Key Compliance Issues OSHA Laboratory Standard Lab Safety Plan, training of staff, MSDSs, emergency plan, secure compressed gas cylinders, out-dated peroxide-formers EPA/State Hazardous Waste regulations Lids, labels, mixing incompatibles Fire/Life Safety Codes 10 gal flammables limit, clear lab egress, hallway storage University policies Training, prevention of injuries, personnel policies, grant proposal review UNC EHS Manual
Training Topics 1. Location of the Laboratory Safety Standard 2. Chemical Hygiene Plan 3. Engineering Controls 4. Health & Safety Hazards 5. Pre-Purchase Review of Products 6. Detection of Release or Presence of Hazardous Chemicals 7. Personal Protective Equipment (PPE) 8. Emergency Response Plan 9. MSDSs 10. Labels & Inventory 11. Location of First Aid & Accident Reports 12. Fire Extinguisher Training & Flammable Hazards 13. Hazardous Waste Procedures 14. Chemistry Stockroom 15. Safety Contact Information
The Laboratory Safety Standard OSHA Standard 29 CFR 1910.1450 1
OSHA Standard 29 CFR 1910.1450 Occupational Exposure to Hazardous Chemicals in Laboratories (The Laboratory Safety Standard) (The Laboratory Safety Standard) 1910.1450(f)(3)(i) “The contents of this standard and its appendices which shall be made available to employees;”
The Chemical Hygiene Plan (CHP) Should be capable of protecting employees from health hazards associated with hazardous chemicals in the laboratory Should be readily available to employees 1910.1450(e)
Standard Operating Procedures SOPs 1910.1450(e)(3)(i) “Standard operating procedures relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals”
Michigan State University SOP Michigan State University SOP GUIDELINES FOR PREPARING SOP's Three methods that can be used to write SOP's: 1.By Process: (distillation, synthesis, chromatography, etc.) 2.By Individual Hazardous Chemical: (arsenic, benzene, hydrochloric acid, etc.) 3.By Hazardous Chemical Class: (flammable, corrosive, oxidizer, etc.) Standard Operating Procedures SOPs 1910.1450(e)(3)(i)
Fume Hoods “A requirement that fume hoods and other protective equipment are functioning properly and specific measures that shall be taken to ensure proper and adequate performance of such equipment;” 1910.1450(e)(3)(iii)
Fume Hoods Each employee should be completely familiar with the proper use and operation of the fume hood in their lab Information on this subject may be located in the ACS Publication provided in the departmental CHP. Additional information may be found online at the links provided in section 3 of the “Detailed Information” 1910.1450(e)(3)(iii)
Fume Hoods Fume Hoods should be tested for flow rate at least annually Arrangements should be made as soon as possible to have the hoods in your lab tested The test results should be posted in a conspicuous place on the hood 1910.1450(e)(3)(iii)
Showers & Eyewashes Showers & Eyewashes “Maintenance. Eye wash fountains should be inspected at intervals of not less than 3 months (6). Respirators for routine use should be inspected periodically by the laboratory supervisor (169). Other safety equipment should be inspected regularly. (e.g., every 3-6 months) (6, 24, 171).” 29 CFR 1910.1450 Appendix A, D. “The routine inspections of showers mentioned in Appendix A of Section 1910.1450 is not a mandatory requirement for which OSHA would normally issue a citation.” “The routine inspections of showers mentioned in Appendix A of Section 1910.1450 is not a mandatory requirement for which OSHA would normally issue a citation.”
Because shower testing is specifically mentioned in the University CHP, we are obligated to test them Testing is also mandated by ANSI “Devices must also be inspected annually to assure compliance with ANSI Z358.1 maintenance and testing requirements.” Showers & Eyewashes Showers & Eyewashes However… ANSI Z358.1 ASU Safety Office ASU Safety Office
“Provisions for additional employee protection for work with particularly hazardous substances. These include "select carcinogens," reproductive toxins and substances which have a high degree of acute toxicity. Specific consideration shall be given to the following provisions which shall be included where appropriate:” 1910.1450(e)(3)(viii)
Health & Safety Hazards Health & Safety Hazards 1910.1450(e)(3)(viii)(A) Establishment of a designated area; 1910.1450(e)(3)(viii)(B) Use of containment devices such as fume hoods or glove boxes; 1910.1450(e)(3)(viii)(C) Procedures for safe removal of contaminated waste; and 1910.1450(e)(3)(viii)(D) Decontamination procedures.
