Section 14

Laboratory Standard

Introduction

Faculty members and students are occasionally exposed to hazardous chemicals such as acetone, bromine, carbon monoxide, formaldehyde, hydrogen sulfide, mercury and nitric acid in campus laboratories. Many accidents and injuries occur annually in laboratories resulting in chemical related illnesses ranging from skin and eye irritation to fatal pulmonary edema.

OSHA’s Laboratory Standard 29 CFR 1910.1450 emphasizes the use of work practices and effective individual protection appropriate to the unique nature of the laboratory. This performance-oriented regulation is intended to provide colleges and universities with the flexibility of implementing safe work practices and procedures specific to their laboratories while at the same time reaching the important goal of reducing injuries and illnesses.

The Laboratory Standard applies to all individuals who work with hazardous chemicals in science and engineering laboratories. Work with hazardous chemicals outside of laboratories is covered by the Hazard Communication Standard, which is covered in Section 13 of this manual. Laboratory uses of chemicals which provide no potential for exposure (e.g., chemically impregnated test media or prepared kits for pregnancy testing) are not covered by the Laboratory Standard.

Although the laboratory safety provisions apply to faculty and other employees such as lab assistants, they do not specifically apply to the student population. However, as a best practice, it is clearly in the best interest of the institution to apply the requirements within the Standard to the student population.

Policy

An individual should be assigned the responsibility for the overall administration of the campus Laboratory Safety Program. The individual should be given the authority to organize an Advisory Committee to oversee the Program.

Note: Children are not allowed in areas where chemicals are present.

Scope

The areas covered by the Laboratory Standard are determined by their conformance with the “laboratory use” and “laboratory scale” criteria, as defined by the Standard. The Standard covers all chemicals meeting the definition of health hazard, as detailed in OSHA’s Hazard Communication Standard 29 CFR 1910.1200.

Although the Laboratory Standard does not specify provisions for work practices to protect employees from potential physical hazards associated with chemicals used in the workplace, it does require that such physical hazards be addressed in the employer’s training program. (See 29 CFR 1910.1450 (f)(4)(B).)

The Laboratory Standard requires continued compliance with OSHA’s permissible exposure limits (PELs) and with the employer’s written Chemical Hygiene Plan. In order to provide additional safeguards for laboratory employees and students who work with these chemicals, the standard also requires special consideration for substances that are thought to be particularly hazardous, including “select carcinogens” as defined by the Standard, reproductive toxins and substances that have a high degree of acute toxicity.

Chemical Hygiene Plan Requirements

The written Chemical Hygiene Plan is the core of the Standard and affords flexibility in providing the type of individual protection appropriate for a specific laboratory. This plan, which is to be developed by the institution, specifies the training and information requirements of the Standard. It also establishes appropriate work practices; standard operating procedures, methods of control, measures for appropriate maintenance and the use of protective equipment, medical examinations and special precautions for work with particularly hazardous substances. The institution is required to evaluate the effectiveness of the Plan at least annually and to update it as necessary. The written Plan must be available to employees, their designated representatives and to the Assistant Secretary of Labor for Occupational Safety and Health.

As part of the written Plan, the institution is required to designate a Chemical Hygiene Officer and, if appropriate, to establish a Chemical Hygiene Committee to provide technical guidance in developing and implementing the provisions of the Plan. The Chemical Hygiene Officer may have a variety of duties such as monitoring, procuring, helping project directors upgrade facilities and advising administrators on improved chemical hygiene policies and practices.

A discussion of the components of the Chemical Hygiene Plan follows.

Employee Information and Training

As part of the written Plan, an employer must establish a training and information program for employees exposed to hazardous chemicals in both the laboratory and workplace. The training program should be initiated at the time of the initial assignment and prior to assignments involving new exposure situations. This provision incorporates the training and information requirements of the Hazard Communication Standard, which includes training on physical and health hazards, thus increasing the protection of laboratory workers.

Information—At minimum, the discussion topics must include the following:

  1. The existence of the Chemical Hygiene Plan and requirements of the Laboratory Standard.
  2. The location and availability of the employer’s Chemical Hygiene Plan.
  3. Permissible exposure limits for regulated substances and recommended exposure limits for other hazardous chemicals where no OSHA standard applies.
  4. Signs and symptoms associated with exposures to hazardous chemicals.
  5. Location and availability of known reference materials, including Material Safety Data Sheets (MSDSs) on the hazards, safe handling, storage and disposal of hazardous chemicals in the workplace.

Training—The employee training plan must consist of the following elements:

  1. The components of the Chemical Hygiene Plan and how it is implemented in the workplace.
  2. The hazards of the chemicals in the work area and the protective measures those employees can take.
  3. Specific procedures put into effect by the employer to provide protection, including engineering controls, work practices and personal protective equipment.
  4. Methods and observations—e.g., continuous monitoring procedures, visual appearance or smell—that workers can use to detect the presence of hazardous chemicals.

