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OCCUPATIONAL EXPOSURES TO
HAZARDOUS CHEMICALS IN LABORATORIES
This section should be used to establish the role of the Chemical Hygiene Plan within "DEPARTMENT".
1.1 History of the OSHA Laboratory Standard
On November 25, 1983, the Occupational Safety and Health Administration (OSHA) published the Hazard Communication Standard which applied to certain manufacturers and in part to certain laboratories. OSHA received many comments regarding whether the procedures of the Hazard Communication Standard should apply to laboratories where the staff is usually highly educated. OSHA decided although "...31.9% of all laboratory workers have bachelors degrees, 20.6% have masters degrees, and 20.9% have doctorates...," that, "...there is some question as to whether laboratory workers actually make themselves as knowledgeable as they should be and some laboratory employees are not professionally trained." 51 FR 26664.
Other unique differences for laboratories were noted including: the small amounts of chemicals used; the vast numbers of different chemicals involved; and that nearly half of the laboratories in one survey could not accurately predict their chemical needs even one month in advance.
OSHA decided that "...Despite the existence of the unique characteristics of laboratory work places, in actual practice incidents of acute adverse health effects resulting from exposures to toxic substances in laboratories do occur. Furthermore, some studies...have shown increased risks of certain types of diseases for laboratory workers. In addition, although laboratory workers are, in general, a well educated work force, there is evidence that many laboratories do not have health and safety programs...". Therefore, OSHA proposed the Occupational Exposures to Hazardous Chemicals in Laboratories" rule from which this Chemical Hygiene Plan originates.
On January 31, 1990, The Department of Labor published in the Federal Register an amendment to 29 CFR 1910, Subpart Z, identified as Section 1910.1450. The title of that amendment is
"Occupational exposure to hazardous chemicals in the laboratory", but is better known as the "Laboratory Standard" (Attachment A).
The effective date of the standard is May 1, 1990. A part of that standard is the requirement for the development of a chemical hygiene plan. That plan must be developed and implemented by January 31, 1991.
1.1.1 Summary of the Laboratory Standard
SUMMARY OF OSHA's HEALTH AND SAFETY STANDARDS;
(29 CFR 1910.1450 LAB STANDARD)
A. Scope and Application
1. Applies to all employers whose laboratories use hazardous chemicals.
2. This amends (for laboratories) all other provisions of 29 CFR 1910 Subpart Z except for PEL.
3. This does not apply to activities that do not fit term "laboratory use".
B. Definitions (See Appendix A)
1. Laboratory - Means any facility where the "laboratory use of hazardous chemicals" occur. It is a work place where relatively small quantities of hazardous chemicals are used on a non-production basis.
2. Laboratory Scale - Means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. "Laboratory scale" excludes those work places whose function is to produce commercial quantities of materials.
3. Laboratory use of hazardous chemicals - Means handling or use of such chemicals in which all of the following conditions are met:
C. Laboratory Standard Application
Where this section applies, it shall supersede, for laboratories, the requirements of all other OSHA health standards in 29 CFR Part 1910, Subpart Z, except as follows:
1. For any OSHA health standard, only the requirement to limit employee exposure to the specific permissible exposure limit shall apply for laboratories;
2. Prohibition of eye and skin contact where specified by any OSHA health standard shall observed;
3. Where the action level or the PEL is routinely exceeded for an OSHA regulated substance the monitoring and medical surveillance parts of the standard will be applied.
1. Initial monitoring - The employer shall measure an employees exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels exceed the PEL or action level.
2. Periodic monitoring - If initial monitoring indicates employee exposure above the PEL or action level the employer shall immediately comply with the monitoring provisions of the relevant standard (also Z-tables)
3. Termination of monitoring - the employer may terminate monitoring in accordance with the relevant standard.
4. The employee must be notified of the result of the monitoring within 15 days of the employer's receipt of the results.
