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Academic ExperiencesRaymondL. SchmidtUniversity of New OrleansNew Orleans,Louisiana 70122INTRODUCTION

Colleges and un iversities will have tocon-sider the OSHA stand ards in all areas of thecampus. At a time when there are seriouspressures on many institutions from decliningenrollment and stand-still budgets, the cloudof more federal standards and the investmentof time and effort to insure compliance toOSHA have generated great anxiety, largelypropagated by rumors and fear of thesestandards. There is concern over possihleinappropriate application of vaguely wordedand difficult to interpr et regulations whichmay require the expenditure of exorbitantamounts of money. Of particular interest tochemists is the effect of these stan dards onlaboratory instrudional programs and re-search activities, essential parts of educationin th e physical sciences.

To quantify the level of OSHA-type in-spections which haveoccurred in colleges anduniversities and t o bette r highlight the majorproblem areas, a brief letter survey was con-ducted during the la te spring of 1976. Th einitial survey was mailed to 687 chemistrydepartment chairmen throughout the UnitedStates, including th e 211 PhD gran ting in-stitutions listed in the 1975ACS Directory ofGraduate Research and 476 institutions of-fering only an underg raduate major inchemistry or graduate work at th eM S level.Ninety-two department chairmen re-sponded.About a month after this survey wasmailed, an excellent special report entitled"Chemical La b Safety and t he Imp act ofOSHA," was published by HowardJ. Sandersin Chemical and Engineering News (May 24,1976). The Sanders report provides an ex -cellent supplement to th e information g ath-ered in our studv but does not attemut toqua n~ l f v hr lmrl d O S H A - t ) p e inspecrwns,t h e rcuncmm Impart u i complinnrt, rsr theimplirarmna c a r O SH A r ryu la l :ms theprogram of research and instruction inaca-demic laboratories.

Paper g resented as part of the Symposiumon Chemical Educator , OSHA and Liabilityat the 172nd American Chemical SocietyNational Meeting, August 29-September 3,1976, San Franc isco, California

editedbyMALCOLM M. RENFREW

University of IdahoMOSCOW,daho 83843

with OSHA

LEVEL OF OSHA-TYPEINSPECTIONS

As a first stage of ou r study, we consideredthe level and scope of OSHA-type inspectionswhich have occurred in academic institutionswith the results shown in Table 1. Ph Dgranting departm ents have been more heav-ily investigated, presumably because of theirlarger research activity. Roughly on e in sixdepar tments whose primary mission is u n -dergraduate instruction has been inspectedcontrasting with one out of four PhD-grant-ing institutions. Clearly, OSHA-type in-spections are being made on a number ofcollege campuses.Table 1. Level of OSHA-Type Inspectiom

Total number of institutionsinspected (19/ 92) 20.7%Ph.D. grantingdepartments (12 /47 i 25.5%Undergraduatedepartments 17/45] 15.6%Inspecting OlgonirotionFederal or State-level OS HA 9(invited 3)State DeDartment of Labor 1insurance com pany 2Campus Health and SafetyOffice 4Outride Consulting Fir m 2Visiting Com mittee 1

The level of anxiety among departmentchairmen is indeed very high; only three re-sponses indicated a favorable feeling aboutOSHA. Better than half the institutions haverequested an inspection either directly fromOSHA, or by using outside individuals fa-miliar wkh the standards, as a matter ofself-preservation. Other inspections appearto have been initiated from the outside di-rectly or as a result of some reported problemby an employee or student to the officialOSHA organizational office.

