The Laboratory Standard, 29 CFR 1910.1450 mandates a Chemical Hygiene Plan (CHP), and your CHP, while locally produced, is required under OSHA regs. And your Chemical Hygiene Officer (CHO), is *required* by the Lab Standard to provide the technical guidance to implement that plan, which they are refusing to do. And since you’ve tried nicely, now it’s time to play hardball.
Send these morons an email and cc everyone up your org chart to the presidents’s office, but *especially* the legal/risk management department, and use the exact words “appears to be a willful violation of OSHA regulation 29 CFR 1910.1450” (as well as University policy) and that you recommend all laboratory operations in the space be barred until the situation is rectified. Sometimes you have to be the Safety Nazi, so be it. The words “willful violation” should strike fear into the legal team as they open up the institution to triple penalties when cited, and it also puts in (discoverable) writing a potential liability that, if not acted upon, could be damning.
If you like overkill, get the local fire marshal involved. Invite them to come do an inspection and then poke them to think about the potential fire hazard of a highly flammable substance with a foam rubber backing (which produces thick toxic smoke when burned) covering the floor where a flammable material fire is already a significant hazard and risk.
Best wishes,
Rob Toreki
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On Jun 25, 2024, at 7:24 PM, Alex Hagen <fischera**At_Symbol_Here**UW.EDU> wrote:
We have a lab in our radiology department that stores and uses chemicals in space with carpeting. They have also conducted lead soldering in that space in the past. We state in our laboratory safety manual that carpet is not allowed in labs and we have noted this issue on all of their inspection reports, but they have said that they will not prioritize this unless there is a state or federal regulation that we can point to. We have explained that the manual is an institutional policy document, but that doesn’t seem to mean much to them. Does anyone here know of a regulation that specifically addresses this issue?
ALEX HAGEN
