II. OSHA LABORATORY SAFETY STANDARD

Also, a laboratory uses a variety of chemicals and procedures. The scale is such that standard

laboratory practices and equipment can be used to minimize the exposure to the chemical

hazards. The utilization of chemicals with similar hazardous properties in a nonlaboratory

environment falls under the OSHA hazard communication standard.

B. Chemical Hygiene Plan

A key component of the OSHA standard is the Chemical Hygiene Plan (CHP). This is an

explicit requirement for laboratory activities that conform to the definitions given in the

preceding section. The facility must develop and carry out a written CHP which satisfies

several criteria. The first three are generalizations but are nevertheless essential. It is not

required in these three sections to define how one is to accomplish them.

1. Capable of protecting employees from health hazards associated with hazardous

chemicals in the laboratory.

2. Capable of keeping exposure levels below the Permissible Exposure Levels (PELs) as

listed in the General Industry Standards, 29 CFR 1910, Subpart Z.

3. The CHP shall be readily available to employees, employee representatives, and on

request to OSHA.

The remaining elements of the plan are much more explicit in their requirements. The

standard states “The Chemical Hygiene Plan shall include each of the following elements and

shall indicate specific measures that the employer will take to ensure laboratory employee

protection.”

4. Standard operating procedures to be followed when working with hazardous

chemicals.

5. Criteria the employer will use to select and implement measures to reduce employee

exposures. This covers engineering controls, personal protective equipment, and hygiene practices. Control measures to reduce exposures to extremely hazardous

chemicals are considered especially important.

6. Fume hoods and other protective equipment must be functioning properly and a

program must exist to ensure that this is so.

7. Employee safety information and training must be provided.

8. Defining a program to determine the need for and procedures for a pre-initiation approval process for some operations.

9. Provisions for medical consultation and medical surveillance for employees when

conditions exist in which exposures in excess of the PELs or action levels may have

occurred or may routinely occur.

10. Designation of personnel responsible for implementation of the CHP, to include

designation of a chemical hygiene officer (CHO) and, if appropriate, a chemical hygiene

committee. Most organizations with a variety of laboratories would normally choose to

form such a committee.

11. Special provisions for additional protection for work with particularly hazardous materials such as carcinogens, reproductive toxins, and acutely toxic substances.

If the scientific worker, for whom this handbook is intended, follows the recommendations

in this handbook, the requirements to meet the desired outcome of the standard should be

met, but a written plan is required. The next section will define what must be covered by the

plan to meet the 11 requirements listed above. The topics will not be covered in the order in

the list.



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1. Goals

The introduction to the plan should succinctly state that the organization, for the specific

laboratory plan, is committed to providing a program that reduces exposure of employee to

hazardous chemicals to below acceptable limits by (1) providing them with adequate facilities

for their work; (2) provision of appropriate en203gineering controls or, if that is not feasible for

valid reasons, with personal protective equipment; (3) providing them, in a timely manner, with

appropriate training in procedures which they are to follow, access to information about the

chemicals with which they are working, the risks associated with the chemicals, how to recognize

hazards which may arise, and emergency responses; (4) providing medical consultation and

surveillance as needed; (5) providing ready access to the plan; and (6) monitoring the continuing

efficacy of the plan.

2. Organization

The organization responsible for implementation of the plan, including key individuals, by

title, should be identified, along with a brief description of the responsibility assigned to each.

An organizational chart should be provided with the following positions (or groups) identified:

A. The senior person in the organization who is charged with the overall responsibility for

safety and health programs in the organization. This position should be at a sufficiently

high level to ensure that the program receives adequate support.

B. The organization under the executive authority charged with actual implementation of the

plan. Normally this would consist of the Environmental Health and Safety Department

and the chemical hygiene committee.

