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Developing a laboratory chemical hygiene plan.

Developing a laboratory chemical hygiene plan

In January of this year, the Occupational Safety and Health Administration published the final standard for "Occupational Exposures to Hazardous Chemicals in Laboratories." [1] This standard applies to all employers engaged in the laboratory use of hazardous chemicals. By Jan. 31, 1991, all labs must have a written chemical hygiene plan (CHP) in place. Ew ef sy laboratory manager or supervisor, you may have been less than delighted to find that you had another program to write and another regulation to comply with. Fortunately, the task is not a daunting one; I wrote mine in a few hours.

Managers of small hospital laboratories or physicians' office labs can accomplish the task quickly. Managers of referral labs and of midsize to large hospital laboratories will need more time to write and implement their programs. Most larger labs will select a committee to set up the program, have drafts read and edited by staff members, and approval endorsed by upper administration. Whatever the effort needed, it must be made; OSHA inspectors will expect to see the written program at any time after the effective date.

My own work history includes labs of all sizes. I am currently the manager of a full-service laboratory with three medical technologists and an assistant. For 17 years, until 1988, I worked at the lab of a hospital with more than 500 beds, and have remained in close contact with the staff there. Previously I was employed at a hospital with 100 beds. My perspective on the needs of labs in general is based largely on these experiences.

* Who is involved. A laboratory is defined for OSHA's purpose as a facility in which relatively small quantities of hazardous chemicals are used but not produced. (Workers in places that manufacture such chemicals are protected under the Hazard Communication Standard.) With rare exceptions, all clinical laboratories will fall under the requirements of this standard.

Laboratory use of hazardous chemicals is defined as the handling of chemicals in which all four of the following conditions are met:

1. Chemical analyses are carried out on what is called a "laboratory scale"--that is, in relatively small amounts;

2. Many kinds of chemicals are used;

3. The procedures involve using chemicals, not manufacturing them; and

4. Safety equipment and written laboratory procedures and practices are available to protect employees.

A chemical hygiene plan is a program developed and implemented by the employer. In it are set forth procedures, such as those involving personal protective equipment; work practices; and training, all of which are designed to protect employees from hazardous chemicals. Where the CHP applies, it supersedes, for laboratories, requirements for all OSHA health standards, with a few exceptions that are too detailed to discuss here. The CHP requires continued compliance with other applicable general industry standards such as personal protective equipment and eyewash fountains. The CHP is to be made readily available to all laboratory employees. You don't necessarily have to write volumes; if a sentence or paragraph will cover a required section, that's all you have to prepare.

* Mandatory requirements. The CHP must include the following eight elements (summarized in Figure I):

1. Standard operating procedures, relevant to safety and health considerations, that are to be followed when chemicals are used. This section, which builds on the foundation of safety requirements already in place in labs, is relatively easy to write. In my own plan, I included many of the safety instructions that I had established before. For example, mouth pipetting is forbidden; flammable chemicals must be stored in their designated cabinet or room; and water is never to be poured directly into an acid.

2. Criteria used by the employer to determine and implement control measures for reducing employee exposure to hazardous chemicals. Are your employees using aprons, lab coats, latex gloves? Must they wash their hands before leaving the lab? Write these criteria into your plan.

3. Procedures to insure the proper functioning of protective equipment and fume hoods; specific criteria for internal inspections of this equipment. The larger the laboratory, the more detailed this section will be. Not all small labs use fume hoods, for example.

4. Provisions for employee information and training on the hazards of chemicals they use. This information must be provided both at the time of an employee's initial assignment to a work area in which hazardous chemicals are used and before the individual begins any assignment that requires the handling of other such chemicals. As many labs will find, some of this material is already available. I found much of it in a safety manual I wrote several years ago, whose first sentence read: "Employees are instructed in the use of the fire extinguisher, eyewash equipment, and emergency shower, all located by the main sink in the lab."

Employee training includes the methods and observations that may be used to detect the presence of a hazardous chemical, the physical and health hazards of chemicals used in the workplace, and the methods with which employees can protect themselves from these hazards. Employees must be trained on the applicable details of the CHP used in their laboratory.

Managers must establish the frequency of refresher information and training. My own manual stipulates that reorientation is to take place at least once a year.

5. The circumstances under which a potentially dangerous laboratory operation or procedure requires prior approval from the employer (lab manager). I have never seen this requirement in action; it is rare in a clinical setting for procedures to require prior approval. Nevertheless, you may wish to include new procedures in this section, which may be as brief as a few sentences long.

6. Provisions for medical consultation and examinations. In a POL or clinic, a physician is usually only a few feet away at any given time. A hospital lab would probably name the emergency room or the employee health department. Medical consultations and examinations are given to employees when they develop symptoms associated with a chemical to which they have been exposed, where exposure monitoring reveals an exposure level routinely above the action level or, if no action level exists, above the permissible exposure limit.

