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Date: Wed, 28 Jul 2004 11:14:23 -0500
Reply-To: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Subject: Re: Latex Glove degeneration
Comments: To: approval1**At_Symbol_Here**esf.uvm.edu
The letter in question states that the training and hazard assessments
required under the Lab standard and the Bloodborne Pathogens standard
can meet the requirements of the PPE standard "if the hazard assessments
and training for laboratory and clinical health care employees are
pertinent for the hazards found in the workplace."
"If," for only having two letters, is a very big word in "OSHA World".
There is a letter of interpretation on the federal OSHA website noting
that the requirement for gloves under the Bloodborne Pathogen standard,
being more specific and stringent, takes precedence over the PPE
standards.
Typically, where two or more training standards apply, we tell
employers that, as long as the training includes the required elements
under each applicable standard, the training can be combined. For
example, we do not expect employers to train their employees on the
health effects of lead in one session under our Employee Right-To-Know
standard (i.e., the MN version of federal HAZCOM), and then have a
separate session covering the health effects of lead under the Lead
standard (190.1025).
It is interesting to note that, in the aftermath of Dr. Wetterhahn's
death, Dartmouth College was cited by federal OSHA for:
1) Training under the PPE General Requirements standard,
1910.132(f)(1);
2) The use of gloves appropriate to the hazards present and glove
selection under the PPE Hand Protection standard, 1910.138(a) and (b);
and
3) Failure of the written Chemical Hygiene Plan to adequately protect
employees from health hazards associated with hazardous chemicals in the
lab. (I believe this citation specifically referenced the uses of gloves
in the lab.)
I too, have used Dr. Wetterhahn's death as an example when training our
investigators on PPE enforcement, both as an example case, and as a
reminder to be aware of their surroundings and their own personal safety
when out in the field.
- Diane Amell, MNOSHA
>>> "List Moderator" 7/28/2004 7:23:53 AM >>>
Date: Tue, 27 Jul 2004 13:42:04 -0700
From: "Larry D. McLouth"
Organization: Lawrence Berkeley National Laboratory
Subject: Re: [DCHAS-L] Latex Glove degeneration
At the risk of straying from the original question, hazard
assessments as prescribed by the OSHA PPE Standard are prudent for
lab operations but according to an OSHA interpretation, they are not
required if these elements are covered in training. See the OSHA
Interpretation entitled:
"01/23/1995 - The application of the Personal Protective Equipment
standard to PPE hazard assessment and training for laboratory and
clinical health care workers." At this URL:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21681
As I read the Lab Standard, the PPE standard and this interpretation,
I think OSHA is saying that the PPE standard was intended for chem
hazards related to operations where the hazards are relatively stable
- i.e, in industrial situations and production processes where the
chem hazards don't change that much. Lab environments are more
dynamic.
I'd be interested in your thoughts on this matter.
BTW we use Ms. Wetterhahn's tragic death as a lessons learned and as
a segue to glove selection during Chem Hygiene Training. We teach
people how to use glove resistance charts and web based selection
databases.
Larry
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