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OSHA LABORATORY STANDARD 29 CFR 1910.1450. FOR TULANE LABORATORY EMPLOYEES January, 2005. OBJECTIVES. To become familiar with the requirements of the OSHA Laboratory Standard and components of Tulane’s Chemical Hygiene Plan

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OSHA LABORATORY STANDARD 29 CFR 1910.1450


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    1. OSHA LABORATORY STANDARD29 CFR 1910.1450 FOR TULANE LABORATORY EMPLOYEES January, 2005 Tulane University - Office of Environmental Health & Safety (OEHS)

    2. OBJECTIVES • To become familiar with the requirements of the OSHA Laboratory Standard and components of Tulane’s Chemical Hygiene Plan • To ensure that all individuals at risk are adequately informed about work in the laboratory, its risks, methods to protect themselves, and procedures to follow in the event of an emergency • To become familiar with common concerns noted during laboratory inspections and with good chemical hygiene practices associated with laboratory work Tulane University - Office of Environmental Health & Safety (OEHS)

    3. OSHA LABORATORY STANDARD • The OSHA “Occupational Exposures to Hazardous Chemicals in Laboratories” Standard, or Laboratory Standard for short, requires employers to protect laboratory workers from health hazards associated with chemical exposure in the laboratory. Tulane University - Office of Environmental Health & Safety (OEHS)

    4. OSHA LABORATORY STANDARDOSHA DEFINITIONS Laboratory - A workplace where relatively small quantities of hazardous chemicals are used on a non-production basis Laboratory Scale – Containers used for reactions, transfers, and handling are small enough to be easily and safely manipulated by one person Tulane University - Office of Environmental Health & Safety (OEHS)

    5. OSHA LABORATORY STANDARDDOES IT APPLY TO YOUR LAB? • The determination of whether the OSHA Laboratory Standard applies as opposed to the OSHA General Industry Standard depends on “laboratory use” and “laboratory scale” criteria. • Some OSHA substance specific standards require coverage to remain under that standard rather than the Lab Standard. (Example: The use of formaldehyde in labs is covered under OSHA Formaldehyde Standard rather than the OSHA Lab Standard.) • Most Tulane labs fall under the OSHA Lab Standard. Tulane University - Office of Environmental Health & Safety (OEHS)

    6. OSHA LABORATORY STANDARDEXEMPTIONS • Quality control laboratories connected with production processes that perform repetitive tasks are exempt from the Lab Standard. • Uses of hazardous chemicals which provide no potential for employee exposure, such as medical labs which only use prepackaged test kits, are exempt from the Lab Standard. Tulane University - Office of Environmental Health & Safety (OEHS)

    7. OSHA LABORATORY STANDARDCHEMICAL HYGIENE PLAN (CHP) • A requirement of the OSHA Lab Standard is for all employers that have laboratories to develop a written Chemical Hygiene Plan (CHP). • Tulane’s CHP is located in the Laboratory Safety section of the OEHS Policies & Procedures Manual which can be found at the OEHS website, www.som.tulane.edu/oehs. Tulane University - Office of Environmental Health & Safety (OEHS)

    8. OSHA LABORATORY STANDARDCHEMICAL HYGIENE PLAN (CHP) • Tulane’s CHP is a generic plan covering the many different types of laboratories at Tulane. • It is to be supplemented by annually updated Standard Operating Procedures (SOPs) developed by laboratory supervisors/principal investigators discussing safety practices and procedures specific to the laboratory. Tulane University - Office of Environmental Health & Safety (OEHS)

    9. OSHA LABORATORY STANDARDCHEMICAL HYGIENE OFFICER (CHO) • The Lab Standard also requires each employer with laboratories to appoint a Chemical Hygiene Officer (CHO). • The certified CHO for Tulane University is Pam Fatland of OEHS. Tulane University - Office of Environmental Health & Safety (OEHS)

    10. OSHA LABORATORY STANDARDRESPONSIBILITIES OF TULANE’S CHO • Develop & update written CHP/ Review Laboratory Standard SOPs • Give guidance in the procurement, use, and disposal of chemicals • Assist in emergency planning and major cleanup activities • Perform laboratory inspections/ audit fume hood performance Tulane University - Office of Environmental Health & Safety (OEHS)

    11. OSHA LABORATORY STANDARDRESPONSIBILITIES OF TULANE’S CHO (Continued) • 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 Tulane University - Office of Environmental Health & Safety (OEHS)

    12. OSHA LABORATORY STANDARDRESPONSIBILITIES OF LABORATORY SUPERVISORS/PRINCIPAL INVESTIGATORS • Compose and annually update Laboratory Standard SOPs specific for their laboratories and submit to OEHS • Provide adequate Personal Protective Equipment (PPE) for laboratory personnel • Provide and document safety training for laboratory personnel • Perform quarterly inspections of labs Tulane University - Office of Environmental Health & Safety (OEHS)