1. Where hazardous chemicals are used in the work place, the employer shall develop and carry out the provisions of a chemical hygiene plan which is:
a) Capable of protecting employees from health hazards associated with hazardous chemicals in that laboratory and
b) Capable of keeping the exposures below the action level or PEL.
2. The Chemical Hygiene Plan must be readily accessible to employees.
a) Standard operating procedures relevant to safety and health;
b) Criteria employer will use to implement control measures to reduce employee exposure to hazardous chemicals;
c) A requirement that fume hoods and other protective equipment are functioning properly and methods to be taken to ensure proper and adequate performance;
d) Provisions for employee training and information;
f) Provisions for medical consultation and examination;
g) Designation of personnel responsible for implementation of the Chemical Hygiene Plan.
h) Provisions for additional protection for employees working with particularly hazardous substances including:
Specific consideration shall be given to the following provisions which shall be included where appropriate:
A) Establishment of a designated area;
B) Use of containment devices such as fume hoods or glove boxes;
C) Procedures for safe removal of contaminated waste; and
D) Decontamination procedures.
4. The employer shall review and update the plan on a yearly basis.
1. The employer shall provide employees with information and training to ensure that they are apprised of the hazards of chemicals in their work area.
2. Such information shall be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations.
3. Information - employees shall be informed of:
a) The contents of this standard
b) The location and availability of the Chemical Hygiene Plan;
c) The PELs for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where PELs do not exist.
d) Signs and symptoms associated with exposures to the
hazardous chemicals used in the laboratory; and
4. Training - Employee training shall include:
a) Methods and observations that may be used to detect the presence or release of a hazardous chemical;
b) The physical and health hazards of chemicals in the work area;
c) Measures employees can use to protect themselves from these hazards, including specific procedures such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
The employee shall be trained on the applicable details of the employers written Chemical Hygiene Plan.
1. The employer shall provide all employees who work with hazardous chemicals an opportunity to receive medical attention under the following circumstances.
a) When the employee develops signs and/or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory;
b) When routine monitoring reveals an exposure above the PEL or action level;
c) When an event takes place in the work area such as a spill or leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure.
2. All medical examinations and consultations shall be performed by a licensed physician or under his/her direct supervision.
3. Information provided to the physician - The employer shall provide the following information to the physician:
4. Physicians written opinion including:
The written opinion shall not reveal specific findings of diagnoses unrelated to occupational exposure.
H. Hazard Identification
1. With respect to labels and Material Safety Data Sheets:
a) Employers shall ensure that labels on incoming hazardous chemicals are not removed or defaced.
b) Employers shall maintain any MSDSs received and make them readily available to employees.
2. The following provisions shall apply to chemicals substances developed in the laboratory:
I. Use of Respirators
When the use of respirators is required to maintain exposure below the PEL, the employer shall provide the proper respirator equipment. Respirators shall be selected and used in accordance with the requirements of 29 CFR 1910.135.
1. The employer shall establish and maintain for each employee an accurate record of any measurements taken to monitor employee exposures and any medical consultation and examinations including tests or written opinions required by this standard.
2. The employer shall assure that such records are kept,
transferred, and made available in accordance with 29 CFR 1910.20.
This section establishes whether "DEPARTMENT" is a "laboratory" as defined by OSHA, which activities must comply with this standard and which others must comply with other OSHA standards, including Hazard Communication.
This section defines who is responsible to implement and enforce the provisions of the Plan. This section also co-assigns responsibility for individual safety to each individual involved.
REMEMBER: NO AMOUNT OF INSURANCE CAN CURE BLINDNESS OR RESURRECT THE DEAD! SO BE RESPONSIBLE FOR YOUR WELL-BEING.
4.0 CHEMICAL HYGIENE AND SAFETY PLAN
This section describes appropriate procedures and practices for chemical hygiene and safety.
The General Standard Operating Procedures are fundamental safety precautions which should be familiar to all employees.
These practices should be followed at all times.
Awareness is the most fundamental rule of chemical safety. Everyone should remain constantly aware of:
NEVER work alone in a laboratory. Someone should be working with you. If that is not possible, then someone should know of the solitary worker and check on him/her at regular intervals.
