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Table I. Common Laboratory Reagents Included in OSHA's -400 Chemical Exposure Standards Acetone Carbon tetrachloride Carbon disulfide Chloroform Dimethyl formamide Isopropyl alcohol Pyridine Toluene
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stance's known or suspected carcinogenicity was published in the Federal Register (3). Classification in Categories I or II would lead to regulatory action based on model standards for these categories. All chemicals within a category would be treated identically regardless of degrees of biological potency. Some of the compounds (see Table I) which may get final classification in Categories I and II are found in many analytical laboratories. Analytical chemists working with any of these chemicals, and most of us are, must become aware of the hazards, limits, and penalties associated with laboratory chemicals that, over the years, have become common tools of our profession. One problem with the initial OSHA proposal is that research laboratories would be covered by the same rules that apply to manufacturing, construction, maritime, and agricultural activities. Research scientists are concerned with safe working conditions and protecting the health of the laboratory worker. However, to control a research laboratory's use of toxic chemicals by the same set of rules that would apply to bulk manufacturing operations could drastically affect the progress of chemistry as a science since many of these compounds are necessary for the conduct of research experimentation. As the ACS has pointed out (4), it is important that the Agency recognize that in the research laboratory the nature of the exposure to the chemical is often in small amounts, coupled with infrequent use and/or of short duration. In addition, research laboratories have specialized facilities for use by qualified workers under a high level of technical supervision. These factors make the research laboratory unique and should allow greater freedom in the use of toxic chemicals without jeopardizing the health and safety of employees in these very special working areas. Trying to apply the same rules to laboratories and nontechnical facil-
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ities brings forward the real possibility that scientific experiments aimed at the heart of OSHA proposals—carcinogenic hazard assessment and control—will be curtailed. The analytical laboratory would be particularly affected by such blanket regulations since a great number of chemicals in small amounts are utilized as reagents and are often isolated, purified, and concentrated prior to analysis. To impose the same control, monitoring, construction of expensive isolation laboratories, and record keeping procedures appropriate for bulk manufacturing operations on chemical laboratories will be an additional burden on laboratory operations without commensurate additional benefit. Since regulations on specific chemicals will be issued based on their potential hazard, it will be necessary for scientists to help the Agency develop laboratory exposure rules and carcinogenic categories based on the best technical information available. Not to do so may lead to restrictions on which chemicals can be used in· analytical laboratories. The Federal Register is one of the best sources of information available for OSHA standards, amendments, corrections, insertions or deletions, but is not usually read by chemists. Ten regional OSHA offices can also serve to link the scientist and the Agency more closely, especially when the scientist has specific questions. In summary, while some regulations indicate how to conduct scientific experiments, OSHA rules go one step further to regulate laboratory facilities by establishing allowable exposure levels and work practices which would be applied in the same way that manufacturing operations are controlled. Only through input of scientists to the Agency on these standards can we hope to minimize the effect of such regulation on research without compromising the intended benefits of health protection. While scientists must be concerned with the hazards of their profession, they must fully dialog the impact of rules aimed at making our profession hazard free.
References
(1) Fed. Regist., 40, 27073 (May 28, 1975). (2) National Cancer Institute Safety Standards for Research Involving Chemical Carcinogens, Office of Research Safety, National Cancer Institute, DHEW Publication No. (NIH) 76-900, June 2, 1975. (3) Fed. Regist., 42, 54148-247 (Oct. 4, 1977). (4) Letter from Dr. Anna J. Harrison, President, American Chemical Society, to Dr. Eula Bingham, Assistant Secretary, Occupational Safety and Health, U.S. Department of Labor, Jan. 20, 1978.
