Is Your Laboratory Compliant with OSHA and NFPA Requirements?

On November 25, 2018, the National Fire Protection Agency (NFPA) issued an updated version of NFPA 45 – Standard on Fire Protection for Laboratories Using Chemicals. NFPA 45 includes information regarding fire protection requirements for laboratories, laboratory design, vent hood use, and safe quantities of flammable materials allowed to be stored and used in the laboratories. The 2019 edition of the standard includes minor changes from the previous 2015 version. Inspection, testing, and maintenance of fire-extinguishing systems in ductwork and chemical fume hoods has been revised from a specific time interval to a schedule that is deemed suitable for the type of system. Also, a minimum inspection frequency of 1 year has been added for chemical storage. The revision of the standard includes references to NFPA 30 – Flammable and Combustible Liquids Code for quantities of flammable and combustible liquids within liquid storage areas that are indoors.

With the release of the updated standard, now is a good time to ensure that your laboratories are compliant with all requirements. While NFPA does not have any power to ensure compliance with their standards, the Occupational Safety and Health Administration (OSHA) often cites NFPA standards when conducting inspections as consensus standards, like NFPA 45, are required to be followed and fall under the prevue of OSHA inspectors. Along with the requirements found in NFPA 45, you should ensure that your laboratories are also compliant with applicable OSHA regulations as well. All containers of hazardous chemicals should be properly labeled, and associated Safety Data Sheets (SDS’s) should be maintained for all chemicals, as required by OSHA’s hazard communication regulation (29 CFR 1910.1200). A Chemical Hygiene Plan (CHP) should also be maintained to protect laboratory workers from harm due to improper handling of hazardous chemicals, as required by OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450). Your CHP should include standard operating procedures that are relevant to safety and health considerations for each activity involving the use of hazardous chemicals. The plan should identify control measures used to reduce exposure to hazardous materials, such as engineering controls, use of PPE, and administrative controls. The plan should include permissible exposure limits (PEL’s) for OSHA-regulated substances, and should identify where SDS’s are made available to laboratory employees. Along with maintaining a CHP, you should ensure that your laboratory employees are trained in methods and observations to detect the presence or release of a hazardous chemical. Training should also identify the physical and health hazards associated with chemicals used in the laboratories, and measures that workers can use to protect themselves from these hazards.

If you need assistance with ensuring that your laboratories are compliant with NFPA and OSHA requirements, please contact CTI at (770) 263-6330.

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