I agree that the Lab Standard includes both health and chemical hazards with regard to topics that must be included in training, which is stated in the reference that you highlighted.
My point was that the scope of the Lab Standard states that it applies to “the laboratory use of hazardous chemicals” and that a hazardous chemical is defined as “any chemical which is classified as health hazard or simple asphyxiant.” Based on that it seems to me that the scope of the Lab Standard doesn’t specifically include physical chemical hazards. As has been stated, however, regardless of how the Lab Standard may be interpreted I think that most of us consider all chemical hazards, and other laboratory hazards, within our laboratory safety programs.
Thanks for the discussion.
I believe that the lab standard absolutely applies to the physical hazards of chemicals. … Jim
Employee training shall include:
Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
The physical and health hazards of chemicals in the work area; and
The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
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I think it is true that the Lab Standard does not specifically cover physical chemical hazards such as flammability, reactivity, etc. If that’s the case then the flammability hazard associated with methane is not specifically covered by the Lab Standard, although its ability to act as a simple asphyxiant is included. I have never made that distinction as I consider all hazards regardless of any regulatory gaps. Anyway, that’s how I read things but please let me know if others have a different opinion.
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The most recent version of the Lab standard has this definition which explicitly includes asphyxiation, so that part of the interpretation would seem invalid.
Hazardous chemical means any chemical which is classified as health hazard or simple asphyxiant in accordance with the Hazard Communication Standard (=A71910.1200).
And the definition of Health Hazard in the latest version of the HCS is
Health hazard means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to =A71910.1200—Health Hazard Criteria.
See https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099 or for a much more readable version see http://www.ilpi.com/msds/osha/
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On Mar 30, 2016, at 1:52 PM, "Funck, Steven" <sfunck**At_Symbol_Here**MESSIAH.EDU> wrote:
Hello all: Our Compliance Coordinator and I were working on a question concerning proper compressed gas storage and ran across the following quote from an OSHA interpretation in 2008. While this pertains to a compressed gas question the comment implies that chemicals which are not listed as hazardous are not covered by the lab standard. How can that be? The implications of this is that all chemicals in a lab would have to be classified as either under the standard or not. Does anyone have thoughts on this.
“You stated in your letter that you are using these cylinders in a laboratory environment. OSHA's laboratory standard, =A71910.1450, Occupational exposure to hazardous chemicals in laboratories, defines "hazardous chemical" as one that has been established to produce acute or chronic health effects in exposed employees. While methane is an asphyxiant, it does not produce the acute or chronic health effects described in 1910.1200 Appendix A to which the lab standard refers. However, methane does present an explosion or flammability hazard. Therefore, OSHA'sHazard communication standard, =A71910.1200, would apply.”
Steven S. Funck, MS, CSMM
Natural Sciences Laboratory Program Manager
One College Ave.
Mechanicsburg, PA 17055
Phone: (717) 796-1800 (ext. 2079)
Fax: (717) 691-6046
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