Hazardous Waste Disposal

Ohio University's Hazardous Waste Disposal Policy have a set of responsibilities for the laboratory coordinators and the faculty. The laboratory coordinators responsibility includes properly disposing of all chemical and hazardous waste generated in the laboratory and the stockroom, they also must coordinate with environmental health and safety (EHS) for correct pickup dates and disposal procedures, obtained numbered "Hazardous Waste Labels" that are required for each container, they must inform the facility of the deadline by which all chemical and hazardous waste should be delivered to the appropriate stockroom, and they must consolidate and package all materials in accordance with EHS procedures and also apply appropriate "Hazardous Waste Labels" and oversee the final pickup by EHS. Facility responsibility includes the disposal of chemical MSDS sheets that indicate the chemical is not hazardous and disposing of them in low concentrations down the drain with copious amounts of water, and also they must complete sections 1-5 of the "Chemical Waste Disposal Request" form.

(http://safetyservices.ucdavis.edu/safetynet/guidelines-completing-chemical-waste-label)

Example of a Chemical Waste Disposal Form

The University of California Irvine has developed a hazardous waste management program that provides a cost effective program to assure compliance will all Federal, State, and local programs. The goal of this waste management program is to develop an operational strategy for managing hazardous wastes generated in teaching laboratories, research laboratories, facilities maintenance, construction operations, and all other operations that involved with the university. This shall establish consensus for policies and procedures that are practical and cost effective as well as promoting excellence in environmental stewardship among students, lab employees and other workers, as well as scientists and academic leaders. The program should promote cooperation, understanding, and mutual respect between environmental protection agencies, academic institutions, and science and academic leaders. This is also a means to develop a plan for implementing policies and procedures for managing hazardous wastes.

(https://www3.epa.gov/recyclecity/dropoff.htm)

Hazardous Waste Disposal Illustration

For household hazardous waste disposal, Waste Management states that items that should not be disposed of in the regular disposal of trash should include any automotive products (antifreeze, fluids, motor oil, filters, gasoline, polish, and wax), batteries (home and vehicle), electronics (TVs, computers, cell phones, and more), fluorescent light bulbs, household cleaners (ammonia, drain cleaner, rust remover, tile/shower cleaner, and more), thermometers/thermostats, paint products (oil paints, latex paint, spray paint, wood preservative, and more), garden chemicals (pesticides, herbicides, fertilizers, and more), sharps (needles), and swimming pool chemicals. Home pickup, return by mail recycling kits, and community collection and drop off are all options for household hazardous waste disposal. For any of these materials listed, they should not be regarded as regular household trash, but instead separated and must avoid dumping down the drain. Waste Management offers a program to develop a community hazardous waste program which involves working with the community in organizing a regular drop-off program and retailer take-back events for everyone in the surrounding area to participate and become aware of the dangers of disposing hazardous materials. If improper hazardous waste collection services are done wrong or inappropriately, they have the ability of contaminating ground water supplies and possibly the land the hazardous waste sits on.

Bloodborne Pathogens

According to OSHA, bloodborne pathogens are considered to be infectious microorganisms found in human blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis B (HBV), hepatitis C (HCV), and human immunodeficiency virus (HIV). Any worker who is dealing with needles or other sharp objects have the ability to be exposed to bloodborne pathogens. Workers in the field of first responders, housekeeping personnel, nurses and any other healthcare personnel, are all at risk and could be exposed to bloodborne pathogens.

(http://www.accuform.com/Motivation-product/Safety-Poster-Bloodborne-Pathogens-Universal-Precautions-For-Those-Exposed-To-Blood-Or-Other-Potentially-Infectious-Materials-In-Their-Occupation--PST158)

Bloodborne pathogen explanation

In order to reduce the exposure to bloodborne pathogens, an employer must implement an exposure control plan for the worksite with emphasis on employee protection measures. It also involves engineering controls, work practice controls, personal protective equipment, employee training, medical surveillance, hepatitis B vaccinations, and other provisions that the OSHA Bloodborne Pathogen Standard contains. Engineering controls are especially important for eliminating and minimizing employee exposure and include the use of safer medical devices, such as needleless devices, shield needle devices, and plastic capillary devices. 