Personal hygiene is an important factor in chemical hygiene. To react with a person, a toxic chemical must contact that person. The four routes of entry (inhalations, ingestion, injection, and eye or skin contact) limit the chemical's ability to contact us. If we properly protect ourselves, we can eliminate the chemical's ability to do harm. Personal hygiene practices include:
There should be no eating, drinking or smoking allowed in areas where chemicals are either stored or used. Because chemicals vapors can be absorbed by food stuff (especially bread) and tobacco, no food or tobacco products should be allowed into chemical areas.
Instead of designating laboratory and stock areas as "No Smoking" areas, ALL areas should be considered "No Smoking"and "No Food or Beverage" except those few areas actually designated as "Smoking Permitted" and "Food and Beverage Permitted."
Most personal protective equipment is provided by "DEPARTMENT" to employees when and where necessary. It is the responsibility of each employee to be certain that the appropriate equipment is worn as necessary.
The most fundamental piece of personal protective clothing is provided by each employee for his/her own use. It is the normal clothing worn in the laboratory. Clothing should be worn to minimize exposed skin surfaces available for direct contact through splashing. Therefore, all employees should wear long sleeve/long legged clothing and avoid short sleeved shirts, short trousers or skirts
Additional equipment available from "DEPARTMENT"includes:
The proper uses and maintenance of the equipment is discussed in Section 4.3.5 on Control Measures.
Common housekeeping practices contribute greatly towards chemical hygiene and safety. A clean work area is much safer than a cluttered or dirty one. Some appropriate housekeeping measures include:
Keep all aisles, hallways, and stairs clear of all chemicals.
- Keep all work areas and especially workbenches clear of clutter and obstructions.
- All working surfaces and floors should be cleaned regularly.
- Access to emergency equipment, showers, eyewashes and exits should never be blocked by anything.
Wastes should be kept in the proper containers and labeled properly.
Any unlabeled containers are considered wastes by end of each workday.
Laboratory staff should be considerate and aware of housekeeping staff. The typical housekeeping staff is not as highly educated on chemicals and their hazards as most laboratory workers. Therefore, for the safety of housekeeping staff, laboratory workers should make sure that:
All chemicals are placed in proper storage areas by the end
of each workday.
All spills are promptly cleaned up and the spilled chemical is properly disposed of.
No chemicals are stored in aisles, stairwells, on desks or workbenches, on floors or in hallways, or left on shelves over the workbenches.
Approval to proceed with a laboratory task should be obtained when:
Any new procedure should be subjected to peer review. Not only from a scientific standpoint, but also to assure that all safety considerations are in place prior to implementation (via use of prior approval form)
Spills of toxic substances or accidents involving any hazardous chemical should be resolved immediately, according to "DEPARTMENT's" Written Emergency and Contingency Plan. That plan should be attached as Appendix C. The overall steps of handling an accident are briefly:
1. Notify your supervisor and appropriate emergency responders immediately.
2. If spilled chemical is flammable, extinguish all nearby sources of ignition.
3. If a person has been splashed with a chemical, wash them with plenty of water for at least 15 minutes, remove all contaminated clothing, and GET MEDICAL ATTENTION.
4. If a person has been overexposed by inhalation, get victim to fresh air, apply artificial respiration if necessary, and GET MEDICAL ATTENTION.
5. In other cases of overexposure, GET MEDICAL ATTENTION and follow the instructions of the medical professional.
6. After securing proper medical attention for a chemical exposure victim, neutralize or absorb the spilled chemical with the proper spill cleanup material and dispose of it in accordance with hazardous wastes procedures.
For more detailed discussions on handling emergencies in the laboratory and evacuation procedures, read Appendix C.
