Ben and colleagues,

The proper language is the “physical and health hazards of chemicals”.

Physical Hazards are included and clearly defined in the standard:

Physical hazard means a chemical that is classified as posing one of the following hazardous effects: Explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid, or gas); self reactive; pyrophoric (gas, liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; in contact with water emits flammable gas; or combustible dust. The criteria for determining whether a chemical is classified as a physical hazard are in appendix B of the Hazard Communication Standard (=A71910.1200) and =A71910.1200(c) (definitions of "combustible dust" and "pyrophoric gas"). 

I find this to be a very specific inclusion of physical hazards. They define it clearly in the standard and they tell you explicitly to train your employees in it.

If I had the magic wand, yes, I would change some of the other language that surrounds this issue. However, in the meantime, we should all simply agree that the lab standard does explicitly include physical hazard of chemicals and requires us to take action concerning them.

Regards … Jim

Jim,

I agree that the Lab Standard includes both health and chemical hazards with regard to topics that must be included in training, which is stated in the reference that you highlighted. 

My point was that the scope of the Lab Standard states that it applies to “the laboratory use of hazardous chemicals” and that a hazardous chemical is defined as “any chemical which is classified as health hazard or simple asphyxiant.”  Based on that it seems to me that the scope of the Lab Standard doesn’t specifically include physical chemical hazards. As has been stated, however, regardless of how the Lab Standard may be interpreted I think that most of us consider all chemical hazards, and other laboratory hazards, within our laboratory safety programs.  

Thanks for the discussion.

Ben

I believe that the lab standard absolutely applies to the physical hazards of chemicals.  … Jim

1910.1450(f)(4)

Training.

1910.1450(f)(4)(i)

Employee training shall include:

1910.1450(f)(4)(i)(A)

Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);

1910.1450(f)(4)(i)(B)

The physical and health hazards of chemicals in the work area; and

1910.1450(f)(4)(i)(C)

The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.

I think it is true that the Lab Standard does not specifically cover physical chemical hazards such as flammability, reactivity, etc.  If that’s the case then the flammability hazard associated with methane is not specifically covered by the Lab Standard, although its ability to act as a simple asphyxiant is included.  I have never made that distinction as I consider all hazards regardless of any regulatory gaps.  Anyway, that’s how I read things but please let me know if others have a different opinion. 

Ben

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Ben Owens

Assistant Director, Laboratory Safety

Environmental Health and Safety Dept., MS 328

University of Nevada, Reno 89557

Office Phone: 775-327-5196

Cell Phone: 775-843-2113

Fax: 775-784-4553

Hazardous chemical means any chemical which is classified as health hazard or simple asphyxiant in accordance with the Hazard Communication Standard (=A71910.1200). 

Health hazard means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to =A71910.1200—Health Hazard Criteria.