C. The CHO for the organization. This person could be the head of the Health and Safety

department or the chairperson of the chemical hygiene committee. However, neither of

these persons would normally be able to devote full time to this work and it is a critical,

full-time position. The responsibility may be delegated to another person, most probably

in the health and safety organization. The chemical hygiene committee should function

to define policies and provide oversight of the program, while the health and safety staff

should provide the daily operational support. The duties of the CHO should include:

1. Assist the individual laboratory managers to develop their own chemical hygiene

programs. The CHO should not be, and indeed is not likely to be, sufficiently familiar

with the operations of individual laboratories to be expected to write the plans for

specific laboratories. They should provide a template or format for the persons

locally responsible for a specific facility.

2. They should develop a “train-the-trainer”program to assist the local managers in

providing the appropriate training for their personnel.

3. The CHO should develop a CHP covering the entire organization, containing basic

policies for chemical procurement, storage, handling, disposal, facility standards,

basic training, availability of Material Safety Data Sheets and other chemical

information, personal protective equipment guidelines, emergency planning for the

organization, and auditing and inspection protocols.

4. The CHO should conduct, or have done under their supervision, laboratory

inspections of equipment, specifically including fume hoods and other fixed safety

equipment, maintenance and housekeeping, chemical storage, and compliance with

the organization and laboratory-specific safety plans.

5. The CHO

should see that a medical consultation and surveillance program is

available to the employees in the event of overexposure conditions and conduct

environmental monitoring as required to support this program.

D. The local laboratory management line of authority. This could be one or more persons,



©2000 CRC Press LLC



dependent upon the size of the operation, with one individual designated as the senior

person to whom responsibility ultimately devolves. The latter individual is responsible

for seeing that the facility develop a CHP for that facility. A recommended approach

would be to make the laboratory plan a second part of a document of which the

organization's CHP would be the first. This would serve two purposes: every employee

would have access to the policies of the organization, and would eliminate repetitious

and possibly conflicting interpretations of these broad, basic policy areas. The

laboratory management might choose to designate a laboratory hygiene officer, if the

number of employees is large enough, to perform some of the following responsibilities

and to liaise with the organizational CHO. Regardless of how it is done, the local

laboratory management has the responsibility to:

1. See that the physical facilities are adequate and in good working order.

2. See that maintenance and housekeeping are satisfactory.

3. Develop and implement safe standard operating procedures for the activities

conducted within the facility. These should be written and maintained in a suitable

form to which the employees would have ready access.

4. Conduct training programs or see that training programs are provided to the employees to inform them of the contents and location of the CHP for the facility, the

location and means of accessing chemical information, such as Material Safety Data

Sheets, the standard operating procedures for the facility, the risks associated with

the chemicals in active use, warning characteristics of the chemicals in use, including

possible symptoms indicating over exposures or possible adverse reactions, emergency response or evacuation plans, and availability of the medical program.

5. Ensure that chemicals are stored, handled, and disposed of properly.

6. Conduct in-house inspections of the facility, conduct, or have conducted, inventories of the chemical holdings of the laboratory, and make sure that suitable personal

protective equipment is available and employed as needed.

E. As discussed in Chapter 1, the employee is the one ultimately responsible for complying

with safety policies, in this instance, as contained in the CHP and standard operating

procedures. They have the responsibility for developing good personal safety habits.

3. Training and Information Program

The CHP must contain a description of the organization's information and training program.

The training and educational programs are to be made available at the time of the employee's

initial assignment to potential exposure situations. Refresher training is to be provided at a

frequency determined by the employer. The information to be provided to the employees must

include:

1. The contents of the laboratory safety standard. Since the standard, including its

appendices, is quite short, this may be accomplished by including a copy as an appendix

to the CHP.

2. The location and availability of the organization's and laboratory's CHP. This is most

easily accomplished by maintaining a master copy of the basic CHP for the organization

at a central location, such as the Environmental Health and Safety department, with

copies of the laboratory CHP in the individual laboratories. However, the latter should

include the basic plan. Access to a computerized information system is becoming widely

available in many commercial laboratory organizations and larger academic institutions.

