This document outlines the key requirements of the OSHA Lab Standard regulations. It discusses common causes of laboratory accidents like inadequate training and safety protocols. It summarizes statistics on laboratory accidents and fatalities. It also reviews several high-profile laboratory accident cases and the systemic deficiencies that led to the incidents. The document explains the hierarchy of hazard controls and the "Swiss cheese" model for managing risk. Finally, it details the main sections of the OSHA Lab Standard, including requirements for chemical hygiene plans, personal protective equipment, employee training, medical consultations, and recordkeeping.

1. Is It Safe?
A Cautionary Tale and Practical Guide to Laboratory Safety and
Compliance with the OSHA Lab Standard Regulations
Speaker :
Dr. Gregory J. Wells, MS, PhD
Sr. Scientist and Chemistry Consultant
The Cecon Group, Inc

2. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 2
Like Life in General
Chemistry Can Get Messy
Entropy happens!

3. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 3
Especially In Today’s Hyper-driven World

4. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 4
We sometimes get so immersed in work or play…
…we can end up in a tight
spot before we know it.

5. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 5
Experience and Expertise Count
But past performance is no
guarantee of future results

6. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 6
And Things Don’t Always Turn Out As Planned

7. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 7
Despite All the Warnings Around Us…
… laboratory accidents, injuries and even death
are still too common in industry and academia.

8. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 8
Workplace Metrics
 About 7,200 OSHA recordable* accidents in research laboratories in 2013**
• About 1 of every 70 lab workers.
• Nearly half of the accidents resulted in days away from work or restricted work duties.
• About 300 deaths attributed to exposure to harmful substances or environments
* Staff injuries requiring more than simple first
aid and attributable to the workplace
** Source: Bureau of Labor Statistics

9. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 9
Tragedy at UCLA
 What happened
 Why it happened
• In late 2008, 23-year-old research assistant Sheharbano
Sangji sustained third degree burns over 40% of her body as
the result of a lab fire at UCLA. She died of her injuries 18
days later.
• Ms. Sangii was inexperienced and not properly trained in the
use and handling of t-Butyllithium solution, an extremely
pyrophoric liquid. She was also not wearing proper PPE.
Proper dispensing
technique for t-BuLi

10. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 10
Explosion at Texas Tech University
• In January, 2010, an explosion lead to a graduate student
losing three fingers, a perforated eye and significant
burns.
 What happened
 Why it happened
• Violated lab rule limiting preparation of high energy
compounds to 100mg or less.
• The student prepared a 10g batch, about half of which
exploded while being ground with a mortar and pestle. Ni(N2H4)2(ClO4)2

11. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 11
Fatal Poisoning at Dartmouth College
 What happened
 Why it happened
• In August, 1996, an experienced research professor, Dr. Karen
Wetterhahm, spilled a drop or two of Me2Hg onto her latex gloves
while transferring by pipette.
• About 5 months later, she developed severe CNS symptoms, lapsed
into a coma 3 weeks later, and died on June 8, 1997, less than a year
after the initial exposure.
• Ignorance of the extreme toxicity (IDLH level) of Me2Hg
• Inaccurate PPE recommended (latex gloves) in manufacturer’s MSDS

12. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 12
Seeing the Bigger Picture
• Inaccurate knowledge – failure to fully appreciate the intrinsic hazards
• Failure to follow – SOPs (if any) or over-reliance on standardized H&S
documents (e.g. “boiler plate” MSDS); missing or inadequate use of PPE
• Cavalier or naive attitude – from inadequate training, poor supervision,
or prior “non-events”
Reveals common threads to these tragic events
often thematic to lab accidents in general
• SYSTEMIC DEFICIENCIES – in training, communication, management
“Experimenting with Danger” – https://www.youtube.com/watch?v=ALBWxGik64A
CSB Accident Review Video

13. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 13
Culture and Attitude
"It's very difficult to change PI’s attitudes. All too often, researchers in laboratories around the
country still work alone and without proper supervision or protection.”
James Gibson, UCLA's director of EH&S.
"In many cases, academic freedom is more important than safety.“
Jim Kaufman, president, Laboratory Safety Institute

14. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 14
 Tracking an initial theoretical investment of $10,000 in publicly traded companies from the mid-90s
to 2012, researchers found that award-winning (CHAA) companies outperformed the S&P 500.
Health and Safety Investments Pay Dividends
“Companies that build a culture of health by focusing on the well-being and safety of their workforce may yield
greater value for their investors.” Journal of Occupational and Environmental Medicine (JOEM, Sept.’13)
CHAA vs. S&P 500 Performance Comparison 1999-2012

15. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 15
Notable Federal workplace milestones
 1893 – Safety Appliance Act
o First federal statute to require safety equipment in the workplace (railroad equipment only)
 1910 – Congress establishes the United States Bureau of Mines
o Conducts safety research but has no regulatory authority
o Many states also enact worker’s compensation laws which discouraged unsafe workplaces
 1968 – LBJ submits a comprehensive occupational health and safety bill to Congress.
o Opposed by many business groups and even labor leadership, the bill dies in committee
 1970 – Occupational Safety and Health Act
o Enacted by Congress and signed into law on December 29 (Nixon)
 Before OSHA – federal mandates to ensure workplace health and safety were minimal
or non-existent.

16. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 16
 Established – 1971 as an agency of the USDL following passage of the Occupational
Safety and Health Act signed into law on December 29, 1970.
Occupational Safety and Health Administration
“To assure safe and healthful working conditions
for working men and women; by authorizing
enforcement of the standards developed under
the Act; by assisting and encouraging the States in
their efforts to assure safe and healthful working
conditions; by providing for research, information,
education, and training in the field of occupational
safety and health.”
Mission

17. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 17
 Authority – establish and enforce workplace regulations based on
guidelines set by certain standards organizations (e.g. ACGIH)
Equates to about one (1) compliance officer for
every 56,000 workers and nearly 3,500 worksites!
Ultimate responsibility is on YOU!
 Employees – 2,305 (2012)
 Annual Budget – $565M (FY 2015)
 Responsibility – for 130 million workers at more than 8 million worksites

18. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 18
The OSHA Lab Standard
29 CFR 1910.1450
 50 Total
 #29 – Department of Labor
Part of the Code of Federal Regulations
Part.Subpart
 1910 – Occ. Safety and Health Standards
 1450 – Occupational exposure to hazardous
chemicals in laboratories
 Requirements – parts (a) – (l) 
Title

19. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 19
Requirements of the OSHA Lab Standard
(a) Scope and Application (p 3327)
• All non-production laboratories
• “Lab scale” operations (small quant.)
• More than 500K lab workers
(b) Definitions
• Chemical Hygiene Officer – “…an employee who is designated by the employer and who is
qualified by training or experience to provide technical guidance
in the development and implementation of the provisions of the
Chemical Hygiene Plan” - 29 CFR 1910.1450(b)
• Chemical Hygiene Plan – “…written program developed and implemented by the employer
which sets forth procedures, equipment, PPE and work practices
that (i) are capable of protecting employees from the health
hazards presented by hazardous chemicals used in that
workplace and (ii) meets the requirements of paragraph (e) of this
section.” - 29 CFR 1910.1450(b)

20. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 20
Requirements of the OSHA Lab Standard
(c) Permissible Exposure Limits (p 3329)
• Do not exceed PELs (see Subpart Z)
• Exposure Limits
 OSHA – PELs: TWA (8h day), STEL (15min), Ceiling (0 Time)
 ACGIH – TLVs (Threshold Limit Value)
 NIOSH – RELs (Recommended Exposure Limit)
• IDLH (Immediately Dangerous to Life and Health) – 30 min limit
3M Respirator Selection Guide – free online

21. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 21
Requirements of the OSHA Lab Standard
(d) Employee Exposure Determination
• Initial Monitoring
• Periodic Monitoring
• Termination of Monitoring
• Notification of Employee
“The employer shall measure the employee’s
exposure to any substance regulated by a
standard which requires monitoring if there is
reason to believe that exposure levels for that
substance routinely exceed the action level (or
in the absence of an action level, the PEL).”
- Federal Register (Pg. 3329)

22. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 22
Requirements of the OSHA Lab Standard
Subpart Z – Compounds with an OSHA Standard Requiring Monitoring
 450 regulated standards, but only the following require monitoring:
• Acrylonitrile
• Arsenic (inorganic)
• Asbestos
• Benzene
• Cadmium
• 1,2-Dibromo-3-chloropropane
• Chromium (VI)
• Ethylene oxide
• Formaldehyde
• Lead
• Methylene chloride
• Vinyl chloride

23. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 23
Requirements of the OSHA Lab Standard
(e) Chemical Hygiene Plan
General information (p. 3329)
• Written CHP
• Accessible to Employees
• Elements and Specific Measures
• Review and Evaluate (at least) Annually

24. Laboratory Safety and Compliance with the OSHA Lab
Standard Regulations
24
Requirements of the OSHA Lab Standard
• Elements and Specific Measures of the CHP
1. Standard Operating Procedures (SOP)
2. Control Measures (Determination / Implementation)
o Elimination; Substitution; Eng. and Admin. Controls; PPE/Training
3. Fume Hoods and other protective equip. (Function properly; maintenance, inspection)
4. Info and Training Provisions (Sect. f)

25. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 25
Hierarchy of Controls

26. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 26
“Swiss Cheese” Model of Managing Risk
Multiple Barriers
 Infrastructure/Engineering
 Technology/Processes (SOPs)
 Training/Supervision
 PPE
Active Errors
 Worker initiated
 Lack of supervision / training
 Admin. / Engineering / Maintenance
Latent weaknesses
Adapted from “Managing the Risks of Organizational Accidents”, James Reason (1997)
Designed
to avoid…

27. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 27
• Slices represent different safety levels or controls designed to prevent incidents
• Holes represent gaps in levels; incidents can occur when holes in various levels “line up”.
• Effectiveness of these controls should be regularly measured and documented to
minimize risk and repair holes when possible
• Concrete, objective indicators that can't be gamed (e.g. chemical inventory and
storage; waste streams; regular lab inspections; housekeeping; # incidents/time;
near misses).
• Training records
• Maintenance records
• Requires relationship between management and staff
• Continuous vigilance (there’s always a “mouse”)
Swiss Cheese Model (cont.)

28. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 28
Requirements of the OSHA Lab Standard
• Elements and Specific Measures of the CHP (cont.)
5. Circumstances requiring prior approval
6. Provisions for Medical Consultations and Examinations (Sect. g)
7. Description of Responsible Personnel (designate who is resp. for enforcement)
8. Provisions for Additional Protection with Particularly Hazardous Substances (PHS)
(Area for use; Fume Hood; Decontamination; Disposal)
PHS classes include

29. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 29
Requirements of the OSHA Lab Standard
 Particularly Hazardous Substances (PHS)
• Select Carcinogens
• Reproductive Toxins
• Highly Toxic Substances
 Also Suggested
• Highly Reactive
• Highly Corrosive
• Highly Flammable or Pyrophoric

30. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 30
Requirements of the OSHA Lab Standard
(f) Information and Training
• Employer Must Provide Workplace Hazard Information
• Condition of Initial Employment and New Exposure Situations
• All Relevant Information – provided and readily available anytime
• Relevant, Periodic Training

31. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 31
Requirements of the OSHA Lab Standard
 Information Requirements
• Contents of Lab Standard and Appendices
• Location and Availability of the CHP
• PELs, TLVs, etc.
• Signs and Symptoms of Exposure
• Location and Availability of References (e.g. MSDS, SOP, CHP)

32. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 32
Requirements of the OSHA Lab Standard
 Training Elements Required
• Methods and Observations to Detect Presence or Release of Hazardous Chemicals
• Physical and Chemical Health Hazards
• Protection & Emergency Procedures
• Training in details of the Employer’s Chemical Hygiene Plan (CHP)

33. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 33
 Recommended precautions when PHS in use
• Designated Area and signage
• Need for Fume Hood
• Appropriate PPE
• Procedures for Decontamination
• Proper Waste Disposal
Requirements of the OSHA Lab Standard

34. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 34
(g) Medical Consultation and Examination (p. 3330)
• Employer Provided Medical Attention and Follow-up Exams
• Provided by Licensed Physician
• All Relevant Information Provided to Physician
• Physician’s Written Opinion
Requirements of the OSHA Lab Standard

35. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 35
Requirements of the OSHA Lab Standard
(h) Hazard Identification (p. 3330)
 Labels and MSDSs
• Labels Not Removed or Destroyed on Incoming Containers (bar codes must not obstruct
existing labels)
• Maintain and Make Available MSDSs – Hard Copies / Network Database
 Chemical(s) Developed in Lab (i.e. non-Commercial)
• In Lab – Provide Training (as per part f)
• Outside Lab – Hazard Communication Standards
 Shipping novel chemicals of unknown hazard requires creating an MSDS for that
chemical and following the provisions of the Federal Hazard Communication
Standard (29 CFR 1910.1200)

36. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 36
Requirements of the OSHA Lab Standard
(i) Respirators (p 3330)
• Provided by the Employer
• Training in proper selection and usage (as per 1910.134)
 OSHA Respiratory Protection Standard 29 CFR 1910.134(f)(1)
requires that the wearer of any tight-fitting respirator be fit tested.
M-95 dust respirator Half-face cartridge Full-face SCBA

37. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 37
Requirements of the OSHA Lab Standard
(j) Recordkeeping (p. 3330)
• Employee Exposure Monitoring
• Medical Consultations
• Medical Examinations
• Written Opinions and Tests
• Retain, Transmit and Make Available as Needed (1910.1020)
o Duration of Employment plus 30 years

38. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 38
Requirements of the OSHA Lab Standard
(k) Dates (p. 3330)
• Effective May 1, 1990 (original Haz. Comm. Std.)
• Develop and Implement CHP before January 31, 1991
• Section k now reserved and left blank for future use
(l) Appendices
• Recommendations and references (non-mandatory)
A. NRC Recommendations (p. 3330)
Based on "Prudent Practices in the Laboratory: Handling and
Management of Chemical Hazards.“ (Nat. Acad. Press)
B. References (p. 3335)
Includes “Laboratory Safety Guidelines” from the Lab Safety Institute

39. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 39
Requirements of the OSHA Lab Standard
“Laboratory Safety Guidelines” (Appendix B)
1. What are the hazards?
Suggests Four Basic Questions Before Proceeding
2. What are the worst things that could happen?
3. What do I need to do to be prepared?
4. What are the prudent practices, protective facilities and protective
equipment (PPE) needed to minimize the risks and consequences?

40. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 40
Programs like TAKE TWO... for Safety™, developed
by DuPont, stimulates thinking and conversation
about safety in the workplace and at home.
“TAKE TWO” means that a person can work more
safely by taking two minutes to think through a job
before that job is started.
Established OSHA and Industry Standards
give us proven tools to work safely and efficiently
Be Proactive, Not Reactive!

41. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 41
Updates to OSHA’s Recordkeeping and Reporting Rule
The rule expands the list of severe work-related injuries and
illnesses that all covered employers must report to OSHA.
Starting January 1, 2015, employers must report the
following to OSHA:
• All work-related fatalities within 8 hours (same as current
requirement)
• All work-related in-patient hospitalizations, amputations, or loss of an
eye of one or more employees within 24 hours

42. Laboratory Safety and Compliance with the OSHA Lab
Standard Regulations
42
Updates to OSHA’s Recordkeeping and Reporting Rule
Summary of What, When and How to Comply

43. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 43
References
OSHA website www.osha.gov
Lab Standard, Fact Sheet http://1.usa.gov/1A7avGp
Lab Standard, Full documentation http://1.usa.gov/1Ee5ZEw
"Prudent Practices in the Laboratory” http://bit.ly/1t09Lzu
Chemical SOP and SOP templates http://www.safety.duke.edu/OHS/chemsopsTemplates.htm
List of PHS (Duke Univ.) www.safety.duke.edu/ohs/phs.htm
NIOSH Pocket Guide to Chemical Hazards http://www.cdc.gov/niosh/npg/
Ansell Chemical Resistance Glove Guide http://bit.ly/1Ab6wZc
3M Respirator Selection Guide http://bit.ly/1yUDngw
Chemical Safety Board (CSB) http://www.csb.gov/
The Laboratory Safety Institute http://labsafetyinstitute.org/

44. Thank You
Please feel free to contact us at:
Phone : 1-646-216-8860
Email : marketing@biopractice.com

45. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 45
Supplemental Slides

46. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 46
Accident Investigation and Mitigation
1. Notification and Response
• If it’s not widely communicated, it never “happened”. Expect more of the same.
2. Site Investigation and Interviews
• Timely, quality data collection at the source is essential to effectively address the problem.
3. Root Cause Analysis (RCA or similar analysis technique)
• Asking the right “whys” can reveal the source of the accident and prevent more of the same.

47. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 47
4. Review and Report of Findings
• Accurate, timely review is the first step to communication and implementation of corrective action.
5. Implement Corrective Measures
• Scope – Resources – Outcome – Metrics
6. Monitoring
• Ensures corrective measures implemented (engineering and/or administrative controls)
• Process-oriented (e.g. training)
• Results-oriented (e.g. lab inspections)
Accident investigation and mitigation

48. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 48
Establishing a PPE Program
 Identify steps taken to assess potential hazards in every employee’s work space
 and in workplace operating procedures
 Identify appropriate PPE selection criteria
 Identify how you will train employees on the use of PPE, including
• What PPE is necessary
• When PPE is necessary
• How to properly inspect PPE for wear or damage
• How to properly put on (don) and adjust the fit of PPE
• How to properly take off (doff) PPE
• The limitations of PPE
• How to properly care for and store PPE
 Identify how you will assess employee understanding of PPE training
 Identify how you will enforce proper PPE use
 Identify how you will provide for any required medical examinations
 Identify how and when to evaluate the PPE program

49. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 49
 Appropriate PPE depends on the activity, recognized hazards and materials in use
• Eyes,
• Face,
• Head,
• Ears,
• Feet,
• Hands, arms, whole body
PPE is designed to protect:
• Goggles,
• Face shields,
• Safety glasses,
• Hard hats,
• Safety shoes,
• Gloves,
• Vests,
• Earplugs or Earmuffs
Includes items such as:

50. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 50
Environmental Protection Agency (EPA)
 Established – Dec. 2, 1970 by executive order (Nixon) and later ratified by Congress, which reorganized and
consolidated many federal governmental environmental responsibilities under one agency
 Mission – protecting human health and the environment by writing and enforcing regulations based on
laws passed by Congress
 Responsibility – maintaining and enforcing national standards under a variety of environmental laws, in
consultation with state, tribal, and local governments.
 Headquarters – Washington, D.C.
- 10 regional offices and 27 laboratories conducting environmental assessment, research and education
 Employees – 17,359 FTE (2011)
- Many more on contractual basis.
- More than half are engineers, scientists and environmental specialists
- Others include legal, public affairs, financial and information technologists
 Annual Budget - $8.2 billion (2014)

51. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 51
Administrative regions of the EPA

52. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 52
Notable EPA Legislation
1970: Water Quality Improvement Act
1974: Safe Drinking Water Act
1976: Toxic Substances Control Act (TSCA)
1977: Clean Water Act
1987: Water Quality Act
1969: National Environmental Policy Act
1970: Wilderness Act
1977: Surface Mining Control and Reclamation Act
1980: Alaska National Interest Lands Conservation Act
1994: California Desert Protection Act
Land
1955: Air Pollution Control Act
1963: Clean Air Act
1965: Motor Vehicle Air Pollution Control Act
1969: National Environmental Policy Act
1976: Toxic Substances Control Act (TSCA)
1990: Clean Air Act Amendments
Air
Water

53. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 53
Notable EPA legislation – Hazardous Waste
1965: Solid Waste Disposal Act
1969: National Environmental Policy Act
1970: Resource Recovery Act
1976: Resource Conservation and Recovery Act
1980: Comprehensive Environmental Response, Compensation and Liability Act ("Superfund")
1982: Nuclear Waste Repository Act
1984: Hazardous and Solid Wastes Amendments Act
1986: Superfund Amendments and Reauthorization Act
2002: Small Business Liability Relief and Brownfields Revitalization Act ("Brownfields Law")

54. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 54
Notable EPA legislation
1969: National Environmental Policy Act
1970: Wilderness Act
1977: Surface Mining Control and Reclamation Act
1980: Alaska National Interest Lands Conservation Act
1994: California Desert Protection Act
Land Usage

55. Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 55
Acknowledgements
• https://www.osha.gov/history/OSHA_HISTORY_3360s.pdf
• http://en.wikipedia.org/wiki/Occupational_Safety_and_Health_Act#cite_ref AllAbout_18-0
• http://en.wikipedia.org/wiki/United_States_Environmental_Protection_Agency
• http://www2.dupont.com/Media_Center/en_AU/assets/downloads/events/TakeTwo_Fact_Sheet.pdf
• www.public.navy.mil/navsafecen
• http://www.rsc.org/chemistryworld/News/2011/October/24101101.asp
• http://www.exiledtees.com
• http://oddstuffmagazine.com/10-wtf-moments-of-the-day-may-31st-2012.html/attachment/45813
• www.change.org
• http://safetyposter.com/ppe-alberta-compliance-poster-ab-01/