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Is It Safe? A Cautionary Tale and Practical Guide to Laboratory Safety and Compliance with the OSHA Lab Standard Regulations

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.

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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
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 2 Like Life in General Chemistry Can Get Messy Entropy happens!
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 3 Especially In Today’s Hyper-driven World
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.
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 5 Experience and Expertise Count But past performance is no guarantee of future results
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 6 And Things Don’t Always Turn Out As Planned
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.
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
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
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
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
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
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
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
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.
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
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
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
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)
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
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)
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
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
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)
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 25 Hierarchy of Controls
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…
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.)
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
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
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
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)
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)
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
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
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)
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
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
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
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?
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!
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
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
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/
Thank You Please feel free to contact us at: Phone : 1-646-216-8860 Email : marketing@biopractice.com
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 45 Supplemental Slides
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.
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
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
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:
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)
Laboratory Safety and Compliance with the OSHA Lab Standard Regulations 51 Administrative regions of the EPA
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
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")
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
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/

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Is It Safe? A Cautionary Tale and Practical Guide to Laboratory Safety and Compliance with the OSHA Lab Standard Regulations

  • 1.
    Is It Safe? ACautionary 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 andCompliance with the OSHA Lab Standard Regulations 2 Like Life in General Chemistry Can Get Messy Entropy happens!
  • 3.
    Laboratory Safety andCompliance with the OSHA Lab Standard Regulations 3 Especially In Today’s Hyper-driven World
  • 4.
    Laboratory Safety andCompliance 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 andCompliance with the OSHA Lab Standard Regulations 5 Experience and Expertise Count But past performance is no guarantee of future results
  • 6.
    Laboratory Safety andCompliance with the OSHA Lab Standard Regulations 6 And Things Don’t Always Turn Out As Planned
  • 7.
    Laboratory Safety andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance with the OSHA Lab Standard Regulations 25 Hierarchy of Controls
  • 26.
    Laboratory Safety andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 feelfree to contact us at: Phone : 1-646-216-8860 Email : marketing@biopractice.com
  • 45.
    Laboratory Safety andCompliance with the OSHA Lab Standard Regulations 45 Supplemental Slides
  • 46.
    Laboratory Safety andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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 andCompliance with the OSHA Lab Standard Regulations 51 Administrative regions of the EPA
  • 52.
    Laboratory Safety andCompliance 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 andCompliance 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 andCompliance 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 andCompliance 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/

Editor's Notes

  • #4 Easy to drop your guard down and let safety take a back seat.
  • #14 Health and safety experts say that they have not seen a significant shift in the behavior of bench scientists or the attitudes of lab heads, who are in the best position to improve safety culture. http://www.nature.com/news/2011/110418/full/472270a.html
  • #15 Ref. http://www.labmanager.com/?articles.view/articleNo/37499/title/Study-Suggests-Companies-with-a--Culture-of-Health--May-Outperform-Others-in-the-Marketplace/ JOEM is official publication of the American College of Occupational and Environmental Medicine (ACOEM). CHAA = Corporate Health Achievement Award, presented by the American College of Occupational and Environmental Medicine (ACOEM)
  • #19 In effect for nearly 25 years (Jan. 1990).
  • #20 Standard originally applied only to private sector, until Pres. Signed an Exec. Order extending it to public sector. Regulation allowed for states to submit their own plan for approval; about 25 State plan states presently (must apply to public sector). Does not apply to QC or other non-research labs. CHO is not an enforcement position, but is more of an advisory role.
  • #21 TWA - Time Weighted Avg.; STEL – Short Term Exposure Limit Limits may vary depending on the agency; eg. formaldehyde – OSHA TWA = 0.75ppm, STEL = 2ppm; ACGIH TLV = 0.3ppm Ceiling; NIOSH TWA = 0.016ppm. Responsible employers usually aim for the lowest of all three groups, but must at least comply with OSHA (if avail.). OSHA enforces other rec. levels if they don’t have one. This is part of the General Duty Clause of the OSHA Act (called 5A1).
  • #22 Action level is typically half the PEL; “Actions” called for include warning signs, training, container labels. Eg. confining substance to fume hood during use at all times removes need for monitoring. DuPont Deepwater site – Pb monitors and routine blood testing during TEA production years.
  • #24 Suggest review and evaluation be done on a rotating basis among staff (active participation, culture).
  • #25 Specific commitments to training schedule communicated.
  • #30 Recommended: Duke University PHS list online (25pp).
  • #32 Good ref: Prudent Practices in the Laboratory (Nat. Acad. Press) – free online; hard copy for ~$100.
  • #35 Confidentiality (HIPPA) rules apply.
  • #37 3M Respirator Selection Guide online
  • #38 Includes MSDS used.
  • #41 http://www2.dupont.com/Media_Center/en_AU/assets/downloads/events/TakeTwo_Fact_Sheet.pdf TAKE is an acronym which stands for: T= Talk: Have I talked with everyone involved with this job? A= Action: Do I know the proper actions I need to follow to do this job safely? K= Knowledge: Do I have the proper knowledge to do this job safely? E= Equipment: Do I have the proper equipment, including the proper personal protective equipment, to do this job safely?
  • #42 Previously, employers were required to report all workplace fatalities and when three or more workers were hospitalized in the same incident. The updated reporting requirements have a life-saving purpose: they will enable employers and workers to prevent future injuries by identifying and eliminating the most serious workplace hazards. (Feb. 2, 2015, OSHA Newsletter osha.news@subscriptions.dol.gov).
  • #43 Feb. 2, 2015, OSHA Newsletter osha.news@subscriptions.dol.gov
  • #48 Reference: http://www.ien.com/article/6-steps-preventing/114723