Prudent Practices in the Laboratory Handling and Management of Chemical Hazards, Updated Version (2011) / Chapter Skim
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11 Safety Laws and Standards Pertinent to Laboratories
11 Safety Laws and Standards Pertinent to Laboratories
Pages 265-282
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From page 265... ...
11 Safety Laws and Standards Pertinent to Laboratories 11.A INTRODUCTION 267 11.A.1 Making Safety Laws and Their Rationale 267 11.A.2 OSHA and Laboratories 268 11.A.2.1 OSHA Enforcement and State OSHA Laws 268 11.A.2.2 The General Duty Clause and "Nonlaboratory" OSHA Standards 268 11.A.2.3 Laboratory Standard Versus Hazard Communication Standard 268 11.A.2.4 PELs, TLVs, and RELs 269 11.A.3 Understanding Other Laboratory Safety Requirements 269 11.B REGULATION OF LABORATORY DESIGN AND CONSTRUCTION 272 11.C REGULATION OF CHEMICALS USED IN LABORATORIES 273 11.C.1 OSHA Standards for Specific Chemicals 273 11.C.2 The OSHA Laboratory Standard 273 11.C.2.1 The Chemical Hygiene Plan 274 11.C.2.2 Particularly Hazardous Substances 274 11.C.3 Chemical Facility Anti-Terrorism Standards 275 11.C.4 Regulations Covering Polychlorinated Biphenyls (PCBs) 275 11.D REGULATION OF BIOHAZARDS AND RADIOACTIVE MATERIALS USED IN LABORATORIES 276 11.E ENVIRONMENTAL REGULATIONS PERTAINING TO LABORATORIES 276 11.E.1 Management of Chemical Hazardous Waste 276 11.E.1.1 Definitions and Types of Hazardous Waste Generators 276 11.E.1.2 Implications of EPA's Definition of On-Site 276 11.E.1.3 Minimum Requirements for Generators 277 11.E.1.4 RCRA Waste Minimization Requirements 277 11.E.1.5 Transportation of Chemicals and Hazardous Waste 277 11.E.2 Management of Radioactive and Biohazardous Waste 278 11.E.3 Discharges to the Sewer 278 11.E.4 Air Emissions from Laboratories 278 11.F SHIPPING, EXPORT, AND IMPORT OF LABORATORY MATERIALS 278 11.F.1 General Shipping Regulations 278 11.F.2 EPA Requirements for Chemical Export and Import 279 11.F.2.1 TSCA Research and Development Exemption 279 11.F.2.2 TSCA Record-Keeping Requirements for R&D Laboratories 279 11.F.2.3 Chemical Exports from R&D Laboratories 279 265
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From page 266... ...
266 PRUDENT PRACTICES IN THE LABORATORY 11.F.2.4 TSCA Requirements for Other Chemical Shipments 280 11.F.2.5 Chemical Imports from R&D Laboratories 280 11.F.2.6 Nanomaterials Under TSCA 280 11.F.3 Requirements for Biological Export and Import 280 11.F.4 Other Export Regulations 281 11.G LABORATORY ACCIDENTS, SPILLS, RELEASES, AND INCIDENTS 281 11.G.1 Laboratory Injuries and Illnesses 281 11.G.2 Planning for Chemical Emergencies 281 11.G.3 Notification Requirements for Spills, Releases, and Other Emergencies 281 11.G.4 Emergency Training and Response 281
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From page 267... ...
federal agency activities. Typically, a public comment period and perhaps public hearings are specified, dur 11.A.1 Making Safety Laws and Their ing which all affected parties have an opportunity to Rationale present their support for or concerns with the regula tions as proposed.
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From page 268... ...
is the primary regulation, but laboratory personnel and EHS staff should understand its relationship to the hazard communi- 11.A.2.3 Laboratory Standard Versus Hazard cation standard. In addition, the general duty clause Communication Standard is often invoked, and OSHA standards not written As noted above, the Laboratory Standard is inspecifically for laboratories may also apply.
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From page 269... ...
that, if exceeded, requires certain Many organizations, faced with the difficulty of de- additional protective measures to be implemented, signing EHS programs that meet both the requirements such as additional confirmatory exposure monitoring, of the Laboratory Standard and the requirements of training, or medical surveillance. Although personal the Hazard Communication Standard, have opted to exposures in research laboratory environments are follow the requirements of the Hazard Communication generally controlled well below all of these limits by Standard for all workplaces, laboratory and nonlabora- the use of local exhaust devices and room air change tory, while additionally adopting and implementing rates, laboratories working with any of the chemicals the Chemical Hygiene Plan requirements of the Labo- covered by an OSHA substance-specific standard must ratory Standard as they apply to laboratories.