The basic unit can be part of this information system and be available to anyone with

access to the system at any time. A computer version has a distinct advantage in that it

can be updated at any time without distribution of many hard paper copies.

3. The OSHA PELs or action levels for the chemicals in use in the employee's work area.

The entire list of PELs can be made an appendix to the CHP to satisfy this requirement



©2000 CRC Press LLC



rather than having to modify this information whenever a new material is brought into the

facility. Not every chemical has an established PEL or action level, but the American

Conference of Governmental Industrial Hygienists (ACGIH) publishes a more

comprehensive list, updated annually, and the National Institutes of Occupational Safety

and Health (NIOSH) also publishes lists of recommended exposure limits, and these must

be made available in the absence of OSHA PELs. The three sets of levels do not always

agree. Where they differ, the OSHA PELs and action levels are the legally applicable

limits. Copies of the ACGIH and NIOSH limits are available as published documents and

can be provided as reference material, available in the workplace. A cautionary statement

should accompany the list of PELs or alternatives, stating that the limits are not absolute

in the sense that a fraction below them is safe while a fraction above is not. Exposure

limits should be kept well below the PELs. There are individuals with greater sensitivity

for whom the legal PEL would be excessive.

4. The location and availability of reference material on the hazards, safe handling, storage,

and disposal of the chemicals found in the laboratory. Note that OSHA uses the word

“found,” not the phrase “in use.” For laboratories that have accumulated a large

inventory of rarely used materials, this alone is an excellent reason to dispose of excess

and obsolete materials. The minimum means of complying with this requirement is to

maintain a file of the Material Safety Data Sheets (MSDSs) provided by the manufacturer

of the chemicals. The MSDSs will satisfy the previous requirement for PELs or other

recommended exposure levels since they include this information. As will be discussed

later, maintaining an up-to-date copy of MSDSs in every laboratory is very difficult, but

computer versions of these data are available which can serve as an alternative. MSDSs

should be supplemented by other compilations of data. One weakness in the MSDS

system is that in order to avoid liability due to recommending a less than necessary level

of care, many manufacturers have gone to the other extreme and recommend very

conservative measures. Manuals such as The Merck Manual and Properties of

Industrial Chemicals by Sax would be good supplements to the MSDS data. Chemical

vendors and distributors also usually maintain this information on their Internet pages.

Labels on commercial chemicals provide much information. The standard requires that

these labels not be defaced or removed. All of this material need not be in each

laboratory, but the employee must be told where it is and how to obtain access to it. This

access should be readily convenient.

5. Indicators and symptoms associated with exposure to chemicals used in the laboratory.

All of the above is basic information which can be provided as part of the basic plan for the

organization, if the employees know where the material is and have reasonable means to obtain

access to it. Some organizations accomplish this by computers, and as the use of computers

approaches universality, this is likely to become the favored approach.

The required training program must include the following elements:

1. The employees must be informed of the methods used to detect releases or the presence

of hazardous chemicals in the workplace. Some of these are available to the employee

directly, such as information concerning warning properties of the chemicals (odor,

visual indicators) or symptoms which might be experienced (irritation, nausea, or

dizziness). Other means of detecting materials which may be used would include fixed

alarms, such as gas monitors, or environmental monitoring by safety and health support

staff. Among equipment which might be available would be detector tubes, ambient gas

meters, passive dosimeters, and sophisticated devices such as portable infrared, atomic

absorption, or gas chromatograph instruments. Detection methods which are available

and might be employed should be listed in the CHP. Where access to these methods is



©2000 CRC Press LLC



through nonlaboratory personnel, the training should include how to obtain the required

aid and the telephone numbers of support personnel. Some of this material, such as the

environmental monitoring services, should be in the organization's basic plan, but the

indicators such as odor or the presence of local fixed gas monitors should be part of the

laboratory's own plan.

