OSHA Lab Standard vs. Other OSHA Standards

The main purpose of the OSHA Laboratory Safety is to supersede and build upon already existing OSHA standards. The primary being the General Duty Clause, which requires an employer to provide it’s workers with a safe work environment free from recognized hazards that are likely to cause injury or death. It also requires employees to comply with occupational safety and health standards and all rules issued that are applicable to their own actions and conduct. The OSHA Lab Standard also covers many other OSHA regulations that covered Hazardous Substances, Protection of Other Personnel In Laboratories, Hazard Communication, Resource Conservation and Recovery, and Definition of a Generator under RCRA.

Regarding “particularly hazardous substances’, you are talking about substances including select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity. In order for a chemical to be classified as a carcinogen, it needs to meet of the following criterion; 1) regulated by OSHA as a carcinogen, 2) listed as ‘known to be a carcinogen’ in the Annual Report on Carcinogens published by the National Toxicology Program or NTP, 3) listed under Group 1 or ‘carcinogenic to humans’ by the International Agency for Research on Cancer, or finally 4) listed in either Group 2A or 2B by IARC or under he category ‘reasonably anticipated to be carcinogens’ by NTP in some cases.

A reproductive toxin is defined as chemicals that affect reproductive capabilities, including chromosomal damage or mutations and effects on fetuses. Chemicals with a high degree of toxicity also require special provisions for worker health. ‘Select carcinogens’, although are specifically identified through reference to other publications, ‘reproductive toxins’ and chemicals with a ‘high degree of acute toxicity’ are not specified further, which has made it more difficult to apply these categories. Some institutions have chosen to adopt the OSHA Hazard Communication Standard definition of ‘highly toxic’, or an LD₅₀ < 50 mg/kg oral dose as a workable definition of  ‘high degree of acute toxicity’. There is little to no agreement on how to determine reproductive toxins.

When handling or working with carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity, consider the use of designated areas, containment devices, special handling of contaminated waste, and decontamination procedures. The OSHA requirement is for evaluation, assessment, and implementation of these special controls when appropriate.

The Resource Conservation and Recovery Act, or RCRA. RCRA was enacted by congress in 1976to address the problem of waste disposal and reduction. Subtitle C of RCRA established a system for controlling hazardous waste from generation to disposal. This is referred to as the ‘cradle to grave’ system. The cradle, however, is the point at which the hazardous material first becomes a ‘hazardous waste’, not when it is first received a laboratory. Under RCRA, the Environmental Protection Agency is given great responsibility in promulgating detailed regulations governing the generation, transport, treatment, storage, and disposal of hazardous waste. RCRA and EPA regulations were written with a focus on industrial-scale generation of hazardous waste, but, with very limited exceptions, they also apply to laboratories that use chemicals.