2. OSHA Laboratory Standard: the Bedrock for Middle School Science Safety

In this section

A. OSHA-related Laboratory Standards
B. Standard Interpretations
C. National Consensus

OSHA’s “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450) or “Laboratory Standard” took effect in 1990. The standard sets the requirements for an employer (Board of Education) to assess the hazards in laboratories and write a “chemical hygiene plan” tailored to meet their needs. Included in the Laboratory Standard is the requirement for an employer-appointed  chemical hygiene officer. The chemical hygiene officer is to provide technical support in developing and implementing the chemical hygiene plan. OSHA’s chemical hygiene plan is the foundation for laboratory safety in Connecticut middle and high schools. Public schools in Connecticut are under the jurisdiction of Connecticut state OSHA and private schools are under the jurisdiction of federal OSHA.

The basic elements of the Laboratory Standard are included in the following outline:

Elements of a laboratory safety plan

• Standard operating procedures.
• Working definitions in reference to the Laboratory Standard.
• Criteria to determine and implement control measures to reduce employee exposure including engineering controls use of personal protective equipment and hygiene practices.
• Requirement that fume hoods and other protective equipment are functioning properly and within specific measures.
• Provisions for employee information and training relative to the laboratory standard, employer’s chemical hygiene plan, chemical references and more.
• Circumstances where laboratory operation requires prior approval from the employer.
• Provisions for medical consultation and examinations.
• Hazard identification, including use of Safety Data Sheets (SDSs) and labeling systems.
• Use of respirators.
• Required record keeping — record of any measurements taken to monitor employee exposures and any medical consultation and examinations including tests or written opinions required by this standard.

(Appendixes)

• Designation of personnel responsible for implementation of chemical hygiene plan including chemical hygiene officer and if appropriate, chemical hygiene committee. The chemical hygiene officer is the employer-designated employee who is qualified by training or experience to provide technical guidance in the development and implementation of chemical hygiene plan. This person usually is a chemistry teacher, department head or laboratory technician.
• Provision for additional employee protection when working with particularly hazardous substances, for example, reproductive toxins, carcinogens. OSHA compliance officers initiate inspections by reviewing the employer’s plans. They then focus on plan implementation and policing.

A complete list of the Laboratory Standard can be found on OSHA’s Web site.

The bottom line for all public school districts and private schools in Connecticut relative to OSHA’s Laboratory Standard is science laboratories are required to have a chemical hygiene plan. The plan must address hazardous chemical use (purchase, inventorying, labeling/identification, use, storage and disposal) and provide training/ information for employees working in laboratories. This allows the employer to be in compliance with OSHA’s Hazard Communication Standard for laboratory science employees.

OSHA technically covers employees, not students in the laboratory. However, to maintain a safe working environment  for science teachers, all laboratory occupants, including students, must follow the chemical hygiene plan. Otherwise, the teacher, as an employee, could be put at risk.

Additional OSHA standards, interpretations of standards (official letters of interpretation by OSHA) and national consensus standards relative to laboratories may also apply to the middle school science laboratory. These include the following:

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A. OSHA-related Laboratory Standards:

1. Section 5.(a)(1)  of the OSH  Act, often referred to as the General Duty Clause, requires employers to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
2. Section 5.(a)(2) requires employers to “comply with occupational safety and health standards promulgated under this Act.”
3. Occupational Noise Exposure Standard (29 CFR 1910.95) deals with acceptable sound/noise levels in the workplace.
4. Personal Protective Equipment Standards (29 CFR 1910.132)  deals with body protective devices such as safety goggles/glasses, aprons, and gloves.
5. Respiratory Protection Standard (29 CFR 1910.134.)  deals with protective devices used to protect occupants from respiratory related exposures.
6. Lockout/Tagout Standard (29 CFR 1910.14.7 and 1910.333) deals with addressing control of dangerous and uncontrolled energy sources such as gas, water, electrical and mechanical devices.
7. Toxic and hazardous substances 29 CFR 1910 Subpart Z
   1. 1910.1000, Air contaminants
   2. Table Z-1, Limits for air contaminants
8. Hazard Communication Standard (29 CFR 1910.1200) deals with hazardous chemicals in the workplace.
9. Bloodborne Pathogen Standard (29 CFR 1910.1030) deals with blood related pathogens such as HIV and HbV.
10. Occupational exposure to hazardous chemicals in laboratories (29 CFR 1910.1450) deals with using chemicals safely in the laboratory.
    •  Appendix A, National research council recommendations concerning chemical hygiene in laboratories (Non-mandatory)
    •  Appendix B, References (Non-mandatory)

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B. Standard Interpretations

Standard interpretations are official responses to questions relative to OSHA safety standards. A growing number of these interpretations are relative to the laboratory standard and can be found on OSHA’s Web site.

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C. National Consensus

National consensuses are not OSHA regulations. They do represent professional/prudent practice and therefore provide guidance from the originating organizations. OSHA compliance officers often reference these practices relative to safety issues or concerns.

American National Standards Institute (ANSI)

• Z358.1. Contains provisions regarding the design, performance, installation, use and maintenance of various types of emergency equipment (showers, eyewashes, drench hoses, etc.). In addition to these provisions, some general considerations apply to all emergency equipment.

American National Standards Institute (ANSI)/ American Industrial Hygiene Association (AIHA)

• Z9.5-2003, Laboratory Ventilation. This authoritative publication is intended for use by employers, architects, occupational and environmental health and safety professionals, and others concerned with the control of exposure to airborne contaminants. The book includes new chapters on performance tests, air cleaning, preventative maintenance and work practices. It also highlights the standard’s requirements and offers good practices for laboratories to follow. The book also offers referenced standards and publications, guidance on selecting laboratory stack designs, an audit form for ANSI Z9.5, and a sample table of contents for a laboratory ventilation management plan.

American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE)

• 110-1995, Method of Testing the Performance  of Laboratory Hoods.  Specifies a quantitative test procedure for evaluation of a laboratory fume hood. A tracer gas is released at prescribed rates and positions in the hood and monitored in the breathing zone of a mannequin at the face of the hood. Based on the release rate of the tracer gas and average exposure to the mannequin, a performance rating is achieved.

National Fire Protection Association (NFPA)

• NFPA 45: Standard on Fire Protection for Laboratories Using Chemicals. Applies to laboratories in which hazardous chemicals are handled or stored.

International Code Council (ICC)

• 2003 International Codes. Links to several standards that are applicable to laboratories, particularly the International Fire Code. Topics addressed in  this code include fire department access, fire hydrants, automatic sprinkler systems, fire alarm systems, hazardous materials storage and use, and fire-safety requirements for new and existing buildings and premises.