2. The chemical and physical hazards of the chemicals in the workplace. This is almost the

same as the basic information on PELs and MSDSs listed in the previous section. Those

requirements basically defined limits of exposure and the sources of data. This

requirement provides that the employees be given chemically specific hazard information

on the chemicals in their work area. It is most important that the chemicals in actual use

are the principal ones for which this information is provided. However, generic hazard

information by class for chemicals present but not in use should be provided as well.

There is always the potential for an accident involving chemicals not in current use. The

employees must be informed that they are not to deface or remove the labels on

commercial containers of chemicals, since they represent a primary source of

information. It is not required by the standard, but following the requirement from the

Hazard Communication Standard 29 CFR 1910.1200, that secondary containers intended

for use beyond a single work shift should be labeled, it is highly recommended that this

be required.

3. The employees must receive training on the measures they can take to protect themselves. The content of this training should be made part of the CHP for each individual

laboratory. Among these measures are:

a. Work practices specific to the laboratory. These include the standard operating and

administrative procedures developed so that the work can be carried out safely and

efficiently.

b. Emergency procedures . This can include a wide variety of measures, including how

to put out a small fire, how to evacuate an area (including identification of primary

and secondary escape routes), steps to take to bring a reaction under control if time

permits, how to relieve pressure on pressurized equipment, how to clean up minor

spills, how to report larger spills and secure help in responding to them, how to use

personal protective equipment available to them, first aid, and close-down

procedures in the event of a fume hood failure or failure of any other item of

protective equipment. Means of initiating a general evacuation from a facility, or the

building in which the laboratory facility is located must exist and should be identified

in this section.

4. The details of the CHP applicable to their area, including the basic organizational plan.

The items listed above are for normal laboratory work. If there are some operations which

require prior approval by a more senior individual or external group, then these must be included

in the training program as well. This need not be a special and possibly more hazardous

laboratory evolution, although that is the primary intent of this requirement, but it could

represent the purchase of selected items of equipment which must meet certain standards of

performance, such as refrigeration units, fume hoods, heating devices, storage cabinetry for

flammables, certain classes of chemicals such as carcinogens, etc.

Additional training is also needed for working with extremely hazardous materials. The

training must include:

1. Where the work must be done. An area must be designated. This can be an isolated suite

of laboratories with controlled access or an area as small as a fume hood, explicitly

defined as the area where the work is to be done.



©2000 CRC Press LLC



2. The use of special containment devices such as hoods or fully contained glove boxes.

3. Standard operating procedures for the work with the material, including use of appropriate personal protective equipment.

4. Means of safe removal and disposal of contaminated material.

5. Procedures to decontaminate the work area.

4. Medical Program

The CHP must define the means by which the facility will comply with the medical

requirements of the standard. In most cases, this procedure should be the same for all

laboratories within an organization, so the means should be spelled out in the basic plan. There

are four specific requirements:

1. Employees working with hazardous chemicals must be provided an opportunity to have

a medical examination, and follow-up examinations if necessary, under any of the

following circumstances:

a. The employee develops any signs or symptoms associated with the chemicals to

which they may have been exposed in the laboratory.

b. For specific substances regulated by OSHA, e.g., formaldehyde, for which exposure

monitoring and medical surveillance requirements exist in the standard for that

substance, the employee must be offered the prescribed medical surveillance program

if environmental monitoring shows a routine exposure level above the action level (or

PEL, if an action level is not specified).

c. An incident occurs such as a spill, leak, or explosion and there is a likelihood that the

employee might have received an exposure to a hazardous substance; the employee

must be offered an opportunity for a medical consultation. The consultation is for the

purpose of determining if a medical examination is needed.

2. “All medical examinations and consultations shall be performed by or under the direct

supervision of a licensed physician and shall be provided without cost to the employee,

without loss of pay, and at a reasonable time and place.”