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From page 270... ...
recognized hazards that are causing or likely in absence of a specific standard to cause serious physical harm Occupational Exposure to 29 CFR § 1910.1450 Laboratory worker protection from exposure Requires a chemical hygiene plan. Hazardous Chemicals in to hazardous chemicals Title 29 rules are written and Laboratories (Laboratory enforced by OSHA Standard)
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From page 271... ...
quality Criteria and standards for the 40 CFR Part 125 Control of discharge to public waters National Pollutant Discharge Elimination System (NPDES) General pretreatment 40 CFR Part 403 Control of discharge of pollutants to public Implemented by local sewer regulations for existing and new treatment works authorities sources of pollution Shipping, Export, and Import of Laboratory Materials Hazardous Materials 48 USC § 1801 et Control of movement of hazardous materials Transportation Act seq.
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Two laws that have perhaps the most impact on laboratories are the Occupational Safety and Health 11.B REGULATION OF LABORATORY Administration's Occupational Exposure to Hazardous DESIGN AND CONSTRUCTION Chemicals in Laboratories (the OSHA Laboratory Standard) and RCRA, under which EPA regulates chemical Laboratory design, construction, and renovation hazardous waste.
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From page 273... ...
1In 2003, the Building Officials and Code Administrators Interna 11.C.2 The OSHA Laboratory Standard tional, Inc., the International Conference of Building Officials, and the Southern Building Code Congress International, Inc. formed the In 1990, OSHA promulgated its Laboratory Standard International Code Council.
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From page 274... ...
elements: 4. Train and inform new laboratory personnel of • the OSHA Laboratory Standard, • employee information and training about the haz • the Chemical Hygiene Plan and its details, ards of chemicals in the work area, including how • OSHA's PELs, to detect their presence or release, work practices • the signs and symptoms of exposure to haz- and how to use protective equipment, and emer ardous chemicals, gency response procedures; • MSDSs, • circumstances under which a particular labora • Prudent Practices in the Laboratory, tory operation requires prior approval from the • methods to detect the presence of hazardous employer; chemicals, • standard operating procedures for work with • the physical and health hazards of the chemi- hazardous chemicals; cals, and • c riteria for use of control measures, such as • m easures to protect laboratory personnel e ngineering controls or personal protection from chemical hazards.
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From page 275... ...
Chapter 10, sections 10.F and 10.E.4.2. The OSHA-mandated special provisions for work with carcinogens, reproductive toxins, and substances 11.C.4 Regulations Covering that have a high degree of acute toxicity include con Polychlorinated Biphenyls (PCBs)
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From page 276... ...
RCRA and EPA regulations apply to laboratories that use chemicals. 11.D REGULATION OF BIOHAZARDS AND RADIOACTIVE MATERIALS 11.E.1.1 Definitions and Types of Hazardous USED IN LABORATORIES Waste Generators As explained in Chapter 4, sections 4.H, and Chap- A generator is any firm or institution whose proter 6, section 6.E.2, most radioactive materials that are cesses and actions create hazardous waste.
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Note that generators producing more than 1 kg of hazardous waste is regulated by DOT in accordance in a calendar month of "acute hazardous waste" (see with the Hazardous Materials Transportation Uniform above) are subject to full regulation under RCRA as a Safety Act.
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materials are aimed at ensuring that the public and EPA has not established emission standards for volatile the workers in the transportation chain are protected organic compounds or other emissions from laboratory from exposure to potentially hazardous materials beoperations, nor has EPA established a special source ing transported. Protection is achieved through the category for research or laboratory facilities.
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should be maintained in a file for 5 years. element or uncombined radical." Chemical substances not regulated or excluded by TSCA include pesticides regulated by the Federal Insecticide, Fungicide, and 11.F.2.3 Chemical Exports from R&D Laboratories Rodenticide Act; tobacco and tobacco products regu Laboratories must complete and send to EPA a TSCA lated by the Bureau of Alcohol, Tobacco, Firearms, Export Notification Form prior to the exportation of and Explosives; radioactive materials regulated by chemical substances listed in the EPA's Chemicals on the USNRC; and foods, food additives, drugs, and Reporting Rule (CORR)
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. by a technically qualified individual.
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This standard paid students are not employees within the scope of must be followed by spill response contractors and the Occupational Safety and Health Act, but both moral fire departments when they respond to a laboratory and legal considerations suggest that colleges and emergency involving hazardous materials. universities provide the same protections to students In most cases, however, the immediate, simple
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From page 282... ...
responses within the scope of this standard." That OSHA's bloodborne pathogen standard describes section goes on to say, "Responses to releases of haz- the necessary precautions for cleaning a spill of human ardous substances where there is no potential safety or blood or body fluids. health hazard (i.e., fire, explosion, or chemical expo
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