As a laboratory manager the volume of paperwork (and computerwork) is ever increasing. Between quality control, testing procedures, fiscal accountability, and a host of other demands the lab manager is wearing more hats than ever. One of the more important hats is the safety hat. OSHA has several Standards that specifically task laboratory supervisors with requirements for assuring a safe workplace. One of the most obvious standards is “Occupational Exposure to Hazardous Chemicals in Laboratories” (29CFR.1910.1450). There are also a number of substance or hazard specific standards that address occupational exposure to over thirty substances including formaldehyde (29CFR1910.1048), blood borne pathogens (29CFR1910.1030), ethylene oxide (29CFR1910.1047) and benzene (29CFR1910.1028). The Hazard Communication Standard or “right to know” standard (29CFR1910.1200) is one of the standards most frequently cited by OSHA. There is a listing of even more substances and allowable limits provided in the “Air Contaminants” standard (29CFR1910.1000). This standard establishes limits on commonly used chemicals such as acetone, ammonia, chloroform, ethyl alcohol, toluene, and xylene. Finally, lest anyone feel neglected the Section 5(a)(1) of the “Occupational Safety and Health Act of 1970” requires that “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” This is the general duty clause that can be used to address any unsafe situation not specifically addressed in other regulations.
In this and successive issues of “Clearing the Air” we want to look at the listed OSHA standards and present some of the more common requirements placed on clinical and microbiological laboratories. For the complete requirements of the described standards and others that apply to your laboratory, contact your safety officer and/or appropriate regulatory authorities.
“Occupational Exposure to Hazardous Chemicals in Laboratories” (29CFR1910.1450), also called the lab standard, was designed to address the laboratory use of hazardous chemicals versus the industrial use. Laboratory use is described as where the chemical manipulations are carried out on a laboratory scale, multiple chemical procedures or chemicals are used, the procedures are not part of a production process, and protective laboratory practices and equipment are available and in common use. Laboratory scale is described as where the containers used for reactions, transfers, and other handling are designed to be easily and safely manipulated by one person.
One of the intents of the lab standard was to simplify the regulatory requirements for laboratories. The substance specific standards were typically designed to address industrial applications where larger quantities of the substances are used every day by many workers. In addition to establishing exposure limits, they describe requirements for exposure monitoring, signage, change rooms, medical surveillance, training, and other things. Some of the requirements seemed excessive for laboratories that may use a substance once or twice a month in very small quantities. Worse yet, some laboratories may use two or more of the substances regulated with substance specific standards and have to comply with multiple sets of requirements. The lab standard maintained the exposure limits set out in the substance specific standards, but provided laboratories with an alternative to the other requirements. Facilities that come under the lab standard are required to develop a chemical hygiene plan (CHP). The CHP is defined as a “written program developed and implemented by the employer which sets forth procedures, equipment, personal protective equipment and work practices” that are capable of protecting the employees from the hazardous chemicals being used in the laboratory. The CHP must protect the employees and keep the exposures below the permissible exposure limits specified in the federal regulations. The lab standard goes on to describe specific elements the CHP must address such as the standard operating procedures for working with hazardous chemicals, how the employer will determine appropriate control measures (such as personal protective equipment and hygiene practices), how the employer will assure the proper functioning of fume hoods and other protective equipment, and how are the employees informed and trained. There are other requirements for the CHP including designation of the personnel responsible to implement the plan (the chemical hygiene officer or CHO).
Although the CHP is required to be somewhat detailed, it can address many substances. Technically, a laboratory that used formaldehyde, xylene, and benzene a couple times a month in small quantities was required to demonstrate compliance to the formaldehyde standard and the benzene standard, as well as making sure that their employees were not exposed to excessive levels of xylene. The lab standard allows that lab to develop a CHP that addresses all the chemicals they work with and they only need to demonstrate that they have a good CHP and are following it.
Some laboratories may be required to meet certain substance specific standards. For example, the formaldehyde standard indicates that the standard become effective for anatomy, histology and pathology labs in it’s entirety on September 1, 1988.