PROBLEM AREAS INACADEMIC LABORATORIES

The major deficienciesare shown in Table2 in the approximate order that a givenproblem was cited. Faulty electrical wiringand missing belt guards are probably themost cited shortcomings, and there is little(Continued on page AI46J

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Safety .. .difference between an industrial-manufac-turing operation and a laboratory in this re-gard. The eost of correcting the commonelectrical faults and belt guards will of coursevary from academic department to depart-ment depending on the level of operation.The per item cost of three-prong plugs forVariaes, pH meters, and other apparatus issmall, but there are usually hundreds of suchitems in any department. T he cost of con-version mounts rapidly, not counting the stafftime required to make the necessary changes.At the California Institute of Technologycorrecting ungrounded electrical equipmentcost %7nn0. .! major worr) ii I l l ? hulk itoragcufflnm-m d A w l w ms in vtwkn.cms and e x w w v e

a m w u t s in th r i n s t r u r t ~ ~ m a lnd re i~nr rhInhcjr.l~urws. c r r l e u chemical ,locknwmiC.NW rluir tu h e 0511.4 standnrds,nnd man"institutions have hegun, or are planning, theconstruction of completely new stockroomfacilities. One chairman, of a campus locatedin a heavily populated downtown area, wrotethe "Chemistry Stores, whieh was previouslyin the Chemis try Building, has had to be re-housed same five miles away, and the totalcost for removing all of the Stores areas(which includes more than purely chemicalstores, but it was the problem of flammabilityof liquids, etc., which dictated this move) wassomewhat in excess of $1 million. This waswithout regard to the fact tha t we now havevery serious delays in obtaining simplechemicals and apparatus in the Chemistry

Table 2. Safety Problemsin Academic Laboratories

I . Improper Electrical WiringA. ungrounded equipment (3 -wirePl"911Overloaded circuits rexcerr ive

unguarded Beit and Pu lley aisemblles.saw blades and Duffer wheels.Improper Storage of Bulk ChemicalsLt c*"ek."n*-. -. "..."",,,

1. Design of shelves. air hsndlinaryst&, fire equibment2. Ungrounded bulk solventdrums6. Laboratolies-Research andInstructional

1. Excessive voiumes of solvents2. Lack of metal safety cans an dmetal cabinets3. Lack of explosion proofrefrigeratorsC. Carcinogenic CompoundsIV . Inadequate Ventilation and ExhaustHood Flow VelocityV. Lack of Eyewash and Safetv ShowelFacilitiesVI. Lerr Major Problem AreasA. waste disposal6. Storage and use of gas cylindersC. Poor houlekeeping practicerD. Inadequate safety rignrE. Inadequate shields for individualexperimentsF. Blockage of escape router betwe enrerearch areas

Department, and the effects are not even yetfully apparent."Almost universal concern was expressedabout the use. handline. and storaee of."hnmrdous materials." esneciallv the sixteen~~ ~ ~ ~ - .~~.~~~* ~ ~presently highly regulated carcinogens (thefamous "14 carcinogens" specified in 1974,plus asbestos fibers and vinyl chloride). In

addition, OSHA and the National Institutefor Occuoational Safetv and Health (NIOSH)are imprbving the stambards on over 400 morecommon hazardous chemicals and periodi-cally issue a "Criteria Document" which de-tails the proposed handling and maximumallowable atmospheric concentration of theseregulated chemicals. The OSHA-NIOSHproject is reportedly scheduled for eomple-tian sometime in lat e 1977.After seeing th eOSHA standards far working with the car-cinogens, academic chemists greatly fearwhat the future holds in the restricted use ofcommon solvents such as benzene, toluene,eyclohexane, and carbon tetrachloride. Dr. J.W. lrvinefrom M.LT. notes tha t "the shadowan the wall is getting darker, and it would nottake a very long list of regulated compoundsto put us out of business." Dr. CharlesKnobler of 1J.C.L.A. indicates tha t "theL herni;try f:rulty feel I here arc iw more than~ n trrsenr fourteen r\ llich can. should, andpronohly utll r,c added 10 th e OSHA l irt i nthe months to come. If th is occurswe expectto experience substantial an d eventually in-surmountable problems in conducting andmaintaining a vigorous and meaningful re-search environment."