Hazard Recognition:

OSHA states that the CDC estimates that 5.6 million workers in the healthcare industry and related occupations are at risk to occupational exposure to bloodborne pathogens. OSHA defines blood as a means of human blood, human blood components, and products made from human blood. Other potentially infectious materials (OPIM) means that the following human body fluid that is visibly contaminated with semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that has been contaminated with blood, and all and any body fluids that cannot be differentiated. Also, any unfixed tissue or organ intact with the skin, and HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV- containing culture medium and other solutions are also considered OPIM's.

Evaluating and Controlling Exposure:

Studies show that about 1/3rd of all sharp injuries occur during disposal. Nurses are particularly at risk because they sustain the most needlestick injuries. The CDC estimates that 62 - 88 percent of sharp injuries can be prevented by simply using safer medical devices. 

(http://www.hpnonline.com/inside/2011-07/1107-IP-Sharps.html)

An example of a sharp safety practice that disposes of needles

Needlestick Safety and Prevention Act:

The Needlestick Safety and Prevention Act was created in 2000 and prescribes safeguards to protect workers against the health hazards caused by bloodborne pathogens. Its requirements address the employers ability to identify, evaluate, and implement safer medical devices such as needleless systems and sharps protection. This Act also has mandated additional requirements for maintaining a sharps injury log for the involvement of non-managerial healthcare workers in identifying, evaluating, and choosing effective engineering and work practice controls. These are workers who are responsible for direct patient care and for those who could potentially be exposed to injuries from contaminated sharps. This Act was implemented into OSHA's Bloodborne Pathogens Standard in 2001. OSHA does not approve or endorse products that could be safer and potentially reduce the risk of obtaining a bloodborne pathogen, it is up to the employer to identify and implement the appropriate, commercial, and effective safer medical device. 

Components of the Chemical Hygiene Plan

According to OSHA, the Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910. 1450) specifies the mandatory requirements of a Chemical Hygiene Plan (CHP) to protect laboratory workers from hard due to hazardous chemicals. The CHP is a written program stating the policies, procedures and responsibilities that protect workers from the health hazards associated with the hazardous chemicals used in that particular workplace. There are certain components that are required to be in the chemical hygiene plan.

The Required CHP Elements:

1. There must be a standard operating procedure that is relevant to safety and health considerations for each activity that is involved with the use of hazardous chemicals. 

2. It must have criteria that the employer will use to determine and implement control measures that can reduce the exposure to hazardous materials with particular attention given to selecting control measures for extremely hazardous materials. Examples of this includes engineering controls, the use of personal protective equipment (PPE), and hygiene practices. 

(http://www.slideshare.net/ohscmcvellore/16planning-to-protect-and-preserve-health-at-work-while-handling-chemicals-in-hospitals-chemical-hygiene-plan-dr-theophilus-s-vijaykumar)

Routes of entry and PPE for a chemical hygiene plan

(http://ehsdailyadvisor.blr.com/2015/11/employees-know-prevent-chemical-exposure/)

Example of worker protection by using PPE

3. There is a requirement to ensure that the fume hoods and other protective equipment are functioning properly and to be able to identify the specific measures that the employer will take to ensure proper and adequate performance of such equipment. 

4. The information that should be provided to the laboratory personnel who is working with the hazardous substances should include the contents of the laboratory standard and its appendices, the location and availability of the employer's CHP, the permissible exposure limits (PELs) for the OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there isn't any applicable OSHA standards, the signs and symptoms associated with exposures to hazardous chemicals used in the laboratory, the location and availability of known reference materials on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including but not limited to the Material Safety Data Sheets received from the chemical supplier. 

