The Occupational Safety and Health Administration’s (OSHA) Laboratory Standard (29 CFR 1910.1450) applies to laboratory use of hazardous chemicals, which includes use in science laboratory instructional spaces (such as high school, college, and university teaching labs) if they meet the definition of a laboratory under the standard. This definition of laboratory includes the following, according to OSHA:

1.    Labs where chemical manipulations are carried out on a laboratory scale;
2.    Labs where multiple chemical procedures are used;
3.    Labs where protective practices and equipment are commonly available; and
4.    Instructional labs where students handle or are exposed to hazardous chemicals.

The OSHA Lab Standard including the Chemical Hygiene Plan (CHP) is primarily for science labs. It is not meant for shops, studios, or production-like environments where chemical use is secondary to the activity (such as art rooms or Career and Technical Education [CTE] programs in woodworking, welding, and auto tech). Those departments are covered under the OSHA Hazard Communication Standard (29 CFR 1910.1200).

Required training intervals are dictated by the following criteria.

1.    At initial assignment
Before working in any school science laboratory setting where hazardous chemicals are present, science laboratory employees must receive training. This ensures they are informed and prepared to work safely.

2.    Prior to any new assignments involving chemical exposure
If a science teacher plans to begin a new activity or task that introduces unfamiliar chemicals or procedures, they need to contact the Chemical Hygiene Officer to be trained on those specific hazards, resulting health and safety risks, and safety actions to be taken (e.g., Personal Protective Equipment [PPE], engineering controls, etc.) before starting the new assignment. (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450)

3.    Refresher annual retraining 
OSHA interprets “at least annually” to mean once every 12 months, not simply once per calendar year. In other words, retraining must occur within 365 days of the last training. Training must cover the hazards of the chemicals in the laboratory, the contents of the CHP, exposure limits, signs and symptoms of exposure, and the location/availability of reference materials (such as Safety Data Sheets [SDSs]). Ensure that employees understand the hazards they may be exposed to and the protective measures in place. Professional organizations like the NSTA also encourage annual refresher training for science teachers to stay current with safety protocols as better professional safety practice. (https://www.nsta.org/nstas-official-positions/liability-science-educators-laboratory-safety?check_logged_in=1)

CHP-required training helps science laboratory teachers (and their students) to be safer in the following ways.

1.    Awareness. Teachers know what hazardous chemicals they’re working with and the potential hazards/risks along with appropriate safety actions to be taken.

2.    Preparedness. Teachers learn how to respond to spills, exposures, or equipment failures.

3.    Consistency. Everyone follows the same documented procedures for purchase, storage, handling, and disposal.

4.    Confidence. Teachers feel safer leading hands-on teaching/learning activities with students because the teachers know that protective measures are in place.

According to OSHA (29 CFR 1910.1450[f]), the information and training program must cover the following items.

1.    Information
•    The contents of the OSHA Laboratory Standard and its appendices;
•    The location and availability of the CHP;
•    Permissible Exposure Limits (PELs) or other recommended exposure levels;
•    Signs and symptoms of chemical exposure; and
•    Location and availability of reference materials, including SDSs.  
(https://www.ncbi.nlm.nih.gov/books/NBK55875/)

2.    Training on These Topics
•    Methods to detect hazardous chemical presence or release (e.g., odor, visual cues, monitoring);
•    Physical and health hazards associated with chemicals;
•    Protective measures, including proper work practices, emergency procedures, and use of PPE; and
•    The applicable procedures in your workplace's written CHP (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450)

Employers must implement and maintain a written CHP, which must be reviewed and evaluated at least annually and updated as needed when there are new processes, equipment, or chemicals. The CHP must also include employee training provisions and be easily accessible to staff. (https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-Z/section-1910.1450)

Given the complexity of school science laboratories and evolving biological, chemical, and physical safety hazards and resulting health and safety risks, it is necessary to conduct annual refresher training for science laboratory educators. This is actually a legal safety standard and better professional safety practice as supported by OSHA and NSTA. This ensures continued compliance, reinforces safer behaviors, and keeps everyone up-to-date with changes in the CHP or lab procedures.

Submit questions regarding health and safety issues in science/STEM instructional spaces to Ken Roy at safersci@gmail.com. Follow Ken Roy on X: @drroysafersci.