By Kenneth Roy
Posted on 2019-06-25
The OSHA Laboratory Standard 29 CFR 1910.1450 details specific recommendations when labeling and storing hazardous chemicals within school laboratories.
First of all, the laboratory standard [(1910.1450(h)(1)(i)] requires that labels on incoming containers not be removed or defaced. Incoming container refers to the original receptacle that holds hazardous chemicals that were purchased and shipped to the lab. But there is not a specific labeling requirement for secondary containers of hazardous chemicals in a laboratory. Secondary containers are used to transfer hazardous chemicals from their original containers. The OSHA lab standard does not require labeling because the contents are only to be temporarily stored in secondary container. Once in the lab, labeling now falls under the OSHA Lab Standard if transferred to secondary container as noted below with reference to Appendix A.
Secondly, the laboratory standard [CFR 1910.1450(b)] allows laboratories flexibility in tailoring their written Chemical Hygiene Plan (CHP) and standard operating procedures to protect employees in laboratories. For example, labels on incoming containers must follow strict labeling requirements for hazardous chemicals under OSHA HazCom standard. Once in academic lab and transferred to secondary container, the lab has flexibility on what is to be required for labeling. This would be noted in the employer’s CHP, and Appendix A provides additional guidance. In addition, 1910.1450(f)(4) requires the employer to train employees regarding the physical and health hazards of chemicals in the work area, the measures employees can take to protect themselves from these hazards, and the employer’s CHP.
In academic science labs covered under the OSHA laboratory standard, chemicals in secondary containers, such as beakers and flasks, require some sort of identification (e.g., chemical name, concentration, date prepared, and hazard information). This helps lab employees protect themselves from chemical and health hazards. The CHP along with employee training will determine the hazards of the chemicals in the secondary containers. Moreover, OSHA encourages employers to consult Appendix A of the laboratory standard, which contains numerous recommendations for labeling chemicals in laboratories. The following recommendations from Appendix A describe examples of proper chemical and waste storage for academic labs.
• Chemicals should be separated and stored according to hazard category and compatibility.
• Follow the safety data sheets (SDS) and label information for storage requirements.
• Maintain existing labels on incoming containers of chemicals and other materials.
• Labels on containers used for storing hazardous chemicals must include the chemical identification and appropriate hazard warnings.
• The contents of all other chemical containers and transfer vessels, including beakers, flasks, reaction vessels, and process equipment, should be properly identified.
Collection and storage of waste
• Chemical waste should be accumulated at or near the point of generation, under the control of laboratory workers.
• Each waste type should be stored in a compatible container pending transfer or disposal. Waste containers should be clearly labeled and sealed when not in use.
• Incompatible waste types should be kept separate to ensure that heat generation, gas evolution, or another reaction does not occur.
• Waste containers should be stored in a designated location that does not interfere with normal laboratory operations. Ventilated storage and secondary containment may be appropriate for certain types of waste.
• Waste containers should be clearly labeled and sealed when not in use. Labels should include the accumulation start date and hazard warnings as appropriate.
For additional information, read the OSHA letter of interpretation regarding laboratory standard requirements.
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