5. The circumstances under which a particular laboratory operation, procedure, or activity requires prior approval from the employer or the employer's designee before being implemented. 

6. The designation of personnel responsible for implementing the chemical hygiene plan, including the assignment of a chemical hygiene officer, and if appropriate, establishing a chemical hygiene committee might be implemented.

7. Provisions for additional worker protection for work with particularly hazardous substances. These can include "select carcinogens" reproductive toxins and substances that have a high degree of acute toxicity. Specific consideration must be given to the following provisions and shall be included where the appropriate establishment of a designated area, the use of contaminant devices such as fume hoods or glove boxes, procedures for safe removal of contaminated wastes, and decontamination procedures. 

8. The employer must review and evaluate the effectiveness of the chemical hygiene plan at least annually and update it as necessary. 

Also, worker training for the chemical hygiene plan should include any methods and observations that may be used to detect the presence or release of a hazardous chemical. This includes monitoring conducted by the employer, continuous monitoring devices, visual appearances of any odor of a hazardous chemical that is being released. Also involved in worker training, is the physical and health hazards of of the chemicals in the work area. 

Cryogenics

Cryogenics are materials whose substances must be cooled at an extremely lower temperature to change from a gas state to a liquid state. Some examples of some common cryogenics include liquid nitrogen, helium, hydrogen, argon, methane, and more. They have an extremely low temperature and a relatively high expansion rate when it changes from liquid to gas. Due to these conditions, it makes it extremely difficult and challenging to work with and is comprised of health and safety concerns for those working with cryogenics. Anyone working with this type of material must be fully aware of the hazards that come with it and what precautions to take to remain safe.

Hazards to cryogenics include ultra cold temperatures, flammability, asphyxiation, and high-pressure gas that can result in over-pressurizing of containers.

(http://www.heattreating.com/value-added-services/cryogenics/)

Example of a possible dangerous workplace with cryogenics. 

One significant occupational exposure hazard is burns and frostbites from handling cryogenics. This type of damage is able to occur within a few seconds of contact with any tissue. Spilling cryogenics could result in hypothermia of those who are exposed. Using the appropriate PPE when working with this type of material is extremely important to protect workers from the danger cryogenics can produce. Another hazard risk is its flammability. Cryogenics are associated with fire and explosion hazards and some of these gases include hydrogen, methane, and acetylene. Oxygen has the ability to accelerate these gases and make them even more hazardous when working with cryogenics. There should be no use of ignition source while working with cryogenics and electrical equipment should also be considered. Any combustibles or flammables should stay away from any source of oxygen. Liquefied inert gases and extremely cold surfaces should also be managed in a way that doesn't create the probability of having oxygen condensing from the atmosphere. Any high pressured gas should be eliminated when dealing with cryogenics. This is because cryogenics are usually stored near there boiling points, interacting with the high pressured gas could result in an explosion. Also, when the liquid form evaporates, it creates a build up of high pressure that could be potentially dangerous.  The evaporation rate will depend on numerous variables including the fluid, storage container design, and environmental conditions but most importantly, the container must include the capacity that it is capable of producing when the liquid turns into a gas form. Ensuring pressure relief devices are used properly and maintained/checked regularly to ensure that there is no leaks or damages. These should be test to see the possible back pressure from the cryogenics as well. Due to the large expansion that takes place when the cryogenic liquid transforms into a gas, the displacing of breathable air is able to form. Long periods of breathing pure oxygen can have harmful effects on the body. Because of this natural ventilation should be used and transporting or using containers with cryogenic material in enclosed spaces should be avoided. 

(http://www.ehs.ucsf.edu/cryogenic-liquids)

Effects of cryogenics on a worker's hand. 

Because of the dangers associated with working with cryogenics, minimizing staff exposure potentials are extremely important as well as the implementation of administrative controls, Personal Protective Equipment (PPE), work methods, and engineering controls. 

