Select Industrial Hygiene Assessment at the NCAR/UCAR ......Select Industrial Hygiene Assessment at the NCAR/UCAR Mesa Laboratory Boulder, Colorado Submitted to Melinda Powers, CIH

Select Industrial Hygiene Assessment at the

NCAR/UCAR Mesa Laboratory

Boulder, Colorado

Submitted to Melinda Powers, CIH

University Center for Atmospheric Research P.O. Box 3000

Boulder, Colorado 80307-3000

Prepared by: CHEMISTRY & INDUSTRIAL HYGIENE, INC.

10201 W. 43 Ave, Suite 201 Wheat Ridge, Colorado

Caoimhín P. Connell

Senior Industrial Hygienist

July 10, 2002

Mesa Review July, 2002 Page 1 CHEMISTRY & INDUSTRIAL HYGIENE INC.

1.0 EXECUTIVE SUMMARY .......................................................................................... 1 2.0 INTRODUCTION ........................................................................................................ 2 3.0 REFERENCES ............................................................................................................. 3 4.0 METHODOLOGY ....................................................................................................... 4 5.0 OBSERVATIONS ........................................................................................................ 4

5.1 Administrative........................................................................................................... 4 5.1.1 Hazard identification and assessment ................................................................ 4 5.1.2 Chemical Procurement and Distribution............................................................ 5 5.1.3 Chemical Inventory Management...................................................................... 5

5.1.3.1 Example Chemical Inventory Management................................................ 5 5.1.3.2 Excess Chemical and Waste Stream Inventory .......................................... 6

5.2 Chemical Storage ...................................................................................................... 6 5.3 Chemical Use ............................................................................................................ 7 5.4 Engineering Controls ................................................................................................ 7

5.4.1 Laboratory Fume hoods ..................................................................................... 7 5.4.2 Pressure Differentials....................................................................................... 10

5.5 Personal Protection Equipment............................................................................... 13 5.6 Physical Plant.......................................................................................................... 13 5.7 Employee Information and Training....................................................................... 14

5.7.1 Special Procedures and Areas.......................................................................... 15 5.8 Emergency Response .............................................................................................. 16 5.9 Individual Laboratories (partial list of general observations)................................. 16

6.0 CONCLUSIONS......................................................................................................... 18 7.0 RECOMMENDATIONS............................................................................................ 19


1.0 EXECUTIVE SUMMARY During June 2002, CHEMISTRY & INDUSTRIAL HYGIENE INC. (C&IH), performed a walkthrough review of the UCAR/NCAR Mesa Laboratory, in Boulder, Colorado. The purpose of the review was to compare practices, procedures and plant facilities in use at the Mesa Laboratory with currently accepted state-of-the-art practices, standard industry practices, prudent practices, national consensus standards and federal regulations for laboratory facilities. No qualitative or quantitative sampling or measurements were performed. All of the information for the review was obtained by direct observation by the reviewer, and through interviews with the laboratory occupants. The review was limited to the work in progress (if any) on the day of the visit, and under the conditions extant on the day of the visit. The review should not be considered an all-encompassing audit, but rather a cursory update intended to identify the more obvious issues which may require improvement or updating. Overall, we found that the physical plant and certain practices and procedures used at the facility do not meet national consensus standards and are below general industry standards expected for a laboratory facility of this type. General physical plant deficiencies included physical building layout, ventilation, emergency egress and engineering controls. To ensure compliance with general industry standards, the physical facility is in need of updating which will require significant fundamental modifications to the very superstructure of the building and a complete redesign and installation of the ventilation systems. In some cases, it may not be physically possible to modify the structure of the building to meet national consensus standards for laboratory use. General chemical handling practices and procedures at the facility are greatly in need of improvement. We observed several storage situations in many of the laboratories which would constitute “serious” violations of code and standards, would be considered unacceptable in an equivalent laboratory in the country, and may constitute potentially serious risks to life and property. Administration of the Chemical Hygiene Program should be re-assessed and should be redesigned to ensure complete participation by all employees affected by the CHP. Computer controlled inventory tracking including expiration dates, end-use dates and automatic flagging of older purchases should be implemented. The EH&S office should have an immediate up-date of new chemicals arriving on site and a monthly or weekly up-date of chemicals no longer on site due to consumption.


