Lab Health and Safety

Fulfilling the OSHA Lab Standard

Fulfilling the OSHA Lab Standard

Key considerations for a safe lab

Vince McLeod, CIH

The Occupational Safety and Health Administration (OSHA) estimates that more than a half-million workers are employed in laboratories in the United States. We all know that there are numerous and various potential hazards faced every day. These can stem from biological, chemical, physical, radiological, and musculoskeletal stresses. But do we give enough thought to prevention and safety? What should we be looking for? This article will attempt to answer these questions and guide you through meaningful laboratory safety measures.

An average academic, research, and/or development facility usually contains a mix of research laboratories, instrument rooms, chemical storage areas, waste handling areas, and busy receiving/loading docks. The Occupational Exposure to Hazardous Chemicals in Laboratories, referred to as the OSHA Laboratory Standard1 was created specifically for non-production labs to protect workers from the diverse hazards encountered in laboratories. The Lab Standard and companion Laboratory Safety Guidance2 are important resources and considered the starting point for any lab using hazardous materials.

Applicability—who is covered?

The OSHA Lab Standard (29CFR1910.1450) applies to any and all employers engaged in laboratory use of hazardous chemicals. The purpose is to provide employees a workplace free from recognized hazards. If covered, employers must meet certain requirements.

What must we do?

First and foremost, employers must designate a chemical hygiene officer (CHO). The CHO must be qualified by experience or training to provide technical guidance in developing and implementing a written chemical hygiene plan (CHP). The CHP details procedures and practices that protect employees from all hazards present in the workplace. Appendix A of the standard is non-mandatory but provides guidance for preparing the CHP. In general, the CHP should address standard operating procedures (SOPs) for health and safety concerns when using hazardous chemicals. Control measures such as engineering controls, personal protective equipment (PPE), and specific work practices to reduce employee exposures should be detailed.

Special protections are required for work with extremely hazardous substances like select carcinogens, acute toxins, and reproductive toxins. These include use only in designated areas, use of containment devices (fume hoods/glove boxes, etc.), decontamination procedures, and waste handling.

Employee training is paramount. Train employees on all hazards present prior to initial work assignment. Ensure training covers signs and symptoms associated with exposures, the permissible exposure limits (PELs), and any other recognized exposure guideline, safety data sheets and specific procedures to protect from exposures.

When writing the CHP, be sure to include requirements from other specific OSHA standards that are relevant. Examples might include specific chemical air contaminants such as benzene, formaldehyde, methylene chloride, etc.; bloodborne pathogens; and respiratory protection, to name some of the most common ones.


Related Article: OnDemand Webinar: How to Create a More Effective Chemical Hygiene Plan


After training, the CHP’s next most important requirement is determining employee exposures. Basically, the employer must ensure that laboratory employees’ exposures to hazardous substances are the PEL. Employers should perform initial monitoring of employees’ exposure to any regulated substance. This is followed by periodic monitoring if any exposures are found in excess of the action level or PEL. The CHP must also provide for medical consultation and examinations where appropriate. Situations would include an employee that develops signs and symptoms of chemical exposure, monitoring shows exposure levels above the action level or PELs, or an event such as a spill, leak, or release resulting in likely exposure.

It should go without saying that hazard identification is key to the OSHA Lab standard. It is the basis upon which all else rides. Requirements include ensuring and maintaining proper labeling and all safety data sheets. This also applies to any substance produced in the laboratory or that is a byproduct of lab activities.

The final main requirement deals with recordkeeping. The employer is responsible for maintaining accurate records according to 29CFR 1910.1020. Important records include training subjects and dates, any medical evaluations, and all monitoring data.

Additional guidance

We mentioned the OSHA Laboratory Safety Guidance document at the outset. It provides additional detail and associated specific OSHA standards that may be of importance. The guidance document addresses chemical hazards and fume hoods, biological hazards, bloodborne pathogens, biosafety cabinets, radiation (ionizing and non-ionizing), noise, and other safety hazards of certain lab equipment such as autoclaves, centrifuges, and compressed gases. Depending on your lab’s activities, it may prove a valuable resource.

Key takeaways:

  • Designate your chemical hygiene officer
  • Write your chemical hygiene plan
  • Train your employees; include all PPE that is appropriate for the tasks as well as standard safety equipment like lab coats, aprons, gloves, eye protection, etc.
  • Evaluate employee exposures; conduct monitoring
  • Review and maintain the CHP including SOPs at least annually
  • Keep proper records and maintain SDS

References:

1) Occupational Exposure to Hazardous Chemicals in Laboratories, 29CFR 1910.1450. US Department of Labor, Occupational Safety and Health Administration, Washington, DC. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10106

2) Laboratory Safety Guidance, US Department of Labor, Occupational Safety and Health Administration, Washington, DC. 2011 https://www.osha.gov/Publications/laboratory/OSHA3404laboratory-safety-guidance.pdf