Spill Control

Risk Management Services states that the purpose of a spill control plan is to ensure that any chemical spills are cleaned up properly and appropriately. There are various steps in a spill control plan that a laboratory personnel should follow and be able to respond to a small laboratory spill without putting themselves in harms way. If there should be any doubt or concern about safety issues, the laboratory personnel should immediately call 911. There should be written safe work procedures in preparation for hazardous operations that are adequately instructed and followed. Accidental spills should be controlled and handled immediately after it happened. It is the responsibility of the supervisor to ensure that the personal protective equipment that is required and/or provided is available when it is needed.

There are different steps that must be noted for different chemical materials such as acids, flammable solvents, caustics, and mercury, but most ideally follow these steps.

(http://aribrokers.com/restoration-safety-handle-chemical-spills/)

Chemical Spill Example

Spill Clean Up Procedure Steps:

1) Immediately notify all personnel and the supervisor of the facility of what was spilled and how hazardous it could be. You must evacuate and post caution signs if necessary. 

2) If any clothing or personal belongings are contaminated, you must immediately remove them and enter the emergency shower. If the eyes have been contaminated, you must immediately wash them in the designated emergency eye wash station for at least 15 minutes. Make sure that the chemical spilled and contaminated is not water reactive.

3)  Obtain the names of the chemicals involved, approximate amount that was spilled, hazards of said chemical, flammability, flash point, vapor pressure, toxicity, and corrosiveness before responding. 

4) Only preform clean-up procedures if the appropriate spill control material, equipment, and personal protective equipment is ready and available, the personnel is familiar with the clean up procedures and equipment, more than one other person in the lab is able to participate, work in teams, and there is no ignition sources present. 

5) After reviewing the MSDS and assessing the hazards from the spill, an established and appropriate clean up is measured and implemented. 

6) Determine the extent of evacuation for how hazard the spill substance and quantity is. 

7) Gather the required equipment and materials required to clean up the spill. 

8) Assemble and put on the appropriate clothing, gloves, eye protection, respirator, or any other required PPE needed when dealing with the specific chemical substance. Make sure the appropriate respirator type and cartridges are used. If SCBA is required, call 911. 

9) Use spill control material to make a container and prevent it from leaking into a drain or container that could further contaminate. 

10) Mix any spill control compound necessary with the spill material and wait for the neutralization/absorption to complete and remove of the material in a spill-proof container. 

(https://www.youtube.com/watch?v=18Kmo-1U1fc)

Demonstration of how to contain and absorb a chemical spill that follows steps 9 & 10

11) Wash the affected area and any personal protective equipment worn with an appropriate chemical cleaning solution to prevent any future contact with the spilt material. 

12) Arrange of a pickup for the spilled substance through ant environmental services facility. 

13) The responsible person of the spill must complete the UBC spill procedures reporting table. 

14) If the spill is reportable, contact any agencies that require notification.

15) Complete any incident or accident forms and send them to any risk management services. 

16) If there is any spill that is greater than one liter that is highly hazardous, highly flammable, highly toxic and corrosive, call 911 immediately. 

Fire Safety

According to Oklahoma State University, fire safety is a vital aspect of laboratory safety. There are a few categories of components related to fire safety that you must consider when preventing fires in the lab.

(http://www.skokiehistory.org/gallery/fdfiresf/FireDeptfires.html)

Image of the Searle Laboratory Fire in Stokie, Illinois of 1977.

Housekeeping:

Areas in the laboratory must be kept clean at all times. Chemicals, especially any liquids, must be refrained from being stored on the floor, except when they are stored in cabinets. Any of these stored items must not be stored in such a way that it blocks fire extinguishers, safety equipment, or any other emergency equipment. The passageways to the emergency equipment must be dry and easily accessed. Any combustibles such as paper, wooden material, etc. must not be stored in the hallway to prevent any acceleration of fire activity and to ensure that the pathway is safe to exit in case of an emergency. All storage containers must be labeled to identify the contents and hazards associated with the materials inside. 

