Date: Thu, 29 Apr 2010 21:47:53 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Mark Grossman <qed**At_Symbol_Here**WESTNET.COM>
Subject: Re: OSHA PPE standard vs. Lab standard
Comments: To: rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM

I may have missed part of the discussion, so my apologies if I am repeating anything than someone else has already said.
I remember taking an OSHA course a while back - not specifically tailored to laboratories - and the one thing that stands out in my mind is the statement that except for the General Duty clause, the OSHA PPE standard is about as broad as you can get, and gives plenty of leeway for OSHA to issue violations.
It states that the employer has to do determine the hazards of the job through a hazard evaluation, provide the appropriate PPE, and someone has to sign off on the evaluations (I'm quoting from memory here).
It's interesting to take a quick look at the general requirements of the standard to see just how all encompassing it is.
Mark Grossman, CIH, CSP
QED Associates LLC
Briarcliff Manor, NY 
----- Original Message -----
From: Russ Phifer
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Sent: Thursday, April 29, 2010 7:01 PM
Subject: Re: [DCHAS-L] OSHA PPE standard vs. Lab standard

The PPE standards are not in Subpart Z, and are not superceded by the lab standard.  You must comply with all the requirements in 29CFR 1910.132-138.  Subpart Z covers 1910.1000+, and is primarily concerned with air exposures.  Lab employees must comply with the lab standard in addition to the PPE standards.


Russ Phifer

WC Environmental, LLC

1085C Andrew Drive

West Chester, PA  19380

610-696-9220x12/ fax 610-344-7519


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From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Michael Ochs
Sent: Thursday, April 29, 2010 5:29 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] OSHA PPE standard vs. Lab standard

I am curious to receive your interpretation on the topic of personal protective equipment (PPE) requirements regarding laboratory work environment since the OSHA lab standard supersedes other OSHA health standards in 29 CFR 1910, subpart Z.  Regarding PPE use in labs, do lab employees need to comply with both the OSHA PPE Standard and OSHA Lab Standard or only the OSHA Lab Standard?



The OSHA Lab Standard states=85

Where this section applies, it shall supersede, for laboratories, the requirements of all other OSHA health standards in 29 CFR part 1910, subpart Z, except as follows:


For any OSHA health standard, only the requirement to limit employee exposure to the specific permissible exposure limit shall apply for laboratories, unless that particular standard states otherwise or unless the conditions of paragraph (a)(2)(iii) of this section apply.


Prohibition of eye and skin contact where specified by any OSHA health standard shall be observed.

1910.1450 ocument?p_table=STANDARDS&p_id=10106

1910.132 cument?p_table=STANDARDS&p_id=9777

Michael Ochs, CIH
Manager, ASU Environmental Health & Safety
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