Laboratories, 29 CFR § 1910.1450; see Appendix A). In brief, the OSHA Laboratory Standard requires organizations to
1. Keep laboratory personnel exposures to chemicals below OSHA’s PELs.
2. Write a Chemical Hygiene Plan.
3. Designate a Chemical Hygiene Officer to implement the plan.
4. Train and inform new laboratory personnel of
• the OSHA Laboratory Standard,
• the Chemical Hygiene Plan and its details,
• OSHA’s PELs,
• the signs and symptoms of exposure to hazardous chemicals,
• Prudent Practices in the Laboratory,
• methods to detect the presence of hazardous chemicals,
• the physical and health hazards of the chemicals, and
• measures to protect laboratory personnel from chemical hazards.
5. In certain circumstances, provide laboratory personnel access to medical consultations and examinations.
6. Keep labels of supplied chemicals intact.
7. Maintain the MSDSs for all your supplied chemicals.
8. For chemical substances developed in your laboratory, train laboratory personnel as described above.
9. Use respirators properly.
It is important to understand that the OSHA PELs and substance-specific standards do not include all hazardous chemicals. It is the laboratory manager’s responsibility under the Laboratory Standard and its general duty clause to apply scientific knowledge in safeguarding workers against risks, even though there may be no specifically applicable OSHA standard. In circumstances where exposure limits are exceeded or where work with particularly hazardous substances is conducted, laboratories must keep records of exposure monitoring and medical surveillance.
The Laboratory Standard refers to the National Research Council’s Prudent Practices for Handling Hazardous Chemicals in Laboratories (NRC, 1981) as “nonmandatory … guidance to assist employers in the development of the Chemical Hygiene Plan.”
One of the most common Laboratory Standard OSHA citations has been for failure to have a Chemical Hygiene Plan or for missing an element in the plan. Another commonly cited violation is failure to meet the employee information and training requirements of the Laboratory Standard.
11.C.2.1 The Chemical Hygiene Plan
The centerpiece of the Laboratory Standard is the Chemical Hygiene Plan. This is a written plan developed by employers. It has the following major elements:
• employee information and training about the hazards of chemicals in the work area, including how to detect their presence or release, work practices and how to use protective equipment, and emergency response procedures;
• circumstances under which a particular laboratory operation requires prior approval from the employer;
• standard operating procedures for work with hazardous chemicals;
• criteria for use of control measures, such as engineering controls or personal protection equipment;
• measures to ensure proper operation of fume hoods and other protective equipment;
• provisions for additional employee protection for work with “select carcinogens” (as defined in the Laboratory Standard) and for reproductive toxins or substances that have a high degree of acute toxicity;
• provisions for medical consultations and examinations for employees; and
• designation of a Chemical Hygiene Officer.
Some firms and institutions have developed a single generic Chemical Hygiene Plan for the entire organization. To be most effective, however, the plan should include detailed protections that are specific to each laboratory, project, experiment, procedure, and worker. Laboratory-specific plans allow considerable flexibility in achieving the performance-based goals of the Laboratory Standard. Model Chemical Hygiene Plans are available from your state OSHA consultation service or the American Chemical Society.
11.C.2.2 Particularly Hazardous Substances
There are special provisions in the Laboratory Standard regarding work with “particularly hazardous substances,” a term that includes “select carcinogens,”