The Laboratory Safety Standard at 25: Implementation of the Standard through the Chemical Hygiene Plan and the Chemical Hygiene Officer – Is it trickling down?

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The Occupational Exposure to Hazardous Chemicals in Laboratories Standard requires that the employer designate a Chemical Hygiene Officer, have a Chemical Hygiene Plan, and actively verify that it remains effective. 29 CFR1910.1450 defines the Chemical Hygiene Plan (CHP) as a written program developed and implemented by the employer which sets forth procedures, equipment, personal protective equipment and work practices that protect employees from health hazards presented by hazardous chemicals used in that work place. The CHP must include provisions for worker training, chemical exposure monitoring where appropriate, medical consultation when exposure occurs, criteria for the use of personal protective equipment (PPE) and engineering controls, special precautions for particularly hazardous substances, and a requirement for a Chemical Hygiene Officer (CHO) responsible for implementation of the CHP. The CHP must be tailored to reflect specific chemical hazards present in the institution laboratory. Laboratory personnel must receive training regarding the Laboratory standard, the CHP, and other laboratory safety practices, including exposure detection, physical and health hazards associated with chemicals, and protective measures. All of these elements of laboratory safety practice are critical for maintaining a safe laboratory workplace. However, relevant to the effectiveness of the laboratory standard are the questions as to how important, how relevant and how usable is the typical Chemical Hygiene Plan? Are Chemical Hygiene Plans currently used and managed in the manner conceived by OSHA when the standard was issued? How do leading institutions use them today and how could they be improved? We present results of a survey of institutional academic and industrial laboratory EHS professionals accessed through the Division of Chemical Health and Safety (DCHAS). We also present the results of a survey about PPE use at a research institution as a test of how to implement lab safety programs on the ground with engaged lab personnel, rather than issuing toothless policies. The survey was carried out among laboratory personnel at a research institution. The surveys are anonymous but the results but include responses from safety personnel in industry and academic research institutions and from researchers in medical research laboratories and employees in clinical laboratories.