edited by MALCOLM M. RENFREW
crl lcrborcrtor
University of Idaho Moscow. Idaho 83843
OSHA and Experimental Safety Design Stephen Sichak, Sr. ARC0 petroleum Products Co.. Harvey, IL 60426
Stephen Sichak is the Safety Supervisor for Atlantic Richfieid's Products Division's Harvey Technical Center. in this position, Steve is responsible for a safety program that covers unskilled personnel, office workers. technicians, and professionals at all degree levels who are trained in avariety of disciplines. Since most of Arco's refinery prqects Originate at the Technical Center, it can be looked upon asa miniature refinery with all of the associated hazards. To control these hazards, the Safety Supervisor has to be knowledgeable in lire protection, personnel safety. industrial hygiene, resource conservation and recovery, and controlled waste disposal. Steve has a degree in chemistry and a degree in Microbiology. He's a Director of the Chicago Section of the American Chemical Society and is a member of the R&D Section's Executive Comminee-Nationai Safety Council. Steve has prior safely expwience withihe Personal Care Division of the Giilette Company and with Dr. Schoii, the foot care company.
Chemistry teachers should hear in mind that governmental safety regulations may presently impact on their laboratories or on laboratories they or their students will occupy in the future. For all practical purposes, the Occupational Safety and Health Act standards apply to employees in all private lahoratories. However, if a state has an OSHAapproved state plan, laboratories operated by state or local government (those at public colleges or universities, for example) are subject to standards "as effective as" OSHA. If the state does not have an approved plan, the aforementioned laboratories are not covered by OSHA or OSHA-equivalent standards. Nonetheless, they must conform to the state's safety and health requirements. And, although these standards strictly apply only t o employees, common sense will not encourage lesser protection for students. Safety, then, must he integrated into the planning of any experiment! Therefore, in the safety design stage of any experiment, consideration should he given to the question "Which Governmental Agencies Regulate the Use of Chemicals in the Laboratory?" A plan for the safe disposal of substances to he used is also as much a part of the experimental design as are the experimental procedures and the acquisition of materials. The Enuironmental Protection Agency (EPA) is responsible far regulating chemicals in the air, in water, and on land, all of which affect the disposal of chemicals. New regulations to control chemical wastes have been developed under the Resource Conservation and Recovery Act (RCRA). See Federal RegisterNol. 45, No. 98133119.33133. This act is intended to provide eradle-to-grave control of hazardous waste. TheEPA defines waste as hazardous if it meets criteria of toxicity, ignitability, corrosivity, or reactivity. The Laboratory Chemical Carcinogen Safetv Standards Subcommittee of the 1J.S.
drafted guidelines for the laboratory use of chemical substances posing a potential accupational carcinogenic risk. The U S . Department of Transportation controls the shipping of chemicals and their transport on any type of public facility, including a private vehicle using public roads. The agency that has, by far, the greatest impact on experimental design is the Occupational Safety and Health Administration, of the U S . Department of Labor. It does not matter whether the impad is actual or potential, OSHA is the agency of concern when i t comes to experimental design. OSHA has established permissible exposure limits (PELS) based on the threshold limit values (TLVs) developed by the American Conference of Governmental Industrial Hygienists for about 400 substances. OSHA has also classified certain substances as carcinogens (see 29 CFR 1910 and 45 FR 6002-5296) and requires exposure monitoring for 27 chemicals, such as asbestos, arsenic, benzene, and lead. In addition, OSHA has established rules that records be kept, warnings be given, and medical examinations be conducted on a regular basis. Hazardous materials and exposures t o physical injury, radiation, noise, and other physical agents are also covered by OSHA standards.
Background and Review One of the most sweeping efforts to regulate industry for social ends came with the enactment of the Williams-Steiger Oecupational Safety and Health Act Although enacted an December 29, 1970, i t was not put into effect until April 28, 1971. Two years later the Occupational Safety and Health Administration was established and the
(Continued on page A10) Presented at the Chicago Section ACS "Cradle to Grave" Symposium. October 21. 1981. Chicago. iL.
