OSHA LABORATORY STANDARD 29 CFR 1910'1450 Manager, Chemical Safety Office of Environmental Health

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OSHA LABORATORY STANDARD29 CFR 1910.1450
Manager, Chemical SafetyOffice of
Environmental Health SafetyPresentation by Pam
FatlandTulane University(504) 988-2800January,
2004
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OSHA LABORATORY STANDARDDEFINITIONS

• Laboratory - A workplace where relatively small
  quantities of hazardous chemicals are used on a
  nonproduction basis
• Laboratory Scale Containers used for reactions,
  transfers, and handling are small enough to be
  easily and safely manipulated by one person

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OSHA LABORATORY STANDARDEXEMPTIONS

• Quality control laboratories connected with
  production processes that perform repetitive
  tasks
• Uses of hazardous chemicals which provide no
  potential for employee exposure, such as medical
  labs which only use prepackaged test kits

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OSHA LABORATORY STANDARDCHEMICAL HYGIENE PLAN
(CHP)

• Tulanes CHP located in OEHS Policies
  Procedures Manual
• Generic Plan, covers all types of laboratories at
  Tulane
• Supplemented by Standard Operating Procedures
  developed by laboratory supervisors/Principal
  Investigators
• Chemical Hygiene Officer for Tulane is Pamela
  Fatland of OEHS

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OSHA LABORATORY STANDARDRESPONSIBILITIES OF CHO

• Develop update written CHP/ Review Laboratory
  SOPs
• Give guidance in procurement, use, and disposal
  of chemicals
• Assist in emergency planning and major cleanup
  activities
• Perform laboratory inspections/ audit fume hood
  performance
• Advise in lab closeouts, renovations, or building
  of laboratory facilities
• Advise in monitoring of exposure levels of
  regulated chemicals
• Seek ways to improve the chemical hygiene program

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OSHA LABORATORY STANDARDRESPONSIBILITIES OF
LABORATORY SUPERVISORS/PRINCIPAL INVESTIGATORS

• Compose and annually update SOPs specific for
  their laboratories
• Provide adequate Personal Protective Equipment
  (PPE)
• Provide document safety training for laboratory
  personnel
• Perform quarterly inspections of labs
• Contact OEHS if monitoring needed, if spill
  occurs, if accident/injury occurs, etc.
• Ensure that facilities are adequate for
  experiments to be performed
• Ensure laboratory workers comply with safe
  chemical hygiene practices

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OSHA LABORATORY STANDARDRESPONSIBILITIES OF
LABORATORY WORKERS/TECHNICIANS

• Plan conduct activities in accordance with
  Tulanes CHP
• Develop good chemical hygiene habits

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OSHA LABORATORY STANDARDSTANDARD OPERATING
PROCEDURES

• Specifics of Chemical Hygiene Plan
• Must be developed by lab supervisor/principal
  investigator
• Must be updated and submitted to OEHS annually
  (usually in April/May)
• Guidelines available on OEHS website under
  Chemical Safety link

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OSHA LABORATORY STANDARDTRAINING INFORMATION

• Must be done at initial assignment and prior to
  new hazardous chemical/new exposure situations
• Responsibility of lab supervisor/principal
  investigator to provide document appropriate
  training send records to OEHS

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OSHA LABORATORY STANDARDTRAINING INFORMATION
TOPICS

• Methods to detect hazardous chemicals in the work
  area
• Signs and symptoms of exposure to chemicals
• Methods to reduce exposure
• Physical health hazards of chemicals used in
  the work area
• PPE and emergency procedures
• CHP/SOPs reference materials

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OSHA LABORATORY STANDARDEXPOSURE CONTROL

• Engineering Controls
• Work Practices
• Personal Protective Equipment

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OSHA LABORATORY STANDARDEXPOSURE CONTROL FUME
HOODS

• Before using toxic or volatile chemicals in a
  fume hood, adequate hood performance needs to be
  confirmed.
• Hoods at Tulane are required to have an alarm or
  airflow indicator/monitor.
• Typically a working fume hood should exhaust at a
  rate of 80-120 feet per minute face velocity.

