Lab Safety What School Administrators Need to Know

In 1990, Federal OSHA’s “Occupational Exposure to Hazardous Chemicals in Laboratories” came into effect. The “Laboratory Standard” (29 CFR 1910.1450) comprehensive Lab Safety standard outlines the responsibilities of employers, particularly educational institutions and school districts, in assessing potential laboratory safety hazards resulting in health and safety risks and the creation of a customized “chemical hygiene plans” to address appropriate safety actions for safer employee workspaces.  A pivotal component of the Lab Safety Standard (29 CFR 1910.1450) is the requirement for a designated chemical hygiene officer responsible for assisting in the development and execution of the chemical hygiene plan.

Based on legal safety standards and OSHA’s guidelines, a chemical hygiene plan is the cornerstone of school districts’ laboratory safety practices. 

As the administrator/supervisor on-site representing the employer, you are responsible for this regulation and its components regardless of your experience, understanding, or awareness of this legal safety standard. 

For those that don’t know: Compliance with OSHA’s Laboratory or Lab Safety Standard is essential and a legal requirement for those employers under OSHA jurisdiction.

Laboratories have a legal mandate to have a chemical hygiene plan that addresses all aspects of hazardous chemical handling, from procurement and labeling to usage, storage, and disposal; as a component of lab safety. Proper lab safety training and information dissemination for laboratory employees is integral to an effective chemical hygiene plan, ensuring adherence to OSHA’s Hazard Communication Standard. It should be noted that federal, state and OSHA equivalent lab safety standards apply based on the type of school (Public, private, charter, independent) and jurisdiction. The takeaway is that there are legal safety standards and accepted better professional safety practices that apply involving the Laboratory Standard’s for lab safety requirements in ALL schools nationally.

Who’s Covered Under OSHA Laboratory Safety Guidance 

It is also important to note that OSHA primarily covers employees, not students, within the work site. Nevertheless, strict adherence to the chemical hygiene plan and approved standard operating plans is vital to maintain a safer environment for science teachers and all instructional space (laboratory) occupants, including students. An adherence to safeguards for administrators/supervisors and teachers as employees prevent or reduces potential risks resulting from possible liability.

Furthermore, other OSHA standards, official interpretations of these standards, and national consensus standards may also apply to high school science instructional spaces (e.g., laboratories and classrooms) and related spaces (preparation rooms and storerooms). Additional standards include General Duty Clause, Occupational Noise Exposure Standard, Personal Protective Equipment Standards, and other regulations. Many of the aforementioned standards can be found on OSHA’s website, providing further guidance for ensuring safety within science instructional spaces. 

A listing of relevant safety standards and regulations that should exist inside each school science department are below.  Remember that you are legally responsible and accountable for these aspects of safety in the science department as the building administrator and supervisor of the school.

Pertinent OSHA-Related Standards for Lab Safety:

1. Section 5. (a)(1) of the OSH Act, commonly called the General Duty Clause, mandates employers to provide employees with a workplace and employment devoid of recognized hazards that could lead to death or serious physical harm.
2. Section 5. (a)(2) necessitates employers to adhere to occupational safety and health standards established under this Act.
3. Occupational Noise Exposure Standard (29 CFR 1910.95) focuses on acceptable sound/noise levels within work environments.
4. Personal Protective Equipment Standards (29 CFR 1910.132) pertain to protective gear for the body, including safety goggles, safety glasses, aprons, and gloves.
5. Respiratory Protection Standard (29 CFR 1910.134) pertains to protective devices designed to shield occupants from respiratory-related exposures.
6. Lockout/Tagout Standard (29 CFR 1910.147 and 1910.333) addresses the control of hazardous and uncontrolled energy sources, encompassing gas, water, electrical, and mechanical systems.
7. Toxic and Hazardous Substances, 29 CFR 1910 Subpart Z: a. 1910.1000, Air Contaminants b. Table Z-1, Limits for Air Contaminants
8. Hazard Communication Standard (29 CFR 1910.1200) focuses on managing potentially hazardous chemicals in the workplace.
9. Bloodborne Pathogen Standard (29 CFR 1910.1030) addresses blood-related pathogens such as HIV and HbV.
10. Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) provides guidelines for the safer use of chemicals in laboratory settings.

• Appendix A: Recommendations from the National Research Council regarding chemical hygiene in laboratories (Non-mandatory)
• Appendix B: References (Non-mandatory)

Interpretations of Legal Safety Standards:

Standard interpretations are official responses to inquiries about OSHA safety standards. Many of these interpretations pertain to laboratory standards and can be accessed on OSHA’s official website.

National Consensus:

National consensus practices are not OSHA regulations or standards but represent better professional safety practices, offering guidance from originating organizations, e.g., NFPA, EPA, ANSI/ISEA, NSTA, etc. OSHA compliance officers often reference these practices when addressing safety concerns.