3. The employer must provide the following information to the referral physician, if

available:

a. The identity of the hazardous chemical(s) to which the employee may have been

exposed.

b. A description of the conditions under which the exposure occurred, including

quantitative exposure data.

c. A description of the signs and symptoms of exposure the employee is experiencing,

if any.

4. The examining physician must provide a written opinion to the employer in a timely

manner which shall include or conform to the following requirements:

a. Any recommendation for further medical follow-up.

b. The results of the examination and any associated tests.

c. Any medical condition (not limited to the ones that may have resulted from the

exposure) revealed in the course of the examination which may place the employee

at increased risk as a result of exposure to a hazardous chemical found in the

workplace.

d. A statement that the employee has been informed of the results of the consultation

or medical examination and any medical condition that may require further



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examination or treatment by the physician.*

e. The written opinion shall not reveal to the employer specific findings or diagnoses

unrelated to occupational exposure. This obviously is to protect the employee's

privacy rights.

5. O SHA does not include the use of respirators under the medical program, but it is

closely related since under the General Industry Standard 29 CFR 1910.134 the ability to

use a resp irator depends upon the employee's health. A basic requirement is the ability

of the employee to pass a pulmonary function test, but the employee must not have any

other health problems which would preclude the use of respirators if they are needed or

required to protect the employee. A statement must be included in the CHP that the

organization has a respirator protection program which meets the requirements of the

general industry standards. This program should be a written one and included in the

employee's training.

5. Laboratory Produced Chemicals

A characteristic of many research laboratories is that chemicals may be produced or

synthesized in the course of the research. If the composition of the chemical is known and it is

a hazardous material, all of the training requirements and other provisions of the standard apply.

If the composition is not known, it shall be assumed to be hazardous and, with the exception of

the requirements for MSDSs and similar information sources, the provisions of the CHP apply.

If the chemical is produced for a user outside the laboratory, the provisions of the Hazard

Communication Standard (29 CFR 1910.1200) apply, including the requirement for providing an

MSDS and proper labeling of the material. Compliance with these requirements will be the

responsibility of the individual laboratory and a commitment to this compliance should be in the

laboratory CHP.

6. Record Keeping

The employer must commit to establishing and maintaining for each employee an accurate

record of any measurements taken to monitor employee exposure and any medical consultations

and examinations, including tests or written opinions required by the standard. Further, the

employer shall assure that such records will be kept, transferred, and made available in

accordance with 29 CFR 1910.20.

7. Summary

The sections immediately preceding this one detail the requirements of the OSHA Laboratory Standard and suggest general means by which an organization and/or laboratory can

comply with it. Appendix A of the standard provides many recommendations of how

compliance can be achieved. These recommendations are not mandatory and are in several

instances out of date. The standard is a performance standard which allows a great deal of

flexibility on the part of the employer and employee. As noted earlier, the bulk of this handbook

(with the exception of Chapter 5, which covers laboratories generally working with materials not

covered by the laboratory standard) is designed to provide specific information on how to

achieve the appropriate level of performance in all facets of laboratory safety, including

designing and equipping of facilities, covered primarily in Chapter 3, as well as operations. The

remainder of this chapter starts from the point of an assumption that an adequate facility is



*

At the author* s institution, when the medical surveillance program began several years ago, 22% of firsttime participants had significant untreated health problems of which, they stated, they were not aware. Very

few of these were related to occupational exposures, but some did require adjustments in their duties.



©2000 CRC Press LLC



available and proceeds from that point to the very beginning of planning a program to be done

in the facility.

III. OPERATIONAL PLANNING

A typical research proposal submitted to a funding source goes into great detail on the

significance of the proposed research, the approach to be taken, and the results sought.

