Occupational Exposures to Hazardous Chemicals in the Laboratory Standard
In January of 1990 OSHA issued this Laboratory Standard. This standard was created because OSHA realized that laboratory use of hazardous materials was quite different than industrial use. In the science laboratory, small quantities of many hazardous materials are used. The main requirement of the Lab Standard is that employers must control exposures to hazardous chemicals at safe levels established by OSHA. For laboratory workers, this standard supersedes the Hazard Communication standard.
- Chemical Hygiene Plan -- This document required
by OSHA states the procedures, policies, and protocols necessary to
keep the employee exposure below hazardous levels. The Chemical Hygiene
Plan (CHP) describes the standard operating procedures that lab
workers must follow when handling hazardous materials. It also list the
controls that the employer has in place to protect employees from these
unsafe levels. Some of these controls are personal protective
equipment, hygiene practices, and special equipment such as fume hoods.
Denison University has developed a CHP for the hazardous materials on our campus. Dr. Richard Doyle wrote the first CHP which has been updated yearly. OSHA stipulates that the CHP must be accessible by all lab employees. Therefore the CHP has been placed on the Campus CWIS. You can also access it from the Security and Safety Home Page or by clicking on CHP
- Monitoring Requirements -- The Lab Standard
requires employers to monitor hazardous materials levels in the work
area if there is concern that the exposure levels may exceed recognized
safety limits. If such monitoring indicates that overexposure occurred,
the employer must reduce those levels. And the employer must then
re-monitor the hazardous levels to make sure the problem has been
corrected.
- Employees Opportunity for Medical Opinion
-- Employers must provide lab employees with an opportunity to get a
medical exam if they may have been overexposed to a hazardous chemical
in the laboratory. Evidence that may suggest overexposure includes
symptoms of overexposure, a hazardous materials accident, or monitoring
that reveals routine levels exceeding permissible exposure levels. The
employer must provide this medical exam at no cost to the employee and
at a time and place convenient for the employee. The employee and
employer will be provided with the results of the exam including
recommendations for follow-up.
- Employee Training and Information
-- Again, as with the Hazard Communication standard, OSHA understands
the importance of training. The best way to protect employees is to
train them about the dangers of the hazardous materials they may use
and how to protect themselves against overexposure.
Employers must provide the employees with the OSHA-established permissible exposure levels (PELs) for the materials they use. Employees should be trained the signs and symptoms associated with overexposure to hazardous materials. The employee also must be made aware of the health hazards associated with overexposure. The training should include how to detect the presence of hazardous materials in the laboratory.
The training should focus on the CHP. OSHA requires that the lab employee knows where the CHP is located and how to follow the procedures in it. This plan should be reviewed with the employee to make them aware of the specific procedures to prevent overexposure including correct work practices, personal protective equipment, and emergency response procedures.
Training should also include access to the MSDSs for hazardous materials on site and how to read and understand the MSDSs. The MSDSs contain specific information on handling, storage, disposal, and first aid in case of exposure to the hazardous chemical. These documents do not have a standard format and are full of acronyms that make understanding them difficult. Therefore, the employer must make an extra effort to assure the employees knows how to interrupt the MSDSs.
OSHA is flexible on how this training should be carried out. But they are very harsh as to the fines imposed if they feel the lab employees have not been adequately trained. The typical scenario of an OSHA inspector's visit might be like this:
During an inspection, the OSHA inspector sees a lab worker handling a solvent such as hexane or acetone. He ask the worker, "Have you read the MSDS for that solvent? Do you know where the MSDSs are located? Where is the CHP located? Have you read it?"
If the lab worker does not answer these questions satisfactorily, the inspector can impose heavy fines on Denison University for failing to comply with the training requirements for affected lab workers, which OSHA views as a "willful violation",
- Hazard Labeling and Identification
-- Employers must make sure that all containers of hazardous materials
arriving on site be properly labeled. The label cannot be removed or
defaced without replacing it with another appropriate label. The MSDS
for new hazardous chemicals must be maintained and available to the lab
employees.
If a material is produced in the laboratory, the employers is responsible to determine if it is hazardous. Until that determination is made, the material should be treated as if it is a hazard.