employer under the act has the general duty to furnish each of his employees employment, and place of employment, free from recognized hazards causing, or likely to cause, death or serious physical harm; and the employer has the specific duty of complying with safety and health standards promulgated under the act. Each employee has the duty to comply with these safety and health standards, and all rules, regulations, and orders pursuant to the act which are applicable to his own actions and conduct.
ADMINISTRATION Administration and enforcement of the act are vested primarily in the Secretary of
* M r . Siehok is chairman o f the ACS Chicago Section Committee on Chemical Solety. A90
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this section. . . ." I t is unfortunate but true that the Occupational Safety and Health A d is based on mechanical orspecification standards rather than on safe performance standards. The idea of abiding by a set of prescribed rules and specifications certainly decreases the satisfaction that accompanies meeting the challenge by successful attainment of safe performance goals.
CXXI. The Occupational Safety and Health Act
INTRODUCTION
I
FEDERAL REGISTER A close examination of the Federal Register, Volume 39, Number 125, Part 11, dated June 21,1974-Department of Labor, Occupational Safety and Health Standards reveals that only a very few existing standards apply to practicing chemists in chemical laboratory operations. Indeed, it appears that Congress did not intend t o cover professional people! For example, Figure 1 depicts a vacuum distillation heing performed with a flammable liquid under a blanket of an inert gas. Certain safety violations were purposely built into this posed scene. Now, if you study the entire situation, you should easily spot a t least four to five deviations from good laboratory safety procedures. Note these violations. A search of the subject index of the Federal Register mentioned above uncovers the fact that nowhere in the compilation of OSHA standards are there any that are specific for vacuum distillations of flammable liquids under an inert gas. Nor are there any for other laboratory operations. What we find instead are listings far Flammable and Combustible Liquids, Flammable Liquid Container Markings, and Flammable Liquids. If a vacuum pump was used, the machine guarding standard would require a belt guard. From the total list of topics, only a few appear t o be even remotely related t o our bench scale operation. These are: Containers, Definitions, Storage Containers, Flammable Liquid Container Marking, and ~gnitionSources. However, after examining the Flammable and Combustible Liquids standards, it was concluded that even though the Occupational Safety and Health Act is a very extensive piece of legislation, no standards could be found to re-
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ment.. .orooerlv assembled with . ation being given to fire hazards from vent gases, and possible equipment breakage or failure. It should he noted that the Occupational Safety and Health Act does indeed have a wide ranging section on Fire Protection in Subpart L. Additionally, the National Fire Protection Association (NFPA) has completed a Tentative Standard on Fire Protection for Laboratories Using Chemicals. Mention is made of this standard a t this time because it has a very good chance of being adopted by OSHA.
Essentially, the NFPA standard prescribes basic requirements for the protection of life and property in laboratories where hazardous chemicals are handled, through prevention and control of fires and explosions involving hazardous chemicals. Although the NFPA standard does not attempt to deal with health hazards that 'are not related t o fires or explosions, many of the requirements to protect against fires and explosions, e.g. those for hood exhaust systems, will also serve to protect persons from exposure to nanfire health hazards of chemicals. I t also contains requirements far conducting laboratory experiments and for handling and storage of hazardous chemicals. If adopted by OSHA, these NFPA standards would begin to fill the need for rudimentary laboratory safety practices. These then could serve a s s base for subsequent sophisticated laboratory safety prsctices. (Copies of the NFPA standards can be obtained from NFPA a t 470 Atlantic Avenue, Boston, Massachusetts 02210.)
