The OSHA Laboratory Standard

1. The OSHA Laboratory Standard Tim Govenor, CSP, CIH Institutional Chemical Hygiene Officer The Ohio State University Govenor.1@osu.edu

2. The OSHA Laboratory Standard • CFR 1910.1450: Occupational Exposure to Hazardous Chemicals in Laboratories • Came from the Hazard Communication Standard • Established in 1990 • State Agencies (H.B. 308) July 1994

3. The OSHA Laboratory Standard • Scope and Application • Does not apply to Laboratory uses of hazardous materials in which there is no chance for exposure (such as kits). • Chemical manipulations are carried out on a “laboratory scale” (one person with small containers). • Not part of a production process.

4. The OSHA Laboratory Standard • Definitions • “Hazardous Chemical” means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees.

5. The OSHA Laboratory Standard • Definitions (1910.1200) • “Health Hazard” includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes.

6. The OSHA Laboratory Standard • Definitions (1910.1200) • “Physical Hazard” means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive.

7. The OSHA Laboratory Standard • Performance Standard • For laboratory uses of OSHA regulated substances, the employer shall assure that laboratory employees’ exposures to such substances do not exceed the permissible exposure limits (PEL’s) specified in 29 CFR 1910, subpart Z.

8. The OSHA Laboratory Standard • Employee Exposure Determination • Initial Monitoring • If above action level or PEL • Periodic Monitoring • If initial monitoring warrants • Employee Notification of Monitoring • Within 15 days • In writing

9. The OSHA Laboratory Standard • The Chemical Hygiene Plan (CHP) • Employee Information • Must be apprised of chemical hazards • Prior to work • New procedures/hazards • Include the Standard, CHP Location, and the PEL’s of the substances • If no PEL, then signs and symptoms of exposure and location of reference material and MSDS’s

10. The OSHA Laboratory Standard • Employee Training • Methods and observations that may be used to detect hazards • Physical and health hazards • Measures used to protect themselves • SOP’s • Emergency Procedures • PPE • Applicable Details of the CHP

11. The OSHA Laboratory Standard • Medical Consultation and Examinations • Medical Attention and Follow-Up Exams will be provided when • Signs and symptoms • Monitoring reveals routine exposure above action level or PEL • Accident/Spill/Leak • Exams by a Licensed Physician without cost or loss of pay at a reasonable time and place

12. The OSHA Laboratory Standard • Medical Consultation and Examinations • Information Provided to the Physician • Chemical Identity • Exposure Conditions • Signs and Symptoms • Written Opinion • Recommendation for follow-up • Results of any tests • Employee has been informed by the physician • Shall not reveal specific findings unrelated to the occupational exposure

13. The OSHA Laboratory Standard • Hazard Identification • Labels shall not be removed or defaced • MSDS’s shall be maintained and accessible • For Chemicals Developed in the Laboratory • The employer shall determine the hazard • Provide appropriate training • Follow Hazard Communication Standard (1910.1200) with respect to MSDS’s and Labeling • Use of Respirators • In accordance with the Respiratory Standard (1910.134)

14. The OSHA Laboratory Standard • Recordkeeping • Medical/Exposure • In accordance with 1910.20 • 30 Years • Training • 3 years (BBP)

15. The OSHA Laboratory Standard The Chemical Hygiene Plan Shall be capable of • Protecting employees from health hazards • Keeping exposures below PEL or action limit • Being readily available to employees

16. The OSHA Laboratory Standard The Chemical Hygiene Plan • Shall include • SOP’s • Control Measures using • Engineering Controls • Administrative Controls • PPE

17. The OSHA Laboratory Standard The Chemical Hygiene Plan • Shall include • Fume Hood Performance measures • Information and training • Prior Approvals for certain operations • Provisions for medical consultations • Designation of Personnel that Implement CHP • Chemical Hygiene Officer • Chemical Hygiene Committee

18. The OSHA Laboratory Standard The Chemical Hygiene Plan • Shall include • Provisions for Additional Protection in working with Select Carcinogens, Reproductive Toxins, and Acutely Hazardous Materials • Establishment of a Designated Area • Use of Containment Devices such fume hoods and glove boxes • Procedures for the safe removal of waste • Decontamination Procedures

19. The OSHA Laboratory Standard • Implementation • Begin with the end in mind. • What will successful implementation look like? • How will you determine (measure) success? • Is it worth doing? • Who is going to do it?

20. The OSHA Laboratory Standard Implementation Identify barriers It is only safety stuff Resistance to change Denial OK but not me I don’t have time for this Rewards and Consequences Ignorance

21. The OSHA Laboratory Standard Implementation Focus on alignment with company goals and values: Cost of implementation-$ Cost of doing nothing-$$$$ Avoid Civil and Criminal offences Potential savings Workers’ Compensation Potential savings hazardous waste, emergency response, Business integrity Professional competency

22. The OSHA Laboratory Standard Implementation Administrative support and involvement Without involvement there is no commitment. Mark it down, asterisk it, circle it, underline it. No involvement, no commitment. --Covey

23. The OSHA Laboratory Standard Implementation Where do we stand? Market, market, market (educational rule of three). Administrative level, grass roots level. Verbal, memo, newsletter, courtesy audit.

24. The OSHA Laboratory Standard Implementation Initial Audit Keep it simple What is really important to know Involve everyone

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26. The OSHA Laboratory Standard Implementation Make it as “painless” as possible Boilerplate document Common SOP’s Forms for chemical inventory, training records Internet access Customer service Implementation guidelines (What do I have to do?) Provide general training (keep it short)

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28. The OSHA Laboratory Standard Implementation Accentuate the positive Recognize achievers Report positive statistics Report and communicate progress Assist the willing, ignore the others Let Administration deal with the unconvinced

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30. The OSHA Laboratory Standard Implementation Fine tuning Field audits Training records Shift from catch-up to keep-up Maintain momentum Inspections

31. The OSHA Laboratory Standard • Implementation Hood Maintenance, repair Hood Flow monitoring devices Shower eye wash maintenance Equipment PPE, Storage cabinets, spill kits Floor Plans

32. The OSHA Laboratory Standard Implementation Exposure monitoring “Reason to believe” Odor threshold<PEL Signs or symptoms Spills, accidents Random direct measurement Medical Surveillance

33. Inspections The OSHA Laboratory Standard

34. The OSHA Laboratory Standard Resources Laboratory Health and Safety Handbook R.Scott Stricoff and Douglas B. Waters CRC Handbook of Laboratory Safety Keith Furr Prudent Practices in the Laboratory National Academy Press

35. The OSHA Laboratory Standard Questions?