based on a successful appeal of a decision tothe Third Circuit U.S. Court of Appeal. Theappealed decision was won not on th e con-tents of the regulations but on the method bywhieh the reeulatians were oromuleated.Standards uu t h r r n n i n < ~ c n iill ctrralnl)reappear inn more leaally bindins f i r r t u i n thenear future.A few institutions have mustered thecourage and financial resources to const ructa special carcinogen handling room completewith independent ventilation systems,shower facilities. and a medical surveillance

projection is $35,000for a single lab plus th eeost of the medical monitoring and recordkeeping. The chairman of one of th e morerespected graduate departments estimates"the cost of soaee to handle such noxious

foot of finished laboratory. 1 know of no leg-islative body that is prepared ta consider sucha floor cast in a legislative appropriation."ECONOMIC IMPACT AND COSTOF OSHA COMPLIANCE

chairmen were not sufficiently aware of theOSHA requirements to venture an order ofmagnitude guess of the costs involved, and toappreciate the meaning of t he term "fullOSHA compliance." Most were, however,very concerned and described the economicimpact on their department or institutionswith phrases ranging from "tremendous,""severe," and "staggering" to "devastating,""castastrophie," and "disastrous". In termsof a dollar value th e numbers range from 10"to 107dollars.There appears to be a correla-tion between thuse inslilutiune which have

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ables affect the estimates such as size of thecampus, age of buildings, and previous cam-pus attitu de and commitment to safety pro-grams. In alimi ted number of cases, relativelyserious objective attempts have been made toarrive at a rough figure for the campus-widecost of OSHA compliance. The averagefigureappears to be in the range of $260 to $500 perenrolled student. For a campus of 10,000students the cost would range between 2.5and 5 million dollars , while for a campus of40,000, th e tota l cost could reach 20 milliondollars. These cost estimates should coverOSHA related problems in all areas of acampus, but probably one third to one half ofthe maney would be required in the scienceand engineeringareas.Using 1974enrollmentfigures nationwide, this calculates t o 2.5-5.0billion dollars tha t public and private highereducation would have to pay to comply withOSHA. These are initial costs to bring insti-tutions up to present standards, and do notinclude the added manpower, record keeping,utility, and personnel services cost, such asproviding annual medical examinations andspecial monitoring examinations for peopleworking in the special carcinogenic labora-tories. Additional staff will be needed tosustain and continually monitor OSHAcompliance and to keep track of the paperwork;a few departments already report staffadditions for these purposes. The initial costand those far maintaining a campus withinOSHA standards must be added onto thealready staggering and steadily increasingcost of higher education.Pubhe institutions must rely on speciallegislative appropriations a nd current oper-ating funds; while private institutions wouldattempt to work through their Boards ofTrustees. The prospects far such specialfunding is not great, but without these addi-tional monies restriction of laboratory coursesand the abolition of research would be theonly way to comply. One instit ution reportsbeing able to make a number of much neededimprovemenb funded mainly from OSHAmoney.AFFECTED AREAS OFRESEARCH

Table 3 summarizes the areas of researchnow governed in some manner by the presentOSHA standards. The experiences thus farwith the 14 carcinogens has precipitated agreat deal of uneasiness about th e future andthe prospects of an even larger list of regu-lated compounds is almost certain. Almostevery area of research would be affected be-cause of the difficulties of obtaining manyTable 3. Affected Areas of Research

I . Ure of regulated carcinogenicCompoundP2. About 80% of organicchem ical researcha. synthesis and/or reactions of novelcompounds of unknown toxicitiesb. Aiky iatin g agentsc. susp ect solvents (CCi,. c,H,, etc.)3. organometallic chemistry4. Organ oberyllium chemistry5. High pressure experiments6. Large vacuum apparatus7. Gel permeation chromatography

8. PhotochemiCBi inveltigationr9. Laser laboratories10 . Biologically hazardous materials11. sciected areas of Diochernicai. Physicaland analytica l research

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Safety . ..chemicals. Synthetic organic research pro-grams would be mast heavily hit. One of th eleading authorities in the area of organaber-vllium chemistrv reoorts that i t is imoossible.rocomply $bith lwr)~llium tandardi that ar eirnpuwl un industry; t h u he has lwrn ftnredtudisrontinur urgunobcryllium r e~ear rh .