Fire Extinguishers:

Laboratory works must be trained for any fire hazards that might be associated with the work that is conducted. Any employees who work in the laboratory must be trained for the ability to use a fire extinguisher in a case of an emergency. This type of training is required by OSHA under the 29 CFR 1910. 157 (g) component. Fire extinguishers must be presentable and available for the general view and never blocked from access.

(http://blink.ucsd.edu/safety/fire/labs.html#Biosafety-Cabinets)

Biosafety Cabinet ruined by a laboratory fire at UC San Diego.

Electrical:

All electrical equipment must be properly grounded and be U. L listed or F. M. approved. There must also be sufficient room for work in the presence of beaker boxes and all circuit breakers and fuses must be labeled correctly for whether they are in the "on" or "off" position. Every electrical cord must be in good and working condition and extension cords are not to be used as a substitute for permanent wiring. These electrical wirings shall not be suspended about any emergency shower or overhead piping. Electrical cords should not be stored where there will be abuse or deterioration of the wire and our facility. This includes storing electrical wiring in holes within walls, under carpet, under other objects, in direct pathways. There shall be no use of multiple outlets unless it has a direct circuit breaker. Without a circuit breaker, it can cause overheating. Amps should never exceed by 15. All electrical standards must be referenced from the NFPA 70 - NATIONAL ELECTRIC CODE

Ventilation Hoods:

Ventilation hoods should only be used to perform necessary tasks that are clearly stated. The more equipment there is in the hood, the greater the air turbulence is and the greater the chance of gas escaping the laboratory. Exhaust fans should be spark-proof if preforming exhaustion of flammable vapors in the laboratory and if it can be corrosive resistant if there is handling of the flames. 

Other components of fire safety in the laboratory include vacuum operations, explosion-proof refrigerators, flammable-liquid storage cabinets, safety shields, compressed gases, cryogenic liquids, laser fire & explosion hazards, and safety audits, 

According to the University of Tennessee's Environmental Health and Safety Program, fire prevention is considered a vital aspect of laboratory safety and requires knowledge and constant vigilance of lab workers. 

The steps in fire lab safety include; (1) recognizing hazards, (2) evaluate the space in the laboratory before chemical reactions take place, and (3) protecting workers and employees of the laboratory through PPE and emergency equipment. 

There are also 4 classes of fire: class A, B, C, and D. Class A is composed of ordinary combustibles or fibrous material (wood, paper, cloth, rubber, and plastics). Class B is any flammable liquids such as gasoline, kerosene, paint, paint thinners, and propane. Class C is energized electrical equipment (appliances, switches, panel boxes, and power tools). Class D is certain combustible metals, such as magnesium, titanium, potassium, and sodium.  

Identification of Hazards in the Laboratory

According to OSHA, identification of hazards are divided into six elements. These elements include safety, biological, physical, ergonomic, chemical, and work organization hazards.

Safety Hazards:

These are the most common type of hazard presented in the workplace. This includes any unsafe conditions that may result in injury, illness, or death. These hazards include spills on the floor, tripping hazards (blocked isles or cords across the floor), working with heights that includes ladders, scaffolds, roofs, or any raised work area. Unguarded machinery and moving machinery parts are considered a safety hazard as well, especially if a worker accidentally touches guard that are removed. Electrical hazards (frayed cords, missing ground pins, and improper wiring), confined spaces, and machinery-hazards (lockout/tagout, boiler, safety forklifts, etc.) are also safety hazards incorporated. 

 Biological Hazards:

These hazards are associated with working with any animals, people, or infectious plant material. Working in facilities such as schools, day cares, colleges and universities, hospitals, laboratories, emergency response, nursing homes, outdoor occupations, and more have the ability to project biological exposure. Types of biological hazards include blood and other body fluids, fungi/mold, bacteria and viruses, plants, insect bites, and animal and bird droppings. 

