Dealing with regulatory compliance issues regarding chemicals handling and storage is an ever present concern for laboratory professionals. Proper handling of chemicals is essential to safe laboratory operations, and there are numerous regulations that mandate such approaches. These are primarily codified in OSHA's 29 CFR 1910.1450 laboratory standard, which includes stipulations for an effective management system, such as appointing a chemical hygiene officer (CHO) and drawing up a chemical hygiene plan (CHP).
Nevertheless, staying in compliance requires constant attention on the part of laboratory professionals. They confront challenges to bring their operations into compliance with new regulations that come into force. They must also maintain chemical safety awareness among a staff that faces numerous other demands for its attention in laboratory settings with high workforce turnover.
Laboratories are getting accustomed to dealing with new Department of Transportation (DOT) rules developed in the wake of 9/11 and published in September 2003. These required all shippers of DOT-defined hazardous materials to develop and adhere to a written DOT security plan. Numerous chemicals handled routinely in labs are listed under DOT's Hazardous Materials Table (49 CFR Part 172), and such materials that become waste also qualify.
As a result, labs have found themselves regulated under DOT rules in addition to the more familiar federal EPA and OSHA rules and state and local regulations-and need to be ready for unannounced DOT inspections. Most of the rules' requirements were mandatory by December 2003, but the final deadline for completing security awareness training for all staffs that handle hazardous materials, even in companies where quantities are insufficient to require a DOT security plan, passed March 23, 2006.
The plans must cover personnel security, facility security including unauthorized access, and en route security for shipments. Also in the transportation area, new EPA regulations that become effective September 5, 2006, require shippers of hazardous waste to use new standardized EPA manifest forms - the waybills used to track waste shipments - that will replace the existing system where different states have used different forms. Laboratory staff handling hazardous waste shipments will need to get used to the new forms, and make sure the correct labels are used in their labs for waste materials handling and storage.
Key elements of a Security Plan include listing materials and identifying those posing significant risk; reviewing current operations; facility security; personnel security; en route security; and security training.
New regulations continue to come forward governing workplace exposures to hazardous chemicals. OSHA's new standard on workplace exposure to hexavalent chromium (Cr(VI)), first published February 28, 2006, took effect May 30.
OSHA's new standard reduces permissible exposure limits (PEL) tenfold, from 52 micrograms to 5 micrograms of Cr(VI) per cubic meter of air as an 8-hour time-weighted average. The standards will be enforceable from November 27 for establishments with more than 20 employees and from June 2007 for smaller ones. The standard has provisions covering preferred methods to control exposure, including respiratory protection, protective clothing and equipment, medical surveillance, and more stringent standards for training workers who handle these materials.
OSHA identifies Cr(VI) compounds in wide use in pigments, chemical synthesis and metal plating. While the new OSHA rules create new compliance requirements for labs handling Cr(VI) materials, the tighter regulations are likely to generate additional business for analytical laboratories.
Another area with tightening regulations is emissions. Federal and state regulators continue to reduce permissible levels for certain chemicals in air and water emissions, particularly for mercury. Mercury is present in trace quantities in numerous products because of its use as a catalyst or in processes, and so it represents a compliance issue for labs over discharge levels. In Massachusetts, for example, the permissible level for mercury in waste streams is now that of non-detection.
Research labs located in universities stand to get some relief, however, from draft proposed rules released May 23, 2006 by EPA that propose a more flexible approach to handling waste streams. The new rules would give universities discretion in determining the most appropriate and effective methods of compliance in handling waste.
Laboratory professionals more broadly are getting regulatory relief from an underlying trend in the laboratory industry-the move toward more sophisticated analytical equipment, which is gradually displacing wet bench chemistry. Such equipment consumes smaller volumes of chemicals and generates less waste to be disposed of. This trend enables some large quantity hazardous waste generators in the lab sector to become small quantity generators, who have less onerous regulations to deal with. Using reduced volumes of flammable solvents such as toluene and xylene also makes meeting fire codes easier for research facilities. Overall, "reducing chemical waste in labs is very positive from an environmental and occupational health perspective
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