Exactly, Russ. The initial question was “PPE Sta ndard or Lab Standard?” to which the correct answer is, “Yes.” To extend the poin t further, all the General Industry Standards (29 CFR 1910) outside Subpart Z remain applicabl e to labs. So labs don’t get to blow past those pesky questions abou t electrical safety, powered industrial trucks, walking surfaces, fire extinguishers, emergency action plans, etc. just because they are labs under the lab stand ard.
Nicholas J. Tsiakals
Division of Research Safety
Chemical Safety Section
University of Illinois at Urbana-Champaign
(217) 244 - 0682
"If we don't train students in risk management and safe ty procedures, then we're not training them for employment in modern industry. If we want someone to turn up in a job and be productive, t hey can't do that if they're not safety aware." p>
-- Prof. Thomas Welton, Head, Department of Chemistry, Imperial College London --
From: DCHAS-L Discu
List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Russ Phifer
Sent: Thursday, April 29, 2010 6:02 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The PPE standards are not in Subpart Z, and are not superceded by the lab standard.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 i n addition to the PPE standards.
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From: DCHAS-L Discu
List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Michael Ochs
Sent: Thursday, April 29, 2010 5:29 PM
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 standa rds in 29 CFR 1910, subpart Z. Regarding PPE use in labs, do lab employee s need to comply with both the OSHA PPE Standard and OSHA Lab Standard or onl y the OSHA Lab Standard?
The OSHA Lab Standard states…
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 fo r laboratories, unless that particular standard states otherwise or unless th e conditions of paragraph (a)(2)(iii) of this section apply.
Prohibition of eye and skin contact where specified by any O SHA health standard shall be observed.
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