Medical Examinations and Consultation

The Laboratory Standard does not mandate medical surveillance for all laboratory workers. There are, however, certain circumstances where employers must provide any employee who works with hazardous chemicals an opportunity for medical attention.

Specifically, medical attention, including any follow-up examination and treatment recommended by the examining physician, must be offered to the following:

Any employee or student who exhibits signs or experiences symptoms associated with exposure to a hazardous chemical used in the laboratory.

Any employee or student who is exposed routinely above the action level or, in the absence of an action level, above the PEL for an OSHA regulated substance for which there are exposure monitoring or medical surveillance requirements.

As a best practice (although not required under the Standard), such examinations and consultations should be extended to students as well.

A medical consultation conducted to determine the need for a medical examination must be offered to any employee who is present in the work area when a spill, leak, explosion or other accident occurs that results in a potential significant exposure to a hazardous chemical.

The employer is required to give to the physician specific information on the identity of the hazardous chemical, conditions under which the exposure occurred and a description of the signs and symptoms experienced by the worker. The employer also must obtain from the physician any written opinion for a recommended follow up examination, medical exam and the attendant test results; any detected medical conditions of the employee that might pose increased risk; and a statement that the employee was informed of the medical examination/consultation results.

Methods of Control and Personal Protective Equipment

As part of the Chemical Hygiene Plan, employers must develop criteria for determining and implementing control measures to reduce employee exposure to hazardous chemicals in the laboratory. Traditionally, these measures have included engineering controls, work practice controls and personal protective equipment. Engineering controls include general ventilation, fume hoods, glove boxes and other exhaust systems. Work practice controls may cover items such as restricting eating and drinking areas, prohibiting mouth pipetting and performing work in such a manner as to minimize exposures to hazardous chemicals and to maximize the effectiveness of the engineering controls.

OSHA policy dictates that engineering and work practices controls are used to reduce employee exposure below the PEL. Respiratory protection is to be used only as an interim measure or when engineering or work practice controls are infeasible. Tasks requiring the use of respiratory protection are to be contracted out (see Appendix 17-G). Other personal protective equipment that must be used in laboratories, if appropriate, includes items such as safety glasses, whole body coverings and gloves.

Safeguards for Particularly Hazardous Substances

Employers must consider including in the Chemical Hygiene Plan additional protective measures, where appropriate, for work involving select carcinogens, reproductive toxins and substances having a high degree of acute toxicity.

Specific consideration must be given to incorporating the following provisions:

Establishment of a designated area with appropriate signs warning of the hazards associated with the substance.

Use of a fume hood or equivalent containment device.

Cleaning of fume hoods at the end of each semester.

Procedures for decontaminating the designated area.

Procedures for safe removal of contaminated waste.

Hazard Identification

Employers must make certain that labels on containers of hazardous chemicals are not removed or defaced. They also must maintain any MSDSs received with incoming shipments of these chemicals and make sure they are available to employees. MSDSs are documents that provide specific information about chemicals, such as their chemical identities, physical properties, associated health hazards, reactivity data, control measures and precautions for safe handling and use.

The employer is not required to prepare an MSDS except in cases where a chemical is produced in the laboratory for another user outside of the laboratory.

Recordkeeping

Employers also must establish and maintain for each employee an accurate record of exposure monitoring results and any medical consultation and examinations, including tests or physician medical opinions. Such records must be kept, transferred and made available in accordance with OSHA’s rule governing access to employee exposure and medical records, 29 CFR 1910.1020.

Under this regulation, exposure records and data analyses based on them are to be kept for 30 years. Medical records are to be kept for at least the duration of employment plus 30 years. Medical records of employees who have worked for less than one year need not be retained after employment, but the employer must provide these records to the employee upon termination of employment.

Although there are no recordkeeping requirements for students, it is suggested that as a best practice records for students be maintained in the same manner as those for employees.

Summary

The requirements of the Laboratory Standard provide employers, employees and students in laboratories with a flexible and viable alternative to traditional substance specific regulations. Compliance with this regulation and implementation of the Chemical Hygiene Plan will provide employees and students with the information and training necessary to improve workplace safety and health and to reduce the number of chemical-related injuries and illnesses in laboratories.

Appendix 14-A

Sample Chemical Hygiene Plan

Introduction

It is the policy of (institution name) to enforce safe work and chemical hygiene practices in our laboratory/laboratories within (insert laboratory location/s).

It is the goal of (institution name) to minimize chemical exposures to people, property and the environment. To this end, we have established a comprehensive Chemical Hygiene Plan as required under OSHA 29 CFR 1910.1450, Appendix A.

Note: Children are not permitted in laboratories or other areas where chemicals are in use.

Scope and Application

This Chemical Hygiene Plan establishes policies, procedures and work practices intended to protect employees from health hazards associated with work involving chemicals, particularly in laboratories. It covers employees (including student-employees, technicians, supervisors and researchers) who handle chemicals at the institution. It also covers laboratory students who may be handling chemicals as part of the educational process. This Chemical Hygiene Plan is available for review by any campus employee/student or his/her representative. It is the responsibility of every person covered by this Standard to comply with the safety guidelines established in this Plan.

