CHEMICAL LABORATORY SAFETY

CHEMICAL SAFETY and ENVIRONMENTAL REGULATIONS

Objectives

Government regulations control many aspects of your work in a chemistry laboratory. They may often be hard to understand but they do have real meaning. This section focuses on selected regulations that are most likely to directly affect you.

OCCUPATIONAL SAFETY and HEALTH ADMINISTRATION

In 1970, Congress passed the Williams-Steiger Occupational Safety and Health Act to be administered by the Occupational Safety and Health Administration (OSHA) under the Department of Labour.   OSHA was created to enact and enforce regulations.

With the same act, the National Institute for Occupational Safety and Health (NIOSH) was created within the Department of Health Education and Welfare (currently Health and Human Resources).   NIOSH is an independent research organization created to recommend regulations.

 The act states that "Each employer -

TOXIC AND HAZARDOUS SUBSTANCES

Toxic and Hazardous Substances contains the regulations that affect laboratory workers the most. It includes:

THE AIR CONTAMINATION STANDARD

The Air Contaminant Standard (29 CFR 1910.1000) applies to all laboratories. It sets permissible exposure limits (PEL).

The PEL is the only way OSHA regulates your exposure. OSHA does not specify how these limits are to be maintained. Your employer must determine compliance by objective means. Industrial hygienists must perform a study and make a determination.

Usually an industrial hygienist collects representative measurements of air concentrations during typical operations with typical control measures in place.

SUBSTANCE - SPECIFIC STANDARDS

The Toxic and Hazardous Substance section covers detailed regulations for each of 25 specific substances or classes of substances. 

asbestos 4 - nitrobiphenyl
a - naphthyamine b - naphthyamine
b - propiolactone coal tar
methyl chloroethyl ether lead
3,3 - dichlorobenzidine N - nitrosodimethyllamine
bis(chloromethyl) ether benzidine
ethyleneimine 2 - acetylaminofluorene
vinyl chloride 4 - methylaminoazobenzene
benzene 1,2 - dibromo - 3 chloropropane
formaldehyde coke oven emissions
acrylonitrile cotton dust
ethylene oxide  

Since the addition of the Lab Standard,  the only parts of the substance - specific standards that apply to most laboratories are the PELs  -  not the provisions on monitoring, medical surveillance, or other aspects of the use of these substances (except in routine exposure).

THE HAZARD COMMUNICATION STANDARD

The Hazard Communication Standard requires companies to let their workers know all about chemical hazards they might face in their job:

  • either during their work or
  • from an accident

The standard specifies three ways to get this information to the employees: 

  • Proper labeling of each container.
  • Access on the job to MSDS and training on how to interpret them.
  • Training on how to tell when a hazardous substance has been released in the workplace and how to protect themselves.

Employers are required to have a written hazard communication program.  Workers must be told about the program and the Hazard Communication Standard itself.

Employees should be aware of the requirement to completely label "secondary" containers. If the container is not used completely by the same person on the same shift, the new container must include all the hazard information from the original label.

The standards described earlier apply to workers in most industries, including those working in chemistry laboratories related to production, such as quality-control labs.

LABORATORY STANDARD

In a research lab or teaching lab, conditions are different, and a particular individual might be exposed to small amounts off many different chemicals in a week.   The Lab Standard (29 CFR 1910.1450), was created to protect workers in these laboratories.   It retains several key provisions of other Toxic and Hazardous Materials standards.

The Lab Standard provides 4 criteria to define laboratories falling under its jurisdiction:

  • Chemicals are worked with in containers that can be safely handled by one person.
  • Multiple chemicals and procedures are used.
  • Protective laboratory practices and equipment are commonly used.
  • Procedures used are not part of a production process for making commercial quantities of chemicals, and they do not simulate a production process.

For most laboratories, the Lab Standard supersedes most of the other standards.  A few provisions of the other standards, however, have been retained:

  • Laboratories still have to adhere to the PELs from the Air Contaminant Standard, so the limits on exposure to hazardous chemicals are the same for lab workers as for general industry workers.
  • The Lab Standard also contains certain provisions of the Hazard Communication Standard. Laboratories must label containers properly, provide MSDSs, and train employees.   The training must include recognition of hazardous chemical releases, health hazards from chemicals used in the laboratory, physical hazards in the lab, and protective measures.

Basically, the Laboratory Standard is designed to give laboratory workers the same protection provided to other workers in the substance-specific standards and Hazard Communication Standard.  It just does it in a different way, primarily through a document called a Chemical Hygiene Plan that laboratories must develop.