There are some fundamental actions which must NOT be used in handling emergencies. Some of them include:
Chemical wastes are regulated by the Environmental Protection Agency under the Resource Conservation and Recovery Act and its amendments. Under new changes to the regulations, a Generator of hazardous wastes is now defined and regulated if the entire facility produces more than 100 KG of hazardous wastes per month, 1 kg of acute hazardous wastes, 100 kg of acute hazardous waste residues or 100 kg of contaminated soil per month.
All employees should be advised by their supervisor on how to handle wastes from their work.
4.2 Standard Operating Procedures (SOPs) & Specific Safety Procedures
Written laboratory procedures normally have a brief description of specific safety practices for that particular procedure. Employees should read and review those practices before commencing a procedure. Employees can find those written references by asking their supervisors.
Chemical safety is accomplished by awareness of the chemical hazards and by keeping the chemical under control through a variety of engineered safeguards. Laboratory personnel should be familiar with the proper use of those safeguards. Laboratory supervisors should be able to detect the malfunction of those safeguards. All engineered controls must be properly maintained, inspected on a regular basis, and never overloaded beyond their design limits.
Laboratory ventilation should be normally not less than 20 linear feet per minute air flow through each room. This gives the workers comfortable breathing air. But 20 feet per minute translates to less than one quarter mile per hour; the flow should not be considered sufficient to prevent accumulation of chemical vapors. Work done with chemicals with low TLVs or high vapor pressures should be done in a fume hood.
Fume hoods should provide 100 to 150 linear feet per minute of air flow. When using a fume hood the worker should be aware that:
The apparatus inside the hood should be kept towards the rear of the hood to prevent vapors from escaping.
Many hoods are installed to provide about 100 feet per minute (just over 1 mph). This velocity will control most low-velocity cross-drafts and the turbulence created by an occasional poor work practice at the face of hood. What is 100 fpm? Blow lightly on your hand so that you can just barely feel air movement - that's about 100 fpm.
Normal, transient, turbulent mixing velocities in laboratory air may be as high as 50 fpm, even under "good" conditions. You can see that it won't take much of a competing velocity to destroy the hood's ability to contain emissions. Here is a list of some competitors:
An upper limit - traditionally, 150 ppm - has been suggested because as the air flows into the hood, eddying around the hood worker's body tends to create a negative pressure area directly in front of the person's body. Any rapid movement of the person's arms may draw contaminated air into that space, which is also the person's breathing zone. The eddying effect becomes more pronounced as the velocity increases. The limit of 150 fpm is a upper-limit compromise between the eddying effect and the need to provide containment.
Flammable liquids should be kept in cans specifically designed for them. The cans should be used according to manufacturer instructions and common safety practices, including:
Cabinets designed for the safe storage of flammable chemicals can only do so if used and maintained properly. Cabinets are generally made of double-walled construction and are made of 18 gage steel. The doors are two inches above the base and the cabinet is liquid proof to that point. Two vents are provided on opposite sides of the cabinet and are equipped with flame-arrestor screens. Always read the manufacturer's information and follow some prudent safety practices such as:
All corrosive chemicals should be kept in cabinets especially designed to hold them. Care must be taken to separate acids from bases by distance or barrier.
Wherever chemicals have the possibility of damaging the skin or eyes, an emergency supply of water must be available. All laboratories must be equipped with eyewashes and safety showers. As with any safety equipment, these can only be useful if they can be used, therefore:
Protective clothing was briefly discussed in Section 4.1.4 Some additional information about the use of protective clothing includes:
OSHA requires all employers to primarily prevent atmospheric contamination. If that cannot keep the vapor concentrations below regulated levels, then the employer will implement a written respirator program (see 29 CFR 1910.134). The written respirator program will discuss such issues as respirator selection criteria, inspection, and maintenance. All personnel using respirators must be trained in their proper use and care. For more, detailed discussion of respirator uses and selection, see "DEPARTMENT's" Written Respirator Program attached as Appendix D.
Because odor thresholds can be greater than the TLVs, odors are not to be used as the primary methods of vapor detection. If suspicious odors are noticed, the investigators should obtain mechanical vapor detectors, such as detector tubes or ionization meters, and respiratory protection.