H & S Hazards IARC - International Agency for Research on Cancer Monographs Programme on the Evaluation of Carcinogenic Risks to Humans NTP - National Toxicology Program 10 th Report on Carcinogens (RoC) ACGIH - American Conference of Governmental Industrial Hygienists OSHA – Regulated Carcinogens Regulated CarcinogensRegulated Carcinogens 1910.1450(e)(3)(viii) C arcinogens
H & S Hazards Group 1: Group 1: The agent (mixture) is carcinogenic to humans. Group 1: Group 2A: Group 2A: The agent (mixture) is probably carcinogenic to humans. Group 2A: Group 2B: Group 2B: The agent (mixture) is possibly carcinogenic to humans. Group 2B: Group 3: Group 3: The agent (mixture, or exposure circumstance) is not classifiable as to carcinogenicity in humans. Group 3: Group 4: Group 4: The agent (mixture, exposure circumstance) is probably not carcinogenic to humans. Group 4: IARC 1910.1450(e)(3)(viii) C arcinogens
H & S Hazards Group 1 "Known Carcinogen" (Sufficient information from human studies to indicate causal relationship) Group 2 "Reasonably Anticipated" (Limited evidence of carcinogenicity in humans; or sufficient evidence of carcinogenicity in experimental animals) NTP 10 th RoC 1910.1450(e)(3)(viii) C arcinogens
H & S Hazards ACGIH A1 confirmed human carcinogen A2 suspected human carcinogen A3 animal carcinogen A4 not classifiable as a human carcinogen A5 not suspected as a human carcinogen 1910.1450(e)(3)(viii) C arcinogens
Select Carcinogens Select carcinogen means any substance which meets one of the following criteria: It is regulated by OSHA as a carcinogen It is listed under the category, "known to be carcinogens," in the latest NTP RoC It is listed under Group 1 ("carcinogenic to humans") by IARC It is listed in either Group 2A or 2B by IARC or under the category, "reasonably anticipated to be carcinogens" by NTP 1910.1450(e)(3)( viii ) H & S Hazards
H & S Hazards Initial Monitoring 1910.1450(d)(1) “Initial monitoring. The employer shall measure the employee's exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels for that substance routinely exceed the action level (or in the absence of an action level, the PEL).” NOTE: NC PELs supersede the Federal ones NC PELs supersede the Federal onesNC PELs supersede the Federal ones
H & S Hazards Initial Monitoring The university has a list of 11 chemicals that require initial monitoring before use. These are only a few of the chemicals that OSHA requires initial monitoring on. Lawrence Livermore National Laboratory carcinogen list Lawrence Livermore National Laboratory carcinogen list 1910.1003 - 1052
H & S Hazards Other Other Materials are Considered by OSHA to be Physical Hazards 1910.1450(e)(3)(viii) “Physical hazard means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer pyrophoric, unstable (reactive) or water- reactive.” “Physical hazard means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer pyrophoric, unstable (reactive) or water- reactive.”
