2A or 2B by IARC or under the category "reasonably anticipated to be carcinogens" by NTP. A category (4) substance is considered a select carcinogen only if it causes statistically significant tumor incidence in experimental animals in accordance with any of the following criteria: (1) after inhalation exposure of 6 to 7 hours per day, 5 days per week, for a significant portion of a lifetime to dosages of less than 10 mg/ m3; (2) after repeated skin application of less than 300 mg/kg of body weight per week; or (3) after oral dosages of less than 50 mg/kg of body weight per day.

"Reproductive toxins" are defined as those chemicals that affect reproductive capabilities, including chromosomal damage (mutations) and effects on fetuses (teratogenesis). Chemicals with a "high degree of toxicity" also require special provisions for worker health. Although "select carcinogens" 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 difficult to apply these categories. Some institutions have chosen to adopt the OSHA Hazard Communication Standard definition of "highly toxic" (LD50 < 50 mg/kg oral dose) as a workable definition of "high degree of acute toxicity." There is very little agreement on how to determine "reproductive toxins."

It is important to understand that the OSHA PELs and substance-specific standards do not include all hazardous chemicals. It is the laboratory manager's responsibility under the Laboratory Standard and the "general duty" clause to apply scientific knowledge in safeguarding workers against risks, even though there may be no specifically applicable OSHA standard.

The OSHA-mandated special provisions for work with carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity include consideration of "designated areas," use of 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. These special provisions are to be included in the Chemical Hygiene Plan.

The Laboratory Standard also requires quite detailed record-keeping, particularly with regard to records of exposure monitoring and medical surveillance, in those circumstances where exposure limits are exceeded or where work with especially hazardous substances is conducted.

9.C.5 Protection of Other Personnel in Laboratories

OSHA standards apply only to "employees" of laboratory facilities. In many cases, students are not employees within the scope of the Occupational Safety and Health Act, but both moral and legal considerations suggest that colleges and universities provide the same protections to students as are provided to all employees regularly working in the laboratory.

Custodial and maintenance staff who service the laboratory continue to be governed by other OSHA standards, particularly the Hazard Communication Standard, which sets forth the information, training, and health and safety protections required to be provided to nonlaboratory employees.

9.C.6 Federal Versus State Regulations

Enforcement of the Laboratory Standard, as well as other OSHA standards, may be a shared responsibility of the federal government and of state occupational safety and health programs. Under Section 18 of the Occupational Safety and Health Act, individual states may be authorized by federal OSHA to administer the act if they adopt a plan for development and enforcement of standards that is "at least as effective as the Federal standards." These states are known as "state-plan" states. In states that do not administer their own occupational health and safety programs, federal OSHA is the regulator, covering all nonpublic employers. State-plan states have generally included public employees in their regulatory approach. What this means is that a given institution may be subject to (1) the federal Laboratory Standard, enforced by federal OSHA, (2) a state Laboratory Standard, enforced by state OSHA, or (3) if a public institution is not subject to OSHA regulation, state public institution health and safety regulations enforced by a state agency. The environmental health and safety office at each institution should have a copy of the applicable standard.

Of the violations of the Laboratory Standard issued by OSHA, many have been for failure to have a Chemical Hygiene Plan or for a missing element in the plan. Another commonly cited violation is failure to meet the "Employee Information and Training" requirements of the Laboratory Standard. It is likely that OSHA enforcement of the Laboratory Standard will increase in the future, as state and federal OSHA inspectors focus more on laboratory activities and the implementation of this still relatively new standard.

9.C.7 Laboratory Standard Versus Hazard Communication Standard

It is important to understand the distinction between the Laboratory Standard and the Hazard Communication Standard. As noted above, the Laboratory Standard is intended, with limited exceptions, to be the



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