edited bv TIMC H ~ M P I O N Johnson C. Smith University Charlotte, NC 28216
safety tips Occupational Exposure to Hazardous Chemicals in Laboratories Understanding the OSHA Laboratory Standard J a m e s A. Kaufman Laboratory Safety Workshop, Curry College, Milton, MA 021 86 OSHA's Health a n d Safety Standards; Occupational Exposures to H a z a r d o u s Chemicals in Laboratories (29CFR1910.1450) was published in the Federal Register on January 31,1990 (pp 33004333). This landmark legislation affects almost all public and private laboratories. For nearly 10 years, there have been discussions focused on the difference between laboratories and other workplaces 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 a s defmed in the Federal Hazard Communication Standard (29CFR 1910.1200). These new laboratory regulations will be easier and less time-consuming to comply with than the Hazard 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 without state OSHA plans, like Massachusetts, are not covered. See the table below for the list of "State Plan States". Check with your State for additional specific requirements. 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 requires that employers appoint a Chemical Hygiene Officer to develop a n d implement a Chemical Hygiene P l a n (CHP). Students are not covered by the OSHALaboratory Standard unless they are institution employees. Teaching assistants 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 $1soc&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. I n 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 violations by a factor of seven. The maximum fine for a serious, 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.
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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 production operation. Supersedes almost all other OSHA health standards in 29CFR1910, subpart Z.
6.Definitions The most important of these is that of the Chemical Hygiene Officer-a person who, by reason of training or expeState 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 Arizona
yes yes
Maine Maryland
no yes
Arkansas
no
Massachusettsno
Pennsylvania
California Colorado Connecticut Delaware Florida
yes no yes no no
Michigan
Rhode Island South Carolina South Dakota Tennessee Texas
Georgia Hawaii
no yes
Idaho
no
New Hampshire
Virginia
iilinois
no
New Jersey
Washington
Indiana Iowa Kansas
yes yes no
New Mexico New York
West Virginia Wisconsin Wyoming
Kentucky
yes
Minnesota Mississippi Missouri Montana Nebraska Navada
North Carolina North Dakota no
Oklahoma Oregon
Utah Vermont
Volume 69 Number 11 November 1992
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rience, is capable of developing and implementing a chemical hygiene plan.
C. Permissible Exposure Limits 'Do not exceed the permissible exposure limits (PEL'S) specified in 29CFR1910, subpart Z. Creates no new exposure levels.
D. Employee Exposure Determination
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Emnlovers must measureem~loveeermamre ifthe actionlevel " . or PELis routmely exceded and a mun~toringstandardrxisLs. There are only nine applwnhlt. auhsranres: nqlonitnle. )norgnnic arsenic, asbestos, 1.2-aihromoJ-chlomprop~nc, rrhylene oxide, formaldehyde, lead, and vinyl chloride. .Periodic monitoring requirements are those in these nine published standards. Termination of monitoring allowed a s per t h e published standards. N o t i f y employee of monitoring results within 15 days of receiving such information.
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 hazards l 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.
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G. Medical Consultation and Medical Examinations Prumde opportunities for mrdicnl attention and follow-up exnrninatior~sdurmg re~wlarworking 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 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 protective equipment. durl't work aloe, wash hands before leaving the lab, etc. define employer's criteria for determining a n d imp l e m e n t i n g control m e a s u r e s , e.g., chemical splash goggles should he worn when handling ehemicals known to be hazardous to t h e eves. chemicals whose hazard to eyes are unknown,or &e&icals hotter than fin ' C- . maintain proper functioning of fume h w d s 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 a n OSHA inspector. Annual refreshers are a mod idea. provide eriwrln for p r m approval of ~pceilicdnrtivilica ur procedures. Each employer must deode what is appropriate 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 hazardous substances: highly toxic substances, select carcinogens, and reproductive toxins. ~~~~~~~
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F. Employee Information and Training . . Apprise workers of hazards ofchcrnicnls in thc workplace and t h r content* of the OSHA Lab Standard. Provide trnining and inforrnatmn at time of initial cmplnyment 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.
912
Journal of Chemical Education
Maintain and do not deface existing labels. Maintain and make available material safety data sheets (MSDS's) received. For departments with lots of old chemicals, 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 hazardous substances. For external use treat a s per Federal Hazard Communication 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 monitoring, medical consultation, and examinations. Keep, transfer, and make records available in accordance with 29CFR1910.20 Access to Employee Exposure a n d 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 recommendations on Chemical Hygiene i n Laboratories Appendix B-Nonmandatory References. Includes Laboratory Safely Guidelines by this author.'
'Copies of Laboratory Safely Guidelrnes are availab e from K a ~ f man & Assoc~ates(I01 Oan Street. We lesley MA 02186 617.2371335). Please encose a stamped ($0.521, self-addressed 9 in. x 12 in. envelope.
