Neal et al.:
I'm going to fall on the other side of the fence on this one - I don't want to see the lab standard any stronger than what it is.
Personally, I think that Cal-OSHA missed the boat on this one and the lab standard is fine as it's written. There is far enough teeth in the statement regarding CHPs "...capable of protecting employees from the health hazards associated with hazardous chemicals in that laboratory..." (1450(e)(1)(i))
Making the Lab Standard prescriptive would be counter-productive for safety in the laboratory. Keeping the standard performance based places the burden of safety squarely where it should be: Front-line management, or in this case, the PI. A prescriptive plan places the safety burden on "The Safety Guy/Gal" who has to go around and look to insure that every jot and tittle of the standard has been met.
Peter and others –
Unfortunately, UCLA and the lab had a CHP which satisfied Cal-OSHA. The reason that there is little mention in the UCLA discussion of the Lab Standard and related is that UCLA is a good example of the standards weaknesses.
Any yes, it would be great to strengthen 1910.1450 and there are discussions along those lines, but that takes changing an existing OSHA standard. Not easy.
There are many ideas being discussed and this list is a good forum for the discussion.
So, how would YOU suggest (1) improving the lab standard and (2) getting OSHA to do it?
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Kudos to C&E News for this excellent review and analysis.
I continue to be surprised that there is so little mention of OSHA’s lab standard or Chemical Hygiene Plans, and no mention in this article. UCLA is required by California law to have a Chemical Hygiene Plan, and their internal report (and CalOSHA citation) mentions it. Experts in the article discuss the need for lab-specific risks assessment, policies, procedures and training. The Chemical Hygiene Plan is the tool for all these things. In response to this tragedy I think it would be good if ACS DivCHAS worked to strengthen the use and implementation of laboratory Chemical Hygiene Plans.
P eter A. Reinhardt
D irector, Office of Environmental Health & Safety
Y ale University
1 35 College St., Suite 100
N ew Haven, CT 06510-2411
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List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Debbie M.
Sent: Monday, August 03, 2009 1:38 PM
Subject: [DCHAS-L] Article from Chemical and Engineering - very complete information about UCLA fatality
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