2.0 INTRODUCTION On June 18th and 19th, 2002, CHEMISTRY & INDUSTRIAL HYGIENE INC. (C&IH), performed an industrial hygiene walkthrough review of the Mesa Laboratory, in Boulder, Colorado. The Mesa Laboratory is managed by the University Center for Atmospheric Research and the National Center for Atmospheric Research. The purpose of the review was to compare observed practices and procedures and plant facilities at the Mesa Laboratory with currently accepted national consensus standards and federal regulations for laboratory facilities. The review was performed by the author of this discussion, Caoimhín P. Connell, Senior Industrial Hygienist for C&IH. The written discussion was reviewed by James Rasmuson, PhD, CIH, DABT. Mr. Connell and Dr. Rasmuson, have extensive experience in chemical laboratories as analytical chemists, and have performed audits for over three hundred individual laboratories for government (DVA, USGS, DOC, etc), and private industry alike. Dr. Rasmuson has no first hand knowledge of the Mesa Laboratory audit but relied on the information contained in this document and performed a technical review of this discussion. No qualitative or quantitative sampling or measurements were performed. All of the information for the review was obtained by direct observation by the reviewer, and through interviews with the laboratory occupants. The review was limited to the work in progress (if any) on the day of the visit, and under the conditions extant on the day of the visit. The review should not be considered an all-encompassing audit, but rather a cursory update intended to identify the more obvious issues which may require improvement or updating. The review is by no means a comprehensive review, and absence of mention of any particular violation in this discussion should not be inferred to mean no violation was present. We have focused our attention on specific areas of concern at the discretion of the evaluator. Specific details of all violations or apparent violations observed by the author have not been included in the discussion. Rather, we have attempted to raise the awareness of specific categories for which there is a need for general improvement. The following laboratories were included in the walkthrough:

9 10 20 019 020 021 022 023 027 034 042A 042E

042F 047A 047B 064 066 174 180 188 190 194 198 Penthouse B

Table 1 Laboratory Room Numbers Included in the Walkthrough


3.0 REFERENCES During our review, we prepared a checklist to standardize the items of interest in each laboratory. The checklist was based on the following references:

• NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals, 2000 The NFPA standard is a comprehensive standard covering several aspects of

laboratory environments. Although not necessarily carrying force of law, per se, NFPA 45 is referenced in building codes and other government documents which do require mandatory compliance. “This edition of NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, was prepared by the Technical Committee on Laboratories Using Chemicals and acted on by the National Fire Protection Association, Inc., at its World Fire Safety Congress and Exposition™ held May 14–17, 2000, in Denver, CO. It was issued by the Standards Council on July 20, 2000, with an effective date of August 18, 2000, and supersedes all previous editions. This edition of NFPA 45 was approved as an American National Standard on August 18, 2000.”1

• ASHRAE 110-1995 Method of Testing Performance of Laboratory Fume Hoods.

This is a national consensus non-mandatory laboratory fume hood evaluation protocol. It is considered by many to be the state-of-the-art document on laboratory fume hood evaluations protocols. The standard contains some language that may conflict with the NFPA 45.

• ANSI/ASHRAE Standard 62-2001, Ventilation for Acceptable Indoor Air Quality

This standard is a national consensus standard widely accepted in building codes and by the industrial hygiene community. The standard frequently carries force of law by implicit or explicit reference in local building codes.

• ANSI/AIHA Z9.5-1992 Standard for Laboratory Ventilation

The ANSI/AIHA standard is also a national consensus standard widely accepted in the laboratory industry but not carrying force of law.

• Title 29 Code of Federal Regulations Part Z, §1910.1450 Occupational exposure

to hazardous chemicals in laboratories. This is the federally mandated occupational standard which carries force of law

for all employees covered by standards administrated by the federal Occupational Safety and Health Administration (OSHA). Mandatory compliance with OSHA standards may be somewhat confused for different groups of employees at the UCAR/NCAR facility; however, each department should drive for complete compliance with this and other OSHA standards.