Responsibilities

Chemical Hygiene Officer

The following employee is responsible for administering and enforcing this Chemical Hygiene Plan and will act as our campus Chemical Hygiene Officer (CHO): [Insert name of designated CHO]

Specific responsibilities include the following:

  1. Identify the physical and health risks of the various chemicals used in the institution’s laboratory facilities.
  2. Develop and implement specific policies and procedures to minimize the risks from the identified hazards.
  3. Perform and document regular, formal chemical hygiene inspections, including inspections of emergency equipment.
  4. Develop Standard Operating Procedures specific to each laboratory’s operations.
  5. Determine the proper level and type of Personal Protective Equipment (PPE) for lab operations.
  6. Ensure that appropriate training has been provided to affected employees and students.
  7. Maintain a current knowledge concerning the legal requirements of the regulated substances handled in the labs.
  8. Provide monitoring for permissible exposure limits (PELs).
    (29 CFR 1910.1000, Z-1 Tables, Z-2 Tables, Z-3 Tables)

Laboratory Supervisor

If there is no designated CHO, the responsibilities listed above will be assumed by the Laboratory Supervisor.

Laboratory Workers and Students

Workers and students are individually responsible for planning and conducting their laboratory operations in accordance with this Chemical Hygiene Plan and good chemical hygiene practices.

Institutional Activities

Each institutional activity involving chemicals can be identified by a specific task. Each task is further defined through the identification of potential hazards associated with performing the task.

Monitoring

Due to the consistent presence of potential airborne hazards in a laboratory setting, it is the policy of (institution name) to routinely monitor for changes in air quality, using direct-reading instruments. Monthly, the CHO shall evaluate the effectiveness of the air handling equipment used to reduce or eliminate airborne contaminants. Fume elimination hoods, point source fume eliminators and ventilation systems in the following areas shall be evaluated:

(List the location of ventilation hoods)

Using a velometer, quantitative airflow measurements shall be taken. Processes that routinely use specific chemicals that may produce chronic health effects shall be monitored on a monthly basis using calorimetric tubes or the best available equipment.

Emergency equipment shall be monitored for preparedness on a monthly basis. This equipment includes but is not limited to the following:

Fire Extinguishers (See Emergency Fire Prevention Plan)

Eyewash Stations

Smoke Detectors

Safety Showers

Spill Kits

In addition, testing may be done at any time on an as-needed basis as determined by the CHO or Laboratory Supervisor.

All test results will be documented and specific corrective action will be taken when the level of contaminant exceeds the applicable level (e.g., PEL, TLV, etc.).

Laboratory Chemicals

(Institution name) stores, processes and handles many chemicals in its laboratory/laboratories. The following campus employee under our campus Hazard Communication Program as defined by 29 CFR 1910.1200 maintains a comprehensive list of all chemicals used in our laboratory/laboratories.

(Person responsible for lists of chemicals)

In addition, a comprehensive inventory of laboratory chemicals shall be conducted annually. The following information should be included:

Product/Chemical Name

MSDS number

Date Received

Quantity Received

Age Sensitive (Y/N)

Date of Inventory

Quantity of Inventory

Primary Hazards

Chemical Procurement

Whenever a chemical is received for use in our campus laboratory/laboratories, it is the responsibility of the CHO to ensure that employees/students whose institutional activity requires working with or around the chemicals receive information on the proper handling, storage and disposal of the chemical.

Note: To control chemicals on campus, all chemicals should be delivered to a centralized receiving area. The area is ______.

Material Safety Data Sheet

Material Safety Data Sheets are maintained for all chemicals used in our campus laboratory and can be accessed through the CHO (or the established database).

Sample materials submitted for analysis or unknown materials received by our campus shall be handled according to routine practices. These practices include labeling, handling, storage and disposal procedures.

Stockroom Storage

Bulk chemicals for use in the laboratory/laboratories shall be separated in a storage area that is clearly identified and well ventilated. Highly toxic chemicals and other chemicals whose containers have been opened will be placed in a secondary non-breakable container, such as a plastic or metal tray, in order to contain a spill or leak.

An employee shall be assigned to inspect chemicals stored in the stockroom/s for replacement, deterioration and container integrity on a monthly basis.

Chemical Transfer

The maximum size container used to store chemicals in our laboratory/laboratories is five gallons. Chemicals that are received in larger quantities shall be placed in smaller appropriate containers and labeled accordingly prior to transfer to the laboratory. Chemicals that are transferred to the laboratories from the receiving area or stockroom storage shall be placed in an outside container or bucket prior to transfer. All chemicals transferred to the laboratories from the receiving area shall be recorded in the chemical inventory prior to being used in the laboratories.

Any transfer of flammable liquids between containers should only be performed when the containers are properly grounded and bonded.

Laboratory Storage

Samples, unused chemical product and hazardous wastes shall be stored in separate locations and will remain segregated for storage purposes.