Typically, the proposal always provides a thorough justification for the technical manpower and

equipment resources needed to carry out the planned program. The hazards which will be

encountered and the means by which they will be controlled are likely to receive much less

attention, and then only if these are sufficiently dangerous or unusual. Unless the research

involves very stringently regulated materials, the reviewer of the proposal often must take on

faith, if the question arises at all, that a basic infrastructure has been established to ensure that

the research can be carried out safely and in compliance with contemporary regulatory standards. This situation does show signs of changing in some areas, such as when human or

animal subjects are involved. The needed infrastructure does not just happen, it requires careful

planning. It is the intent of this chapter to provide essential information to guide planning for

safe operations in the laboratory.

The first order of priority, after authority to proceed on a specific program is obtained, is to

order all of the essential items of equipment which will be needed. Orders for major items of

equipment frequently take extended periods to be processed and delivered, 9 to 10 weeks being

as short an interval as might reasonably be expected, especially in a facility supported by public

funds, encumbered by an abundance of bureaucratic requirements. If installation is required,

such as when an additional hood is needed, this period could be extended for months since the

installation will have to be carefully planned to ensure, among other things, that the air handling

system has sufficient capacity and that fire code requirements can be met, especially if the duct

work must penetrate multiple floors. Scheduling and pricing of the actual work cannot be done

in such instances without working plans. This delay may be critical when the work is scheduled

to be completed within a fixed contract period with annual renewals depending upon progress,

as are many academic research contracts.

If new employees need to be hired, a number of factors must be considered in addition to

technical skills. As noted earlier, attitude is extremely important. A research laboratory is not the

place for a casual attitude toward safety. Skills and experience are, of course, important, but a

vital consideration should be a compatible personality. It is critical in any group effort for

personnel to be able to work together. It is not necessary to be “popular,” but it is important for

individuals to be receptive to the ideas of others and tolerant of differences in points of view.

A group of persons working under the stress of strained relationships is likely to be an

unproductive and unsafe group. Obviously, it is important that an individual to be hired is

safety conscious and willing to comply with the employer's safety policies. A principal

investigator needs to establish a clear line of authority for the laboratory personnel, both for

day to day operations and for emergencies. These may not be the same. The individual trained

to manage the scientific aspects of the research may not have as appropriate a background to

handle an emergency situation as would a senior technician who might have received special

training in safety areas, such as chemical spill control or emergency first aid. Where there is the

possibility of ambiguity, responsibility for various duties needs to be clearly assigned,

especially those duties associated with safety. It would be well, for example, to designate a

relatively senior person as the laboratory chemical hygiene officer (LCHO) and if necessary,

provide access to additional safety training to that individual. This individual could be

responsible, under the laboratory CHP, for such items as safety orientation of new employees

and safety training of all employees when new materials or procedures are incorporated into the

laboratory operations. They might be asked to perform or review a hazard analysis of any new

laboratory operations, and to secure any authorizations or clearances which might be needed.



©2000 CRC Press LLC



It could be this individual's duty to assign other persons the responsibility of being sure that

chemicals are shelved according to compatibility and to maintain safety items such as first aid

kit supplies, personal protective equipment, spill kit materials, Material Safety Data Sheets, or

maintenance of equipment in safe condition. The LCHO and/or the laboratory supervisor needs

to act as liaison with the safety department to provide access to any new information which

might affect the laboratory ' s operations. A knowledgeable employee, who could be the LCHO,

needs to be designated as the person responsible for ensuring the safe disposal of hazardous

materials. This individual needs to be responsible for seeing that all surplus and waste materials

are properly identified and segregated if waste materials are combined into common containers.

Individuals handling hazardous waste must receive training in the risks associated with that

operation.

The emergency planning required under the OSHA Laboratory Safety Standard requires an

effective emergency plan to be developed for each individual laboratory, which is consistent

with and integrated into the plan for the entire building and that of the corporation or

institution. It needs to take into account procedures for temporarily interrupting the research

operations or for automating uninterruptible operations if possible to allow employee evacuation during an emergency. An operation can and should be allowed to fail where necessary to

protect personnel from serious injury. This plan should be reviewed periodically to ensure that

it is still appropriate. As has been noted many times earlier in this handbook, research programs,

especially in academic institutions, change rapidly, not only in the materials in use and the

operations being conducted, but also in the participating personnel (due to student

involvement). Evacuation plans need to be tested periodically to ensure that they are effective.

