A Dozen Safety Plans Laboratories May Need
These plans are instrumental to ensuring compliance and keeping workers safe.
- By Karen D. Hamel
- Aug 01, 2012
Workplace safety for laboratory employees goes beyond having everyone read a few manuals. Depending on the hazards present, safety plans that specifically address each hazard may need to be developed and communicated.
Because laboratories have different chemicals and equipment, the required safety plans for each location may vary. Having the right plans in place is the first step toward greater workplace safety.
Often, safety plans can be combined into one master plan with annexes for specific topics. This can help simplify plan management as well as training.
The use of hazardous chemicals in a laboratory necessitates a written Chemical Hygiene Plan. This plan must "set forth procedures, equipment, personal protective equipment and work practices" to protect employees from chemical hazards (29 CFR 1910.1450).
OSHA specifies a number of plan elements in this standard and requires that the plan be readily available to employees. Safe practices, such as prohibiting anyone to work alone in a laboratory or smoking, eating, or drinking, may be among the standard operating procedures that the chemical hygiene plan establishes.
OSHA's Hazard Communication Standard (29 CFR 1910.1200) helps ensure worker safety by requiring employers to identify chemical hazards and create a written plan outlining steps that will be taken to eliminate or minimize those hazards.
Obtaining and maintaining Safety Data Sheets (SDS), properly labeling containers, and providing training are all plan elements required by the standard.
If laboratory workers are exposed to blood or other potentially infectious materials, a written "Exposure Control Plan" that details procedures to limit exposure is required under OSHA's Bloodborne Pathogen Standard (29 CFR 1910.1300). The plan must discuss universal precautions, engineering and work practice controls, personal protective equipment (PPE), cleaning methods, and availability of vaccines and other preventive measures. It must be communicated and available to workers and be updated annually or if changes are made at the workplace.
Officially called the "Control of Hazardous Energy Standard" (29 CFR 1910.147), this standard says lockout/tagout plans are required when employees will service or maintain machines or other equipment that could potentially release stored energy and cause injuries. The standard addresses electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources.
Employers must establish a program that is suited to the particular needs of a workplace and the types of equipment that will be serviced or maintained. It must outline the steps for de-energizing equipment and affixing appropriate lockout or tagout devices or otherwise preventing injuries caused by equipment start-up.
When flammable liquids, spontaneously combustible materials, or any other chemical that presents a fire hazard is present, fire prevention plans are required (29 CFR 1910.39). Plans must list fire hazards and outline proper storage and handling of flammable liquids, including the types of equipment available to control fire hazards, procedures to prevent accumulation of flammable materials, and regular maintenance that will be performed to prevent hazardous conditions.
Various OSHA standards require Emergency Action Plans, with 29 CFR 1910.38 being the main one. A well-developed Emergency Action Plan will clearly outline the types of emergencies that could occur at the facility, as well as the steps that each employee should take to stay safe during an emergency.
Directions for reporting fires and other emergencies should be listed in the plan, as well as evacuation procedures and a method for accounting for employees after an emergency.
Process Safety Management
Threshold qualities of chemicals such as anhydrous ammonia, formaldehyde, chlorine, nitric oxide, and bromine necessitate a written Process Safety Management (PSM) Plan (29 CFR 1910.119).
Plans must include "information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process."
Checklists, fault tree analysis, engineering controls, and administrative controls applicable to the hazards may all be part of the plan.
After engineering, mechanical, and administrative controls have been applied to avert hazards, PPE is a last line of defense that employers can use to guard employees from "environment, chemical hazards, radiological hazards or other mechanical irritants." (29 CFR 1910.132)
A PPE plan should address the selection of PPE and discuss how it protects against an identified hazard, as well as how the equipment is to be fit, used, and maintained. General PPE planning and training elements may sometimes be part of the facility's Hazard Communication Plan.
Hazardous gases, fumes, dusts, fogs, smokes, mists, sprays, and vapors emitted in laboratories can damage workers’ respiratory systems, causing irritation, cancer, diseases, and even death. When airborne hazards exceed permissible exposure limits, Threshold Limit Values, or recommended exposure limits, employers must establish a respiratory protection program (29 CFR 1910.134).
Respiratory protection plans must cover selection of respirators, fit testing, use and care of the respirator, change out schedules, and a process for evaluating the effectiveness of the program.
About 30 million workers are exposed to hazardous levels of noise each year. Manufacturing settings and construction sites are two traditional places where high workplace noise levels are almost expected. However, if noise levels exceed an 85 dB time weight average (TWA) in a laboratory, a hearing conservation program is required (29 CFR 1910.95).
A NIOSH study determined that 100 percent of occupational noise-induced hearing loss is preventable. Programs should be structured to help prevent hearing loss and provide workers with the knowledge and tools needed to protect themselves.
Where radiation sources such as alpha, beta, gamma, and X-rays are used, written programs that outline procedures for shielding, PPE, and administrative and other controls are required to detail the methods to be used to keep employee exposure below permissible limits (29 CFR 1910.1096).
Radiation incidents must be evaluated and exposure records must also be maintained. Copies of operating procedures must be kept in "conspicuous locations" to ensure employees working in areas with ionizing radiation can observe the documents regularly.
Toxic and Hazardous Substances
In addition to general industry precautions that must be taken when working with hazardous materials, OSHA also has specific regulations for a number of toxic and hazardous substances (29 CFR 1910, Subpart Z). Carcinogens, vinyl chloride, chromium, cadmium, and formaldehyde are among the materials that have specific regulations that supersede general hazardous material handling safety precautions.
Written plans that address these hazards should include documentation of applicable engineering controls and work practices, respiratory protection procedures, container labeling and management processes, and training requirements.
Other regulations may apply based on the specific hazardous materials being used or the processes that are in operation. OSHA can also enforce using its general duty clause if an inspector deems a practice unsafe that is not covered by a specific regulation.
Combining safety plans, where permissible, reviewing them regularly, and ensuring that workers are not only trained, but also are implementing the correct practices helps to ensure compliance and keep workers safe.
This article originally appeared in the August 2012 issue of Occupational Health & Safety.
Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer, and technical writer for New Pig. She has more than 24 years of experience helping EHS professionals find solutions to meet industry consensus standards as well as EPA, OSHA and DOT regulations. She is a Certified Safety Professional (CSP), OSHA-authorized General Industry Outreach Trainer, Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) Trainer, hazmat technician, serves on the Blair County, Pa. LEPC, and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She conducts seminars, webinars, and trainings for a variety of national organizations. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email, firstname.lastname@example.org.