Changes to GHS & OSHA Laboratory Standards

Across the United States, more than 500,000 workers are employed in laboratories. The laboratory environment can be a hazardous place to work, with exposure to numerous potential hazards including chemical, biological, physical and radioactive hazards, as well as musculoskeletal stresses. Laboratory safety throughout the U.S. is governed by numerous local, state and federal regulations, although, over the years, OSHA has created more universal rules and published guidance to make laboratories increasingly safe for those who operate around and in them.

Here on the Clarion Safety blog, we’ll be publishing a multi-part news series over the next few weeks, highlighting laboratory safety in the U.S. We’ll focus on chemical, biological, physical, and other safety hazards in lab settings, with an aim to deliver clear guidance and easily accessible materials.

In this first installment – as a foundation to these – we’ll be covering key requirements and standards that apply to laboratories across the U.S.

Laboratory Requirements for U.S Workplaces
For U.S.-based employers, there are several primary OSHA standards that apply to laboratories as a whole, as well as individual standards that apply on a case by case basis for certain laboratory categories. The Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450) is the primary standard which was created specifically for non-production laboratories or those with a limited variety of chemicals. Additional OSHA standards provide rules that protect workers, including those that work in laboratories, from chemical hazards as well as biological, physical and safety hazards.

For those hazards that are not covered by a specific OSHA standard, OSHA often provides guidance best practices that align with OSHA, ANSI, and NFPA standards on protecting workers. There are 28 states that have their own OSHA-approved occupational safety and health standards, which may be different from federal standards, but must be at least “as effective as” the federal standards. Below are some of the key standards Federal OSHA dictates.

General Duty Clause for Labs
It goes without question that Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSH Act), the General Duty Clause, which requires that employers “shall furnish to each of its employees: employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees.” is required in laboratory settings. This means that even if an OSHA standard does not exist for a specific hazard or hazardous operation, protection of workers from all hazards or hazardous operations may still be enforceable under this clause.

In addition the General Duty Clause, the following laboratory specific and adjusted standards from OSHA apply:

1. The Occupational Exposure to Hazardous Chemicals in Laboratories Standard
29 CFR 1910.1450 is commonly referred to as the “Laboratory” standard, and covers laboratories where the chemicals worked with are a limited variety or small scale. This means that all substances being worked with should be able to be managed by one person, the chemicals are not used for production processes, multiple chemicals are used, and protective practices and equipment are in use and available. If a business falls under those parameters, then OSHA requires that employers designate a Chemical Hygiene Officer and have a written Chemical Hygiene Plan (CHP), and actively verify that it remains effective.

The CHP must include provisions for

• Worker training
• Chemical exposure monitoring where appropriate
• Medical consultation when exposure occurs
• Criteria for the use of personal protective equipment (PPE)
• Engineering controls
• Special precautions for particularly hazardous substances
• Requirements for a Chemical Hygiene Officer responsible for implementation of the CHP.

The CHP must be specific to chemical hazards present in the laboratory where it is to be used. Laboratory personnel must receive training regarding the Laboratory standard, the CHP, and other laboratory safety practices, including exposure detection, physical and health hazards associated with chemicals, and protective measures. Laboratories which may not be included under this standard include those which use chemicals in building maintenance of a laboratory, produce chemicals for commercial sale, or carry our chemical quality control testing.

2. The Bloodborne Pathogens Standard
29 CFR 1910.1030includes changes mandated by the Needlestick Safety and Prevention Act of 2001, which mandates employers to protect workers from infection with human bloodborne pathogens in the workplace and provide and pay for appropriate PPE for any workers with occupational exposures. The standard covers all workers with “reasonably anticipated” exposure to blood or other potentially infectious materials (OPIM). It requires that information and training be provided before work begins that may involve occupational exposure to bloodborne pathogens, annually thereafter, and before a worker is offered hepatitis B vaccination. It also requires advance information and training for all workers in research laboratories who handle HIV or HBV.

This was issued as a performance standard, which means that an employer must develop a written exposure control plan (ECP) to provide a safe and healthy work environment, but is allowed some flexibility in accomplishing this goal. The ECP requires employers to make exposure determination assessments, establish procedures for evaluating incidents, and determine a schedule for implementing the standard’s requirements, including engineering and work practice controls.

3. The Control of Hazardous Energy Standard
29 CFR 1910.147 is often called the “Lockout/Tagout” standard, and establishes basic requirements for locking and/or tagging out equipment while installation, maintenance, testing, repair, or construction operations are in progress. The primary purpose of the standard is to protect workers from the unexpected energization or startup of machines or equipment, or release of stored energy. The procedures apply to the shutdown of all potential energy sources associated with machines or equipment, including pressures, flows of fluids and gases, electrical power, and radiation. For more information on LOTO procedures, visit our blog post on violation and accident prevention.

4. The Hazard Communication (HazCom) Standard
29 CFR 1910.1200 is a set of requirements first issued in 1983 by OSHA which requires evaluating the potential hazards of chemicals, and communicating information concerning those hazards and appropriate protective measures to employees. The standard includes provisions for:

• Developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present.
• Labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces.
• Preparation and distribution of material safety data sheets (MSDSs) to workers and downstream employers.
• Development and implementation of worker training programs regarding hazards of chemicals and protective measures.

This standard was merged with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in order to reduce trade barriers, increase cost savings, and provide a common and understandable approach to labeling. It requires all manufacturers and importers of hazardous chemicals to provide material safety data sheets to users of the chemicals describing potential hazards and other information. They must also attach hazard warning labels to containers of the chemicals. Employers must make MSDSs available to workers and train them in the hazards caused by the chemicals they are exposed to and the appropriate protective measures for handling.

New Updates Coming Soon to GHS
It’s important to note that changes may be coming soon to the GHS standards, impacting laboratory professionals and manufacturers, as the Globally Harmonized System of Classification and Labeling of Chemicals subcommittee of experts is meeting from December 7-9^, 2022 to discuss changes to the following:

• Simultaneous classification in physical hazard classes and precedence of hazards
• Use of non-animal testing methods for classification of health hazards
• Classification of skin sensitizers using the results of local lymph node assays test methods in accordance with OECD Test Guideline 442B
• Classification criteria for germ cell mutagenicity;
• Practical classification issues (proposed amendments to the Globally Harmonized System)
• Nanomaterials
• Improvement of annexes 1 to 3 and further rationalization of precautionary statements
• Practical classification issues
• Practical labelling issues

Stay tuned here on the Clarion Safety blog for updates on these changes and how they effect equipment manufacturers and workplaces.

Creating a Safety Strategy That Works
Understanding the above standards, and the combinations that apply to you, are paramount in implementing an effective safety strategy into a laboratory setting. When it comes to your laboratory workplace safety measures, consider the efficacy of your warnings by making sure to use best practice labels and signs – ones that employ the use of the latest, standardized symbols and that consider material (in line with the environment at hand to ensure legibility and durability.)Reach out to us here at Clarion Safety Systems for more laboratory and equipment safety insight – including how we can help create custom labels, signs and tags in line with your injury and illness prevention program. Keep in mind that we offer a variety of signs and labels specific to the healthcare industry, as well as customization related to symbols and site-specific signage, including custom lab door signs.

• Standards Insider