The Basics of Laboratory Safety: What must be in place?

What is a laboratory?

In Section (b) of 29 Code of Federal Regulation (CFR) 1910.1450 – Occupational exposure to hazardous chemicals in laboratories, OSHA/VOSH defines a laboratory as “a facility where the ‘laboratory use of hazardous chemicals’ occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.” Hazardous chemicals are defined as “…any chemical which is a physical or a health hazard.”¹

“Laboratory use of hazardous chemicals” means handling or use of such chemicals in which all of the following conditions are met:

Chemical manipulations are carried out on a “laboratory scale;”
Multiple chemical procedures or chemicals are used;
The procedures involved are not part of a production process, nor in any way simulate a production process; and
“Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.²

“Laboratory scale” means working with substances where the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person.³

Commonwealth of Virginia facilities house laboratories of various types, including educational, research, medical and veterinary, forensics, and analytical testing. Several basic programs and safeguards must be in place to protect the laboratory employees in each of these settings. A comprehensive laboratory employee safety program combines OSHA/VOSH standards included under 29 CFR 1910 Subpart Z (Toxic and hazardous substances) and Subpart I (Personal protective equipment [PPE]) with industry best practices.

Subpart Z of 29 CFR 1910 contains the standards associated with toxic and hazardous substances. Two of these have a direct relationship with exposures in a laboratory. They are sections 1910.1200 – Hazard communication and 1910.1450 – Occupational exposure to hazardous chemicals in laboratories, also known as the “laboratory standard.” What is the difference? The hazard communication standard addresses the evaluation of the potential hazards of chemicals, communicating information concerning hazards and appropriate protective measures to employees. The laboratory standard further defines these issues as they relate to laboratories. The laboratory standard supersedes the hazard communication standard where appropriate, but when it does not apply, the hazard communication standard does apply.⁴

Hazard communication

The hazard communication standard achieves the goal of communication through the use of:

A written program
Labels and other forms of warning
Material safety data sheets (MSDS)
Information and employee training⁵

The written program describes how these requirements will be met. In addition, a chemical inventory list of the hazardous chemicals known to be on-site should be compiled. These materials should be listed as identified on the corresponding MSDS. Lists may be developed for the entire operation or by separate work areas. For example, one list could contain chemicals used in a laboratory and another list could include those used by maintenance or housekeeping employees.

In laboratories, employers are responsible to make sure that chemicals are received with the appropriate MSDS, and that proper labels are attached and in good condition. The MSDSs are to be “readily accessible to laboratory employees during each work shift when they are in their work areas.”⁶ Paragraph (b)(3)(iii) of the hazard communication standard (1910.1200) requires employers to see that laboratory employees receive information and training as outlined in paragraph (h) of the hazard communication standard.⁷

The laboratory standard, 29 CFR 1910.1450, is intended to apply in laboratories that meet OSHA/VOSH’s definition of a laboratory, superseding “the requirements of all other OSHA health standards in 29 CFR 1910, subpart Z, except:

For any OSHA health standard, only the requirement to limit employee exposure to the specific permissible exposure limit shall apply for laboratories, unless that particular standard states otherwise or unless the conditions of paragraph (a)(2)(iii) of this section apply. [1910.1450(a)(2)(i)]
Prohibition of eye and skin contact where specified by any OSHA health standard shall be observed. [1910.1450(a)(2)(ii)]
Where the action level (or in the absence of an action level, the permissible exposure limit) is routinely exceeded for an OSHA regulated substance with exposure monitoring and medical surveillance requirements shall apply. [1910.1450(a)(2)(iii)]”⁸

Laboratory standard The laboratory standard is made up of six main parts, including:

Employee exposure determination
Written plan (Chemical Hygiene Plan)
Training
Medical consultation and examinations
Hazard identification
Recordkeeping⁹

Initially, the employer must determine employee exposures to hazardous substances believed to be present. If the hazardous substances are required to be monitored by an OSHA/VOSH standard and exposure levels may routinely exceed action levels, then periodic exposure monitoring is required. The exposure monitoring should be conducted under the guidelines of the applicable standard. Employees must be notified of the monitoring results in writing within 15 days of receipt by the employer.