The lab Standard is called a "performance-based" standard because, rather than specifying exactly what procedures must be used, it simply requires that the controls and work practices spelled out in the Chemical Hygiene Plan must perform well enough to keep exposures to hazardous chemicals below the PELs or other exposure limits.

A Chemical Hygiene Plan must be easily accessible to all employees. It should be reviewed at least once a year and updated if necessary, and should contain the following information:

  • Names of those responsible for implementing the plan, including a Chemical Hygiene Officer to take charge of implementation.
  • Standard operating procedures workers should follow for all laboratory activities.
  • Conditions under which workers must first get approval before carrying out a laboratory operation.
  • Criteria for the control measures used to reduce exposure to hazardous chemicals -  for example, requiring use of a fume hood when a chemical's PEL is less than 50 ppm.
  • Methods used to make sure fume hoods and other protective equipment are functioning properly.
  • Provisions for training employees in both chemical and physical hazards and giving them safety information.
  • Free medical attention for employees who have been exposed to hazardous chemicals, including those who only exhibit exposure symptoms.

Besides physical symptoms, evidence of exposure could be a spill, leak, or explosion - or it could simply be measured air concentrations routinely exceeding what are called action levels.

Action levels are found in some of the substance-specific standards, and are usually half the PEL.  When an action level is exceeded routinely, OSHA requires laboratories to monitor exposures.   If no action level is specified in a substance-specific standard, the exposure concentration that triggers monitoring is the PEL itself.   Monitoring procedures are outlined in each substance-specific standard.

Special protective measures needed to protect people working with what OSHA calls "particularly hazardous" chemicals, including:

  • Reproductive toxins, such as lead compounds and organomercurials, which can damage chromosomes or developing fetuses.
  • Highly toxic substances, such as cyanide compounds.
  • Certain cancer-causing chemicals called "select carcinogens" such as benzene and vinyl chloride.

The Lab Standard requires employers to consider whether these particularly hazardous chemicals should be worked with only in a "designated area".

The Lab Standard also requires employers to consider whether any additional measures are needed to protect those working with particularly hazardous chemicals.   The measures could include face shields, fume hoods or other containment devices, and waste removal procedures.

To make sure the Lab Standard is followed, OSHA inspectors visit laboratories to scrutinize their operations.  Inspectors review the employer's Chemical Hygiene Plan and training programs.   They also check records, especially exposure-monitoring data and medical records, and observe how employees use equipment in the lab.

Flammable and combustible liquids are covered by OSHA in 29 CFR 1910.106 Subpart H.

This is the same as NFPA's 30 standard.  NFPA now has a new standard covering laboratories, 45 standard.

The OSHA regulation limits the container size for certain materials of construction.   It also limits the amount of flammable and combustible liquids allowed in a single laboratory or fire area.

Respirator protection and use is covered by OSHA regulation 29 CFR 1920.124.

If you think you need a respirator, consult with your supervisor, an industrial hygienist, or a safety officer.

OSHA required employers to have a written program addressing the following issues:

  • selection and use
  • training in use and limitations
  • regular cleaning and disinfection
  • storage in a convenient and clean location
  • inspection and maintenance
  • work surveillance to make sure environmental conditions do not exceed capabilities of the device
  • medical approval for use

OSHA also has regulations concerning many other hazards, for example:

  • ionizing radiation
  • lasers
  • explosives
  • noise

Your employer will have rules designed to meet these regulations, local codes, and insurance company rules.

Each of the regulations has its own record keeping requirements.

Each employer must maintain an injury and incident log.

Report injuries and accidents as required by your company's procedures.

ENVIRONMENTAL PROTECTION AGENCY

The EPA was created in 1970 and regulates many areas, such as

Several laws passed by Congress and placed under the care of the EPA may affect the way that you work in the lab.

Resource Conservation and Recovery Act

The EPA regulations with the biggest effect on chemistry laboratories are probably those from the Resource Conservation and Recovery Act (RCRA) of 1976. 

RCRA deals with the management of waste material that may be hazardous.

The main intent of RCRA regulations is to protect the public and the environment by instituting a "cradle-to-grave" monitoring system.

This closely tracks and regulates the handling of hazardous waste from the time the waste was first generated to the time it is eventually disposed of.

The most important regulations are Parts 261 and 262.

Part 261: Identification and Listing of Hazardous Waste

Explains how to determine if the waste is hazardous and how to categorize it.

Part 262: Standards Applicable to Generators of Hazardous Waste

Describes the responsibilities waste generators have before turning hazardous waste over to a transporter.  It includes:

Hazardous Wastes

In the laboratory, a chemical product is not a waste until you intend to discard it.

A waste is hazardous if it is specifically listed or if it has certain specific characteristics.