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OSHA LABORATORY STANDARDEXPOSURE CONTROL
EYEWASHES/SHOWERS

• Eyewash fountains are required in work areas
  where formaldehyde, irritants, or corrosive
  chemicals are used and there is the potential for
  a splash to the eye
• Eyewashes must be tested weekly by the laboratory
  personnel/Showers must be tested at least
  annually by Facilities Services
• Emergency showers/eyewashes must be readily
  accessible, clear of obstructions, and clearly
  labeled

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OSHA LABORATORY STANDARDEXPOSURE CONTROL WORK
PRACTICES

• Good housekeeping
• Maintain aisles/uncluttered work areas
• Proper storage/handling
• Substitution of less hazardous materials
• Scaled down experiments
• Secondary containment
• Good chemical hygiene practices

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OSHA LABORATORY STANDARDEXPOSURE CONTROL
PERSONAL PROTECTIVE EQUIPMENT

• PPE is used as a final alternative in the event
  that engineering controls and work practices do
  not adequately prevent exposure to chemicals
• PPE must be adequate for the substance being
  handled and must be available in different
  sizes/styles (i.e., powdered unpowdered gloves)
• Respirators require a medical evaluation and
  annual fit-testing
• PPE must be inspected to make sure it is in good
  condition
• Personnel must be trained on PPE

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OSHA LABORATORY STANDARDEXPOSURE CONTROL
PERSONAL PROTECTIVE EQUIPMENT

• When using PPE, remember the Infectious Disease
  concept of Universal Precautions Treat ALL
  materials as if they are contaminated (with
  infectious materials, hazardous chemicals, etc.)

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OSHA LABORATORY STANDARDLABORATORY INSPECTIONS

• OEHS (Annual)
• Supervisor/Principal Investigator (Quarterly)
  www.som.tulane.edu/oehs/InspChckList.htm
• Other

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OSHA LABORATORY STANDARDEXPOSURE MONITORING

• Contact OEHS if there is an exposure problem or
  if you feel monitoring is needed in you lab
• Be aware of chemicals with permissible exposure
  limits (PELs) use adequate ventilation

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OSHA LABORATORY STANDARDPRIOR APPROVAL

• Contact OEHS for prior approval when using high
  risk substances, for grant environmental
  statements, or for projects with possible safety
  concerns

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OSHA LABORATORY STANDARDTOXICS/HIGH RISK
CHEMICALS

• Designated Area
• Containment Devices
• Waste Removal
• Decontamination Procedures
• Emergency Plans

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OSHA LABORATORY STANDARDMEDICAL PROGRAM

• Signs and Symptoms
• Exposure Above PELs
• Spill/Leak

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OSHA LABORATORY STANDARDSUPERVISOR/PI COMPLIANCE
CHECKLIST

• Annual SOPs, chemical inventories
• Training documentation
• Quarterly Inspections/Inspection Response
• PPE assessments/inspections
• High risk chemicals documentation
• Updated door signs
• Exposure monitoring results
• Medical records/Injury Reports
• Prior Approval protocols
• Fume Hood functioning before use
• Weekly Eyewash Inspections

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LABORATORY INSPECTION CONCERNS
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HOOD CONCERNS

• Airfoil missing
• Hood not working (Exhaust too high or too low)
• Hood sash stuck/broken/needs repair
• Panel missing or broken
• Vaneometer needs mounting or repair
• No alarm/ alarm not working
• Additional exhaust needed

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HOOD CONCERNS

• Chemicals on edge of hood
• Large equipment in front of hood/exhaust
• Paper towels in hood
• Hood used for chemical/equipment storage
• Work at least 6 inches inside hood

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HOOD CONCERNS

• Countertop filter replacement schedule
• Perchloric acid used in regular fume hood
• BSC/Walk-in/Perchloric Acid hood not properly
  used

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CONCERNS WITH FIRE ALARMS, EXTINGUISHERS,
EQUIPMENT

• Fire extinguisher/equipment blocked
• Relocate/mount fire extinguisher or extinguisher
  needed
• Extinguisher needs inspection

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CONCERNS WITH FIRE ALARMS, EXTINGUISHERS,
EQUIPMENT

• Emergency light or strobe blocked or needed
• Smoke detector needs to be secured
• Exit sign needed or not illuminated
• Door closure needs adjustment

