Control Measures
The OSHA Lab Standard (29 CFR 1910.1450) requires that laboratory personnel implement appropriate control measures to ensure that chemical exposures are maintained below regulatory limits and as low as reasonably achievable. In general, control measures can be categorized as administrative controls, engineering controls, procedural controls (i.e., standard operating procedures), or personal protection.
Administrative Controls
Administrative controls consist of various hazard control requirements that are established at an administrative level (e.g., by the principal investigator, laboratory manager, laboratory supervisor, department chair, laboratory safety coordinator, department safety committee, or University Environmental Health and Safety) to promote safety in the laboratory.
Administrative controls describe the way the work is done and include other measures to reduce employee exposure to hazards. Administrative controls do not remove hazards, but limit or prevent exposure to the hazards.
Examples of administrative controls include written plans and standard operating procedures, signs, labels, training, supervision, timing of work, personnel substitutions, using a lab partner, and more. PIs, Lab Managers, and Lab Supervisors must:
- Ensure that all laboratory personnel have been provided with adequate safety and compliance training to enable them to conduct their duties safely (see Training Requirements).
- Ensure that all laboratory personnel have been provided with adequate procedural (experiment-specific) training and they are proficient to enable them to conduct their duties safely.
- Require prior approval of experimental procedures and implement additional control measures for certain particularly hazardous operations or activities.
- Restrict access to areas in which particularly hazardous chemicals are used.
- Post appropriate signs to identify specific hazards within an area.
- Require that various standard practices for chemical safety and good housekeeping be observed at all times in the laboratory.
Prior Approval of Hazardous Operations
The OSHA Lab Standard requires that activities involving certain particularly hazardous chemicals be reviewed and approved in advance by an appropriate individual or group. Depending upon the specific department, this approving entity is primarily the PI, Lab Manager, or Lab Supervisor, but could also be the Department Safety Committee, the Laboratory Safety Coordinator, or the Department Chair.
At the time of approval, any additional required control measures for the project shall be specified in writing (see SOP 3.7). Examples of the types of operations that must receive prior approval are those involving the use of select carcinogens, reproductive toxins, acutely toxic chemicals, energetic materials (explosives), highly reactive or shock sensitive chemicals, or highly corrosive or oxidizing chemicals. In addition, any operation that
produces potentially hazardous results must receive prior approval.
Laboratory Entrance Signs
The entrance to each laboratory in which chemicals are used or stored shall be posted with the names and phone numbers of the Principal Investigator, Lab Manager, or Lab Supervisor and any other designated personnel who can be contacted in the event of an emergency.
The signage system is designed to fulfill regulatory signage requirements and alert lab users and visitors to specific hazards located in individual laboratories. The lab signs may not list every hazard associated with a lab and do not replace basic laboratory safety training or practice.
The OSHA Laboratory Standard requires that carcinogens, reproductive toxins and chemicals with a high degree of acute toxicity (known as “particularly hazardous substances”) be handled in a “designated area.” Although a designated area may be a small portion or a single fume hood within a laboratory, the laboratory signs provide a means of designating the entire laboratory as an area where particularly hazardous substances may be used.
Accurate door postings facilitate emergency response actions by providing immediate information to firefighters, paramedics, and others. Incorrect postings may place others in danger and/or delay implementation of control measures to minimize certain emergency situations (e.g., fire, explosion, etc.), thereby increasing the damage to the room and/or other portions of the building.
The Hazard Assessment and Laboratory Signage (HALS) Program described below has been developed to provide researchers with a tool to prepare and order a permanent laboratory sign for this purpose.
The HALS sign sent to and printed by the laboratory personnel after filling out the appropriate information may be used temporarily until the permanent sign is prepared and delivered.
Hazard Assessment and Laboratory Signage (HALS) Program
HALS is a web-based program designed to assist laboratory supervisors in identifying the hazards present in their laboratories and communicating this information to anyone who enters their labs. The laboratory PI, Lab Manager, Lab Supervisor or their representative can log onto the HALS Program to complete the sign.
At IUB (IUE, IUK, IUN, IUS, IUSB): www.ehs.indiana.edu/hals
At IUPUI: www.ehs.iupui.edu/hals/home.asp
The laboratory PI, Lab Manager, Lab Supervisor, or their representative will then complete an electronic profile of the laboratory, and the information is incorporated into a door sign. The sign lists the name of the Principal Investigator, Lab Manager, Lab Supervisor and the name of any alternate contacts that are responsible for the room, along with corresponding contact numbers.
The PI, Lab Manager, Lab Supervisor, or their representative must select the most important hazards in their lab area from a list of hazards. They then rate the risk level as “low”, “moderate”, or “high” for each hazard. Use the drop down menus for guidance selecting the hazard types and ratings for each category.
For biological hazards present in the laboratory, please choose from Biosafety Level 1, 2 or 3 (BSL1, BSL2 or BSL3). Please note that you should have approval from Biological Safety before a sign can be posted indicating biological materials in use.
If radioactive materials are in use in the laboratory then please indicate “Present” on the pull down menu. Please note that you must have approval from the Radiation Safety Office before a sign can be posted indicating radioactive materials in use.
Eye protection classifications are based on the need for eye protection to enter the laboratory. Use the drop down menu to select the required level of eye protection (Class 1, 2 or 3).
The sign provides a method to limit access to specific personnel and also provides an area for you to type any additional warnings you would like posted.
All laboratory signs must state “No Food or Drinks”.
