Date: Wed, 1 Sep 2004 11:03:13 -0700
Reply-To: "Larry D. McLouth" <LDMcLouth**At_Symbol_Here**LBL.GOV>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Larry D. McLouth" <LDMcLouth**At_Symbol_Here**LBL.GOV>
Organization: Lawrence Berkeley National Laboratory
Subject: Re: Certification of Hazards Analyses Used to Select PPE
Comments: To: Gordon Miller
In-Reply-To: <p0601020dbd5aa54f9ad4**At_Symbol_Here**[]>

The enclosed OSHA interpretation raises questions about the direct
applicability of  29 CFR 1910.132 (d)(2) to lab environments....What's
your opinion?

It sounds like OSHA is allowing some latitude for labs.

Regardless, LBNL is working on an electronic system that links chemical,
physical and biological hazards (as well as their corresponding
controls) to specific work areas (bldg/room).  We have other
requirements that are driving this.  All of our data - chem inventory,
training, HR, are in Oracle databases so they can be integrated and
accessed with a web front end.  The plan is to have an electronic
hazards/control summary report.  Space owners/PIs/responsible persons
must review summary report and acknowledge that controls (including PPE)
are in place.  This acknowledgment constitutes a record that is
retained.  As I said this is under development...but we have some funding.

Does anyone have an opinion on how long such records should be
maintained?  Do they fall under 1910.1020 Exposure and Medical Records?
If so, then it would be the length of employment plus 30 years.


Gordon Miller wrote:

> How do you meet the requirement of 29 CFR 1910.132 (d)(2), "The
> employer shall verify that the required workplace hazard assessment
> (that guides the use and selection of PPE) has been performed through
> a written certification that identifies the workplace evaluated; the
> person certifying that the evaluation has been performed; the date(s)
> of the hazard assessment; and, which identifies the document as a
> certification of hazard assessment." (or its equivalent under state
> OSHA regs)?

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