(http://www.slideshare.net/ruthlepago/occupational-hazards-27259485)

Examples of biological hazards. 

Physical Hazards:

Physical hazards are considered to be any hazard that include factors from the environment that can harm the body without necessary touching it. These include radiation (ionizing, non-ionizing, EMF's, microwaves, radiowaves, and etc.), high exposure to sunlight/UV rays, hot and cold temperature extremes, and constant and consistent loud noise. 

Ergonomic Hazards:

These types of hazards occur during the type of work being preformed that cause a strain on the body because of the work conditions. These hazards are considered to be the hardest to spot. Short term exposure to ergonomic hazards can create sore muscles, but long term exposure can result in serious illnesses. These hazards include improperly adjusted workspaces and chairs, frequent lifting of materials, poor posture, awkward and repetitive movements, constant repetition, using too much force, and vibration. 

(http://www.gribbins.com/summer-safety-tip-ergonomics/)

Example of an idea ergonomic structure in the workplace. 

Chemical Hazards:

Chemical hazards are present when a worker is exposed to any chemical preparation in the workplace in any form (solid, liquid, or gas). Some chemical hazards are safer than others, but it depends on how sensitive the worker is to the chemical. Even common solutions can cause illness, skin irritation, and breathing problems. Some chemical hazards include liquids (cleaning products, paints, acids, solvents - especially in an unlabeled container), vapors and fumes that come from welding or exposure to solvents, gases such as acetylene, propane, carbon monoxide, and helium, flammable materials such as gasoline solvents and explosive chemicals, and pesticides. 

Work Organization Hazards:

Work organization hazards include hazards or stressors that cause stress (short-term effects) and strain (long-term effects). These hazards are associated with workplace issues such as workload, lack of control, and/or respect. Examples of work organization hazards include workload demands, workplace violence, intensity and/or pace, respect (or lack of), flexibility, control or say about things, social support and relations, and sexual harassment. 

OSHA Laboratory Standards vs. Other OSHA Standards

According to OSHA Laboratory Safety Guidance, over 500,000 workers are employed in laboratories in the United States. The laboratory can be a hazardous environment to work in, especially when employees are exposed to numerous potential hazards including biological, physical, and radioactive hazards. Muscular distresses are also considered hazardous. Laboratory safety has been regulated by OSHA over the years by publishing rules and guidelines which are regulated at the local, state, and federal regulation. These documents are intended for supervisors, principal investigators, and managers who are responsible for maintaining safe, healthy environments for all employees to work in.

Under Section 5(a)(1) of the Occupational Safety and Health Act of 1970, the General Duty Clause, requires that employers "shall furnish to each of his employees employment and a place of employment in which are free from recognized hazards that are causing death or serious physical harm to his employees." This indicates that even if the OSHA standard has not been promulgated that deals with a specific hazard or hazardous operations may be enforceable under the section 5 (a)(1) of the OSH Act. The principle OSHA standards cover the major hazards that workers are most likely to encounter on a daily basis. Employers must be fully award of the OSHA standards and must implement all aspects of standards that apply to specific work conditions in their facilities. Occupational health and safety professionals use a framework called the "hierarchy of controls" to select ways of dealing with workplace hazards. This strategy prioritizes intervention strategies based on the premise that the best way to control a hazard is to systematically remove it from the workplace, rather than relying on workers to reduce their exposure. The hierarchy of controls consists of: engineering controls, administrative controls, work practices, and personal protective equipment (PPE). Most employers use a combination of control methods. They must evaluate their own individual workplace to develop a plan for protecting their workers that may combine both immediate actions as well as longer term solutions.

