(17) Appendix I
Purpose and Scope of the OSHA (29 CFR) Laboratory Standard
The ACS reference, Living with the Laboratory Standard, gives a clear description
of this topic. Selections are given here.
The primary purpose of the OSHA Laboratory Standard, as described in 29-CFR 1910.1450, is to provide a means to protect laboratory workers from exposure to hazardous chemicals. The Standard requires employers to develop a written plan, called a Chemical Hygiene Plan, which details how the facility will control exposures. As a performance-oriented Standard, the administrative and engineering controls utilized by the facility are to be uniquely designed to fit the laboratory's specific circumstances and procedures. In other words, while the Hazard Communication Standard (which exempts laboratories) details the information to be provided to employees about hazards, the Laboratory Standard leaves the design of the program up to the facility's management. While there are specific areas of concern which must be addressed, there is considerably more flexibility allowed the facility than when the Hazard Communication Standard applies. The Laboratory Standard does not supersede or replace other OSHA regulations such as those dealing with fire, electrical, or reporting.
. . .
Much has been made of the term "performance-oriented" with respect to the Laboratory Standard. When OSHA first issued the Hazard Communication Standard to address employees' "right-to-know" regarding the hazardous substances present, the assumption was that employees had little knowledge about chemical hazards. This did not take into account the academic chemistry training and hazard awareness inherent to those who work in the laboratory; as a result, laboratory facilities were exempted. When attempting to apply the same objectives to laboratory workers in a different Standard, however, it was realized that laboratory facilities themselves were too different from each other to regulate uniformly. Thus, the idea of a performance-oriented Standard was developed. Perhaps a better description might be "achievement-based," as OSHA expects laboratories to achieve a level where routine operations are accomplished safely and chemical exposures are minimized, utilizing the special skills and knowledge of the laboratory employee. Still, the structure had to be in place and additional "teeth" had to be put into the Standard to force laboratories to pay more than lip service to the requirements. The OSHA Laboratory Standard became the first Standard to specifically require the Chief Executive Officer of the facility to hold the ultimate responsibility for implementation.
. . .
The basis of the [Chemical Hygiene Plan] is an evaluation of the hazards of the chemicals used in the laboratory. While the Standard provides the basic elements that the plan must cover, how these elements are covered is dependent on the facility's policies and procedures. The employer, however, is required to provide a workplace where laboratory procedures and equipment conform to generally accepted laboratory safety practices, or to be able to show that these are effective in minimizing exposures.