mfety in the chernicol loborotory
edited by MALCOLM M. RENFREW University of idaho Moscow, Idaho 83843
OSHA Standards for Laboratories Kenyon D. Yoder Miles Laboratories, Inc., P.O. Box 40, Elkhart, IN 46515 Federal OSHA regulations generally do not apply to public employees, such as those in national laboratories or public-supported colleges and universities, and they do not directly protect students. A recently proposed rule published in the July 24. 1986,
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Kenyon D. Yoder is Supervisor of Chemical and Radiation Safety in !he Corporate Safety and Healih Depanment of Miles Laboratories. Inc. where he is involved in the administration of iabwatory and some manufactwing areas lor comp iance with NRC and OSHA programs, i* ci~dingthe recently enaclw Hazaro Corn muni&tion Standard.
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Journal of Chemical Education
Federal Register (51 FR No. 142, p 26660) would apply directly to employees in private high schools and privately funded colleges. The program may ultimately have an effect on all laboratories in the public sector and be universally applied, at least as a model, to practices in student laboratories. This proposed rule has been recommended for the health protection of personnel handling toxic materials. I t has been under consideration for nearly 10 years and reviewed by a working group of laboratory experts from various disciplines. When the program is implemented by chemical laboratories, it will provide a greater assurance of a healthy environment for students. Toxic materials are a common part of our lives. Under this proposed rule, toxic materials include such
common chemicals as acetic acid, acetone, ammonia, hydrochloric and sulfuric acid, formaldehyde, ethyl alcohol and other alcohols, as well as additional chemicals commonly found in student laboratories. Teachers and professors need to be aware that the educational facilities, and experiences learned, need to model more closely what will be expected in the business and industrial setting and to guide their instructions accordingly. This proposed rule is the first one developed by OSHA specifically for the laboratory community. The goal is toprovidelaboratory employees with protection from the exposure to toxic materials. To that end, the standard would apply to all employers and employees engaged in the laboratory use of
toxic substances on a laboratory scale. This could affect about one million employees in more than 74,000 academic, clinical, and industrial laboratories. The only exemptions currently proposed by OSHA are small laboratories (specifically those in group medical practice, dental, and veterinary facilities). The term "laboratory" refers to a workplace where relatively small quantities oftoxic mbstances are used o n a nonproduction basis. "Laboratory use" means handling or use of such substances where (1) chemical manipulations are carried out on a small, noncommercial scale, (2) multiple chemicals are in use in a single room, and (3) protective practices and equipment are in common use. The term "toxic substances" includes not only thosc substance- rpecifically regulated hy OSHA, as found in the Subpart Z list, hut aLso auhsulnces regarded as carcinogens or potential carcinogens by the lnternatiunal Agency for Research on Cancer {IAHC),and the National Taairal. ogy Program (NTP). In brief, the standard proposes to exempt the "laboratory use of toxic substances" from all OSHA substance-specific health standard requirements other than permissible exposure limits (PEL'S), on the condition that the employer (1) develop and carry out a detailed chemical hygiene plan, (2) require the use of respirators where necessary to keep exposure below PEL'S, and (3) maintain certain records. The centerpiece of the proposed standard is a Chemical Hygiene Plan to be developed by the employer. The plan must be capable of protecting laboratory employees from toxic substances and keeping exposure of OSHA-regulated substances below permissible limits. The plan must address a number of elements and indicate the specific measures that will be taken to ensure employee protection. The important elements ofthe Chemical Hygiene Plan are bighligbted in the table. The intent of OSHA is to provide a highly performance-oriented rather than the usual engineering-based standard for Limiting exposure. For example, there are no specific face velocities required for laboratory fume hoods. Each employer would write plans suitable for the facility to ensure safe, careful work practicerather than detailedproced u e s and equipment specifications. This standard recognizes that laboratories tend to change chemicals and procedures freauentlv and cannot ~ r e d i c ttheir use. Through proper work prartrces, use ofsafety equipment, and measures takpn to evaluate employee exposure, all laboratory personnel will be assured of a healthier work environment. The consensus of the interested groups following the preparation of this standard is that the proposed rule will be adopted nearly in its present form. Some of the specifics may change, but the basic requirements in the Chemical Hygiene Plan will remain a part of the standard. The public provided comments on the standard to OSHA until October 22, 1986. The comments are now being reviewed and evaluated to create new provisions under 29 CFR 1910.1450. The standard will become effective 90 dam following publication of a final rule with the requirement that a Chemical Hyfiene Plan b~ implemented within one year.
Chemlcal Hygiene Plan 1. Standard operating procedures. 2. Criteria for determining and implementing conboi meawes. 3. A requirement Uut proledive equipment function properly. 4. Employee infwmation and baining pracb dures. 5. A description of the circumstances under which a particular laboratory Operation shall require prior employer approval before implementation. 6. Provisions for an exposure evaluation for employee^ who reasonably suspect lhey have been "overexposed", i.e.. exposed to a toxic substanceabove the application PEL or (if none) the applicableTLV. 7. Provi~ions fora f r e e medical consultation for any employee whenever an exposure evebation indicates that m% employee is likely to have been overexposed. 8. An opportunity fw the employee to receive further free medical examinations andlor medical surveillance recommended by lhe consulting physician. 9. Designation of personnel responsible fw im plementation of the chemical hygiene plan. 10. Provisions fwadditionai employee wwk protection for carcinogens w potential carcinogensdesignated by IARC, NTP, w OSHA.
The plan must alsc include a n u m b of elements for protecting employees working with carcinrt genic substances as highlighted blow. Carcinogenic Working Conditions 1. Establish a regulated area wilh restricted access. 2. Ensure that work is conducted in a properly operating fume hood, glove box, or equivalem containment device. 3. Specify procedures for safe removal of contaminated waste. 4. Specify personal hygiene practices within and upon leaving the regulated area. 5. Specify procedures to ensure vacuum lines and pumps we protected from contamination. 6. Specify appropriate protection apparel far lhe regulated area.
Volume 64
Number 4
April 1987