EYE PROTECTION So far, we've concentrated an flammable hazards depicted in the scene of Figure 1. What about eye protection? If we once again take a look a t Figure 1, we see that our chemist has not equipped herself with any type of eye protection-neither a safety shield nor safety glasses. This time, reference to the Federal Register of June 27, 1974 does find entries far Eye and Face Protection with pertinent subtitles of Optical Corrections and Protector Requirements. Unlike the previous problem of not being able t o find specific standards for a
laboratory vacuum distillation of a flammable substance, eye and face protection is quite direct: "Protective eye and face equipment shall he required where there is a reasonable probability of injury that can be prevented by such equipment. In such cases, employers shall make conveniently available a type of protector suitable for the work to be performed, and employees shall use such protectors. No unprotected person shall knowingly he subjected to a hazardous environmental condition. Suitable eve protrcturi shall he pr.widr4 u here machine5 or operationi prrrcnr rhe harard t,f rlying obpctr. glare, liquids, injurirws radiation, or a combination of these hazards." Section 2 of this standard provides for the minimum requirements of eye protectors; section 3 discusses corrective lenses; sections 4 and 5 refer to the manufacturer's identifying mark and limitations, and section 6 spells out that "Design, construction, testing and use of devices for eye and face protection shall be in accordance with American National Standard for Occupational and Educational Eye and Face Protection (287.1-1968)." Unfortunately, the term safety glasses can he confusing. A Food and Drug Adminstration ruling, which became effective January 1, 1972, requires that all preseription eyeglass and sunglass lenses he impact-resistant. Impact-resistant lenses are NOT the equivalent of industrial-quality safety lenses, and they should not be used in an industrial or academic laboratory. Only safety eyewear that meets or exceeds all the requirements of Standard (Continued onpogeA9fil ~
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287.1,cited above, is approved for full-time use by industrial workers. The 287.1standard specifies that industrial safety lenses be a t least three millimeters thick, and capable of withstanding an impact from a one-inch diameter steel ball dropped 50 inches. The FDA ruling does not mention lens thickness, and a smaller, Sb inch diameter steel ball is used for impact resistance testing. Eye wash fountains fall under the medical services and first aid provision of the Occupational Safety and Health Act. Specifically, it states, "where the eyes or body of any person may he exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall he provided within the work area for immediate emergency use."
CHEMICALS Up to this point, flammability and eye hazards of the scene depicted in Figure 1 have been discussed. What about chemicals per se? The only chemical that can he identified in the posed scene of Figure 1 is tetrahydrofuran. In addition to the possibility of forming explosive peroxides, this suhstance is hazardous on contact with the skin and upon inhalation. Tetrahydrofuran is only one of the more than 40,000 chemical substances in commercial use in the United States. Compounding this figure is a myriad of new chemicals which are synthesized regularly
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with shout eight new compounds considered for production each week. As you know, chemicals can be flammable, toxic, and corrosive or they may present other hazards. Yet, quite typically, chemists have taken a cavalier attitude toward chemical exposure. The reason for this attitude is that, too frequently, ehemical hazards are not considered in undergraduate or graduate laboratories. Indeed, there are relatively few chemists who show that they are aware of the toxicity of even the most common substances they handle. For example, benzene is known to cause liver and kidney damage in the parts per million range and all forms of leukemia have been observed in workers exposed to benzene. A similar link exists between cadmium and nerve disorders. More recent eaamples of chemieally-induced occupational health problems will be cited after we find out what standards exist for chemicals in Volume 39, Number 125 of the Federal Register. The subject term index for standards that may have some significance for working chemists lists 29 chemicals and chemically related terms: 2-aeetylaminofluorene, acetylene, air contaminants, airhone radioactive materials exposure limits, 4amino-diphenyl, ammonia, ammonia nitrate, asbestos, henzidine gnd i t s salts, bervllium. cadmium. his-chloromethvl , ether. ~. & r n p r c & I gns cylinders, :Wdichlorohen~icliltr(and its salts,, 4-dimcthyIan1inonzobenzene, ethyleneimine, hydrogen, mercury, 4,4'-methylene-his-(2 chloroaniline), methyl chloromethyl ether, alpha-naphthylamine, beta-naphthylamine, 4-nitrohi-