The purpose of the Chemical Hygiene Plan (CHP) is to provide guidelines for prudent practices and procedures for the use of chemicals in the laboratory. The laboratory standards requires that the CHP sets forth procedures, equipment, PPE, and work practices capable of protecting workers from the health hazards presented by chemicals used in the laboratory. Each CHP must include Standard Operating Procedures (SOPs), Criteria for Exposure Control Measures, Adequacy and Proper Functioning of Fume Hoods, Information and Training, Requirement of Prior Approval of Laboratory, Medical Consultations and Examination, Chemical Hygiene Officer Designation, Particularly and Hazardous Substances.There are twenty-five states and two U.S territories that have their own OSHA-approved occupational safety and health standards, which must be at least "as effective as" the federal standards. The purpose of the laboratory standard is to ensure that workers in non-production laboratories are informed about the hazards of chemicals in their workplace and are protected from chemical exposures exceeding allowable levels The Laboratory standard achieves this protection by establishing safe work practices in laboratories to implement a Chemical Hygiene Plan (CHP).

(http://safety.lovetoknow.com/OSHA_Standard_Precautions)

Applying OSHA Standard Precautions to the workplace.

(http://www.oshacampus.com/blog/health-and-safety-provisions-for-construction/)

OSHA Laboratory Standard Components

OSHA, the Occupational Safety and Health Administration federal agency, is regulated under the Department of Labor in all states and territories. Under the General Duty Clause-29CFR1903.1, OSHA requires that employers must free of organized hazards that are causing, or are likely to cause death or serious physical harm to employees. These employers must comply with occupational safety and health standards promulgated under the Williams-Steiger Occupational Safety and Health Act of 1970. The Emergency Temporary Standards, which is under the Section 6 (c) (1) OSHA Act, OSHA can issue an emergency temporary standard (ETS) if the Secretary determines that "employees are exposed to a grave danger from exposure to substances or agents....; and that such emergency standard is necessary to protect employees from the danger." When OSHA conducts its inspections, there is no advance notice, unprogrammed, imminent danger, fatality or catastrophe, complaint or referrals, and is programmed when it is based on criteria such as an industry with high employee industry rates.

Complaint vs. Referral

According to OSHA regulations, a complaint is referred to as a notice of an alleged hazard given by past or present employee, a representative of the employee, or a concerned citizen. Complaints are considered more formal and must meet the complaint criteria (OSHA7 form). Serious complaints must be inspected within 30 days of filling and non-serious complaints are filed within 120 days. A referral is considered to be a notice of an alleged hazard or violation of the Act given by any source not included above, such as the news media. 

A Typical OSHA Inspection

During a typical OSHA inspection, there is an opening conference, presentation of credentials, there is an employer/employee representative present, a walk-through inspection, sample collection, and a closing conference. OSHA will grant citations if there is imminent danger, criminal/willful danger, other-than-serious, and egregious situations. Fines can range from $7,000 - $500,000 and can include imprisonment for situations with fatalities.

(https://www.grainger.com/content/qt-inspection-practices-policies)

OSHA inspection flow chart

Who is Exempt from OSHA?

Anyone who is self-employed, has a family owned and operated farm, regulations supported by other agencies and/or laws, and Federal/State employees. 

OSHA Information and Training

(http://safex.us/Did-You-Know/Compliance-Updates)

Statistics on workplace fatalities

Employees are required to be informed of hazard communication, which informs of hazards that can be within the laboratory setting, They also frequently trained, they begin and receive this information before working and prior to new exposures, and review periodically for a refresher. Some information items include: OSHA lab standard content, location and availability of CHP, applicable PEL's and other exposure limits, sign and symptoms of exposure, and location of hazard reference materials. Training items include: hazard recognition methods, physical/health hazards in the lab, the use of PPE and hazard control, and content of CHP. 

What's a Chemical Hygiene Plan?

They are standard operating procedures, They are relevant to safety and health of employees and contain specific steps and general rules professionals must follow. They are the employer's criteria for determining and implementing control measures, engineering controls, PPE (Personal Protection Equipment), and safe work and clean hygiene practices. Additional protection is required for particular select carcinogens that are regulated by OSHA and listed by the National Toxicology Program  as "known carcinogen" or "reasonably anticipated to be carcinogen" and known by the the International Agency for Research on Cancer as "carcinogenic to humans" or "reasonably anticipated to be carcinogen." This includes reproductive toxins, mutagens, teratogens, and acutely toxic materials. 