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CONCERNS WITH FIRE ALARMS, EXTINGUISHERS,
EQUIPMENT

• Storage within 18 inches of sprinkler head
• Exit locked or blocked

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EYEWASHES/DRENCH HOSES/SHOWER CONCERNS

• Eyewash needs adjusting/ not working
• Eyewash/shower needed
• Shower handle too high or missing, cover plate
  coming off
• Drench hose handle missing/ needs repair
• Eyewash needs caps

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EYEWASHES/DRENCH HOSES/SHOWER CONCERNS

• Eyewash, drench hose, shower, or sink blocked
• Plastic eyewash bottle in laboratory

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SIGNAGE CONCERNS

• Door sign needed/ changes needed
• Eyewash, refrigerator, equipment labels needed
• Signage needs mounting
• Signage blocked

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CHEMICAL STORAGE CONCERNS

• Gas cylinders improperly or not secured
• Gas cylinders missing caps
• Excess lecture bottles

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CHEMICAL STORAGE CONCERNS

• Unlatched flammable cabinet or flammable cabinet
  not closing properly
• Flammable cabinet blocked or unsteady.
• Greater than 10 gallons of flammable liquids are
  stored outside of a flammable cabinet
• Improper grounding or bonding
• 5 gal or 55 gal containers used

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CHEMICAL STORAGE CONCERNS

• Chemicals are stored on the floor
• Incompatible chemicals are stored together,
  evidence of corroding containers or cabinets
• Old, undated ether found in lab
• Improperly labeled or unlabeled containers
• Uncapped containers
• Improper chemical or glassware storage (Could
  fall, lip needed, needs lock key)

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CHEMICAL STORAGE CONCERNS

• Evidence of improper chemical disposal or
  disposal of chemicals needed

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REFRIGERATOR/FREEZER CONCERNS

• Flammables stored in improper refrigerator or
  freezer
• Refrigerator or freezer needs defrosting or
  cleaning
• Food or beverages found in refrigerator, freezer,
  or cold room
• Gasket needs replacing or cleaning

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EATING/DRINKING/SMOKING/LABORATORY ATTIRE
CONCERNS

• Evidence of eating, drinking, or smoking in lab
• Improper laboratory attire (Shorts, sandals)

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EQUIPMENT/ELECTRICAL CONCERNS

• Equipment needs repair or discard
• Unguarded equipment or improper guarding
• Improper storage of equipment
• Tagged equipment in use

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EQUIPMENT/ELECTRICAL CONCERNS

• Electrical covers missing or broken light covers
  missing
• Lights not working
• Exit signs or emergency lighting needed

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EQUIPMENT/ELECTRICAL CONCERNS

• Electrical panels are blocked
• Cheater plugs are in use, or items are not
  plugged in properly
• Improper multi-outlet strip or outlet usage
• Improper extension cord usage
• Electrical cords through doorways or walls

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EQUIPMENT/ELECTRICAL CONCERNS

• GFCI, vacuum breaker, serrated tip faucet needed
• Space heater in lab
• Heat producing equipment left on and unattended

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HOUSEKEEPING AND RELATED CONCERNS

• Poor housekeeping
• Paper pads need replacement
• Combustible storage needs removal
• Trash needs removal
• Maintain aisles and exits
• Slip/trip hazards (cords, floor tiles, etc.)
• Evidence of a spilled chemical

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HOUSEKEEPING AND RELATED CONCERNS

• Mold growth, ceiling needs repair, tiles stained
  or missing
• Peeling paint, rust, stains
• Ventilation blocked, dirty, or improper
• Poor condition tubing or improper Bunsen burner
  use

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HOUSEKEEPING AND RELATED CONCERNS

• Doors not latching properly
• Holes in walls need repair
• Hall storage

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BIOHAZARDS/SHARPS CONCERNS

• Unsecured sharps
• Improper trash can, waste bag, sharps container
• Sharps box on side or missing top
• Glass box, biohazard box, sharps container needs
  disposal (2/3rds full)
• Broken glassware needs to be discarded

