Controlling Laboratory Chemical Hazards
The OSHA Lab Standard (29 CFR 1910.1450) requires that laboratory personnel implement appropriate control measures to ensure that chemical exposures are maintained below the regulatory limits and as low as reasonably achievable. In general, control measure can be categorized as administrative controls, engineering controls, procedural controls (i.e., standard operating procedures), or personal proactive equipment (PPE)
Administrative Controls
Administrative controls consist of various hazard control requirements that are established ay an administrative level (e.g., by the PI, Laboratory Manager, Laboratory Supervisor, Department Chair, Environmental Health and Safety-Safety Committee (EHSSC, or EHRS) to promote safety in the laboratory. Administrative controls describe the way the work is done and include, but not limited to, other measures to reduce employee’s exposure to hazards. Administrative controls do not remove hazard, but limit or prevent exposure to hazards. Examples of administrative controls include written plans and SOP(s), signs, labels, training, supervision, timing of work, personnel substitutions, using a lab partner, and more. PI(s) must:
- Ensure that all laboratory personnel have been provided with adequate safety and compliance training to enable them to conduct their duties safely.
- Conduct an assessment of the hazards in the laboratory by completing a Laboratory Hazard Assessment For Chemical Handling (LHACH ) Form
- Ensure that all laboratory personnel have been provided with adequate procedural (experiment-specific) training, and they are proficiently able to conduct their duties safely.
- Require prior approval of experimental procedures and implement additional control measures for certain hazardous or “High-Risk” operations or activities.
- Restrict access to areas in which particularly hazardous or “High-Risk” chemicals are used.
- Post appropriate signs to identify specific hazards within an area.
- Require that various standard practices for chemical safety and good housekeeping be always observed in the laboratory.
Prior Approval of Hazardous Operations
The OSHA Lab Standard requires that activities involving certain particularly hazardous chemicals be reviewed and approved in advance by an appropriate individual or group. Depending upon the specific department, this approving entity is primarily the PI, but could also be the Department Safety Committee, the LSC, or the Department Chair. At the time of approval, any additional required control measures for the project must be specified in writing. Examples of the types of operations that must receive prior approval are those involving the use of select carcinogens, reproductive toxins, acutely toxic chemicals, energetic material (explosives), highly reactive or shock-sensitive chemicals, highly corrosive chemicals, oxidizing chemicals or “High-Risk” chemicals. In addition, any operation that produce’s potentially hazardous results must receive prior approval.
Laboratory Entrance Signs
The entrance to each laboratory in which chemicals are used or stored must be posted with the names and phone numbers of the PI, LSC and any other designated personnel who can be contacted in the event of an emergency. The signage system is designed to fulfill regulatory signage requirements and alert lab users and visitors to specific hazards located in individual laboratories. The lab signs may not list every hazard associated with a lab and do not replace basic laboratory safety training or practice.
The OSHA Laboratory Standard requires that carcinogen, reproductive toxins, and chemical with a high-degree of acute toxicity (known as “particularly hazardous substances’) to be handled in a” designated area.” Although a designed area may be a small portion or a single chemical fume hood within a laboratory, the laboratory signs provide a means of designating the entire laboratory as an area where particularly hazard substances may be used.
Accurate door posting facilitate emergency response actions by providing immediate information to both internal and external police, firefighters, paramedics, EHRS and other emergency responders. Incorrect postings may place others in danger and/or delay implementation of control measures to minimize certain emergency situations (e.g., fire, explosion, etc.) thereby increasing the damage to the room and/or other portions of the building.
Procedural Controls
Procedural Controls (or work practice controls) are an administrative control typically in the form of rules, requirements, and standard operating procedures (SOP(s) that define the way certain types of chemicals are to be handled, or the way specific operations involving chemicals are to be conducted, to minimize hazards. The Chemical Hygiene Program contains several rules, requirements, and SOP(s) which are generally applicable to all laboratories. It is the responsibility of the PI and personnel in each laboratory to develop written SOP(s) for specific procedures performed in their laboratory. These laboratory-specific procedures must be well documented and accessible to authorized personnel. Training must be provided to new personnel by those that are proficient in the procedures. New personnel must eb supervised and proficient in performing the procedures before they are authorized to proceed.
Engineering Controls
Engineering controls consist of various measures for reducing a hazard at its source or for separating personnel from the hazard. In the laboratory, examples of engineering controls include isolating a particular chemical operation, enclosing a potential explosive reaction, or utilizing local exhaust such as a chemical fume hood for an operation that produces airborne chemicals. Because engineering controls function to reduce or eliminate a hazard at its source before its is created, they must eb fully considered and utilized whenever possible as the first step in chemical hazard control within the laboratory.
Personal Protective Equipment (PPE)
For may laboratory operations, the risk of chemical exposure cannot be eliminated with engineering and procedural control measures. Fore this reason, it is necessary to supplement such measures with the use of personal protective equipment (PPE) and apparel. Because PPE functions as barrier between the laboratory worker and the chemical hazard, rather than reducing or eliminating the hazard, its use must always be in addition to (and never as a substitute for) appropriate engineering and procedural controls.
It is the responsibility of the PI of the laboratory to ensure that appropriate PPE is provided and used by all laboratory personnel. Such equipment must be adequate to ensure personnel are protected from chemical exposure to the eyes, skin, and respiratory tract. PPE must be based on the hazard. Careful consideration to street clothes must eb given when working with potential fire hazards such as flammables, reactives, and pyrophoric. Synthetic fabric street clothes are not appropriate for these applications and all-cotton or fire-resistant lab coats or apparel must be utilized. The Laboratory Hazard Assessment For Chemical Handling (LHACH ) Form should be utilized to evaluate hazards and help assign the proper PPE based on the hazard. Please see the TU Respiratory Protection Program for detailed information about the use of respirators.