1 Quoted from the NFPA Standard, ©NFPA, 1 Batterymarch Park, PO Box 9101, Quincy, MA 2269-9101, An International Codes and Standards Organization


• Guidelines for Laboratory Safety – Health and Safety Considerations DeBerardinis, L.; Baum, J.S.; Gatwood, G.T. et al, 1987 (ISBN 0-471-89134-7) This private publication is an extremely useful book which describes proper

physical layout of laboratories.

• National Research Council Prudent Practices in the Laboratory – Handling and Disposal of Chemicals, 2000 For many years, the Prudent Practices manual has been the “bible” of safe

practices in the chemical laboratory. Prudent Practices is incorporated, by reference, in the OSHA standard Occupational exposure to hazardous chemicals in laboratories.

4.0 METHODOLOGY To perform the review, we prepared a draft checklist to standardize the items on which we chose to focus. The items were selected in light of the fact the review was to be based on a cursory walkthrough and limited interview. A copy of the completed checklist is included as Appendix A. Upon entering each study laboratory, we spent several minutes speaking with the laboratory occupant(s). We asked for an overview of operations in the laboratory, the objective of the work being performed, a synopsis of the equipment in use, immediate electrical power and space requirements and future needs. Following the interview, we walked through the laboratory observing the configuration of the laboratory, hoods, contents of cabinets, and drawers. During our audit, we collected approximately 160 digital photographs and video clips from the 24 laboratories. Those photographs will accompany this discussion on a CD in “jpg” format.

5.0 OBSERVATIONS Based on our walkthrough, we have compiled the following general discussion headings and observations.

5.1 Administrative Administration of health and safety programs such as the OSHA mandated Chemical Hygiene Plan is evidenced by the employees’ knowledge of training requirements, procurement procedures, waste disposal, and emergency preparedness. Overall, we believe there are several areas for improving the administration of health and safety rules by making those rules available and mandatory upon all employees working in the laboratories.

5.1.1 Hazard identification and assessment Overall, researchers are allowed to develop and implement projects independent of external review by the EH&S office. Within the current NCAR environment, a


researcher is at liberty to develop and perform a new test procedure using chemicals and processes which may increase risk of injury to themselves, others or NCAR property without the knowledge of the EH&S office. Such new processes or tests are not subject to review by competent industrial hygienists who may be in a position to suggest alternatives in the process that could either reduce risks, or increase preparedness in the event of an emergency. The EH&S office provides hazard information on chemicals that are purchased through the accepted procurement practice. However, researchers are at liberty to independently purchase chemicals in a manner which circumvents the auspices of the EH&S office. This ability to independently purchase chemicals weakens the overall ability of the EH&S office to properly manage risk at the facility.

5.1.2 Chemical Procurement and Distribution We learned that although there is a procurement process which routs chemical purchases through the EH&S department, researchers autonomously purchase chemical products from a variety of sources that are not included in the EH&S procurement process. As such, chemical compounds are brought on-site without the knowledge of the EH&S office. These products then can be moved from location to location, and possibly abandoned in various rooms where they become high liability legacy chemicals. Both the NFPA 45 and Prudent Practices address ordering and procurement procedures (NFPA 45 Chapter 7 and Prudent Practices 4.C.1). The procurement practices exhibited at NCAR are not consistent with standard industry or best management practices for chemical laboratories.

5.1.3 Chemical Inventory Management Similarly, chemical inventory practices are not capable of tracking the chemical product from “cradle to grave” and documenting the date when the product exits the system and is either completely consumed or otherwise no longer on-site.

5.1.3.1 Example Chemical Inventory Management Ideally, upon entering the system, a bar-coded sticker should be affixed to the product. The scanned item should include the name of the responsible party receiving the product, the destination location, name and CASRN, quantity and expected lifetime in the system. Once the product is emptied, the affixed label should be removed and affixed to a tracking clip-board permanently stationed at the entrance to each laboratory. Periodically (weekly or even randomly), EH&S personnel walking through the halls could scan the product bar code, effectively removing the product from the system, and update the on-site inventory. When new orders for chemicals are received through the EH&S office, the computer could automatically seek internal information in the system to see if the compound is already on-site and available, thus negating the need for ordering the material.


If a researcher maintained the product for an unnecessary length of time, or accidentally failed to remove the bar code after the product is completely consumed or disposed, the expected life-time date would be exceeded and the EH&S office could be notified of the potential presence of a legacy compound. Chapter 4.D of Prudent Practices describes some of the elements of such a system.

