A Chemical Conundrum

In 1983, OSHA established its first version of the Hazard Communication standard. These regulations were made law in response to a lack of hazard information given to over 30 million United States employees working with chemicals. OSHA estimates that 650,000 chemicals are used in over three million work places across the country. Recognizing that the work performed in laboratories is unique—relatively small quantities of hazardous chemicals are used on a non-production basis—OSHA promulgated the Chemical Hygiene standard (more simply known as the Laboratory standard) in 1990.

The Chemical Hygiene standard regulations supersede HazCom standard regulations in the laboratory setting. However, there are still several HazCom rules that affect labs such as those involving hazard determination, chemical labeling, and Safety Data Sheets. The Chemical Hygiene standard brings another layer of exposure protection to the lab employee through the required establishment of a series of chemical safe work practices. Understanding how both sets of laboratory regulations work together is important in creating an overall lab chemical management program.

The regulations for creating a chemical inventory are expressed in the HazCom standard. OSHA requires a list of hazardous chemicals in every work place where they are manufactured, stored, or used. This inventory can be a useful tool for many reasons. Use the list to document the required chemical risk analysis. Review the chemicals in the lab for their hazards, and indicate on the inventory list any applicable hazard warnings such as the signal word and pictograms. CAP requires that you determine which chemicals in the lab are carcinogenic or reproductively and acutely toxic. Once that analysis is complete, it can also be documented on the inventory list. Record average volumes of the chemicals stored in the lab as well. This information may be helpful in a fire situation so that the fire department or other rescue workers will be aware of what they may encounter.

Laboratories must designate a Chemical Hygiene Officer, a point person who is qualified and responsible for providing technical guidance for the implementation and operation of the entire lab chemical management program. The Lab Standard even mentions the establishment of a Chemical Hygiene Committee if the lab or chemical program is larger. Details of this lab chemical safety structure should be spelled out in the lab’s required Chemical Hygiene Plan.

If you read the actual Chemical Hygiene Standard on OSHA’s web site, you can see it is not very long (unlike the HazCom standard or others). Because of the volume of chemicals used in labs, the standard’s main focus is protecting employees from those chemicals via written procedures, physical barriers (such as PPE and engineering controls), and health monitoring. A model Chemical Hygiene Plan must include exposure control methods, a chemical fume hood maintenance process, a detailed training program, and medical consultation and follow-up when chemical exposure limits are exceeded. Appendix A of the standard (called National Research Council Recommendations Concerning Chemical Hygiene in Laboratories) was created to assist laboratories with the development of a complete and compliant Chemical Hygiene Plan.

A third set of OSHA regulations that affects labs and chemical safety is the Formaldehyde standard. The exposure monitoring section gives instructions on how to perform vapor monitoring for this carcinogenic chemical. The laboratory has an option to monitor each employee individually, or it may set up a representative sampling strategy and measure exposures within each job classification and for each work shift. The purpose of this strategy is to properly characterize the exposure of every employee without having to monitor each one. Simply stated, that means if Jane and John perform the same duties and are equally exposed to formaldehyde in their work day or for a specific task, you may monitor only Jane’s exposure and share the results with both employees. That said, the CAP standard on the Anatomic Pathology inspection checklist states that each new employee should have formaldehyde vapor monitors performed. While it references the OSHA formaldehyde regulations, the standard fails to include OSHA’s wording about representative monitoring. That can be an issue if a CAP inspector follows strict adherence to those standards and does not subscribe to OSHA’s intent. Clearly representative vapor monitors make sense and are safe, but you may have to challenge the case with certain inspectors.

Chemical management in the laboratory can certainly seem daunting, and there are many regulations (federal and otherwise) that affect how the lab program may be run. The basic safety strategies exist for the purposes of protecting the employee from chemical exposure, but so many details are involved with the process. Proper storage of flammables and corrosives, labeling, and waste handling are just some of the topics not even touched upon in this article, but they also must be considered for safety purposes. If operating the chemical management program is your duty, be sure to understand the regulations, and build a team of staff who will work together to ensure safe chemical processes in the laboratory.


Scungio 1

Dan Scungio, MT(ASCP), SLS, CQA (ASQ) has over 25 years experience as a certified medical technologist. Today he is the Laboratory Safety Officer for Sentara Healthcare, a system of seven hospitals and over 20 laboratories and draw sites in the Tidewater area of Virginia. He is also known as Dan the Lab Safety Man, a lab safety consultant, educator, and trainer.

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