Volume 60
Number 1
January 1983
A9
Secretary of Lahor had to promulgate existing federal standards and national consensus standards. From the moment OSHA was introduced as a hill in 1968, it was and still is controversial, and from its enactment, i t has been in a state of flux. When enacted in 1970, its declared Congressional purpose and policy was: "To assure so far as possible every working man and woman in the nation safe and healthful working conditions to preserve our human resources."
Standards OSHA provides for the Secretary of Labor to establish specific safety and health standards. As previously indicated, these standards currently impact on experimental design and, chances are, they will impact even more in the future, despite the present moves in Washington against federal regulations. Standards are legally enforceable workplace regulations governing conditions, practices, or operations to assure safe and healthful workplaces. OSHA adopts standards for compliance by employer and employee. All standards are published in the Federal Register along with amendments, corrections, insertions, or deletions. From OSHA's current and projected standard activities, you should be able to glean some insight as to haw OSHA does or will impact on your experimental safety design. As part of
its reply to a suit filed in U.S. District Court in Washington, D C., OSHA has revealed its priorities for the next two years. The Labor Department's reply said The majority of OSHA's health standards staff (13 project officers and seven supporting professionals) will be required to devote their full time to OSHA's highest oriorities: the develooment of standards for arsenic; ashestos; access t o employee cwmaure and medical ool- ~ ...r... ~ . - records: ~ cancer ~ icy; lead; cotton dust; labeling; respirators; and the relationship of personal protective equipment and engineering controls. The remainder of OSHA's health standards staff ( 3 project officers and 4 supporting professionals) will assist in the development of the highest priority standards detailed above, and will also examine other hazards which OSHA believes merit consideration a t this time. This second group includes: ethylene oxide, cadmium, anesthetic gases, chromium, nickel, methylene bis-o-chloro-analine and radiofrequeney radiation. Five of these hazards (ethylene oxide, cadmium, chromium, nickel, and methylene bis-o-chlora~analine) pose potential life threatening risks of cancer.. . It is estimated that dedication by OSHA's health standards staff to the aforementioned activities will occupy the full time and energies . of the staff for a t least two years. . . The 4.4-methylene-bis(2~ehloro-aniline) standard was part of the original temporary emergency health standard covering the 14 suspected carcinogens. A subsequent court order vacated this MOCA standard along with the laboratory handling provisions of all ~
the carcinogens. This is but one illustration of the state of flux of the Occupational Safety &Health Act. On April 14,1981, OSHApublished, in the Federal Register (4fiFR21785), a request for comments and information on the title "Occupational Health Hazards of Toxic Chemicals in Laboratories." The summary reads OSHA is considering regulations to protect laboratory from exposure ~ ~ workers ~ ~ ~ ~ to hazardous chemicals and is seeking alternatives to the substance-specific standards that are used far protection of chemical plant employees. The agency currently has regulations requiring expw sure monitoring for use of 21 chemicals, such as benzene, asbestos, arsenic, and lead. Unless OSHA establishes regulations or euidelines soeeificallv for labs. these
laboratories per se.] OSHA presently regulates employee exposures t o toxic chemicals under the general industrv health standards. which are codified prima& in Subpart Z o f 2 9 CFR Part 1910. Most of these standards are applicable to exposure in laboratories as well as in more typical industrial environments. However, OSHA recognizes that from the standpoint of occupational health, the usual laboratory environment differs in important respects from typical industrial environments. For example, the chemicals to which laboratory workers are exposed tend to he more numerous and more variable; they are usually used in smaller, more variable amounts, for shorter periods of time; and it is not always possible to predict in advance what chemicals will be in use. Because of thesefaetors, OSHA has been considerine develooment of a eenI ,. . I : . I d l r I !I 111111 I d ry :u i,ll,w I ,r l h r : ~rv, \I A ~ l l I ,, 1 1 8 . substances. This is not the first time that the unique cireumslances of exposure to toxic suhstanees in laboratories have been addressed. For ex^ ample, on January 22,1980, OSHA published a standard for the "Identification, Classification and Regulation of Potential Occupational Carcinogens" (45 FR 5001), referred to as the Cancer Policy. In addition to the OSHA Cancer Policy, other recent documents address laboratory
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