OSHA has noted that many laboratory workers use known or suspected carcinogens. While industrial workers might use only one or a limited few chemical carcinogens, laboratory workers are likely to use many such chemicals.
Exposures to those carcinogens would at least have an additive impact on risk, if not synergistic. To limit the possible exposures, "DEPARTMENT" has special procedures and precautions for work with carcinogens. See Appendix B for a list of carcinogens used in "DEPARTMENT" and subject to this section.
Special work areas are designated for work with carcinogens. The rooms, including storage areas for the chemical carcinogens, will have restricted access. Signs warning "Authorized Personnel Only" will be posted at entrances to these work areas, and if necessary, the areas will be locked. Only personnel with special instruction on the hazards and safe handling of carcinogens will be permitted access to the areas.
The rooms where carcinogens are used and stored should be kept at a slight negative pressure when compared to the rest of the rooms.
4.4.2 Closed System Protection
All work involving carcinogens must be done in specially equipped closed systems to reduce the risks of employee exposure to the vapors. The closed systems include fume hoods, glove boxes or similar devices.
4.4.3 Handling of Contaminated Waste Waters
Rinse water and other waste waters contaminated with carcinogens are to be collected for disposal. Specific disposal procedures will be outlined by "DEPARTMENT's" Hazardous Waste Officer and will be consistent with RCRA.
4.4.4 Personal Hygiene
Laboratory workers using carcinogens shall take extra precautions in maintaining good personal hygiene. In addition to hygiene practices in Section 4.1.2, workers will wash before leaving the facility.
No food, beverage or tobacco products will be permitted in the restricted areas.
4.4.5 Protection of Vacuum Systems
To protect vacuum lines and pumps, HEPA filters or high efficiency scrubber systems should be used.
4.4.6 Protective Apparel
Persons working in restricted areas should not wear any personal items such as jewelry which might be lost if decontamination is not possible. When possible, disposable clothing should be used. Gloves and long sleeves should be used at all times to prevent skin contact with the carcinogen.
4.4.7 Additional Precautions
Work with carcinogens should be done with the smallest amounts possible. Purchases of the chemicals should be restricted to minimal amounts necessary to prevent uninterrupted work.
5.0 CRITERIA FOR CONTROL MEASURES
This section examines criteria and guidelines which can or will be used to determine the use of engineered controls and personal protective equipment.
Most materials used have some guidelines for exposure, such as Threshold Limit Values (TLV) or Permissible Exposure Limits (PEL). When such values exist, they will be used to assist the Safety Officer or the Chemical Hygiene Officer in determining proper safety precautions, including control measures and safety apparel.
When TLV or PEL values exist and are low, the user of the chemical must use it in an operating fume hood or if a fume hood is not available, a respirator will be used in accordance to the "DEPARTMENT" Respirator Program (see Appendix D).
When TLV or PEL values are not available for that substance the Lethal Dosage information LD50 will be assessed. If that is low, then the chemical must also be used in a fume hood if possible, or a respirator must be used.
Whenever the chemical has a high vapor pressure, meaning that it evaporates quickly at room temperature, it will be used in a fume hood or else respiratory protection is needed. Those controls are necessary even if the chemical with the high vapor pressure also has a very high TLV or LD50, because such chemicals are likely to reach their exposure limits in air at least as quickly as a chemical with low exposure guidelines and a low vapor pressure.
Fume hoods or respirators will be used when: (see chem/exhaust hoods use guide)
In general, a flammable chemical is determined by its flash point, the lowest temperature at which an ignition source can cause the chemical to ignite momentarily. Although the lowest temperature at which the chemical will catch fire with an ignition source is called the "fire point," it is rarely more than one or two degrees greater than the "flash point." Therefore, the flash point will be used as the reference of "fire hazard" here at "DEPARTMENT".
OSHA and NFPA have guidelines on when a chemical is considered flammable. Those guidelines are herein adopted for use in the laboratory.