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PPE CONCERNS

• Improperly stored PPE
• PPE not disposed properly
• Need to use PPE
• Poor condition PPE
• Verify fit-test/medical for respirator use
• Verify PPE for cryogenic use

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MISC. CONCERNS

• Thermostat covers missing
• Emergency phone labels needed
• Bicycles in laboratory
• Improper or broken furniture
• Molding coming off
• Utility fixtures corroding

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MISC. CONCERNS

• Prohibited animal in lab
• Improper railing, toeboard or guard rail needed

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BUILDING BLOCKS OF LABORATORY SAFETY

• Right Attitude
• Safety Education
• Communication
• Equipment
• Vigilance
• Coordination
• Alternatives
• Avoid Complacency

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CHEMICAL SHIPMENTS

• Read labels/paperwork/documents before opening
• Visually inspect shipment for indications of
  damage look for leaks, wet stained areas, sounds
  associated with breakage, lingering aromas
• Open in hood by trained staff wearing proper PPE
• Know who to notify and what to do in emergency

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CHEMICAL STORAGE

• Minimize purchases order and store only what is
  needed
• Avoid storing on floor and in fume hood practice
  good housekeeping
• Use shelves with lips flammable cabinets if
  available
• Use secondary containment to minimize spills
• Segregate by hazard class
• Inventory periodically to weed out deteriorating
  or unneeded chemicals

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REFRIGERATORS

• Explosion-proof designed to operate in hazardous
  flammable or explosive atmospheres
• Explosion-safe (or laboratory-safe) designed for
  storage of flammable materials (Ignition sources
  such as lights, door switch, thermostat, and
  exposed electrical components and circuitry are
  removed from interior chamber external
  components such as compressors, wiring,
  circuitry, and controls are located at top of
  refrigerator to minimize ignition from vapors
  heavier than air)
• Household not designed for laboratory use (Vapors
  can build up and possibly ignite)

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LABORATORY CLOSE-OUTS

• Policy designed to ensure laboratories are left
  in a safe condition when vacating or renovating
  the laboratory
• Procedures include making provisions for
  hazardous chemicals, biologicals, sharps,
  cylinders, radioactive materials, and equipment
  such as fume hoods or biological safety cabinets
• Must notify OEHS of plans (Notification Letter)
• Must certify that hazardous materials have been
  properly removed and that the area has been
  decontaminated before area can be renovated or
  re-occupied (Pre-Close-Out Certification)
• Also includes Move-in reminders and tips

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UNATTENDED EXPERIMENTS

• Unattended experiments are discouraged
• If necessary, design experiment to prevent
  release of hazardous substances in the event of
  interruptions in utility services such as
  electricity, cooling water, and inert gas
• Leave lab lights on and post signs identifying
  nature of experiment, hazardous substances in
  use, and responsible person to contact in an
  emergency
• Make arrangements for other workers to
  periodically inspect the operation

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ORGANIC PEROXIDES

• Know the hazards specific to the chemical (MSDS)
• Order only what is needed in small container
  sizes
• Date containers when received, when opened, and
  when to discard Store properly
• Use correct PPE
• Routinely test for peroxides
• Know what to do in an emergency clean up spills
  immediately
• Dispose of properly and in a timely manner

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PERCHLORIC ACID

• Use perchloric acid fume hood made of proper
  material and designed with a washdown system
• Do not use or store organic solvents in hood
• Add acid to water
• Use full body protection goggles, faceshield,
  gloves, apron
• Do not mix perchloric acid waste with any other
  waste
• Store perchloric acid away from organic acids
  (including acetic acid), organic bases, and other
  organic or flammable materials use secondary
  containment when storing

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SCALE-UP OF EXPERIMENTS

• Scale-up is frequently a contributing cause for
  an energetic incident
• As the scale of a reaction increases, the need
  for more efficient heat removal is needed
• Heat which cannot safely dissipate to the
  surroundings may be retained in the reaction
  vessel leading to a rapid increase in temperature
  and reaction rate
• The end result is a violent reaction
• Monitor temperature, provide cooling

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Respect Your Chemical Hygiene Plan!

• Tulanes Policy
• SOPs Specific to Your Lab