    13. OSHA LABORATORY STANDARDRESPONSIBILITIES OF LABORATORY SUPERVISORS/PRINCIPAL INVESTIGATORS(Continued) • Contact OEHS if monitoring is 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 Tulane University - Office of Environmental Health & Safety (OEHS)

    14. OSHA LABORATORY STANDARDRESPONSIBILITIES OF LABORATORY WORKERS/TECHNICIANS • Plan and conduct activities in accordance with Tulane’s CHP and their laboratory’s SOPs • Develop good chemical hygiene habits Tulane University - Office of Environmental Health & Safety (OEHS)

    15. OSHA LABORATORY STANDARDSTANDARD OPERATING PROCEDURES • The SOPs cover specifics of the Chemical Hygiene Plan that apply to a particular laboratory. • The SOPS must be developed by the lab supervisor/principal investigator. • The SOPs must be updated and submitted to OEHS at least annually (usually in April/May). Tulane University - Office of Environmental Health & Safety (OEHS)

    16. OSHA LABORATORY STANDARDSTANDARD OPERERATING PROCEDURES • Guidelines for the Lab Standard’s annually updated SOPs can be found on the OEHS website, www.som.tulane.edu/oehs under the chemical safety link. • This format may be used, or the laboratory supervisor/principal investigator may develop his own format, as long as safety procedures for the specific laboratory are documented. Tulane University - Office of Environmental Health & Safety (OEHS)

    17. OSHA LABORATORY STANDARDTRAINING & INFORMATION • Training must be done at initial assignment and prior to new hazardous chemical/new exposure situations. • The purpose of training is to ensure that all individuals at risk are adequately informed about the work in the laboratory, its risks, methods to protect themselves, and procedures to follow in the event of an emergency. Tulane University - Office of Environmental Health & Safety (OEHS)

    18. OSHA LABORATORY STANDARDTRAINING & INFORMATION • It is the responsibility of the lab supervisor/principal investigator to document appropriate training & send records to OEHS. • Training documentation forms can be found at www2.som.tulane.edu/oehs/safety/04F-oehss03.pdf • Online quizzes at the end of this PowerPoint presentation will go directly to OEHS and will serve as training documentation for the OSHA Lab Standard presentation. Tulane University - Office of Environmental Health & Safety (OEHS)

    19. OSHA LABORATORY STANDARDTRAINING & INFORMATION • The lab supervisor/principal investigator must also provide training on laboratory specific information such as the SOPs for the laboratory, the proper use of particular chemicals and equipment in the laboratory, the appropriate PPE for the chemicals being used, etc. (see next slide for supervisor/PI training topics). Tulane University - Office of Environmental Health & Safety (OEHS)

    20. OSHA LABORATORY STANDARDTRAINING & INFORMATION TOPICSThe OSHA Lab Standard States that you must be familiar with the following: • 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 and reference materials Tulane University - Office of Environmental Health & Safety (OEHS)

    21. OSHA LABORATORY STANDARDTRAINING & INFORMATION TOPICS • For information on resources where you or your supervisor/ principal investigator can find specific chemical safety information, see the OEHS PowerPoint presentations on “Sources of Chemical Safety Information” and “The OSHA Hazard Communication Standard” on the OEHS website, www.som.tulane.edu/oehs Tulane University - Office of Environmental Health & Safety (OEHS)

    22. OSHA LABORATORY STANDARDEXPOSURE CONTROLThere are three main ways to control exposure to chemicals: • Engineering Controls (usually consists of ventilation, safety showers/eyewash units, etc.) • Work Practices (handling, storage, housekeeping, etc.) • Personal Protective Equipment (gloves, eye/face protection, etc.) Tulane University - Office of Environmental Health & Safety (OEHS)

    23. 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. At the very least, use a piece of tissue to make sure the hood is exhausting. Tulane University - Office of Environmental Health & Safety (OEHS)

    24. OSHA LABORATORY STANDARDEXPOSURE CONTROL – FUME HOODS • Typically a working fume hood should exhaust at a rate of 80-120 feet per minute face velocity. • Report problems promptly to Facilities Services. • DO NOT perform work with toxic or volatile chemicals if the hood is not operating properly! This is the user’s responsibility. Tulane University - Office of Environmental Health & Safety (OEHS)

    25. OSHA LABORATORY STANDARDEXPOSURE CONTROL – FUME HOODS • For more information on proper fume hood use or biological safety cabinets, see the OEHS PowerPoint presentation on Laboratory Ventilation found on the OEHS website, www.som.tulane.edu/oehs Tulane University - Office of Environmental Health & Safety (OEHS)