The chemical hygiene plan (CHP) is a written document that specifically outlines the standard operating procedures of the laboratory as related to the use, storage, and disposal of hazardous chemicals. It is a vital tool in training employees and ensuring that the laboratory safety policies and procedures are being followed. In addition to standard operating procedures, the CHP should address exposure control methods, such as PPE, engineering controls, and hygiene practices. Other factors to include are the proper operation of equipment, such as fume hoods, special permission requirements, provisions for working with highly hazardous substances, decontamination, and disposal. The CHP is a good place to outline medical consultation and examination provisions, as well as the training requirements as mandated by the laboratory standard.

An employee, who is qualified by training or experience, should be designated as chemical hygiene officer to make sure the CHP is implemented and reviewed annually. If appropriate, a chemical hygiene committee should be established. The written CHP should be readily available to laboratory employees.

Training should be provided initially and whenever there is a change in the laboratory or a new exposure is identified. Retraining requirements can be determined by the employer. Training should include:

Contents of the standard
Location of the CHP
Details of the CHP
Exposure limits for the chemicals being used
Signs/symptoms of exposure
Location and availability
- Reference materials
- Safe handling procedures
- Storage and disposal
- MSDSs
How to detect the presence or release of a hazardous chemical
The physical and health hazards of the chemical
Protective measures
- Work practices
- Emergency procedures
- PPE ¹⁰

The laboratory standard outlines the guidelines associated with medical examinations and consultation in paragraph 1910.1450 (g)(1-4). Under certain conditions, laboratory employees must be given the chance to receive medical attention at no cost, including any necessary follow-up visits. This evaluation must be completed by or supervised by a licensed physician. This service must be made available under the following situations:

Employee develops a sign or symptom of an exposure
Monitoring reveals exposure over permissible limits
Potential exposure occurred
- Spills
- Leak
- Explosion¹¹

The physician must be informed of the signs and symptoms the employee is experiencing, the identity of the chemical, the details of how the exposure occurred, and the quantities involved. Following the examination, the physician must provide a written opinion that includes:

Recommendation for follow-up
Results of medical exam and tests
Condition(s) which could cause increased risk to employee
Statement that the employee has been informed of the results¹²

Any conditions revealed in the examination not related to the exposure should not be included in the written opinion.

Hazard identification of chemicals is dependant on two main sources of information: the container label and the MSDS. It is the employer’s responsibility to make sure that the materials are received with the proper labeling in place and that these labels remain in good, useable condition. Each shipment of material should also be accompanied by the corresponding MSDS. Each MSDS should be maintained in accordance with hazard communication standard and kept readily accessible to employees. The employer is also responsible to determine and identify any hazards and safeguards necessary for any by-products produced.

The laboratory standard also indicates that certain records be retained. Records to be maintained include:

Training documentation
Exposure monitoring
Medical consultation/examination¹³

These records should be kept in accordance with 29 CFR 1910.1020 – Access to employee exposure and medical records, of Subpart Z. With some exceptions, most exposure and medical records must be maintained for the employee’s period of employment plus 30 years. Access may also be restricted under this standard.

Appendix A of 29 CFR 1910.1450 lists the non-mandatory National Research Council recommendations concerning chemical hygiene in laboratories and should provide helpful information for developing a CHP.

Respiratory Protection

There may be situations under the laboratory standard where the use of a respirator is required to bring exposure levels to within permissible limits. In these cases, the OSHA/VOSH respiratory protection standard 29 CFR 1910.134 applies. For additional information related to the respiratory standard, refer to the Workers’ Compensation Services – Loss Control (WCS-LC) web article titled, “Respiratory Protection: The Right Respirator” (April 2006).

Bloodborne Pathogens

Employees in some laboratories in the Commonwealth may be exposed to biological or potentially infectious materials as well as chemicals. The necessary precautions for protecting employees by controlling exposures through a written exposure control plan are defined in 29 CFR 1910.1030, the bloodborne pathogens standard of Subpart Z.

The WCS-LC web article Preventing Bloodborne Pathogen Exposures (April 2004) provides information regarding bloodborne pathogen exposures and controls. Also, Bloodborne Pathogens Compliance Instruction, (CPL 2-2.69) is available on OSHA’s website at www.osh a.gov.

