OSHA Laboratory Safety Standard

A key item of the fixed equipment in most research laboratories other than those employing only the least hazardous materials is a work enclosure, usually denoted, at least for chemicals, by the common name fume hood. The OSHA Laboratory Safety Standard, while stopping short of requiring a fume hood in each laboratory, does point out that work with almost any hazardous substances can be done safely if done in a suitable, properly functioning, hood. Some laboratory facihties have been constructed recently with no open bench space, with all work within the facility being done within... 

A major and valid justification for OSHA to adopt the laboratory safety standard to supersede the general industry standards and the hazard communication standard for the laboratory environment was thatthe laboratory environment is radically different from industrial facilities and most other types of occupations. The organizational structure for research institutions is not nearly so structured, especially in the academic environment,and operations are different in size and character. The laboratory standard uses this difference as a criterion as to whether the laboratory standard is to be applied to a program. 

In older descriptions in the literature, the role of the safety department was seen as largely advisory in the scientific work environment. Underthe OSHA laboratory safety regulations,each laboratory does have the responsibility for developing and carrying out its own chemical safety plan. However, the central administration of an organization has the responsibility to ensure that the industrial hygiene safety plans for individual laboratories comply with OSHA standards. 

One of the most devastating injuries a person can suffer is loss of eyesight. There are a number of protective measures which should be taken in the laboratory to prevent eye injury. However, should aU of these measures fail and chemicals enter the eye, an effective eyewash station is an essential item of fixed equipment that should be immediately available. Although superseded by the Laboratory Safety Standard, OSHA does require in Section 1910.151(c) of the General Industry Standards that... 

As stated in the section on the hazard communication standard. Section VII.B of this chapter, OSHA defines health effects, for the purposes of the standard, in Appendix A to 29 CFR 1910.1200. The definitions given below are from that appendix. The laboratory safety standard also specifically suggests using these same definitions for guidance in defining hazardous... 

Ethylene oxide is used here as an example of a carcinogenic compound and is one for which a specific standard was adopted by OSHA relatively recently (August 24, 1984). The standard, in its appendices, provides an unusually complete guide to the safe use of this material. The laboratory safety standard may modify some of the specific requirements, but adhering to them would form the basis of a sound management strategy. 

A key provision of the laboratory safety standard is that procedures be developed to ensure that it would be unlikely that any individual on a worst-case basis will exceed a 0.5 ppm action level for an 8-hour TWA exposure. These levels are to be measured without taking into account any respiratory protection provided by personal protective equipment. When any circumstance changes in such a way that the levels of exposure may increase, it will probably be necessary to demonstrate anew that the levels are lower than the action levels. Records of these data must be kept and available for examination. If the action levels are exceeded, steps must be taken to reduce the levels, preferably by means of engineering controls. Medical surveillance provisions of the laboratory safety standard would be invoked by persistent levels above the OSHA action levels. 

Chemical hygiene plan A written plan that addresses job procedures, work equipment, protective clothing, and training necessary to protect employees from chemical and toxic hazards, required by OSHA under its laboratory safety standard. 

Many state and federal clinical laboratory (CLIA) programs have included worker safety criteria, and the Canadian Office of Laboratory Security—strengthened in response to the possibility of bioterrorism—has added a laboratory safety division. Based upon these models it seems a reasonable prediction that OSHA will soon launch the process of coordinating and consohdating worker safety laboratory standards into a new and comprehensive code. 

Naturally, while awaiting additional investigation or laboratory test results, it may be necessary for preliminary reports, status reports, and draft reports. However, the final incident investigation report must satisfy the requirements of the OSHA Process Safety Management standard. An OSHA PSM report shall, at a minimum, include ... 

Becauseoftheindependenceofthe various divisions,orschools,in largerorganizations, the separate internal administrative units may find it desirable to establish their own safety committees. The unit committees would adapt the overall institutional safety policies which must be followed in the context of their own operations and areas of responsibility. It would probably be desirable to identify an individual as the division chemical hygiene officer to act as liaison with the individual representing the central authority. This position is not required, however, for a subunit (other than the laboratory) of an organization under the OSHA laboratory standard. 

Many actions are influenced by the costs involved, as in the preceding example. A continuing question involves who should be responsible for paying for safety facilities and equipment. Underthe OSHA laboratory standard, the adequacy of a facility toallowworktobe done safely is a key condition. There are some straightforward guidelines that can be used ... 

The person responsible for the work being performed in the laboratory is to be a competent scientist. This individual shall develop and implement a safety and health program for the facihty that meets the requirements of the OSHA Laboratory Standard. The individual workers are to be fuUy trained in the laboratory procedures being employed and to have received special training in the risks specifically associated with the materials or work being performed. The workers are to be informed about the means available to them to detect hazardous conditions and the emergency procedures that should be foUowed,... 

Comment by the California Association of Cytotechnologists re Xylene exposure re the OSHA Proposed Performance Standard for Laboratories Using Toxic Substances, 51 FR 26660, July 24, 1986. U.S. Department of Health and Human Services, Centers for Disease Control, National Institute for Occupational Safety and Health, Health Evaluation Reports HETA 83-048-1347, HETA 830076-1414, HETA 81-422-1387, Cincinnati, OH. 

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