7. Design of the person or persons responsible for implementation of the CHP, including the designation of a chemical hygiene officer and, if desired, a chemical hygiene committee. This section in my manual consists of one sentence: "The responsible person, also refferred to as the chemical hygiene officer, is the laboratory supervisor, working under the direction of the laboratory director." If a committee will be appointed, you may want to explain who will be on the committee, how members will be selected, and what their reponsibilities will be in relation to the chemical hygiene officer.

8. Provisions for additional employee protection for work with particularly hazardous substances. Designated areas are to be established for the use of any such substances. Other provisions to be considered are the use of containment devices such as fume hoods or glove boxes, procedures for safe removal of contaminated waste, waste, and decontamination procedures. The larger the lab, the more detailed this section will be.

* Information staff. Employees are to be given five important points of information:

1. The contents of the standard.

2. the location of the chemical hygiene plan.

3. Permissible exposure limits (PELs) for OSHA-regulated subtances or recommended PELs for other chemicals used in your lab.

PELs can be obtained from the closest Federal OSHA regional or area office, or if your state has its own OSHA program, from the state or its regional offices. Other helpful sources are the Material Safety Data Sheets (MSDSes)--forms filled out by manufacturers, as required by OSHA--which are full of information and easy to use. Be sure all employees know where they are kept.

The section on PELs took me the longest to write. The average laboratory worker knows nothing about them. What are we to do with this information once we obtain it? Who will monitor such levels in the lab? Industrial hygienists have the necessary equipment, but hardly anyone else does. Attempting to clarify PELs represents a typical example of the difficulty one may have in interpreting the standard.

Appendix A to the Federal Register listing of the standard, intended for use as a resource in preparing the CHP, seems to admit that requiring such testing may be overdoing restrictions: "Regular instrumental monitoring of airborne concentrations is not usually justified or practical in laboratories but may be appropriate when testing or redesigning hoods or other ventilation devices or when a highly toxic substance is stored or used regularly (e.g., 3 times/week)."

4. Signs and symptoms associated with exposures to hazardous chemicals used in your laboratory. (Check your MSDSes for information.)

5. The location of reference material on the hazards, safe handling, storage, and disposal of hazardous chemicals found in your laboratory. These references should include, but not be limited to, the information in the Material Safety Data Sheets, American National Standard Institute (ANSI) standards, National Fire Protection Association (NFPA) guidelines, and toxicology texts.

Whenever a leak or spill may lead to overexposure, a consultation must be provided to determine whether a medical examination is necessary. All medical examinations and consultations resulting from spills or other occurrences are provided without cost to the employee and without loss of pay. If a chemical odor persists after a leak, spill, or container breakage, for example, a private or state industrial hygiene consultant should be contacted to monitor the area. Larger facilities may have their own industrial hygiene or safety personnel to monitor the area until the odor level subsides.

It is essential that laboratory managers establish a record of any measurements taken of each employee to monitor exposures and any medical consultation and examinations performed. Again, we are all so record-conscious these days that most laboratory managers and supervisors are already making an effort to do this.

Labels on containers of hazardous chemicals must not be removed. MSDSes are to be maintained and readily accessible to employees and to any OSHA inspector who ask to see them.

* No exceptions. Read the standard thoroughly. Even if your lab has a hazard communication program in place, a detailed safety manual and procedures, extensive employee records, and more, you will still have to develop a CHIP. Most of the records and information you'll need probably reside in your other records and files. By using this information, you will be able to write and implement a CHP with relative ease. Take the opportunity to revise the update information in your safety manual. Appendix A to the standard provides a suggested format for your table of contents (Figure II).

If you get stuck, call your local OSHA representative. Depending on the state in which you work, you'LL speak with either a Federal or a state agent. Ask for assistance. That's what they are there for. The agent will not, however, develop your CHP for you.

I don't deny that being married to a state OSHA consultation supervisor made the procedure easier for me. Nevertheless, my husband wishes more laboratorians would ask for help when needed. You will not be reported to a government agency for any violation simply because of the phone call.

If you haven't written your CHP yet, you still have more than a month to prepare. Once you have pulled existing information together and indentified the rest, you'll be well on your way to developing a chemical hygiene plan that will meet OSHA requirements and take your laboratory one step closer to total safety.

(1) "Occupational Exposures to Hazardous Chemicals in Laboratories." Federal Register, Rules and Regulations, 29 CFR 1910. 1450, Vol. 55, No. 21, Jan. 31, 1990.

Shirley A. Ramaley is laboratory manager at Hematology Associates, Phoenix. She wishes to thank Thomas R. Ramaley, M.P.H. C.I.H., supervisor of consultation, education, and training for the Arizona Division of Occupational Safety and Health for his contributions to this article.
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Author:Ramaley, Shirley A.
Publication:Medical Laboratory Observer
Date:Dec 1, 1990
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