OSHA IN THE INSTRUCTIONALLABORATORIESJus t what the OSHA standards mean inthe instructional laborataries of colleges anduniversities is not very clear. A number ofresoondants indicate ereat difficultv inwading, inrerpr~ring,nnd npplyrng thepre5-t standards ro th r instrucrlonnl sl ruo-tam. Thew i, a drlinitr nerd tor rhe academ ~ccommunity to define a good se t of guidelinesand regulations which could pre-empt the

vagueOSHA standards. There is a surprisinglack of published material about the stan-dards and solutions to soecific instructionalproblems from a n OSHA viewpoint.More than one institution, however, has

come under scrutiny for insufficient venti-lation in instructional labs because of studentcom~laints.A number of chairmen reoort

extend and rearrange duct systems with a ne tresult of very little, probably not sufficient,improvement in air flaw. One chairman re-ports "Our new (occupied January, 1973)chemistry building has been inspected forcompliance. The results are tha t the researchlabs can be made to meet OSHA stand ardswith relatively simple modifications to thehoods. Th e instructional labs are somethingelse again. In these, the studen ts work under

timates t hi t it will take 1.7 mi ll ia ~ ollars tolrriny the canopy 11, od% n our insrrurrlunnllab, up to 0Stl.4 srnndmds. and nn oddi-tlr.nai Sltit),UvJpcv J e n r t o pav rhe addrdelectrical costs."All chemistry laboratories get more smellytha n we would like but the best most peoplecan do is make a subiective value iudement,.ns c r whether the vapor ronctntrati

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Safety . ..safety equipment. The legal aspects of labo-ratory supervision causes a great deal ofconcern and many in s t ~~ t0 tSow carry theirawn liability insurance in addition to thatcarried bv the emplovina college or univer-~ .sity.Another pressure is the increasing cost ofmaterials since organic chemical costs haverisen substantially in the past couple of years.These cpsts will skyrocket even faster as thefederal regulations further force manufac-turers to document toxicity hazards. This hasforced a shift to micro amounts of materialsin undergraduate experiments in organicchemistry. The use of small amounts reducesthe storage problems hut increases theteaching difficulties since technique becomesmare important than principles. This putsmore pressure on the instructor to design anddevelop challenging and innovative experi-ments which give a meaningful laboratoryexperience in the careful handling of chemicalcompounds, an increasingly more difficulttask asmore and mare common chemicalsareadded to th e toxic substances list. Severalinstitutions have yielded to such economic,logistic, andlor OSHA pressures by cuttinghack what used to be a full year of freshmanchemistry laboratory to a single semester.This reduces the problems by one half but italso reduces the experience gained by fresh-men by one half.As the pressure of OSHA regulations andrising costs increase in the future, academicchemists will need to sharpen their argu-ments for retaining the laboratmy experienceas par t of the undergraduate scientifictraining program. Many fear that as suchpressures mount, various administrators,~nrtieularlvhose less favorable to the sci-

ternative to laboratory experience is to edu-cate chemists (and others who now heavilypopulate our laboratory courses, such aspremed students, nurses, and medical tech-nologists) by the use of demonstrations andfilms. Graduates will then have a degree butno hands-on experience in areas of special-ization. If students cannot work with chemi-cals in eantralled-supervised instructionallaboratories, of what use is a lot of book- ,learning in their future world of work. In-dustrial employers have for years criticizedacademia for producing job candidates whowere too narrow, too specialized, too theo-retical, and unable to adapt. Without labo-ratory experiences the essence of chemistryand all experimental sciences is lost, andscience becomes an ivory-tower philosophicaltheory rather than a useful, productive dis-cipline for the service of humanity. Theoverkill of safety rules may cause under-graduate instructional laboratory operationsto become so complicated and time.comsuming tha t chemistry will become a philo-sophical science rather than an experimentalscience.

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