Personal Protective Equipment

The proper selection and use of PPE is another key factor in protecting laboratory employees from hazardous materials. OSHA/VOSH standards 29 CFR 1910.132-138 address the requirements for a comprehensive written PPE program. Under the PPE standards, the employer is responsible for making sure the following are completed:

Performing and documenting a “hazard assessment”
Identifying and selecting appropriate PPE
Training employees
Enforcing proper use of PPE
Periodically reviewing, updating, and evaluating the effectiveness of the PPE program¹⁴

In laboratories, protective clothing, eye and face protection, and gloves are the key forms of PPE in use. However, exposure monitoring may mandate the use of respiratory protection as well. To ensure that the correct PPE is being used by employees, identification of hazards and exposures must be performed through a hazard assessment of the laboratory environment and procedures. With this information, appropriate PPE can be chosen. Employees must then be trained regarding:

When PPE is necessary
What PPE is necessary
How to put on, take off, adjust ,and wear PPE
Warning labels
Limitations of the PPE
Cleaning, maintenance, and proper storage of PPE
Inspection of PPE
Replacement and/or disposal of PPE¹⁵

It is the responsibility of the employer to enforce the proper use of PPE. However, for all PPE, if it fits and is comfortable, it is more likely to be worn. If it does not fit or fits poorly, it will not provide the necessary protection.

Emergencies

In all laboratories, there is the chance that an emergency will occur. Emergencies may involve a chemical spill, fire, or a medical problem. An emergency response plan should be in place to ensure that appropriate measures are taken in an emergency. This plan should consider all of the possible emergency situations that may arise given the particular activities in the specific laboratory. Employees should be trained in what actions to take and participate in practice drills to increase the chance that they will react appropriately in the event an emergency does occur. A common acronym to help remember the steps to take is N.E.A.R. or Notify, Evacuate, Assemble, Report.¹⁶ Notify the proper responders of the situation; Evacuate if necessary; Assemble and account for all laboratory employees, and produce a Report as to what happened, followed by an investigation and appropriate response with the goal of preventing future occurrences.

OSHA/VOSH standards provide a good foundation for providing laboratory employees with a safer work environment. The next article in this series, “The Basics of Laboratory Safety (Part Two): What should be in place?” will discuss industry best practices, the next component in the development of a strong and comprehensive laboratory safety program.

¹ U.S. Department of Labor, Occupational Safety and Health Administration. “OSHA standard, 29 CFR 1910.1450.” Retrieved December 12, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

² Ibid.

³ Ibid.

⁴ Ibid.

⁵ U.S. Department of Labor, Occupational Safety and Health Administration. “OSHA standard, 29 CFR 1910.1200.” Retrieved December 12, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

⁶ Ibid.

⁷ Ibid.

⁸ U.S. Department of Labor, Occupational Safety and Health Administration. “OSHA standard, 29 CFR 1910.1450.” Retrieved December 12, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

⁹ Ibid.

¹⁰ Ibid.

¹¹ Ibid.

¹² Ibid.

¹³ Ibid.

¹⁴ U.S. Department of Labor, Occupational Safety and Health Administration. “OSHA standard, 29 CFR 1910 Subpart I.” Retrieved December 28, 2006 from, http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level
=1&p_part_number=1910#1910_Subpart_I

¹⁵ Ibid.

¹⁶ Oklahoma State University. “Laboratory Safety Manual.” Retrieved December 28, 2006 from, http://www.pp.okstate.edu

References

Occupational Safety and Health Administration (n.d). 29 CFR 1910.1200 – Hazard communication. Retrieved December 12, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

Occupational Safety and Health Administration (n.d). 29 CFR 1910.1450 – Occupational exposure to hazardous chemicals in laboratories. Retrieved December 12, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

Occupational Safety and Health Administration (n.d). 29 CFR 1910.1030 – Bloodborne Pathogens. Retrieved December 28, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

Occupational Safety and Health Administration (n.d). 29 CFR 1910.1020 – Access to employee exposure and medical records. Retrieved December 28, 2006 from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10027

Occupational Safety and Health Administration (n.d). 29 CFR 1910 Subpart I – Personal Protective Equipment. Retrieved December 28, 2006 from, http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level
=1&p_part_number=1910#1910_Subpart_I

Oklahoma State University (5/2005). Laboratory Safety Manual. Retrieved December 28, 2006 from, http://www.pp.okstate.edu

American Industrial Hygiene Association (n.d.). AIHA Laboratory Health & Safety Committee Website. Retrieved December 12, 2006 from, http://www2.umdnj.edu

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