L. Swihart REM, Purdue 9/17/2003

1. OSHA Lab Standard 26 CFR 1910.1450 & The Purdue Chemical Hygiene Plan L. SwihartREM, Purdue 9/17/2003

2. “Compare and Contrast?” Since there are unavoidable similarities, important differences, and high potential for confusion… …the OSHA Lab Standard and its Chemical Hygiene Plan requirement are presented in terms of the differences from and similarities to the OSHA HazCom Standard and its Hazard Communication Programrequirement.

3. HazCom came first. (when was that?) HazCom, as it applies to employers, excepts laboratories (without defining laboratory) from everything except: Keep labels intact Train and Inform Keep incoming MSDSs Make outgoing MSDSs for chemicals leaving

4. Lab Standard came after.Apparently because it was agreed that holding chemical lab research to HazCom rules would impede research. Call it 1990. • Applies to "employers engaged in the laboratory use" of hazardous chems. • Lab use defined -- four-part definition 1. Laboratory scale 2. Multiple chemical procedures or chemicals 3. Not a production process or related 4. "Protective laboratory practices and equipment" available and in common use

5. Both HazCom and Lab Standard mandate that the employer make a "plan" • 1910.1200 mandates a HCP • (Hazard Communication Program) • 1910.1450 mandates a CHP • (Chemical Hygiene Plan)

6. Which Program Where? • Many employers/workplaces have to have both (a HCP and a CHP) • Arguments still abound about exactly how to apply either/both when/where and to whom. • Many employers implement strict rules covering both sets of bases. …..for example ……

7. LBNL.org -- “The Hazard Communication Standard was developed to inform employees who work with hazardous chemicals of the risks associated with those chemicals. A separate standard (the "Laboratory Standard") was specifically developed for laboratory operations because these environments often differ from industrial and office settings in the use and handling of hazardous chemicals. “LBNL combined both of these requirements into this Chemical Hygiene and Safety Plan in order to establish a standardized framework for chemical hygiene practices, information dissemination, and training at LBNL regardless of the occupational setting.”

8. How is this relevant to you? • What sort of jobs is your training and degree likely to get you? • Where will you be in 5 years? • Is your crystal ball working? Mine’s been out of order for a long time.

9. Lab Standard • Twelve sections(a) - (l). • It’s LESSstrict than HazCom. • But similar in parts. !?

10. (a) Scope and Application • “All employers engaged in the ‘laboratory use’ ....” • Supersedes other subpart Z requirements except: • PEL limitations • Skin and eye contact prohibition • Monitoring/surveillance requirements (what is Subpart Z again?)

11. (b) Definition -- expanded “Laboratory use of hazardous chemicals” • Chemical manipulations are carried out on a "laboratory scale;“ and • Multiple chemical procedures or chemicals are used; and • 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.

12. (c) PELs, and(d) Exposure Determination • Section (c) - Employer shall assure that PELs ARE NOT EXCEEDED. • Section (d): Employer shall • measure exposure if reason to believe action levels are routinely exceeded, written notice of results to employee within 15 working days. • if monitoring is warranted, obey relevant standard for monitoring

13. (e) Chemical Hygiene Plan • The Lab Standard requires that the employer develop and carry out a written CHP which will • protect employees from... chemicals, & • keep exposures below the PELs, & • be readily available to employees, & • include all of the following elements:

14. SOPs. Control measure criteria. Safety equipmentmaint/testing. Provisions for INFORMATION & TRAINING. Required CHP elements • List of operationsrequiring prior approval. • Designation of Chem Hygiene Officer. • Provisions for “select carcinogens....” • Annual review of CHP effectiveness.

15. Training Information & Methods of detection contents of 1910.1450 location, availability of employer CHP Physical and health hazards reference material Protective measures Signs/symptoms CHP details LIMITS (PELs, TLVs,...) (f) Specific elements of:

16. I. signs/symptoms shown II. monitoring indicates need III. An “event” results in likelihood of exposure Opportunity shall be provided under circumstances I, II, III (g) Medical evaluation/ consultation Shall be followed by Dr.’s written opinion Requires that Employer provide info to Dr. • Shall be • no cost • licensed physician

17. Hazard Identification (h) • Labels remain intact. • Keep the MSDSs you get. • Determine hazards of homebrew chems ... or assume hazardous if not possible. • Prepare MSDSs for chemicals traveling to another user outside the laboratory.

18. The Rest • (i) Respirator use • (j) Recordkeeping • (k) Effective date • Jan 31, 1991 - CHP written and implemented • (l) Appendices, non-mandatory

19. Major differences MSDS requirement inventories the "supersede" business annual review medical evaluation Chemical Hygiene Officer monitoring required if…

20. Major similarities same definitions, largely. info/training requirements, mostly. the GOAL is the same. (What was the goal again?)

21. Thank you.