    26. 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 laboratory personnel. Showers must be tested at least annually by Facilities Services. Tulane University - Office of Environmental Health & Safety (OEHS)

    27. OSHA LABORATORY STANDARDEXPOSURE CONTROL – EYEWASHES/SHOWERS • Emergency showers/eyewashes must be readily accessible, clear of obstructions, and clearly labeled. • For more information on emergency eyewash/shower requirements, see the OEHS PowerPoint presentation on Eyewashes/Showers on the OEHS website, www.som.tulane.edu/oehs Tulane University - Office of Environmental Health & Safety (OEHS)

    28. OSHA LABORATORY STANDARDEXPOSURE CONTROL – WORK PRACTICES • Laboratory technique is important in minimizing exposure to hazardous chemicals. • There is no substitute for adequate planning and knowledge when using hazardous materials. Tulane University - Office of Environmental Health & Safety (OEHS)

    29. OSHA LABORATORY STANDARDEXPOSURE CONTROL – WORK PRACTICES • Practice good housekeeping. • Maintain aisles and uncluttered work areas. • Properly store and handle chemicals. • Substitute less hazardous materials when possible (such as non-mercury thermometers). • Scale down experiments. • Use secondary containment. • Use good chemical hygiene practices. Tulane University - Office of Environmental Health & Safety (OEHS)

    30. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT (PPE) • 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 & powder-free gloves). Tulane University - Office of Environmental Health & Safety (OEHS)

    31. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT (PPE) • A Dartmouth researcher got one drop of dimethylmercury on her latex glove and died from the exposure. Latex was not appropriate for protection for work with dimethylmercury. • Latex or PVC gloves are not suitable for direct contact with corrosive or highly toxic chemicals. • Glove permeability charts are available from glove manufacturers to help you decide which type of glove is appropriate for use with different chemicals. Contact OEHS for more information or if you have questions. Tulane University - Office of Environmental Health & Safety (OEHS)

    32. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT • 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, how and when to use it, how to maintain and store it, etc. Tulane University - Office of Environmental Health & Safety (OEHS)

    33. 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.). • Plan for the worst case scenario and be ready for an emergency. Tulane University - Office of Environmental Health & Safety (OEHS)

    34. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT (PPE) • PPE is covered in depth under the OSHA Personal Protective Equipment and OSHA Respiratory Protection Standards. The PPE standard requires an assessment for hand, eye and face, and body protection in the work area. • See OEHS PowerPoint presentation on personal protective equipment as well as the PPE section of the OEHS Policies and Procedures Manual at www.som.tulane.edu/oehs for more information on PPE. Contact OEHS for information on Tulane’s respiratory protection program. Tulane University - Office of Environmental Health & Safety (OEHS)

    35. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT (PPE) • In addition to wearing suitable PPE, a laboratory worker must also dress appropriately for their work. For example, sandals/flip-flops, shorts, and tops with exposed midriffs are inappropriate attire for laboratory work with hazardous materials. Tulane University - Office of Environmental Health & Safety (OEHS)

    36. OSHA LABORATORY STANDARDEXPOSURE CONTROL – PERSONAL PROTECTIVE EQUIPMENT (PPE) • Regular prescription eyeglasses do not take the place of safety glasses or goggles. • The American Chemical Society has taken the position that contact lenses may be worn in the laboratory as long as appropriate eye protection such as safety glasses or goggles, as required of other workers in the laboratory, is also worn. Tulane University - Office of Environmental Health & Safety (OEHS)

    37. OSHA LABORATORY STANDARDLABORATORY INSPECTIONS • OEHS annually inspects the laboratories for safety concerns. • Supervisors/principal investigators must perform quarterly inspections and submit them to OEHS. For a generic lab quarterly inspection form, see the OEHS website www.som.tulane.edu/oehs under the chemical safety link, or you may create your own inspection form specific to your lab. Note concerns and address them with a plan of correction. Tulane University - Office of Environmental Health & Safety (OEHS)

    38. OSHA LABORATORY STANDARDLABORATORY INSPECTIONS • Other entities such as the fire department, insurance companies, or regulatory agencies (OSHA, EPA) may also perform laboratory inspections. Contact OEHS if an outside agency inspector wants to inspect your laboratory. Tulane University - Office of Environmental Health & Safety (OEHS)