It was remarked upon earlier that the transient nature of a building's population in the academic

environment creates difficulties in ensuring participation of all of the occupants. Drills held at

least once a year should include enough “permanent” occupants to help those who are less

familiar with the evacuation procedure.

Every aspect of the laboratory operations should be evaluated to see if it could be made

more efficient and safer. Purchasing of reagents, for example, should be reviewed to see how

much is actually needed on hand at a given time. If all chemicals are ordered early in the program

and the program needs shift, a substantial and wasted investment in surplus chemicals could

result. Today, where disposal of waste chemicals has become such a major legal issue, the cost

of disposing of surplus chemicals often exceeds the original costs . The quality of partial

containers of chemicals may have become dubious, and the initial investment in the excess will

represent a drain on the currently available funds. Anticipation of needs is critical, especially

where equipment is involved. As noted earlier, delivery of essential items of equipment may be

delayed for extended periods. The temptation is to “make-do” with equipment not specifically

designed to meet the actual needs, with serious safety implications being involved on occasion.

The regulations, and the information on which they are based, change sufficiently

frequently that it is unreasonable to expect every purchaser to be able to keep up with the

current regulations. Further, the entire body of relevant information regarding laboratory safety

has become so extensive and so complex that again it is unlikely that a single individual can be

sufficiently knowledgeable to adequately consider every factor. For example, the review of the

purchase of a fume hood is usually not based so much on the characteristics of the hood, but

on the installation. Has the location been reviewed for availability of sufficient make-up air? Has

the path of the exhaust duct been selected and has the exhaust blower been sized

appropriately? Will fire separations have to be penetrated? The flagging of the purchase order

so that the Purchasing Department will look for sign-offs to see that these questions have been

answered, and if they had not been considered, ensure that they are before the order is

processed. It is highly likely that the order will have to be modified if these factors have not

been addressed, and it is highly desirable that specifications be changed prior to ordering

unsuitable equipment.

An evaluation of the potential exposures of individuals to hazardous materials should be



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made as early as possible. It may be necessary to consider selectively placing individuals in

work assignments, although one has to be very careful in such cases to avoid triggering

charges of discrimination based on factors such as gender or disability. Still, if there are known

risks, for example, of teratogenic effects from a chemical, it would certainly be surprising if an

expectant mother did not have some concerns about working in an area where it was in use,

even if the levels were well below the acceptable OSHA limits for the average worker. Any work

regimen would need to be fully discussed between the individual and the supervisor in such a

case and be based on knowledge, not speculation. Often, once the exposure potential or lack of

one is clearly understood, concerns may disappear. Failure to consider the employee's rights

to a working environment free of recognized hazards could lead to a complaint to OSHA or

another regulatory agency which could, in extreme cases, cause the program to be interrupted

pending resolution of the safety issues.

Prior planning is needed, especially in facilities in which students are expected to be

working. Legal safety standards usually have been designed for permanent employees, and

although many graduate students and students on work-study programs receive stipends for

their efforts, they may not be considered or treated as “real” employees by others in the work

area. They typically have less experience and a different purpose in being in the laboratory than

do permanent personnel. The pressures associated with completing the various hurdles of a

degree program, especially those accompanying completing a research program for a thesis or

dissertation within a tight schedule, often lead to students working long hours, going without

enough sleep, and eating odd diets. The result may be working without adequate supervision

and being affected by factors that could cause impaired judgment. The laboratory safety

program should take these factors into account and make a special effort to see that these

younger persons understand the goals of the safety program, as it bears upon the operations

of the laboratory and the need to comply with the safety polices of the organization and the

laboratory.

A. Quantities

The recommendation that volumes of reagents kept on hand be kept to the minimum needed

for a reasonably short working period is found in virtually every laboratory safety manual.

