OSHA Hazard Communication Requirements for Radioactive Substances

1. OSHA Hazard Communication Requirements for Radioactive Substances By Elliot Stein U.S. Department of Energy New Brunswick Laboratory

2. Function of New Brunswick Laboratory (NBL) • NBL sells certified nuclear reference materials (i.e. uranium, plutonium, thorium, etc.). • Only lab of its type in the U.S. and one of 3 worldwide • NBL is DOE Government Owned and Government Operated (GOGO) Laboratory • NBL de facto small chemical manufacturer

3. Are Radioactive Substances Included in Haz Com Standard? 2012 Hazard Communication Standard does not apply to: 1910.1200(b)(6)(xi) Ionizing and nonionizing radiation However, OSHA has exposure limits for soluble and insoluble forms of uranium. Uranium is toxic as a heavy metal exclusive of its radioactivity.

4. OSHA Interpretation Letter of 4/15/13* • “When the laboratory ships nuclear standards that have only ionizing radiation hazards, it is not required to comply with the HCS requirements. Nevertheless, it has been OSHA 's longstanding position that if the radioactive material contains another type of chemical hazard that is not the result of the radioactivity of the chemical, the HCS requirements apply. See 59 Fed Reg. 6126, 6155 (Feb. 9, 1994) (final rule) (when "another type of hazard is presented along with the [radioactive] material (e.g., a container with a biological sample packed in a hazardous solvent), then the container would be subject to the requirement of the HCS for the other hazardous chemical"); 53 Fed. Reg. 29833, 29841 (Aug. 8, 1988) (proposed rule) (when "a radioactive chemical presents other types of chemical hazards that are not the result of the radioactivity of the chemical, it will be covered for those hazards"). Therefore, when the nuclear standards that are shipped have a chemical hazard that is not the result of the radioactivity of the chemical, the standards must be labeled for those chemical hazards and have a MaterialSafety Data Sheet (MSDS) or SDS.” • *Letter Thomas Galassi, Director US DOL OSHA Directorate of Enforcement Programs to Elliot Stein dated April 15, 2013

5. Common Chemical Hazards of Radioactive Materials Unrelated to Radioactivity • Is material acidic or basic (i.e. uranyl nitrate, plutonium nitrate, etc.)? • Is material reactive (i.e. pyrophoric uranium shavings, etc.)? • Can material form other hazardous products (i.e. uranium hexafluoride exposed to moisture in air generates hydrogen fluoride and uranyl fluoride, etc.). • Does material have toxicity unrelated to radioactivity (i.e. depleted uranium is toxic as heavy metal, etc.).

6. Radioactive Material Requirements relative to OSHA Lab and Haz Com Standards • Laboratories storing or using radioactive materials must comply with OSHA Lab Standard requiring labeling, SDSs, training, etc. • Non-laboratory areas of facility must comply with HCS requirements requiring labeling, SDSs, training, etc.

7. Example of NBL Haz Com Label Uranium Hexafluoride • U.S. Department of Energy • New Brunswick Laboratory • 9800 S. Cass Ave., Building 350 • Argonne, IL 60439 • 1-630-252-CRMS • Off Hours Emergency Numbers: 1-630-252-6131 or 1-630-252-5731 • URANIUM HEXAFLUORIDE • (CRM 113-A, CRM 113-B ) • Danger! • Fatal if Inhaled • Causes Severe Skin Burns and Eye Damage • Toxic to aquatic life with long lasting effects • Radioactive • Do not breathe gas • Do not get on skin or in eyes. • Wear respiratory protection, gloves and goggles. • First Aid: Inhalation: Immediately call 911 . Remove to fresh air at once. External/Eyes : Immediately call 911 Wash continuously with fresh water for 15 minutes. Apply calcium gluconate gel to skin surfaces. • In Case of Fire: Negligible fire hazard. Use triclass, dry chemical or carbon dioxide fire extinguisher. For larger fires use water spray, fog or foam.

8. Example of NBL SDS Uranyl Nitrate

9. Questions