OSHA Lab Standard 26 CFR 1910.1450

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OSHA Lab Standard 26 CFR 1910.1450
The Purdue Chemical
Hygiene
Plan
L. SwihartREM, Purdue 9/17/2003
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Compare and Contrast?

• Since there are unavoidable similarities,
  important differences, and high potential for
  confusion
• the OSHA Lab Standard and its Chemical Hygiene
  Plan requirement are presented in terms of the
  differences from and similarities to the OSHA
  HazCom Standard and its Hazard Communication
  Program requirement.

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HazCom came first.
(when was that?)

• HazCom, as it applies to employers, excepts
  laboratories (without defining laboratory) from
  everything except

• Keep labels intact

• Train and Inform

• Keep incoming MSDSs
• Make outgoing MSDSs for chemicals leaving

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Lab Standard came after.Apparently because it
was agreed that holding chemical lab research to
HazCom rules would impede research.
Call it 1990.

• Applies to "employers engaged in the laboratory
  use" of hazardous chems.
• Lab use defined -- four-part definition
• 1. Laboratory scale
• 2. Multiple chemical procedures or chemicals
• 3. Not a production process or related
• 4. "Protective laboratory practices and
  equipment" available and in common use

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Both HazCom and Lab Standard mandate that the
employer make a "plan"

• 1910.1200 mandates a HCP
• (Hazard Communication Program)
• 1910.1450 mandates a CHP
• (Chemical Hygiene Plan)

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Which Program Where?

• Many employers/workplaces have to have both (a
  HCP and a CHP)
• Arguments still abound about exactly how to apply
  either/both when/where and to whom.
• Many employers implement strict rules covering
  both sets of bases.

..for example
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LBNL.org -- The Hazard Communication

• Standard was developed to inform employees who
  work with hazardous chemicals of the risks
  associated with those chemicals. A separate
  standard (the "Laboratory Standard") was
  specifically developed for laboratory operations
  because these environments often differ from
  industrial and office settings in the use and
  handling of hazardous chemicals.
• LBNL combined both of these requirements into
  this Chemical Hygiene and Safety Plan in order to
  establish a standardized framework for chemical
  hygiene practices, information dissemination, and
  training at LBNL regardless of the occupational
  setting.

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How is this relevant to you?

• What sort of jobs is your training and degree
  likely to get you?
• Where will you be in 5 years?
• Is your crystal ball working? Mines been out of
  order for a long time.

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Lab Standard

• Twelve sections (a) - (l).
• Its LESS strict than HazCom.
• But similar in parts.

!?
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(a) Scope and Application

• All employers engaged in the laboratory use
  ....
• Supersedes other subpart Z requirements except
• PEL limitations
• Skin and eye contact prohibition
• Monitoring/surveillance requirements

(what is Subpart Z again?)
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(b) Definition -- expanded
Laboratory use of hazardous chemicals

• Chemical manipulations are carried out on a
  "laboratory scale and
• Multiple chemical procedures or chemicals are
  used and
• The procedures involved are not part of a
  production process, nor in any way simulate a
  production process and
• "Protective laboratory practices and equipment"
  are available and in common use to minimize the
  potential for employee exposure to hazardous
  chemicals.

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(c) PELs, and(d) Exposure Determination

• Section (c) - Employer shall assure that PELs ARE
  NOT EXCEEDED.
• Section (d) Employer shall
• measure exposure if reason to believe action
  levels are routinely exceeded, written notice of
  results to employee within 15 working days.
• if monitoring is warranted, obey relevant
  standard for monitoring

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(e) Chemical Hygiene Plan

• The Lab Standard requires that the employer
  develop and carry out a written CHP which will
• protect employees from... chemicals,
• keep exposures below the PELs,
• be readily available to employees,
• include all of the following elements

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Required CHP elements

• List of operationsrequiring prior approval.
• Designation of Chem Hygiene Officer.
• Provisions for select carcinogens....
• Annual review of CHP effectiveness.

• SOPs.
• Control measure criteria.
• Safety equipmentmaint/testing.
• Provisions for INFORMATION TRAINING. ?

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(f) Specific elements of
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• Opportunity shall be provided under circumstances
  I, II, III

(g) Medical evaluation/ consultation

• Shall be followed by Dr.s written opinion

• Requires that Employer provide info to Dr.

• Shall be
• no cost
• licensed physician

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Hazard Identification (h)

• Labels remain intact.
• Keep the MSDSs you get.
• Determine hazards of homebrew chems
• ... or assume hazardous if not possible.
• Prepare MSDSs for chemicals traveling to another
  user outside the laboratory.

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The Rest

• (i) Respirator use
• (j) Recordkeeping
• (k) Effective date
• Jan 31, 1991 - CHP written and implemented
• (l) Appendices, non-mandatory

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Major differences

• MSDS requirement
• inventories
• the "supersede" business
• annual review
• medical evaluation
• Chemical Hygiene Officer
• monitoring required if

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Major similarities

• same definitions, largely.
• info/training requirements, mostly.
• the GOAL is the same.

(What was the goal again?)
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Thank you.