5.1.3.2 Excess Chemical and Waste Stream Inventory Although the normal mechanism for removing excess or waste chemicals from the inventory is to notify the EH&S department, many legacy compounds and waste products are on-site and are not part of the chemical inventory. There appears to be no mechanism capable of automatically alerting EH&S to the potential that a material is languishing unused in laboratory.

5.2 Chemical Storage Improper chemical storage constituted the single largest observed potential for injury and loss of property. Chemical storage is extensively covered by OSHA, Prudent Practices and the NFPA 45 standards. Chapter 2 of the NFPA 45 standard requires laboratory units to be classified as Class A (High Fire Hazard), Class B (Moderate Fire Hazard), Class C (Low Fire Hazard), or Class D (Minimal Fire Hazard). The NFPA 45 fire hazard classification of any specific laboratory is incumbent on several other factors including the quantities of flammable and combustible liquids per unit area of the laboratory. Then, based on the Fire Hazard Classification, certain facility design features must be met, and certain practices, restrictions and prohibitions become mandatory within that laboratory space. During our audit, based on the estimated fire hazard classification, we observed conditions that would be considered violations of the NFPA 45 standard. For example, we found many examples of legacy chemicals of unknown composition stored in unmarked bottles (sometimes designated with a question mark); containers whose labels had degraded to the point of illegibility; strong oxidizers stored in containers that had degraded to the point the container’s integrity was completely compromised; flammable compounds stored in open wooden cabinets; strong oxidizers stored with organics; bases stored with acids in wooden cabinets. In at least two laboratories, we observed lecture bottles of flammable and reactive gases stored with mineral acids to the extent where the lecture bottles were heavily damaged due to the corrosive effects of the acid vapors, (in violation of OSHA standard 29 CFR §1910.101(a)).


We observed numerous large compressed gas cylinders containing flammables, reactive gases and O2 which were free standing and unsecured in violation of OSHA standard 29 CFR §1910.253(b)(4)(i) and NFPA Standard 8.1.5.1 which states:

8.1.5.1 Cylinders shall be secured from tipping over by holders designed for such service.

Similarly, in many of the laboratories we visited, banks of cylinders are stored; some of which may only be used once a year and at even lesser frequencies. This practice is in violation of NFPA 45 which states:

8.1.2 Cylinders that are not necessary for current laboratory requirements shall be stored outside the laboratory unit in accordance with NFPA 55, Standard for the Storage, Use, and Handling of Compressed and Liquefied Gases in Portable Cylinders.

In some cases, regular domestic style refrigerators and freezers are being used for the storage of flammable materials, oxidizers and and/or peroxide formers. According to NFPA 45:

9.2.2.3 Refrigerators, freezers, and cooling equipment located in a laboratory work area designated as a Class I location, as specified in the Exception to 3.6.2, shall be approved for Class I, Division 1 or 2 locations and shall be installed in accordance with Article 501 of NFPA 70, National Electrical Code.

Overall, chemical storage practices were sufficiently substandard to be considered serious, potentially dangerous and requiring immediate concerted attention by the laboratory staff in consultation with the EH&S office.

5.3 Chemical Use In general, the chemical use during the days of our visit, was very limited. That is, there was very little actual chemical use during our visit through the laboratories. Therefore, we did not have the opportunity to observe actual chemical use practices and procedures.

5.4 Engineering Controls The primary engineering controls we focused on were general dilution ventilation, local ventilation, and laboratory fume hoods.

5.4.1 Laboratory Fume hoods The NFPA 45 standard requires:

6.4.6 Laboratory hood face velocities and exhaust volumes shall be sufficient to contain contaminants generated within the hood and exhaust them outside of the laboratory building. The hood shall provide containment of the possible hazards and protection for personnel at all times when chemicals are present in the hood.


Similarly, in its laboratory standard, OSHA states:

29 CFR §1910.1450(e)(3) The Chemical Hygiene Plan shall include each of the following elements and shall indicate specific measures that the employer will take to ensure laboratory employee protection; (including)

29 CFR §1910.1450(e)(3)(iii) A requirement that fume hoods and other protective

equipment are functioning properly and specific measures that shall be taken to ensure proper and adequate performance of such equipment.

