While 29 CFR 1910.1450, Occupational exposure to hazardous chemicals in laboratories may not apply to your facility, it contains invaluable lessons in chemical hygiene. Chemical hygiene, by definition, addresses specific hazards that come from working with chemicals, and delves into topics such as how to protect workers from harm, limit occupational exposure, set down a list of requirements for use, and how to inform employees of rights and obligations. To this end, the general scope and application of 1910.1450 presents a practical, thorough, and intensive criteria which could be followed by any health and safety department.
The Standard sets an outline for a chemical hygiene plan that includes, but is not limited to, integrating a Hierarchy of Controls, ensuring equipment is maintained and used correctly, instituting prior approvals for hazardous chemicals, designating a hygiene officer, and finally, establishing provisions for the replacement (or elimination) of known health hazards such as toxins, poisons, carcinogens and reproductive risks. In the event known health hazards cannot be avoided, then requirements are introduced for their management by means of designation of use areas, carefully labelled waste collection, and equipment decontamination.
Let's briefly review a typical Hierarchy of Controls – engineering controls, administrative controls, and Personal Protective Equipment (PPE). They are always presented and instituted in this order of importance, for logical and sensible reasons.
Engineering a person safe means designing systems such that the employee no longer has to think about the safety of their overall environment. This typically equates to adequate air flow (exchange) in the work environment. You will recall, that of the four means of exposure to a health hazard (injection, absorption, inhalation, and ingestion), inhalation is the primary means of introduction. The passive act of breathing is the most precious thing to protect. Of course, no finely tuned engineering system is adequate to protect someone who is using safety equipment incorrectly.