However, a visit to almost any laboratory will reveal many bottles and other types of containers

accumulating substantial layers of dust. Many of the more recently acquired reagents very

likely will be duplicates of these older materials. There must be good reasons for this apparently

needless duplication.

It would appear to make a great deal of sense to order what you need and replace it when it

appears that more will be needed. There are at least three reasons why this common sense

approach is so rarely followed, two of which are attributable to factors in the purchasing

process:

1. It takes time to process an order. Unless a central stores facility maintains a stock of

chemicals at the research facility, the processing of a requisition, receipt of an order by

the vendor, and delivery are unlikely to take less than 1 month, unless an alterna-tive

buying process has been established, such as a blanket order system or previously

cleared requisitions for low-value purchases. Under these circumstances, a purchaser

tends to buy more than is currently needed in order to avoid having to order frequently

and to avoid delays in receipt of the needed material.

Container Size

One liter, each



1.000



6 x 1 liter, case



0.558



4 liter, each



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Cost/Liter



0.526



4 x 4 liter, case



0.359



10 liter



0.303



20 liter



0.225



2. Unit chemical costs decrease rapidly with the increasing size of the container. For

example, for one grade of sulfuric acid, the following pricing schedule has been

established by one major vendor (note that these have been normalized to set the price

per liter of the smallest size to equal 1). Obviously, if the volume of usage justifies the

purchase, the largest size is the most economical to buy. However, there are several

reasons why such a purchase is probably unwise for more reasonable levels of usage.

It increases the potential risk, as in this example, to have more material than is actually

needed, and storage space will have to be found for the excess material. If it is not used

relatively quickly, the quality may become suspect, and users will be reluctant to use it

in their research programs. The cost of disposal of any eventual surplus material is likely

to eliminate any initial economic gain from buying in volume, unless the surplus can be

used by someone with less critical applications.

3. In addition to the two reasons given above, sometimes a researcher wants to be sure of

the consistency of the reagent, so he buys enough for his needs from one lot. However,

some chemical firms will, upon request, set aside an amount of a given lot and maintain

it at their regional warehouse to accommodate a larger user.

An examination of the purchases of the various kinds of research reagents by most

university or corporate research facilities will probably reveal that a relatively small proportion

of them are bought in substantial quantities. At the author's institution, fewer than 75 of the

more than 1200 different chemicals purchased during a typical year exceeded an amount of 50

kg. Where this is true, it would appear feasible to set up a central stores for at least a limited list

of chemicals. Stocking of these stores areas should probably emphasize the middle ranges of

sizes. If, in the example given above, multiple-case lots of 4-liter containers were the primary

sizes purchased from the vendor for stocking, most of the cost savings of volume purchases

could be passed on to the local purchaser. Smaller sizes would have the advantage of being

likely to be completely emptied, thus eliminating the cost of waste disposal completely for these

containers, but forcing the users to buy small sizes could lead to buyer resistance because of

a perceived inconvenience. It might be desirable to restrict the purchases of larger sizes to those

who can establish a need or for those items for which it is feasible, disburse chemicals from

drums into smaller containers by stores workers.

Except for the high-volume materials, most remaining chemicals are bought in relatively small

quantities to meet specific needs of individual programs. Some chemicals pose unusual hazards,

such as ethers that degrade over a short period of time. It is desirable to keep track of which

group is ordering them and where they are to be found. A central stores area would make a

convenient distribution center for these special materials and would facilitate maintenance of

records of their use.

Bar code technology has now made it possible to conveniently mark every container

received and distributed from a stores area with a unique identification code which includes the

name of the chemical, the date received, the quantity, and the recipient. The last of these can be

tied to a specific facility, and a specific laboratory within the facility. The availability of powerful

desktop computers now makes it possible, with appropriate software that is commercially

available, to establish a tracking program for every container from the point of purchase to its



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