Process Safety Management (PSM)

Process Safety Management (PSM), according to Managing Hazardous Materials – A Definitive Text, is considered when applying management systems to identify, evaluate, and control process-related hazards with the goal of safe operation and maintenance of chemical processes. This applies to specific processes rather than entire facilities. A process is considered to be "any activity involving a highly hazardous chemical, including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities." Any process is subject to PSM standard if it could contain greater than a threshold quantity of a chemical listed in a standard. The PSM program elements include employee participation (availability to review processes and procedures), process safety information (must be revised and reviewed after every change in procedures), process hazard analysis (updated and revised to account for potential hazards associated with the new equipment), operating procedures (mandate steps for operators), operator training (requiring training and verification for new procedures), contractor management (installs new materials), pre-startup safety reviews (shutting down or starting processes), mechanical integrity (routine inspection of equipment), management of change (selecting and installing new nodes of materials or machinery that is effective and cost-friendly), hot work (brazing lines), incident investigation (investigating the portion of the process involved in an incident), emergency response (reviewing the response plan), audits (evaluates the whether the management of change program adequately addresses the changes made in the procedure), and trade secrets (involved in the business-confidential process). Each of these elements are critical in the overall success of Process Safety Management.

(http://www.training.dupont.com/process-safety-management-system)

DuPont's Process Safety Management

The process safety information that must be documented must include chemical information ( hazards, properties, and reactivity/incompatability), process technology (process or blow flow diagrams, process chemistry, and safe operating limits), and process equipment (piping and instrumentation diagrams, materials of construction, and design codes and standards). 

Process Hazard Analysis (PHA) is considered a formal, team-based approach that helps evaluate the risks that are associated with chemical hazards, to identify procedures and equipment where the risks aren't adequately managed, and to make recommendations to correct these issues. Examples of PHA include checklists, what-if analysis, hazard and operability analysis, failure mode and effect analysis, and fault-tree analysis. The first technique mentioned uses a checklist comprised of pre-determined questions relevant to the system. This type of process safety analysis is most applicable to the early design of processes, relatively simple processes, or a process with which the facility or industry has extensive experience or knowledge. What-if analysis is used by team-brainstorming to determine and question the potential process failures the facility or industry might have. Hazard and operability uses guidewords to focus team discussions around specific deviations (high flow, low flow, or high temperature). Failure mode and effect analysis focuses on ways in which individual process components might fail. Fault-tree analysis focuses on top events first, such as an explosion, and then identifies potential combinations of events that could have led to the top event. This process uses AND and OR logic gates when discussing possible modes of events. This event gives the most quantitative analysis of event probabilities.

An OSHA-compliant PHA must be based on thorough process safety information and must be preformed by a multi-disciplinary team. A proper PHA must address the hazards of the process, administrative, and engineering controls, the consequence of failure of these controls, human factors, facility sitting, previous incidents, and the range of effects.

Pre-Startup Safety Reviews (PSSRs) ensure that the new or modified process is constructed to the appropriate design specifications, that the appropriate operating and emergency procedures are put in place, and that employee and contractor training has effectively been completed before the start-up. They also ensure that PHA's have been modified and subject to management-of-change programs and have been conducted on new processed as well.

(http://www.sustainableplant.com/2011/04/the-future-of-process-management/)

Devastation from process safety management issues

The management of change evaluates proposed changes or alterations to processes to identify and address potential health and safety risks. These changes include adding new/different equipment, modifying the design, changing operation parameters, or using different material for construction. A change with grades of stainless steel in the facility or industry could be catastrophic if the chemical and hazards in the area if they are not able to process the chemical and its conditions.