phenyl, N-nitrosodimethylamine, nitrous oxide, oxygen, heta-propiolaetone, radiation, zinc. Fourteen of the chemicals listed are carcinogens which shortly will be discussed in depth. A fifteenth cancer suspect agent, vinyl chloride, will he added to this list in January of 1975 if OSHA is upheld in the courts. The listing Air Contaminants leads us to Subpart G-Occupational Health and Environmental Control. In this section, 1910.93, three tables are presented: Table G-l (Threshold Limit Values of Airborne Contaminants for 1970-American Conference of Governmental Industrial Hygienists), Table G-2(Threshold Limit Values of Airborne Cantaminents-American National Standards Institute), and Table G-3 (Mineral Dusts). Threshold limit values refer to airhone concentrations of substances and represent conditions under which it is believed that nearly all workers may he repeatedly exposed day after day without adverse effect. Section 1910.93 with its three tables is not only of extreme relevance to us as chemists, it has also elicited mare activity to date than any other section of the Oceupational Safety and Health Act. This section states, "An employee's exposure to any material listed in tables G-1,G-2, or G-3of this section shall be limited in accordance with requirements of the following paragraphs." Eight-Hour Time Weighted Auerages An employee's exposure to any materials in Tables G-1,G-2, and G-3,in any 8-hour work shift of a 40-hour work week, shall (Continued on page A 102)
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not exceed the 8-hour time weighted average limit given for that material in the table. "C'-Ceiling Values "An employee's exposure to any material in Table G-1, the name of which is preceded by a "C" shall a t no time exceed the ceiling value given for that material in the table." Acceptable Ceiling Concentrations An employee's exposure t o a material listed in Table G-2 shall not exceed a t any time during an &hour shift the acceptable ceiling concentration limit given for that material in the table, except for a time period, a concentration allowed in the column under "acceptable maximum peak ahove the acceptable ceiling concentration for an 8-hour shift." Example: During an 8-hour work shift, an employee may be exposed to a concentration of benzene above 25 o.o.m. (but never above 50 p.p.m.) only for a maximum period of 10 minutes. Such exposure must be compensated by exposures t o cancentrations less than 10 p.p.m. so that the eumulative exposure for the entire &hour work shift does not exceed a weighted average of 10 p.p.m. Threshold Limit Values (TLV) were adopted as legal official federal reqirements for industrial air by publication in the Federal Register (Vol. 36,No. 105, May 29, 1971). These represented "startup" health standards for 400 substances. Since then, only 15 of 550 projected OSHA health standards were issued in three years. This was due partly to cautious lead-
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ership and cumbersome methods of converting NIOSH criteria documents into OSHA standards, but mostly due to the agency's lack of information a n the thausands of chemicals coming into the workplace. "We have this Toxic Substance List of 15,000 chemicals which will double by next year at the present rate of chemical development," said NIOSH's Deputy Director Edward J. Baier about the 1972 list. "But when i t comes to knowing just how dangerous each chemical is, let alone how carchogenic, we just don't have the data." Indeed NIOSH's 1973 Toxic Suhstance List contains 25,000 entries. Of these 25,000, only 11,000 are actual chemical suhstances, the other 14,000 are synonymous names and codes taken largely from Chemical Abstract Services. The 1974 edition has 42,000 listings, 13,000 of which are different chemicals. Unfortunately, NIOSH's research recommendations and OSHA's oromuleation of standards settled into a "wont first" approach. Of eight initial OSHA criteria documents, four were related to chemical erposure, i.e. asbestos, beryllium, carbon monoxide, and inorganic lead. Then the problem of "chemical health collapse" moved abruptly from the scientific journals to the daily newspapers. When this happened, two mare temporary standards were promulgated by OSHA. One standard sets times after which farm workers can reenter fields treated with 21 organophosphorous pesticides; the other required certain work practices t o avoid exposure to 14 (Continued onpage AIM)
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