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Previous by Date: Subject: Re: [DCHAS-L] OSHA LAB Standard applicability Date: Wednesday, March 30, 2016 2:47:01 PM Author: Allen Niemi <anniemi**At_Symbol_Here**MTU.EDU> |
Next by Date: Subject: Re: [DCHAS-L] OSHA LAB Standard applicability Date: Wed, 30 Mar 2016 19:11:43 +0000 Author: "Schlereth, Sarah" |
I believe that the lab standard absolutely applies to the physical hazards of chemicals. … Jim
1910.1450(f)(4)
Training.
Employee training shall include:
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.);
1910.1450(f)(4)(i)(B)
The physical and health hazards of chemicals in the work area; and
1910.1450(f)(4)(i)(C)
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.
James A. Kaufman, Ph.D.
President/CEO
The Laboratory Safety Institute (LSI)
A Nonprofit Educational Organization for
Safety in Science, Industry, and Education
192 Worcester Street, Natick, MA 01760-2252
508-647-1900 Fax: 508-647-0062
Cell: 508-574-6264 Res: 781-237-1335
Skype: labsafe; 508-319-1225
jim**At_Symbol_Here**labsafetyinstitute.org www.labsafetyinstitute.org
Chair, ICASE Committee on Safety in Science Education
International Council for Associations of Science Education
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From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Benjamin G Owens
Sent: Wednesday, March 30, 2016 2:31 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] OSHA LAB Standard applicability
I think it is true that the Lab Standard does not specifically cover physical chemical hazards such as flammability, reactivity, etc. If that’s the case then the flammability hazard associated with methane is not specifically covered by the Lab Standard, although its ability to act as a simple asphyxiant is included. I have never made that distinction as I consider all hazards regardless of any regulatory gaps. Anyway, that’s how I read things but please let me know if others have a different opinion.
Ben
--------------------------------
Ben Owens
Assistant Director, Laboratory Safety
Environmental Health and Safety Dept., MS 328
University of Nevada, Reno 89557
Office Phone: 775-327-5196
Cell Phone: 775-843-2113
Fax: 775-784-4553
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of ILPI Support
Sent: Wednesday, March 30, 2016 11:15 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] OSHA LAB Standard applicability
The most recent version of the Lab standard has this definition which explicitly includes asphyxiation, so that part of the interpretation would seem invalid.
Hazardous chemical means any chemical which is classified as health hazard or simple asphyxiant in accordance with the Hazard Communication Standard (=A71910.1200).
And the definition of Health Hazard in the latest version of the HCS is
Health hazard means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to =A71910.1200—Health Hazard Criteria.
See https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099 or for a much more readable version see http://www.ilpi.com/msds/osha/
Rob Toreki
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On Mar 30, 2016, at 1:52 PM, "Funck, Steven" <sfunck**At_Symbol_Here**MESSIAH.EDU> wrote:
Hello all: Our Compliance Coordinator and I were working on a question concerning proper compressed gas storage and ran across the following quote from an OSHA interpretation in 2008. While this pertains to a compressed gas question the comment implies that chemicals which are not listed as hazardous are not covered by the lab standard. How can that be? The implications of this is that all chemicals in a lab would have to be classified as either under the standard or not. Does anyone have thoughts on this.
“You stated in your letter that you are using these cylinders in a laboratory environment. OSHA's laboratory standard, =A71910.1450, Occupational exposure to hazardous chemicals in laboratories, defines "hazardous chemical" as one that has been established to produce acute or chronic health effects in exposed employees. While methane is an asphyxiant, it does not produce the acute or chronic health effects described in 1910.1200 Appendix A to which the lab standard refers. However, methane does present an explosion or flammability hazard. Therefore, OSHA'sHazard communication standard, =A71910.1200, would apply.”
Steven S. Funck, MS, CSMM
Natural Sciences Laboratory Program Manager
Messiah College
One College Ave.
Suite 3049
Mechanicsburg, PA 17055
Phone: (717) 796-1800 (ext. 2079)
Fax: (717) 691-6046
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