"Flammable" is generally used to refer to chemicals with a flash point below 100 degrees Fahrenheit (F). Chemicals with flash points between 100 and 200?F are termed "Combustible". Combustible chemicals have caused buildings to burn down; therefore, any chemical with a flash point below 200?F will be considered a "fire hazard" and will be stored in a flammable solvent storage area or flammable storage cabinet. They will be used in a vented fume hood, away from source of ignition.
More detailed discussions on fire hazards can be found in OSHA's regulations (29 Code of Federal Regulations 1910) and your local fire codes.
While NFPA has developed some guidelines on what constitutes a reactive chemical, their emphasis is centered on a fire emergency.
Other guidelines on which chemicals are reactive can be found in regulations from the Department of Transportation (49 CFR) and the Environmental Protection Agency (40 CFR).
At "DEPARTMENT", a reactive chemical is one which is:
Once a chemical has been determined to be reactive, all proper safety precautions will be used including extra segregation in storage and prohibition on mixing with other chemicals without appropriate personal protection and precautions.
A corrosive chemical is defined by OSHA, DOT, and EPA. So "DEPARTMENT" will consider a chemical corrosive if it fits the definition of corrosive found in regulations by:
- or it has a very low or very high Ph.
A skin or eye contact hazard chemical is one where the chemical's route of entry for its toxic effects is through the skin or eyes. Chemicals which are contact hazards will be determined by examining medical and industrial hygiene literature.
6.0 EXPOSURE EVALUATIONS AND MEDICAL CONSULTATIONS
This section discusses the reasons for performing a formal evaluation of suspected exposures, the documentation of such, and arrangements which should be made with medical professionals. This section MUST be tailored by "DEPARTMENT" and the following information is presented to supplement, not replace, your own criteria for evaluation and agreements with local medical professionals.
6.1 Suspected Exposures to Toxic Substances
There may be times when employees suspect that they have been exposed to some toxic substance in the laboratory. It is up to "DEPARTMENT" management to develop criteria which will help determine if the suspicion is reasonable. If the circumstances surrounding the complaint are determined to cause a reasonable suspicion of exposure to a chemical, then a designated responsible and unbiased individual in "DEPARTMENT" will initiate actions to formally evaluate the complaint.
6.1.1 Example Criteria of "Reasonable" Suspicion of Exposure
The following are examples of some events or circumstances which "DEPARTMENT" might reasonably consider as evidence that an exposure to toxic substances is likely:
It should be "DEPARTMENT" policy to promptly investigate ALL complaints to determine risk of employee overexposure to the toxic substance in their work place.
Once a complaint of possible hazardous chemical exposure has been received, the complaint should be documented in a short memo along with the decision of appropriate action. If it was decided that no further evaluation of the event is necessary, the reason for that decision should be included in the document. If a decision is made that the complaint should be investigated, then a formal Exposure Evaluation will commence.
6.2.1 Steps of Exposure Evaluation
The actual steps of the Exposure Evaluation will have to be determined by a responsible person or persons in "DEPARTMENT", preferably with the assistance of a qualified safety professional or Industrial Hygienist. Some steps that might be considered (but not limited to) include:
1. Interviewing the person initiating the complaint, and the victim if it is not the same person.
2. Listing essential information about the circumstances of the complaint including:
3. Air sampling of the area for suspect chemicals.
4. Determining how the symptoms compare to the information on the MSDS.
5. Deciding whether to send victim for medical evaluation.
6. Review of the adequacies of present control measures and safety procedures.
The employees must be notified of the results of any monitoring within 15 days of receipt of those results.
6.3 Medical Consultation
When employees are suspected or known to be overexposed to toxic chemicals, they should receive prompt medical attention. To ensure that they do receive proper and informed medical attention, "DEPARTMENT" should contract medical professional who is experienced in treating victims of chemical overexposure. The contracted medical professional should also be knowledgeable about which tests or procedures help determine if there has been an overexposure (techniques called "Differential Diagnosis").
It is authority of ______________ (person or title) to authorize medical consultation in Non-Emergency cases.