Procedural Controls
Procedural controls (or work practice controls) are an administrative control typically in the form of rules, requirements, and standard operating procedures (SOPs) that define the manner in which certain types of chemicals are to be handled, or the manner in which specific operations involving chemicals are to be conducted, in order to minimize hazards. The Standard Operating Procedures section of this Plan contains a number of rules, requirements and SOPs, which are generally applicable to all laboratories.
It is the responsibility of the PI and personnel in each laboratory to develop written SOPs for specific experimental procedures performed in their laboratory. These laboratoryspecific procedures must be well documented and accessible to authorized personnel (incorporated into the laboratory manual or CHP). Training must be provided to new personnel by those that are proficient in the procedures. New personnel must be supervised and proficient performing the procedures before they are authorized to proceed.
Engineering Controls
Engineering controls consist of various measures for reducing a hazard at its source or for separating personnel from the hazard (see Section 6.0, Laboratory Safety Equipment). In the laboratory, examples of engineering controls include the substitution of less hazardous chemicals in an operation, isolating a particular chemical operation, enclosing a potentially explosive reaction, or utilizing local exhaust such as a fume hood for an operation that produces airborne chemicals (see Chemical Fume Hoods).
Because engineering controls function to reduce or eliminate a hazard at its source before it is created, they should be fully considered and utilized whenever possible as the first step in chemical hazard control within the laboratory.
Personal Protective Equipment
For many laboratory operations the risk of chemical exposure cannot be totally eliminated through the use of engineering and procedural control measures. For this reason, it is necessary to supplement such measures with the use of personal protective equipment (PPE) and apparel. Because PPE functions as a barrier between the laboratory worker and the chemical hazard, rather than by actually reducing or eliminating the hazard, its use must always be in addition to (and never as a substitute for) appropriate engineering and procedural controls.
It is the responsibility of the principal investigator, lab manager, or lab supervisor of the laboratory to ensure that appropriate personal protective equipment is provided to and used by all laboratory personnel. Such equipment should be adequate to ensure personnel are protected from chemical exposure to the eyes, skin, and respiratory tract.
Selection of personal protective equipment is described in SOP 3.16. Personal protective equipment is selected based on the hazard. The Laboratory Chemical Personal Protective Equipment Guidance Form is found in Appendix A can be used for this purpose in the laboratory and will help assign the proper PPE based on the hazard. Careful consideration to street clothes must be given when working with potential fire hazards such as flammables, reactives, or pyrophorics. Synthetic fabric street clothes are not appropriate for these applications and all cotton or fire-resistant lab coats must be utilized.
- Eye Protection
Appropriate PPE for the eyes is required whenever there is a reasonable probability that the eyes could be exposed to chemicals. Vented safety goggles are the preferred eye protection to be worn when chemicals are handled in the laboratory. These must be worn over prescription glasses. All protective equipment for the eyes must bear the stamp Z87, which indicates that it meets the performance guidelines established by the American National Standards Institute in ANSI Z87.1 “Practice for Occupational and Educational Eye and Face Protection.”
- Face Protection
A face shield is required whenever there is a potential for severe chemical exposure from splashes, fumes, or explosions. Because a face shield alone does not adequately protect the eyes, it must be worn over safety goggles. In general, any operation that requires a face shield must be conducted inside a hood with the sash down as an additional barrier.
- Hand Protection
Because the hands are typically the part of the body in closest contact with chemicals in the laboratory, they are particularly vulnerable to chemical exposures. For this reason it is essential that laboratory personnel select appropriate protective gloves and wear them whenever handling chemicals. Because different glove materials resist different chemicals, no one glove is suited for all chemical exposures. Glove selection guides are available from most glove manufacturers and must be consulted before choosing a glove.
For assistance contact University Environmental Health and Safety for your respective campus.
- Foot Protection
Foot Protection Safety shoes or other specialized foot protection are generally not required for most laboratory operations. However, footwear that completely covers the skin of the feet must be worn whenever chemicals are being used. Perforated shoes, sandals, fabric shoes or cloth athletic shoes must not be worn in laboratories. They offer no barrier between the laboratory workers and chemicals or broken glass. Leather shoes or equivalent (chemically resistent shoes) with slip-resistant soles are required. Shoes may have to be discarded if contaminated with a hazardous material.
- Body Protection
By virtue of its large surface area, the skin is at considerable risk of exposure to chemicals in the laboratory. To lessen this risk, it is essential that laboratory personnel wear clothing, which, to the extent possible, covers all skin surfaces (i.e. shorts are inappropriate attire for the laboratory). In addition, a fully-buttoned lab coat or chemical resistant apron must be worn during chemical manipulations. Clothing and lab coats should be regarded not as means of preventing exposure, but as means of lessening or delaying exposure. The effectiveness of clothing as a protective barrier for the skin depends upon its prompt removal in the event that it becomes contaminated. Do not wear synthetic fabric street clothes or polyester lab coats when working with flammables, reactives, or pyrophorics. Use all cotton or fire-resistant materials.
- Respiratory Protection
The implementation of appropriate engineering and procedural controls should always be the preferred strategy for ensuring that any airborne levels of chemicals within the laboratory are well below regulatory limits.
However, in rare circumstances where such control measures are not sufficient, laboratory personnel may need to utilize respirators for a particular operation. In such instances, personnel must participate fully in the University’s Respiratory Protection Program, which requires a medical evaluation, respirator fit-testing (to ensure that the respirator properly fits the persons face and that there are no leaks which may lead to chemical exposure), and training prior to respirator use.
Contact University Environmental Health and Safety for your respective campus for more information.