Date: Fri, 20 Feb 2004 14:50:14 -0500
Reply-To: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Organization: ASU Safety & WC Office
Subject: Re: FW: Request 1910.1450
Comments: To: "Peart, Charlyn M"
In-Reply-To: <006C2D20440A1141A4CCD4B2FEA4C7CF04623853**At_Symbol_Here**>
If I have documentation that the hood is working properly (e.g. annual or
semi-annual containment verification), and the person(s) using the hood have
been trained on how to properly use the hood, then I would not normally
conduct exposure monitoring.

However, I would conduct testing if I do NOT have documentation of the hood,
OR if any of the following is true:
- There have been any complaints, no matter how minor, of smells, exposure
symptoms, etc that could even remotely be attributed to the chemical.
- There is any reason to believe that improper use of the hood, horseplay,
etc is going on.
- The chemicals have the ability to cause immediate impairment (physical or
cognitive), especially if the chemical's olefactory detection limit isn't
well above the Action Level.
- Your workplace is a litigious environment and you are using known or
strongly suspected carcinogens.

Not to be construed as legal advice, my opinion only, yada yada.

"Remember that free advice is priceless and worthless at the same time"
Appalachian State University
Industrial Hygiene Office

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Peart, Charlyn M
Sent: Thursday, February 19, 2004 5:07 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] FW: Request 1910.1450

> My question for the group is related to the Lab Standard OSHA
> 1910.1450 and the relationship with Subpart Z.  I am looking for air
> monitoring practices for laboratory employees regarding work in the
> fume hood and small quantity bench top work for OSHA regulated
> chemicals.  In addition to the monitoring practices the rationale for
> that approach would be helpful.
I included the following references....

> 1910.1450(d)(1) ---employer shall measure the employee's exposure to
> any substance regulated by a standard which requires monitoring if
> there is reason to believe that exposure levels for the substance
> routinely exceed the AL.
> 1910.1450 (C) --for lab use of OSHA regulated substances, the employer
> shall assure that the lab employees' exposure to such substances do
> not exceed the PEL.
> Using methylene chloride as an example, 1910.1052 (d)(1) states--where
> MC is present in the workplace, the employer shall determine each
> employee's exposure by taking a personal breathing zone sample or
> taking representative sample.
> Based on this information (and other information in the standard) do
> you conduct air monitoring for employees working in a fumehood?  If
> not, is this because you do not anticipate levels which exceed the
> action level per 1910.1450(d)(1) above?  How do you document this
> rationale / assessment?
> Thank you for your assistance.
>  Charlyn M. Peart
> Charlyn M. Peart, CIH
> Safety & Industrial Hygiene
> (215) 652-5565
> WP20-111

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