The person who will be examined will visit "DEPARTMENT" specialist: _______________ (name of contract _______________ (address) and ( ) _______________ (phone with area code).
It is the responsibility of _______________ (person or title) to arrange for the transportation of the person to be examined to and from the medical center (NOTE: if chemical exposure is confirmed or suspected, "DEPARTMENT" cannot assure that the victim can properly operate a motor vehicle).
The medical report will be sent directly to _______________ (person or title of primary contact named in the contract between "DEPARTMENT" and the contracted medical professional) and he will pass the appropriate information along to those involved.
6.3.2 Medical Consultation Contract and Capabilities
Appendix E has a copy of the Contractual Agreement and the Statement of Qualifications of our medical consultant.
All memos, notes and reports related to a complaint of possible exposure to toxic substances must be maintained in a file for easy retrieval with a cross-reference in the victim's personnel file. For more on reports and recordkeeping, see Section 8.0.
The employee shall be notified of the results of any medical examination with regard to any medical condition which might exist from overexposure to a chemical.
7.0 EMPLOYEE INFORMATION AND TRAINING
This section incorporates the minimal informational requirements of the OSHA Standard with suggestions for making an employee informational and training program effective. To see the minimum regulatory requirements, see Appendix A.
7.1 Informational Requirements
OSHA has required that employees be informed of:
Information does not need to be a formal training session in a classroom setting. Information can be from informal group or individual discussions with one's supervisor, posted notices, or handout booklets. OSHA has not shown interest in how the employees learn this information, but if asked by an OSHA inspector, the employees must be able to answer those issues accurately.
7.2 Preparing the Tools of Training Program
Although OSHA allows the information to be passed to employees in a non-classroom setting, formal training remains one of the best methods to ensure that all employees understand that safety is an issue to take seriously. There are many commercially available training aids with which your designated trainer can prepare a very comprehensive program.
Training aids available include:
- "Canned" programs designed by commercial concerns and professional organizations.
- Slides on specific topics or problems; books and booklets on safety matters.
- Overheads, books, slides, etc., prepared by your own company.
"Canned" Versus "Live" Programs
An employer may wish to compare the advantages and disadvantages of training programs involving live speakers versus taped presentations. The following table illustrates some of the advantages and disadvantages of each.
COMPARISON OF LIVE/CANNED TRAINING PRESENTATIONS
7.3 Development of a Training Program
A training program should be fully developed before it is
presented. There are numerous suggestions available for course development.
One suggestion comes from OSHA (Federal Register Vol. 49 No. 146, Friday, July 27, 1984,
Pages 30290-30294). OSHA Training Guidelines.
1. Determine if the training is needed.
2. Identify the training needs (who, what, when).
3. Identify the goals and objectives.
4. Develop learning activities.
5. Conduct the training.
6. Evaluate the program's effectiveness.
7. Improve/Supplement the program as necessary.
7.3.1 Determine if the Training Program is Needed
As with any major project, it is necessary to determine whether the program is necessary. In this case, the necessity is a regulatory one and not something which could be considered optional. To conserve the costs of training, it would be valuable to determine if there are any other training needs which are compatible with the OSHA training. For example, EPA's hazardous wastes regulations mandate that any employee involved with hazardous waste management must be trained on the hazards, which are very similar to OSHA's training requirements.
7.3.2 Identify the Training Needs
The regulatory contents of the training program have already been outlined. Other needs should be identified, including:
- Who has to be trained and on which topics.
- When to best do the training.
- How shall the training be done (the best format for the audience).
- Which topics should receive the most emphasis.
7.3.3 Identify Goals and Objectives
Training has many possible options and details to review. There are many safety topics which could be discussed. There are so many details, in fact, that it is possible to forget why the program is taking place. Remember that the Laboratory Standard training program is primarily for discussions on chemical safety and how the labels and Material Safety Data Sheets can improve safety, if properly used.