Once a waste has been classified as hazardous, it must be handled, stored and disposed of according to RCRA regulations.

There are four lists of specific hazardous wastes.

K - specific industrial process wastes
F - wastes that occur across a number of industries (solvents)
P - dangerous commercial chemical products (acutely hazardous) for example: cyanide salts, nickle carbonyl
U - commercial reagent chemicals

There are four categories of characteristic wastes:

ignitability - burn easily under specific conditions or readily cause combustion
corrosivity - concentrated acids and bases, highly corrosive liquids
reactivity - chemically unstable
toxicity - wastes that would release toxic materials into the groundwater if buried in a landfill not designed to isolate them from the environment.

Hazardous waste must be stored properly until it is picked up by an approved transporter.

A manifest, having multiple copies, is a record of everyone who handles the waste until its ultimate disposal.

Hazardous wastes that cannot be treated or that is still hazardous after treatment must be placed in an approved landfill.

The landfill typically has a liner made of strong, dense polyethylene that does not absorb chemicals.  Liquid flows down the liner and is collected and pumped out of the landfill.

Underneath the plastic liner is a clay liner to slow the release of liquid from any tear or leak.

Waste Minimization

To reduce disposal costs, it is important to minimize the amount of waste generated.

Steps to Minimization

It is generally best to design a chemical process so that hazardous byproducts are detoxified or treated as part of the process - not accumulated as waste for later treatment. 

Non-hazardous Disposal

Most non-hazardous wastes can be discarded with ordinary trash.

Local laws and regulations determine which chemical wastes can be put in the trash.

Pouring non-hazardous wastes down the drain is also legal in most areas, depending on restrictions by the local sewage treatment plant.

Waste should be diluted and flushed down with plenty of water before and after.

All chemicals poured down the drain must be compatible with the drain and sewage pipes.

Hazardous Waste Disposal

NEVER dispose of hazardous waste in the trash or down the drain!

Wastes are inventoried as it is packed and a copy is attached to the drum.

Recordkeeping

The responsibility for the hazardous waste remains the responsibility of the generator (laboratory) !!

All records must be carefully maintained at least three years. Most laboratories hold them indefinitely.

There is NO statute of limitations on hazardous waste !!!! 

TOXIC SUBSTANCE CONTROL ACT

The Toxic Substances Control Act (TSCA) states that every new chemical or new use of an old chemical must be proven to be safe. (Premanufacture Notification, PMN)

Chemicals that will be used purely for research and not included in a product are exempt from this process.  They must be labeled "for research purposes only."

TSCA contains recordkeeping and notification requirements.

If employees feel they have been adversely affected by a chemical exposure in a way not previously known for that chemical, the employer must record the allegation, whether or not the employer believes it is true.

Any new information on substantial risk of injury to health or the environment by a chemical must be reported to the EPA.

COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION and LIABILITY ACT

The Superfund is legally known as the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

CERCLA forces hazardous waste generators to pay for past mistakes by collecting money from them to clean up landfills.

CERCLA was later reauthorized by Congress  with additional known as the Superfund Amendments Reauthorization Act (SARA).   The best known amendment is the Community-Right-To-Know-Act.

The Right to Know Act ensure that communities have access to information on hazardous chemicals used in their neighborhoods. 

Small laboratories may not have much to report unless they use some extremely toxic materials.

SARA also requires reporting of routine emissions, both planned (stack emissions) and unplanned (fugitive emissions). 

Fugitive emissions are those for which the employer cannot account after performing a mass-balance calculation. 

CLEAN AIR ACT

The Clean Air Act (CAA) regulates emissions to the air.

The CAA is frequently administered by state environmental agencies.  In Texas, this is the Texas National Resource Conservation Commission (TNRCC).

Research emissions are generally exempted, except for specifically listed carcinogens or other chemicals that may harm the local environment.

CLEAN WATER ACT

The Clean Water Act (CWA) is also called Federal Water Pollution Control Act.

The Clean Water Act has the same function as the Clean Air Act, except it is for water.

State environmental agencies administer a permitting system and quantitative limits are set depending on local conditions. 

Laboratory waste that is poured down the drain goes to the local municipal sewage treatment facility, which must comply with the terms of the permit.

Sewage facility operators determine what can be put into the sewer.  In most places there are a few chemical wastes that can be discarded down the drain.

DEPARTMENT OF TRANSPORTATION

The transportation of chemicals is regulated under the Hazardous Material Transportation Act (HMTA). Hazardous chemicals must be categorized, properly packaged, labeled and recorded on a shipping manifest.

Aircraft transport of hazardous materials is strictly regulated.

Careful observation of these Department of Transportation (DOT) rules for transporting chemicals is absolutely essential.