(9) Information Requirements
9.1 - OSHA Requirement
Employees shall be informed of [the following]:
a. Contents of [the OSHA (29 CFR) Laboratory Standard] and its appendices which shall be made available to employees.
b. Location and availability of the employer's Chemical Hygiene Plan.
c. Permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard.
d. Signs and symptoms associated with exposure to hazardous chemicals used in the laboratory [see Section 11].
e. Location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier.
9.2 - Chemistry Department Implementation of the OSHA Requirement
All members of the Chemistry Department, including office and shop staff and
cleaners, must be informed of the location and content of the OSHA Standard,
the Department CHP, and individual references such as MSDSs for encountered
chemical substances. Section
9 details plans for information dissemination.
Documents and references must be located so that they can be readily accessed by Department members; in some cases, web-based access is the most convenient.
9.3 - The Departmental Chemical Hygiene Plan
Printed copies of the CHP will be distributed to each PI for location in that
person's laboratory area, and to strategically located offices and shops. Updates
will be distributed annually. The CHP will be posted on the Internet and be
linked to the Chemistry Department webpage.
9.4 - MSDS and PEL
a. Manufacturers' Safety Data Sheets (MSDSs) [30]
For each hazardous chemical in the lab, the PI must ensure the availability in an easily accessible location of an MSDS which meets the criteria of the applicable OSHA standard (29-CFR 1910.1200 g).Law requires that for incoming shipments, the accompanying MSDS must be retained, not simply a generic version for that particular chemical (see section 10). However, at Stony Brook, the majority of MSDSs are received directly and retained by EHS; their contents are posted on the EHS website. PIs are responsible for training lab workers to retrieve MSDS information from Internet postings including but not limited to the EHS website [31].
If the PI becomes aware of any data or if a report is published suggesting a hazard not indicated on the current MSDS for a particular chemical, the PI must prepare a new MSDS as a replacement within three months, and must discuss the new information with the preparer of the original data sheet.
The minimum content but not the format of the MSDS is specified by the OSHA regulation. For this reason, MSDSs differ in quality, and it is often useful to consult more than one. The ACS website gives information on the federal standard for MSDS content, and suggestions for interpretation.
The Chemical Hygiene Plan is required to provide that signs and symptoms of exposure to hazardous chemicals be communicated to lab workers. The MSDS of a substance is a convenient source of this information.
b. Permissible Exposure Limits (PELs) and Other Recommended Exposure Limits
MSDSs must include known exposure limits, either OSHA PELs or American Conference of Governmental Industrial Hygienists' threshold limit values (ACGIH TLVs). The Merck Index gives LD50 information in some of its entries.OSHA sets PELs to protect workers against the [adverse] health effects of exposure to hazardous substances. PELs are regulatory limits on the amount or concentration of a substance in the air. They may also contain a skin designation. PELs are enforceable . . . PELs are based on an 8-hour time weighted average (TWA) exposure [32]
The OSHA reference gives links that supply PELs for a number of regulated substances.
9.5 - Inventory
Although not mandated by OSHA to be part of the CHP, [33]
an inventory is required by other regulations.[34]
The PI should maintain an inventory of chemicals in his or her lab area. The
inventory will record for each substance the following information: name, manufacturer,
CAS number, specific location, initial quantity, and eventual removal from stock.
A check of which substances remain in stock will be done annually. To facilitate
communication among groups, it is recommended that PIs all use the same Excel
format for inventory.
References:
[30] Useful information about MSDSs is found on the ACS OSHA Hazard Communication Standard website, which is the source for the information in this section,The ACS reference summarizes OSHA Regulations (Standards 29-CFR) Hazard Communication - 1910.1200 g <http://www.osha-slc.gov/OshStd_data/1910_1200.html> accessed October 00.
[31] MSDS Pro <http://www.msds.sunysb.edu> accessed
October 00; or Environmental Health and Safety <http://www.ehs.sunysb.edu/
MSDS> accessed May 02.
[32] OSHA Permissible Exposure Limits <http://www.osha-slc.gov/SLTC/pel/index.html>
accessed July 00.
[33] Living with the Laboratory Standard, p 20. "Although
the Laboratory Standard does not require an entire inventory of your chemical
supply, it does require that you have a MSDS for all hazardous chemicals. This
in itself requires an inventory."
[34] EPA Part 370 Hazardous Chemical Reporting - Community
Right-to-Know <http://www.epa.gov/docs/epacfr40/chapt-I.info/subch-J/40P0370.pdf>
accessed November 00; EPA Part 355.30 Emergency Planning and Notification <http://www.epa.gov/docs/epacfr40/chapt-I.info/subch-J/40P0355.pdf>
accessed November 00; the New York State Department of Environmental Conservation
regulation 6 NYCRR; the New York State Office of Fire Prevention and Control
regulation 9 NYCRR part 1174. This last requires reporting of "any amount"
of explosive, poison gas, poison and irritant, flammable solid, radioactive
material, dangerous-when-wet material, or etiologic material; or five gallons
of flammable liquid within the building.