Time-Sensitive Chemicals Health & Safety Hazards
H & S Hazards Time-Sensitive Chemicals 1. 1. Peroxide formers 2. 2. Peroxide formers that can undergo hazardous polymerization 3. 3. Materials that become shock or friction sensitive upon the evaporation of a stabilizer 4. 4. Materials that generate significant additional hazards by undergoing slow chemical reactions DOE
Berkeley Peroxide Storage H & S Hazards Time-Sensitive Chemicals
Before Ordering… Determine the least amount of material that will suffice, and order that amount - even if the initial cost is higher Determine if a less hazardous material would could be substituted Determine if a colleague already has the material in house, and will share
Detection of Release or Presence of Hazardous Chemicals 6
1910.1450(f)(4)(i)(A) “Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);”
Spills 1910.1450(f)(4)(i)(A) Considered “Major” or “Minor” by university A “Major” spill, would be considered one that you could not contain by yourself Keep a spill kit in the laboratory. The organic labs have chemical specific kits There is more information at: Chemical Spills Chemical Spills
PPE “The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.” 1910.1450(f)(4)(i)(C)
Goggle regulations for laboratories are included in the packet Links to proper glove type based on chemical class are included in the packet glove type based glove type based The official position on respirators is: avoid using them by using engineering controls (hoods). If you require a dust mask or respirator, you MUST undergo training with the Industrial Hygienist. PPE 1910.1450(f)(4)(i)(C)
Emergency Response Plan Emergency Response Plan a) A written emergency plan should be established and communicated to all personnel; it should include procedures for ventilation failure (200), evacuation, medical care, reporting, and drills (172). 29 CFR 1910.1450 Appendix A, D 9a.
The University ERP “The priorities for emergency response are life safety, property protection and preservation of academic programs.” The university ERP deals with major disaster responses and the protocols for such You should read and familiarize yourself with the details of this plan Emergency Response Plan
The Departmental ERP “Faculty or staff of the A.R. Smith Department of Chemistry who observe any emergency or disaster in the classrooms, instructional laboratories, research laboratories, or chemical storeroom facilities operated by the department will immediately report this incident to University Police by dialing Ext. 8000 and giving details of the nature, location, and extent of the incident.” “Faculty or staff of the A.R. Smith Department of Chemistry who observe any emergency or disaster in the classrooms, instructional laboratories, research laboratories, or chemical storeroom facilities operated by the department will immediately report this incident to University Police by dialing Ext. 8000 and giving details of the nature, location, and extent of the incident.” Emergency Response Plan
MSDSs OSHA Standard 29 CFR 1910-1450 (h)(1)(ii) “Employers shall maintain any material safety data sheets that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible to laboratory employees.”
MSDSs But, do I need an MSDS for every chemical?But, do I need an MSDS for every chemical? www.alan.net/prglol OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs 1.Is the chemical a general household or office product?Yes____ No____ 2.Is the chemical being used for its intended purpose?Yes____ No____ 3.Is the chemical used in small quantities? Yes____ No____ 4.Is the chemical’s use incidental to your work (used infrequently and for short periods of time)? Yes____ No____ Appalachian Safety Office - MSDS OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs Okay, but do I have to have a hard copy of each MSDS on hand? OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs Refer to the standard – “…ensure that they are readily accessible to laboratory employees.” If you are going to maintain MSDSs electronically, you must guarantee that anyone working in your lab… OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs Have access to a computer The computer system is always available OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs OSHA Standard 29 CFR 1910-1450 (h)(2) What about new chemicals that are developed in my lab?
MSDSs OSHA Standard 29 CFR 1910-1450 (h)(2) 1910-1450 (h)(2)(i) If the composition of the chemical substance which is produced exclusively for the laboratory's use is known, the employer shall determine if it is a hazardous chemical as defined in paragraph (b) of this section. If the chemical is determined to be hazardous, the employer shall provide appropriate training as required under paragraph (f) of this section. 1910-1450 (h)(2)(ii) If the chemical produced is a byproduct whose composition is not known, the employer shall assume that the substance is hazardous and shall implement paragraph (e) of this section. 1910-1450 (h)(2)(ii) If the chemical substance is produced for another user outside of the laboratory, the employer shall comply with the Hazard Communication Standard (29 CFR 1910.1200) including the requirements for preparation of material safety data sheets and labeling. requirements for preparation of material safety data sheets
MSDSs OSHA Standard 29 CFR 1910-1450 (h)(1)(ii) What information must be on the MSDS?
