OSHA Laboratory Standard: Promoting Safety in Labs

1. Laboratory Safety Chris James Oregon OSHA Senior Occupational Health Consultant

2. Labs vs Industry A Division of DCBS • Substance specific standards don’t work well for laboratories; labs likely handling more chemicals • Lab Standard addresses this • http://osha.oregon.gov/OSHARules/div2/div2Z-1450-occ-exp-haz-chem.pdf • http://osha.oregon.gov/OSHAPubs/2274.pdf

3. OSHA’s laboratory standard focuses on the unique nature of laboratory work, emphasizing knowledge, prudent work practices, and effective personal protection. This performance-oriented standard aims to reduce worker injuries and illnesses in a cost-effective way by allowing employers in industrial, clinical, and academic labs the flexibility to implement safe work practices and procedures specific to their workplaces.

4. “Laboratory Use” Must meet these conditions: A Division of DCBS • Laboratory Scale- Designed to be handled easily and safely manipulated by one person • Multiple chemicals/procedures • Not production or simulating production • Protective practices and equipment used

5. Outside Scope General Industry Rules apply for: A Division of DCBS • Chemicals for maintenance of lab • Production of chemical(s) for sale • Any quantity • Quality control testing of a product

6. “Laboratory scale” A Division of DCBS “Laboratory scale” means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. For this type of laboratory use, OSHA’s laboratory standard applies instead of all other health standards in Subdivision 2/ Z of the Oregon OSHA rules. For instance, the Hazard Communication Standard does not apply to this type of chemical use, so the requirements of the substance-specific standards in 2/Z would not apply except: • You must obey the part of an applicable standard that prohibits eye and skin contact. • You must not exceed the Permissible Exposure Limits (PELs) in the Air Contaminant rules or substance-specific standards. • You must follow the exposure monitoring and medical surveillance requirements of the laboratory standard if an action level listed in an applicable rule is routinely exceeded.

7. Chemical Hygiene Plan Written Plan Must specify: A Division of DCBS • Training & Information required by standard • Work Practices/SOPs • Controls/PPE • Medical Surveillance • Special Precautions for Particularly hazardous chemicals. • Must evaluate at least annually and update when any new hazards are introduced.

8. Chemical Hygiene Officer A Division of DCBS • May have other duties • i.e. Lab Manager • May be appropriate to setup a chemical hygiene committee

9. Required Information Must make available to employees: A Division of DCBS • OR OSHA Lab Standard • Written Chemical Hygiene Plan Implementation • OR OSHA Permissible Exposure Limits (PEL) or recommended limits • Physical and Health Hazards of Chemicals • Signs and symptoms of exposure • Safety Data Sheets (SDS)

10. Required Training A Division of DCBS • Details of Chemical Hygiene Plan • Hazards of chemicals used • Training on exposure controls • I.E. PPE use, respirators, etc • Methods to detect chemicals • How to use and evaluate fume hoods and other controls

11. Medical Attention A Division of DCBS • Medical Surveillance not specifically required • Must provide medical attention for chemical exposures at no cost if requested by employee, without loss of pay, and at a reasonable time and place. • Medical records maintained for duration of employment, plus 30 years. Exception: < 1 year of employment, can provide documents to employees when leaving.

12. Labeling Secondary Containers A Division of DCBS • Name of chemical • Hazards of chemical • Not required if used in same shift

13. Hoods A Division of DCBS

15. Most common OSHA citations (National data) A Division of DCBS • Occupational exposure to hazardous chemicals in laboratories. • Respiratory Protection • Maintenance, safeguards, and operational features for exit routes. • Portable fire extinguishers.

16. Summary Laboratory standard requirements provide employers and employees in labs with a flexible, viable alternative to traditional substance-specific regulation. Compliance with this regulation, including implementing a chemical hygiene plan, provides workers with the information and training necessary to improve workplace safety and health and to reduce the number of chemical related injuries and illnesses in labs.

17. CSB- Experimenting with Danger https://youtu.be/ALBWxGik64A

18. UCLA • Lack of PPE/ not fully utilized • May have been working alone • Handling highly reactive substance with an open flask of a flammable solvent nearby that spilled. • No documented evidence of adequate & appropriate training.

19. UCLA Outcome • Improve Safety Accountability & oversight • Improve training • Provide proper PPE • Conduct unannounced inspections • Improve Lab Safety Culture

20. Dartmouth • Professor • 1-2 droplets on gloved left hand • Did not report incident

21. Dartmouth Outcome • Nobody “knew” that this chemical could seep through the gloves worn. • “Unimaginably shocking”- Dead within 10 months. • Implement comprehensive hazard evaluations rather than relying on SDS. • Discovery of a “real need” for deeper understanding of chemical interactions, especially with PPE. • Wake Up Call/ Signature Event

22. TTU • 2 grad students; worked with this material >1 year • Energetic or Explosive Compound(s) • Concern with variability of small batches- GO BIGGER! • “They believed” keeping it wet with solvent would prevent explosion. • More senior grad student removed goggles • Explosion • Lost 3 fingers • Perforated eye • Cuts & burns to other parts of body • Extensive Lab Damage/ flying projectiles

23. TTU Outcome • Tendency to blame operator(s). • Insufficient safety & accountability by PI’s, Chemistry Department and TTU Administration. • Grad students had not received any formal training with explosive compounds. • “Verbal agreement”- batch size limit- no discovery. • Use of PPE not consistently enforced. • Change Safety Culture • 2 Prior “near misses”- nothing learned

24. TTU Outcome • Create tracking system to document near misses, incidents, accidents to facilitate learning. • Grant funding entity (DHS) did not impose any specific safety requirements with compound(s) and TTU did not evaluate the hazards. • Grad students had not received any formal training with explosive compounds. • Revised and expanded CHP to ensure Physical Hazards are evaluated and controlled. • Resulted in a lot of momentum for Safety Consciousness

25. Key Lessons • Same high standard for excellence extended to Lab Safety and EHS Programs. • Ensure research specific hazards are evaluated and controlled by developing specific written protocols & training. • Expand Lab Safety Plans to address physical hazards. • Chain of Command- Safety reports directly to appropriate personnel with authority to oversee & implement safety improvements. • Document and communicate all near misses & incidents.

26. “Exploring unknown involves risk Accepted by Society, but we need to approach these risks as safely as possible.”