Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSH Act), the General Duty Clause, requires that employers:
"...shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to
cause death or serious physical harm to his employees."
"...shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees."
This means employers are responsible to protect employees from all workplace hazards they recognize, not just specific hazards or hazardous operations.
For example, best practices that are issued by non-regulatory organizations such as the National Institute for Occupational Safety and Health (NIOSH), the Centers for Disease Control and Prevention (CDC), the National Research Council (NRC), and the National Institutes of Health (NIH), can be enforceable under section 5(a)(1) of the OSH Act of 1970.
There are several specific OSHA standards that apply to laboratories as well as other OSHA standards that apply to various aspects of laboratory activities.
Employers must be fully aware of these standards and must implement all aspects of the standards that apply to specific laboratory work conditions in their facilities.
It’s important to know that not all laboratories are covered by the Laboratory Standard. For example, most quality control laboratories are not covered under the standard. These laboratories are usually adjuncts of production operations, which typically perform repetitive procedures for the purpose of assuring reliability of a product or a process.
On the other hand, laboratories that conduct research and development and related analytical work are subject to the requirements of the Laboratory Standard, regardless of whether or not they are used only to support manufacturing.
"Laboratory use of hazardous chemicals" means handling or use of such chemicals in which all of the following conditions are met:
The Laboratory Standard consists of five major elements:
Each laboratory must identify which hazardous chemicals will be encountered by its workers. Hazardous chemicals can be serious physical and/or health threats to workers in clinical, industrial, and academic laboratories. Hazardous laboratory chemicals include:
OSHA rules limit all industry exposures to approximately 400 substances.
The standard requires the employer to designate a Chemical Hygiene Officer and have a written Chemical Hygiene Plan (CHP), and actively verify that it remains effective. The CHP must include provisions for:
The CHP must be tailored to reflect the specific chemical hazards present in the laboratory where it is to be used. Laboratory personnel must receive training regarding the Laboratory Standard, the CHP, and other laboratory safety practices, including exposure detection, physical and health hazards associated with chemicals, and protective measures. See a sample CHP and more information on CHP elements.
Laboratory workers must be provided with information and training relevant to the hazards of the chemicals present in their laboratory. The training must be provided at the time of initial assignment to a laboratory and prior to assignments involving new exposure situations.
The employer must inform workers about the following:
Training must include the following:
OSHA has established permissible exposure limits (PELs) for hundreds of chemical substances. A PEL is the chemical-specific concentration in inhaled air that is intended to represent what the average, healthy worker may be exposed to daily for a lifetime of work without significant adverse health effects.
The employer must ensure that workers’ exposures to OSHA-regulated substances do not exceed the PEL. However, most of the OSHA PELs were adopted soon after the Agency was first created in 1970 and were based upon scientific studies available at that time. Since science has continued to move forward, in some cases, there may be health data that suggests a hazard to workers below the levels permitted by the OSHA PELs.
Other agencies and organizations have developed and updated recommended occupational exposure limits (OELs) for chemicals regulated by OSHA, as well as other chemicals not currently regulated by OSHA. The American Conference of Governmental Industrial Hygienists (ACGIH), the American Industrial Hygiene Association (AIHA), the National Institute for Occupational Safety and Health (NIOSH), as well as some chemical manufacturers have established OELs to assess safe exposure limits for various chemicals.
Employers must conduct exposure monitoring, through air sampling, if there is reason to believe that workers may be exposed to chemicals above the action level or, in the absence of an action level, the PEL.
The employer should notify workers of the results of any monitoring within 15 working days of receiving the results. Some OSHA chemical standards have specific provisions regarding exposure monitoring and worker notification. Employers should consult relevant standards to see if these provisions apply to their workplace.
Employers must do the following:
Employers must maintain an accurate record of exposure monitoring activities and exposure measurements as well as medical consultations and examinations, including medical tests and written opinions.
Employers generally must maintain worker exposure records for 30 years and medical records for the duration of the worker's employment plus 30 years, unless one of the exemptions listed below applies:
Such records must be maintained, transferred, and made available to an individual's physician or made available to the worker or his/her designated representative upon request.
The following are the National Research Council’s recommendations concerning the responsibilities of various individuals for chemical hygiene in laboratories:
Chief Executive Officer
Chemical Hygiene Officer
Witnessing lab procedures gone awry may make students think twice about some of their own safety shortcomings. Featuring Sue Bober, Schaumburg High School, development videos for chemistry teachers are available at http://elearning.flinnsci.com.
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