~afetyin the chemicd laboratory
edited bv MALCOLM M. RENFREW
University of ldaho Moscow, ldaho 83843
or "Right to Know" Howard H. Fawcen Fawcen Consultations, 12920 Matey Road, Wheaton, MD 20906
At a time when deregulation is in vogue, new regulations a t the federal, state, and local levels may still have significant implications for the academic community as well as for the manufacturing and related industries t o which they are specifically directed. The problem and a possihle solution were presented decades ago (I). The full legal scope of the new communication standard and similar laws has not been fully reviewed hv the courts. hut it aooears that the emphyees and personnel ot cdlrges and uniwriitics who use, handle, and disposc of chemicals have a legally required .'need to know" concerning the hazards involved and the prudent precaution% suggcsred. As industry tunrs u p to meat the May 25, 19R6. drndline tor rhe OSHA standard, students and others in academia, including professors, teachers, and administrators, should be alerted to the increased concern which the federal, state, and local (city and county) codes now place on full and complete disclosure of chemical hazards and t o the precautions needed t o handle, use, and dispose of chemicals safely. It has become too costly, both in human life as well as in terms of legal liability and professional responsihility, to continue indifference or "lukewarm lip service" to chemical health and safety. This paper addressed the new OSHA requirements; readers should consult their state and local laws far specific additional requirements imposed by local codes enacted in recent years. If the pursuit and understanding of natural forces are the main driving forces of science, the dissemination of knowledge, often obtained a t high cost bath financially and in human terms, should he important as well. If the new knowledge results in profitable enterprises, the consensus is that science has benefited the national interest; if,on the other hand, essential knowledge is ignored, suppressed, or truncated, and humans or the environment are degraded, doubt is east on all scientific activities. Many question whether scientists, including chemists and
..
A70
~
~~
Journal of Chemlcal Education
engineers, are truly advancing human wellbeing, and it is essential that scientists eommunieate all data needed t o assess and properly control chemicals, their interaetions, their effects on living systems, and their ultimate disposal (2). Over the years, the "positive" side of chemicals and their reaction products has been rightly publicized, hut far Less attention has been focused on the hazard ootenr d or many I hrm~ralxif the? are impmperly handled ur imprudently d~spusedin spite of the critical importance (3). Marie Curie is credited with the statement that "nothing in life is to be feared; i t is only to he understood". If we apply this concept to chemical health and safety, the recent standard on hazard communication h) the (IS.Occupatimal Safety and llealth Admin~tmtionshould reliwr some of rhc present ~~nenkinesa cuncerning ~hrmirnls. Since lahoratory personnel are usually the first persona in any organization (academic or industrial) t o work with and to have an understanding of the physical, chemical, and physiological properties of chemicals, the standard should he of special interest and concern to the "bench chemist" and other supporting staff as well as to professors, administrators, and management. The standard, published in the Federal Register, Volume 48, No. 228, November 25, 1983, p p 53280-53348 ( 2 9 C F R P a r t 1910.1200, Hazard Communication; Final Rule) is intended t o make information available to employees so that work practices are controlled to prevent improper or excessive exposures. A secondary purpose ma\. be to neutralize iome d' the negative assessment8 abtut the "quality of life", e l peciallv where rhemirnls and chemivallv related materials are produced, handled, reacted, and disposed of (4). T h e standard requires t h a t chemical manufacturers and importers convey hazard information to downstream employers by means of informative labels on containers and by material safety data sheets (MSDS's). All chemical manufacturers and ~
~~~~~~~~~~~~~
importers are required to assess the hazards of chemicals they produce or import, and all employers having workplaces in the manufacturing division, Standard Industrial Classification (SIC) Codes 20 through 39, must provide information to their employees concerning hazardous chemicals by means of hazard-communication programs, which include informative labels, MSDS's, training, and access to written records. In addition, distributors of hazardous chemicals are required to ensure that containers they distribute are properly labeled and, that a MSDS is provided to their customers. At this writing, i t is not clear what are the limits of these regulations, since a federal court has ordered OSHA to toughen these requirements, in that the standard should he extended to other workers (such as construction and services) and be less restrictive on the disclosure of trade secrets (5). OSHA's primary intent in promulgating the final hazard communication standard was to ensure that employees will receive as much information as needed concerning the hazards in their work area, and that this information will he presented t o them in useable, readily accessible form. The seeondary intent was to write the standard in such a way that companies or Laboratories that have voluntarily instituted effective programs of hazard communication for their employees may continue to use these programs without substantial modifications. Laboratories were given special consideration during the preparation of the hazard communication standard, and the text (pp 53287-53289) contains interesting comments on the control of chemicals in aeademic and industrial laboratories. OSHA gave limited coverage of the standard to laboratories, including provisions that the emolover ensure that labels on incamine con, lainera are not r e m o r d
