New Standards How they Affect Testing Protocols in ...The order of the Law ... protective equipment...
Transcript of New Standards How they Affect Testing Protocols in ...The order of the Law ... protective equipment...
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New Standards – How they
Affect Testing Protocols in
Laboratory Testing
2013
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The order of the Law
There is a legal pecking order that dictates what Codes and
Standards should be use for worker protection.
#1 LAWS
A OSHA FEDERAL
B OSHA STATE
C EPA FEDERAL
D EPA STATE
E NRC FEDERAL
F ADA FEDERAL
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The order of the Law Continued
#2 CODES
A NFPA (FIRE)
B BUILDING (IBC, BOCA, UBC, ETC.)
C ASME, JIC, NEC, ETC.
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The order of the Law Continued
#3 ANSI NATIONAL CONFORMANCE STANDARDS
A NSI/ASHRAE 110 FUME HOOD PEFORMANCE
B ANSI/ AIHA Z9.5
C ANSI/ASHRAE III 1988 TESTING AND BALANCING
D ANSI/ASHRAE 62 - SUPPLY AIR QUALITY
E ACGIH- INDUSTRIAL VENTILATION HANDBOOK
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The order of the Law Continued
#4 STANDARDS, GUIDELINES, AND RECOMMENDED
PRACTICES
A. SEFA -1 (FUME HOOD TRADE ORGANIZATION)
B. PRUDENT PRACTICES IN LABORATORIES
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OVERVIEW
Many regulatory changes have been brought
into the laboratory environment
The basis for the OSHA 29 CFR Part 1910 is to
encourage joint labor management efforts to
reduce injuries and diseases arising out of
employment in laboratory environment as well
as developing innovative methods, techniques,
and approaches for dealing with occupational
safety and health problems.
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What types of hazardous chemicals
are present in laboratories?
Hazardous chemicals present physical or health
threats to workers in clinical, industrial, and academic
laboratories.
They include carcinogens, toxins, irritants, corrosives,
sensitizers, hepatotoxins, nephrotoxins, neurotoxins
as well as agents that act on the hematopoietic
systems or damage the lungs, skin, eyes, or mucous
membranes.
OSHA currently has rules that limit exposures to
approximately 400 substances.
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The New Standard
The new OSHA standard differs from many
OSHA health standards in that it does not
establish new exposure limits but sets
other performance provisions designed to
protect laboratory workers from potential
hazards in their work environment.
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OSHA Standard
Permits a greater degree of
flexibility in laboratories for
developing and implementing
employee safety and health
programs.
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Expected Benefits
• Increased worker awareness of
potential risks
• Improved work practices • Existing PPE
• Engineering controls
• fume hoods
• vacuum systems
• glove boxes
which limit chemical exposure and are
considered conventional technology that
can be found in nearly all laboratories.
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“Laboratory use”?
Performing chemical procedures using small
quantities of hazardous chemicals on a
laboratory scale and not as part of a
production process in an environment where
protective laboratory practices and
equipment are in common use.
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ANSI Z9.5 – 2012
Function of a
Laboratory?
Laboratories conduct teaching, research,
quality control, and related activities and
should satisfy several general objectives, in
addition to being suited for the intended use
they should be:
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ANSI Z9.5 – 2012
• Energy efficient without sacrificing safety,
compliance, or space condition requirements
• Safe places to work, comply with environmental,
health, and safety regulations, and
• Meet any necessary criteria for the occupants and
technology involved in terms of control of
temperature, humidity, and air quality.
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Employers are required to have a
chemical hygiene plan
If your laboratory employees use hazardous
chemicals, you must develop and implement a
written chemical hygiene plan to protect them. In
addition to appropriate safety and health
procedures and hygiene practices for hazardous
chemicals in laboratories, the plan must
include the following:
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Chemical Hygiene Plan
• Criteria for reducing employee exposure to hazardous
chemicals;
• Use of personal protective equipment;
• Requirements that ensure fume hoods and other
protective equipment are functioning properly;
(ASHRAE – 110)
• Provisions for employee training;
• Circumstances requiring employer approval of certain
laboratory operations, procedures, or activities before
implementation;
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Laboratory Ventilation Management Plan
(LVMP)
Management shall establish a Laboratory
Ventilation Management Plan (LVMP) to
ensure proper selection, operation, use,
and maintenance of laboratory ventilation
equipment.
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ANSI Z9.5 – 2012
LVMP
Ensure proper operation of the lab ventilation
systems, help protect laboratory personnel
working with potentially hazardous airborne
materials, provide satisfactory environmental
air quality and maintain efficient operation of
the laboratory ventilation systems.
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ANSI Z9.5 – 2012
LVMP
Provides the framework for
keeping the systems operating to
satisfy the primary functional
requirements of building
personnel.