Chemical Identity Section I: Manufacturer’s Name, Contact Information, Date Prepared Section II: Hazardous Ingredients/Identity Information Section III: Physical/Chemical Characteristics Section IV: Fire and Explosion Hazard Data Section V: Reactivity Data Section VI: Health Hazard Data Section VII: Precautions for Safe Handling and Use Section VIII: Control Measures MSDSs OSHA Standard 29 CFR 1910-1450 (h)(1)(ii)
MSDSs Section 1 No Date? Useful for ordering or research Section 6? Section 2
MSDSs Section 4? OSHA Standard 29 CFR 1910-1450 (h)(1)(ii) This will tell you what class flammable Section 7? Section 6?
MSDSs Section 3? OSHA Standard 29 CFR 1910-1450 (h)(1)(ii) This information might be useful in an accidental release Section 8 Section 7
MSDSs Section 5? OSHA Standard 29 CFR 1910-1450 (h)(1)(ii) Oh, here’s the date! MSDS Demystifier MSDS Demystifier This would help with labeling and storage. You will know if it is a time-sensitive material. Waste & spills LD 50 s
Labels Time-Sensitive Chemicals The full chemical name Date received Date opened Date of decision Peroxide level There is no specific regulation on these, but… the industry standard is -
Label Systems ANSI - American National Standards Institute NFPA - National Fire Protection Association HMIS - Hazardous Materials Identification System HMIG - Hazardous Materials Identification Guide DOT - Department of Transportation
Labels & Signs ANSI Standard Z535.4-1998 DANGER indicates an imminently hazardous situation which, if not avoided, will result in death or serious injury. This signal word is to be limited to the most extreme situations. WARNING indicates a potentially hazardous situation which, if not avoided, could result in death or serious injury. CAUTION indicates a potentially hazardous situation which, if not avoided, may result in minor or moderate injury. It may also be used to alert against unsafe practices.
Flammability Hazard Health Hazard Reactivity Hazard Special Hazard Hazard Rating 4Severe 3Serious 2Dangerous 1Minor 0Slight NFPA DIAMOND
The Hazardous Materials Identification System, HMIS® HMIS System OLDNEW HMIS® III
Hazardous Material Identification Guide - HMIG System developed by Lab Safety Supply, Inc. HMIG is based on type of PPE that should be used when working with the chemical HMIG System HMIG System HMIG System
DOT Label Codes “The Hazardous Materials Transportation Act of 1975 (HMTA), is the major transportation-related statute affecting transportation of hazardous cargoes.” DOT Codes DOT Codes
Labels OSHA Standard 29 CFR 1910-1450 (h)(1)(i) OSHA Labeling Standard “Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced.”
Labels Secondary Containers The full chemical name The date of preparation Concentration All that is required under the Laboratory Safety Standard OSHA Standard 29 CFR 1910-1450 (h)(1)(i) That being said…
Labels ANSI Z129.1: American National Standard for Hazardous Industrial Chemicals - Precautionary Labeling and ANSI Z535.4 ANSI Z129.1 ANSI Z129.1 OSHA's Hazard Communication Standard (HCS), at 29 CFR 1910.1200(f)(5) states "... the employer shall ensure that each container of hazardous chemicals in the work place is labeled, tagged or marked with... (i) Identity of the hazardous chemicals...and (ii) Appropriate hazard warnings, or alternatively, words, pictures, symbols or combination thereof,...to...provide the employees with the specific information regarding the physical and health hazards of the hazardous chemicals." OSHA Standard 29 CFR 1910-1450 (h)(1)(i) RTK Labels
Inventory Make sure that there is a current inventory available for your research lab The standard format is a Microsoft Excel Spreadsheet Information should include full chemical name, formula, physical form, CAS # and NFPA information ( amount present in area would also be useful information)
Segregate incompatible chemicals General storage should never be alphabetical Never store chemical on the floor Inventory
Location of First Aid Supplies and Accident Reports 11
First Aid Supplies There is an assortment of first aid supplies in the Stockroom. They are in a drawer in Section 200. Some of the teaching labs also have first aid kits More information on kit contents can be found at the ASU Safety Office kit contentskit contents
