For the sake of continuing this discussion, I’m leaning on Harry’s side of the fence (see, we c an agree on some things, Harry).
As noted, prescriptive-based standards are what resulted in OSHA getting slammed in its early days- guard rails at specific heights, toilet seats’ dimensions not to exceed…. etc, etc (My wife worked for OSHA in ’76- she quickly went over to the industrial sector)
I am, however, open to incorporation o f Behavior-based compliance language into the standard; Chemical Hygien e Committees may meet the requirements of the standard, but, as with many/ mo st committees, what gets said around a conference table doesn’t always g et mandated in the laboratory. A safety program in an individual laborat ory is only as good as the occupants want it t o be. Changing behavior is not easy, and, some will say, near impossible. S o, how does a university offer incentive to not only develop but sustain safe laboratory practices? Administrative example- if the Department Head is not on board, why should the PI’s comply? If ther e are no regularly-scheduled departmental meetings in which safety is on the agenda EVERY time, then there is no sustainability. If there are no regularly scheduled meetings led by the PI, in which safety procedures are discussed for the SPECIFIC experiments being conducted, then everyone assum es everyone knows safe procedures for working with reactives. It 8217;s all about communication, and that can be a sensitive topic. (We had a fire here due to a researcher’s error in mistaking sodium hydride f or sodium hydroxide). A new graduate student does not want to appear to be uninformed on a laboratory technique- this is where senior researchers need to s tep up- there’s nothing like shared experience as a training tool. That line goes far beyond the realms of laboratories. (Reading a manual on how to replace pads on disc brakes and having someone show you how is a perfect example.)
As a performance-based standard, Harry is right that the CHP is direct & straightforward. What it canno t do is change behavior- unfortunately that sometimes only happens as a result of fire, explosion, or death.
-Stefan Wawzyniecki, CIH, CHMM< /font>
University of Connecticut
Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On
Behalf Of Harry Elston
Sent: Tuesday, August 04, 20 09 7:46 AM
Subject: Re: [DCHAS-L] Artic le from Chemical and Engineering - very complete information about UCLA fatali ty
Neal et al.: span>
I'm going to f all on the other side of the fence on this one - I don't want to see the lab stand ard 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 i t'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 laborat ory. 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 ti ttle of the standard has been met.
Peter font> 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 th at UCLA is a good example of the standards weaknesses.
Any yes, it wou ld 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 Y OU suggest (1) improving the lab standard and (2) getting OSHA to do it?
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Kudos to C&E News for this excell ent review and analysis.
I continue to be surprised that there is so little mention of OSHA’s lab standard or Chemical Hygiene Plans, a nd 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 laborator y Chemical Hygiene Plans.
Peter A. Reinhardt
Director, Office of Environmental Health & Safety
Yale< span style='font-size:10.0pt;font-family:Tahoma;color:blue'> University
135 College St., Suite 100
New Haven, CT 06510-2411
Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On
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Sent: Monday, August 03, 200 9 1:38 PM
Subject: [DCHAS-L] Article f rom Chemical and Engineering - very complete information about UCLA fatality
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