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How does this affect NEBB?
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The US Congress has put some teeth into the regulations
– providing for a monitoring process to ensure the health
of the workers through continuous monitoring.
The employer is required to measure an 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).
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How must employers monitor
employee exposures?
Monitoring used to be terminated when
employee exposures were below the action
level but now the burden of proof lies with
the employer that all devices have been
properly tested and commissioned with
periodic verification of performance.
Monitoring and healthcare can continue
for an employee’s entire life.
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Exposure Control Devices
There are numerous exposure control
devices including:
• Laboratory Fume Hoods
• Biological Safety Cabinets (BSC)
• Glove boxes
• Local exhaust hoods, and other ventilated
enclosures
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Exposure Control Devices
There are numerous exposure control
devices including:
• Laboratory Fume Hoods
• Biological Safety Cabinets (BSC)
• Glove boxes
• Local exhaust hoods, and other ventilated
enclosures
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OSHA
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OSHA requires that, employers are responsible
for ensuring that exposure control devices are
functioning properly and implementing feasible
control measures to reduce employee
exposures if the exposures exceed the PELs.
The problem is:
OSHA does not promulgate specific control
device testing protocols.
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OSHA
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But, if an employer discovers through their
hazard assessment efforts or employee
feedback, that exposure control devices
are not effectively reducing employee
exposures, it is the employer's
responsibility to adjust controls or replace
engineering controls as necessary.
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Performance Evaluation
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The performance of an exposure control
device is ultimately determined by its
ability to control exposure to within
applicable standards or other safe limits.
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Who evaluates the performance?
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The LVMP should provide guidelines and
specifications for implementation and
proper operations of the complete
laboratory environment.
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Beginning of the LVMP
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• Commissioning to verify proper performance prior
to occupancy and use of the laboratory hoods
• Training programs for ensuring proper use,
testing and maintenance of the laboratory hoods
• Design of laboratory ventilation systems
• Maintenance procedures for providing and
documenting reliable operation
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LVMP
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• Periodic confirmation that the ventilation system
is used properly
• Proper selection of appropriate laboratory hoods
• Specification of monitors to continuously verify
proper operation of the laboratory hoods, and standard
procedures for routine testing..
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NEBB’s Involvement
NEBB through it’s various disciplines can provide the
expertise to the Laboratory Owners, Managers,
Engineers, etc. for the development and required
confirmation of a Laboratory Ventilation Management
Plan (LVMP) to meet the continuously changing research
environment.
Guidance by the knowledgeable Certified Professionals
in the diverse yet integrated NEBB programs will provide
a safer environment while enhancing the reputation and
integrity of the organization.
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Training
Enhancement of the training opportunities in all the
disciplines to meet the requirements in the Laboratory
environment.
Provide increased awareness to the biological and
chemical dangers associated with the research industry.
Verify that all disciplines have a safety plan and follow it!
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Meeting the Need!
Educating our clients
– What do they need for a viable LVMP
• Development of the plan
– How to start
• Implementation of the proper testing
– Follow through
• Continuous monitoring
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Consequences
Under the laboratory standard, routine exposure
above an action level will require the same exposure
monitoring and medical surveillance provisions as in
the relevant substance specific standard.
In plain old English – there is a liability to monitor
and provide necessary medical and financial
assistance until?
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What does it all mean?
The OSHA standard added the term hazardous chemical
to further clarify the fact that the laboratory employer must
offer protection to all laboratory workers in all situations.
It also defines employees not as not just laboratory
workers but also personnel that through their course of
employment are required to enter the lab where potential
exposures may occur; such as maintenance, custodial, or
contractors. Even personnel with advanced degrees;
e.g., chemists and researchers may not possess the
proper training in safety aspects associated with chemical
exposures.
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Monitoring or testing?
The changes in OSHA Laboratory Standard affects other
regulations and standards; such as AIHA/ANSI Z9.5 -
2012 which in turn has adopted these changes as well as
US Congress input.
Without proper determination of performance of
exposure control devices and continued monitoring
to ensure proper and adequate performance, all
parties are exposing themselves to greater liability
not just to an exposed worker but everyone in that
environment.
The liability for health care monitoring is not assigned to
just the owner/employer but can include all parties from
manufacturer, installer, TAB contractor, etc.
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NEBB’s Involvement
While this is only one area of involvement for
NEBB, the continued research and
development as well as healthcare industries
are growing rapidly requiring the expertise
available from our Certified Professionals.
Besides providing a safer environment, we
are able to promote the competency of our
organization and provide a viable opportunity
for the NEBB firms and CP’s.
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Questions or
comments?
36 Copyright © 2013 NEBB. All rights reserved.