One special objective of any chemical safety course is that hazardous chemicals can be handled safely. Special safeguards may have to be used when handling a chemical, however, the chemical can ultimately be handled safely. This theme of safety might be repeated several times in the program.
7.3.4 Develop Training Program
Developing the training program can be simplified by using existing systems, shows and programs for common safety issues such as flammable or corrosive chemical safety. Some parts may have to be tailor-made for a unique situations if, for example, the company uses an internal labeling system on containers or an internal MSDS in place of those provided by manufacturers.
7.3.5 Conduct the Training
There may be some special problems to anticipate when conducting the training such as:
Scheduling - How to make sure everyone is trained, even those who are on vacations.
Questions - How to address the audience's questions both during and especially after the training sessions.
7.3.6 Evaluate the Program's Effectiveness
Because OSHA's enforcement of training is by a Performance Standard (meaning how well the people remember what was discussed as opposed to whether they attended the class), testing of some sort should be given after each program to ensure that everyone understands what was discussed.
Documentation of everyone's attendance in the program can help somewhat in proving to OSHA that the training did take place, but the OSHA inspector may request some other proof of the program's effectiveness.
7.3.7 Improve/Augment the Program
If necessary, the training program could be improved, updated, or added to. The way of determining that requirement is to have an active way of testing or evaluating the program's effectiveness.
7.3.8 Training Under 29 CFR 1910.1450
Training under 29 CFR 1910.1450 must include the following:
(See p. 3329, January 31, 1990, Section f, 4, i of Federal Register Volume 55, No. 21.)
8.0 RECORDS AND RECORDKEEPING
This section reviews the value of documenting compliance with this safety standard, not just for OSHA's information, but for general liability and the ability to periodically access the safe conduct of employees.
Specific records may be required in the event of lost work time resulting from an exposure or accident on the job. The standard form OSHA 200 is used to document lost workdays from incidents that occur at work. Contact your OSHA office to determine which forms and documents must be kept.
In addition to records required by OSHA, it might be desirable to keep special records developed internally which document suspected exposures and employee exposure complaints regardless of the outcome of the Exposure Evaluation. Other incidents and activities could be documented for future reference. Some examples of desirable records include:
- Complaints from Employees - Even if the complaint is found to be unjustified, it is desirable to keep a record of the complaint, the investigation, and the outcome. The complaints might be about chemical exposure, but could include complaints about inoperative engineered controls or defective personal protective equipment.
- Repair and Maintenance Records for Control Systems - Demonstrate that equipment such as fume hoods are well maintained and kept in proper operating order.
- Major Safety Suggestions from Employees - Can be valuable to improve laboratory safety. Even if the issue is decided to be non-workable, the fact that the suggestion was taken seriously and examined is valuable.
All records should be kept for at least as long as the employees affected are employed at the facility. OSHA requires some records to be kept for 30 years beyond the employee's time of employment. It is prudent to develop an archiving system to keep all important documents related to safety employee training and distribution of Material Safety Data Sheets for the lifetime of the company.
The Laboratory Standard requires that records be maintained of all Exposure Evaluations, Medical Consultations and reports, and that those records be maintained in accordance to 29 CFR 1910.20. That section requires those records to be maintained for at least 30 years and describes the accessibility of the records.
Remember that depending on the task and activity, there can be special recordkeeping requirements from OSHA, EPA, or other Federal and State agencies.
Lab Standard Regulations (29 CFR 1910.1450)
The following appendices are not included in the model plan, but should be made part of your Chemical Hygiene Plan.
Appendix B: List of Carcinogens at "DEPARTMENT (contact EH&S for dept chem inventory"
Appendix C: "DEPARTMENT" Emergency Action Plan - see
Appendix D: "DEPARTMENT" Respiratory Program, if needed
Appendix E: Contractual Agreement with the Statement of Qualifications of our Medical Consultant (request from Employee Health Center)
Appendix F: List "DEPARTMENT" safety references and locations for Material Safety Data Sheets
Appendix G: Spill Control Plan (Slug Discharge Plan) Sign (to be posted by sanitary drains