EMPLOYEES RESPONSIBILITY IN THE EVENT OF A JOB-RELATED INJURY OR ILLNESS Report all injuries or illness to your supervisor immediately Seek appropriate medical attention from the following authorized primary care physicians: ASU Student Health Services Watauga Medical Center Emergency Room Contact Watauga Medics at 9-911 for emergency transportation to Watauga Medical Center Emergency Room. For non-emergency transportation to ASU Student Health Services or Watauga Medical Center Emergency Room, contact University Police at ext. 8000 or 2150. ASU Safety Office ASU Safety Office
“Accident records should be written and retained” There is a short form for non-work related injuries in the manual All injuries should be reported and a report filled out 1910.1450 App A Accident Reports 7 (a)
Fire Extinguisher Use & Flammable Hazards Fire Extinguisher Use & Flammable Hazards 12
Class IIIA Class II COMBUSTIBLE (Flash Point > 100 °F) Class IC FLAMMABLE FLAMMABLE Class IA Class IB (Flash Point < 100 °F) (Flash Point < 100 °F) 200 140 100 73 OSHA 100 °F Boiling Point °F ° F Flash Point ° F Examples Standard 29 CFR 1910.106
NFPA DIAMOND NFPA 30 (2000) 4 Danger Flammable gas or extremely flammable liquid (Class IA liquids) 3 Warning Flammable liquid flash point below 100° F (Class IA; IB; or IC) 2 Caution Combustible liquid flash point of 100° to 200° F (Class II; or IIIA) 1 Combustible if heated 0 Not combustible Flammability Hazard
Flammable Liquid Storage Refer to OSHA Standard 1910.106(d)(2)(iii)(a)(2) – Table H- 12. 1910.106(d)(2)(iii)(a)(2) 1910.106(d)(2)(iii)(a)(2) 1910.106(d)(3) -- Design, construction, and capacity of storage cabinets (i) -- Maximum capacity. Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids may be stored in a storage cabinet.
Fire Emergencies We are now allowed to use fire extinguishers without formal training. There is a handout in your manual The official evacuation distance from the building during a fire drill or actual emergency is 50 feet.
Labeling of Waste “Hazardous Waste” Contents as chemical names Start date of accumulation PI name and room number The approximant amount (%) of each chemical is also helpful Segregate incompatible chemicals The NC EPA manual is on the M drive. EPA 40 CFR 260-270
Stockroom Use General storage chemicals must be checked out from the stockroom. There is a sign out book by the back door. Indicate what room the chemical is moving to, and how long it will be there. If indefinite, notify the stockroom manager. If you use up all of a general storage chemical, notify the stockroom manager. Do not remove equipment from the stockroom without notifying the stockroom manager. Chemicals prepared in the stockroom should be labeled according to 29 CFR 1900.1200 (HAZCOM)
Complete individual inventories Decide as a department on a uniform labeling system Test time-sensitive chemicals Remove all time-sensitive chemicals that are out of date Test eyewashes and showers Gather MSDSs for all chemicals used in teaching labs
2. Chemical Procurement, Distribution, and Storage (a) Procurement. Before a substance is received, information on proper handling, storage, and disposal should be known to those who will be involved (215, 216). No container should be accepted without an adequate identifying label (216). Preferably, all substances should be received in a central location (216). 29 CFR 1910.1450 Appendix A, D 2a.
(b) Inspections. Formal housekeeping and chemical hygiene inspections should be held at least quarterly (6, 21) for units which have frequent personnel changes and semiannually for others; informal inspections should be continual (21). 29 CFR 1910.1450 Appendix A, D 3b.
8.Prominent signs and labels of the following types should be posted: (a) Emergency telephone numbers of emergency personnel/facilities, supervisors, and laboratory workers (28); 29 CFR 1910.1450 Appendix A, D 8a.
(c) Discarding Chemical Stocks: Unlabeled containers of chemicals and solutions should undergo prompt disposal; if partially used, they should not be opened (24, 27). Before a worker's employment in the laboratory ends, chemicals for which that person was responsible should be discarded or returned to storage (226). 29 CFR 1910.1450 Appendix A, D 11c.