Key Professional Organizations and Their Enforceable Lab Safety Standards:

• American National Standards Institute (ANSI): ISEA International Safety Equipment Association
  • Standard Z358.1-2014 encompasses provisions for designing, performing, installing, using, and maintaining various emergency equipment, including showers, eyewashes, and drench hoses. General considerations also apply to emergency equipment.
  • Eye and Face protection (ANSI/ISEA Z87.1-2020), the American National Standard for Occupational and Educational Personal Eye and Face Protection Devices, is the latest edition of the standard for eye and face protection. – Safety glasses with side shields are to be used when dealing with solids (e.g., projectiles and glassware).  – Indirectly vented chemical splash goggles are to be used when dealing with hazardous liquids (e.g., acids, bases, alcohols).  *Approved certified chemical splash goggles can also be used in lieu of safety glasses with solids.
• Foot Protection (ANSI Z41.1-1991 and Z41.1-1999) The American National Standards Institute’s Z41 Committee on Personal Protection-Protective Footwear has merged into ASTM International’s Committee F13. With this merger, F13 oversees the redrafting of ANSI Z41 performance requirements and test method standards for safety footwear.
• Hand Protection (ANSI/ISEA 105-2016) The American National Standard for Hand Protection rates gloves and other cut protective clothing on a consistent numeric rating scheme for mechanical, thermal, chemical, dexterity, and other performance criteria. Therefore, the availability of appropriate gloves of various sizes should be made based on the chemicals encountered (vinyl, nitrile, heat-resistant, etc.).
• American National Standards Institute (ANSI) / American Industrial Hygiene Association (AIHA):
  • Standard Z9.5-2003, Laboratory Ventilation, serves employers, architects, occupational and environmental health and safety professionals, and others concerned with airborne contaminant control. It covers performance tests, air cleaning, preventative maintenance, and work practices. The standard highlights requirements and good laboratory practices, along with references and guidance on selecting ventilation designs.
• American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE):
  • Standard 110-1995 outlines a quantitative test procedure for evaluating laboratory fume hood performance. It involves releasing tracer gas at specified rates and positions, then monitoring exposure in the breathing zone. A performance rating is based on tracer gas release and average exposure.
• International Code Council (ICC):
  • The 2003 International Codes include standards relevant to laboratories, particularly the International Fire Code. This code addresses fire department access, fire safety systems, hazardous materials storage, and fire-safety requirements for new and existing buildings.
• National Fire Protection Association (NFPA):
  • NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, is applicable to laboratories handling or storing hazardous chemicals.
  • NFPA 101, Life Safety Code is applicable for many aspects in the science department including occupancy loads, fire extinguishers, fire safety equipment among others.

References

• International Code Council (ICC). 2012. IBC: 1004.1.1 Areas without fixed seating: Table 1004.1.1 Maximum Floor Area Allowances Per Occupant.
• Motz, L. L., J. T. Biehle, and S. S. West. 2007. NSTA guide to planning school science facilities, Second Edition. Arlington, VA: NSTA Press.
• National Fire Protection Association (NFPA). 2015. Section 7.3.1.2 Occupant Load, Life Safety Code 101– 75.
• National Research Council (NRC). 2012. A framework for K–12 science education: Practices, crosscutting concepts, and core ideas. Washington, DC: The National Academies Press.
• National Science Teachers Association (NSTA) Safety Advisory Board. 2013. Safety in the Science Classroom, Laboratory, or Field Sites.
• National Science Teachers Association (NSTA) Safety Advisory Board. 2014a. NSTA-Duty or Standard of Care.
• National Science Teachers Association (NSTA) Safety Advisory Board. 2014b. Overcrowding in the Instructional Space.
• National Science Teachers Association (NSTA). 2007a. NSTA Position Statement: Liability of Science Educators for Laboratory Safety.
• National Science Teachers Association (NSTA). 2014a. Duty of Care.
• National Science Teachers Association (NSTA). 2014b. Overcrowding in the Instructional Space.
• National Science Teachers Association (NSTA). 2015a. NSTA Position Statement: Safety and School Science Instruction.
• National Science Teachers Association (NSTA). 2015b. Managing Your Chemical Inventory; Parts 1, 2, and 3.
• NGSS Lead States. 2013. Next Generation Science Standards: For states, by states. Washington, DC: National Academies Press.
• Occupational Safety & Health Administration (OSHA). 1987. 29 CFR 1910.1200 Hazard Communication Standard (Right to Know Law).
• Occupational Safety and Health Administration (OSHA). 1990. 29 CFR 1910.1450. The Laboratory Standard, Part Q (Chemical Hygiene Law).
• Roy, K. 2006. Proactive safety. Science Scope 30 (1): 72, 74.
• West, S. and L. Kennedy. 2014. Science Safety in Secondary Texas Schools: A Longitudinal Study.
• West, S., and L. Kennedy. 2014. Safety in Texas Secondary Science Classrooms. Texas Academy of Science (58).
• Connecticut-High-School-Science-Safety/OSHA-Laboratory-Standard