Re: Certification of Hazards Analyses Used to Select PPE

Larry -

The way I understand the Lab Standard, it does not expressly replace any of
the general OSHA requirements (only parts of Subpart Z).  A laboratory
facility must comply with 1910.132 in the same manner as other industries.
While the Chemical Hygiene Plan may indeed incorporate the certification
requirement for PPE / hazards assessment, I don't see where labs have any
particular latitude compared to other facilities.  It would be prudent to
include a statement in the front of the CHP certifying the completion of PPE
/ hazards assessment.

As to the length of time such records should be maintained, I believe the
PPE / hazards assessment should be an ongoing function - as hazards change,
PPE should be re-evaluated accordingly.  I don't see the need to maintain
records for term of employment + 30 years except for employee medical
records.  1910.132 is not employee specific.  That said, an electronic
hazardous & control summary is a great idea, particularly if it is
maintained on a regular, ongoing basis.

Russ Phifer

WC Environmental, LLC
PO Box 1718, 1085C Andrew Drive
West Chester, PA  19380
610-696-9220/610-344-7519 fax
rphifer**At_Symbol_Here**glasmesh.com

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]On Behalf Of
Larry D. McLouth
Sent: Wednesday, September 01, 2004 1:03 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: Certification of Hazards Analyses Used to Select PPE

The enclosed OSHA interpretation raises questions about the direct
applicability of  29 CFR 1910.132 (d)(2) to lab environments....What's
your opinion?

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATION
S&p_id=21681
<http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21681>

It sounds like OSHA is allowing some latitude for labs.

Regardless, LBNL is working on an electronic system that links chemical,
physical and biological hazards (as well as their corresponding
controls) to specific work areas (bldg/room).  We have other
requirements that are driving this.  All of our data - chem inventory,
training, HR, are in Oracle databases so they can be integrated and
accessed with a web front end.  The plan is to have an electronic
hazards/control summary report.  Space owners/PIs/responsible persons
must review summary report and acknowledge that controls (including PPE)
are in place.  This acknowledgment constitutes a record that is
retained.  As I said this is under development...but we have some funding.

Does anyone have an opinion on how long such records should be
maintained?  Do they fall under 1910.1020 Exposure and Medical Records?
If so, then it would be the length of employment plus 30 years.

Larry

Gordon Miller wrote:

> How do you meet the requirement of 29 CFR 1910.132 (d)(2), "The
> employer shall verify that the required workplace hazard assessment
> (that guides the use and selection of PPE) has been performed through
> a written certification that identifies the workplace evaluated; the
> person certifying that the evaluation has been performed; the date(s)
> of the hazard assessment; and, which identifies the document as a
> certification of hazard assessment." (or its equivalent under state
> OSHA regs)?

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