    39. OSHA LABORATORY STANDARDEXPOSURE MONITORING • Contact OEHS if there is a chemical exposure problem in your area or if you feel that chemical exposure monitoring is needed in your lab. • Be aware of chemicals with permissible exposure limits (PELs) – levels of exposure which should not be exceeded during a normal workday. Exposures may need to be monitored if there is reason to believe that the exposure to hazardous chemicals routinely exceeds the PELs. Tulane University - Office of Environmental Health & Safety (OEHS)

    40. OSHA LABORATORY STANDARDEXPOSURE MONITORING • Exposure levels may also need to be measured if a person has developed signs or symptoms of overexposure or in the event of a spill or leak. • OEHS has industrial hygiene staff and equipment to monitor for a variety of chemicals. Notify OEHS if there is a problem such as unusual odors, spills, chemical injuries, sudden exhaust problems, greater than routine exposure to highly toxic chemicals, etc. • Use adequate ventilation. Tulane University - Office of Environmental Health & Safety (OEHS)

    41. OSHA LABORATORY STANDARDPRIOR APPROVAL • Contact OEHS for prior approval and safety advice when using high risk substances (i.e., explosives, “select” carcinogens, reproductive toxins, substances with a high degree of acute toxicity), for grant “environmental compliance” statements, or for projects with possible safety concerns. Tulane University - Office of Environmental Health & Safety (OEHS)

    42. OSHA LABORATORY STANDARDPRIOR APPROVAL • Whenever high risk substances such as explosives, “select” carcinogens, reproductive toxins, or substances having a high degree of acute toxicity are used, a protocol sheet describing the project and the safety procedures/precautions that will be followed should be submitted to OEHS for review. Tulane University - Office of Environmental Health & Safety (OEHS)

    43. OSHA LABORATORY STANDARDPRIOR APPROVAL • Many grants require an environmental compliance statement be signed by the OEHS Director stating the researcher is in compliance with environmental health and safety laws. • OEHS reviews these protocols in depth, determines if the researcher is in compliance, suggests additional safety precautions that may be needed, etc. • DO NOT wait until a grant is due to submit such protocols. It takes time to perform this review. Tulane University - Office of Environmental Health & Safety (OEHS)

    44. OSHA LABORATORY STANDARDTOXICS/HIGH RISK CHEMICALSOSHA requires the following when using toxic or high risk chemicals such as allergens, embryotoxins, “select” carcinogens, toxic chemicals, etc.: • Use only in a designated area with restricted access and warning signs posted stating the hazard (may be entire laboratory, fume hood, etc.). • Use containment devices (such as fume hood, glove boxes, local exhaust). • Personnel must be familiar with waste removal procedures. Tulane University - Office of Environmental Health & Safety (OEHS)

    45. OSHA LABORATORY STANDARDTOXICS/HIGH RISK CHEMICALSOSHA requires the following when using toxic or high risk chemicals: • Decontamination procedures must be established (such as how to clean equipment that may become contaminated). • Emergency plans must be available in the event material spills, a splash occurs, etc. Tulane University - Office of Environmental Health & Safety (OEHS)

    46. OSHA LABORATORY STANDARDTOXICS/HIGH RISK CHEMICALSOSHA requires the following when using toxic or high risk chemicals: • Records of the materials used, names of workers involved, and dates/amounts used should be kept since, in many cases, illnesses related to chemical exposure can take years to develop. Tulane University - Office of Environmental Health & Safety (OEHS)

    47. OSHA LABORATORY STANDARDTOXICS/HIGH RISK CHEMICALSOSHA requires the following when using toxic or high risk chemicals: • SOPs should include specific requirements and special procedures for using toxic or high risk chemicals in the laboratory. Tulane University - Office of Environmental Health & Safety (OEHS)

    48. OSHA LABORATORY STANDARDMEDICAL PROGRAMA medical evaluation is available to all Tulane employees who experience: • Signs and symptoms of exposure to a chemical • Exposure above the Permissible Exposure Limits (PELs) on a routine basis • A spill/leak Tulane University - Office of Environmental Health & Safety (OEHS)

    49. OSHA LABORATORY STANDARDMEDICAL PROGRAM • The employee should fill out an injury/illness form and report to Occupational Medicine at the Hospital for medical care, or to the emergency room if after regular working hours, or the employee may go to their personal physician. Tulane University - Office of Environmental Health & Safety (OEHS)

    50. OSHA LABORATORY STANDARDSUPERVISOR/PI COMPLIANCE CHECKLISTThis is a summary of some of the paperwork and duties required by the lab supervisor/principal investigator: • Annual SOPs, chemical inventories submitted to OEHS • Training documentation submitted to OEHS • Quarterly inspections and inspection response to annual OEHS inspections submitted • PPE assessments done/PPE inspected and in good condition • High risk chemicals documentation and usage records kept Tulane University - Office of Environmental Health & Safety (OEHS)