The traditional method of assessing laboratory fume hood performance is hinged on measuring the face velocities of the fume hood. However, exclusive reliance on this method can be both misleading and “potentially dangerous.”2 According to one leader in the field of laboratory fume hoods: 3

As-installed and as-used ASHRAE 110 testing of thousands of fume hoods reveals that an average of 17% of the hoods tested pass face velocity criteria of 80-120 fpm but fail to meet the ACGIH ASHRAE 110 tracer gas control level of 0.1 ppm. Many lab design and health & safety professionals are realizing that face velocity has almost no correlation to fume hood containment, that its use and results are fraught with errors and are turning to the ASHRAE 110 test as a better measure of actual hood containment.

This author (Connell) has discussed the myths of face velocity in the past.4 In several cases during this review of the Mesa Lab, we observed that laboratory fume hoods had been identified with a label indicating the hood’s face velocity had been tested; occasionally the documented test was several years old. However, a single random cursory challenge of one hood by us during our walkthrough using a visible titanium dioxide fume indicated that the hood in question was not capable of capturing and containing the challenge fume. The challenge fume escaped the hood and entered the surrounding laboratory and thence into the common hallway. NFPA 45 requires

6.13.1 When installed or modified and at least annually thereafter, laboratory hoods, laboratory hood exhaust systems, and laboratory special exhaust systems shall be inspected and tested. The following inspections and tests, as applicable, shall be made: (1) Visual inspection of the physical condition of the hood interior, sash, and ductwork (see 5.5.2) (2) Measuring device for hood airflow (3) Low airflow and loss-of-airflow alarms at each alarm location

2 Hitchings, D. Labs for the 21st Century, EPA Presentation June 20, 2001 (Web site location: http://www.epa.gov/oaintrnt/21century/conf/conf1999/abstracts/dhitchings.htm) 3 Hitchings, D. Labs for the 21st Century, EPA Presentation June 20, 2001 (Web site location: http://www.epa.gov/oaintrnt/21century/conf/conf1999/abstracts/dhitchings.htm) 4 Connell, C.P. The Significance of Laboratory Fume Hood Face Velocities http://members.aol.com/CIHJOR/face.html


(4) Face velocity (5) Verification of inward airflow over the entire hood face (6) Changes in work area conditions that might affect hood performance

Based on our observations, the majority of hoods have not been so tested. Similarly, NFPA 45 states:

6.3.5 The location of air supply diffusion devices shall be chosen so as to avoid air currents that would adversely affect the performance of laboratory hoods, exhaust systems, and fire detection or extinguishing systems. (See Sections 4.2 and 4.5, and 6.9.1.) room, or to a shaft. (See 3.1.5 and 6.10.3.)

And also:

6.9.1 Laboratory hoods shall be located in areas of minimum air turbulence. Based on our observations, only a very small minority of the lab fume hoods we observed (if indeed any at all) meet these requirements. NFPA also states that for new installations, laboratory hoods shall not be located adjacent to a single means of access to an exit or to high-traffic areas. We believe that the requirement is sufficiently important that all existing hoods should similarly meet this requirement. In many cases, the laboratory hoods are exclusively located adjacent to a single means of access to an exit and/or to high-traffic areas. We have also noted that in contradiction to the NFPA standards, several hoods exhaust directly into the building envelope atop Penthouse Tower B. (The “building envelope” is a stagnant zone of air surrounding each building and is influenced by the shape of the building, local topography, micrometeorological conditions, and nearby structures.) The placement of a stack vent on a roof whose purpose is to vent away an obnoxious, explosive or toxic gases is a complex process which involves the need to calculate the building envelope. 5 The configuration of the exhaust termini from the laboratory hoods vis-à-vis the building structure is inconsistent with good industrial hygiene ventilation and the NFPA standard. NFPA 45 states:

6.4.11 Air exhausted from laboratory hoods and special exhaust systems shall be discharged above the roof at a location, height, and velocity sufficient to prevent re-entry of chemicals and to prevent exposures to personnel.

5ASHRAE-Fundamentals, 1989 Chapter 14, AIRFLOW AROUND BUILDINGS, American Society of Heating Refrigeration and Air-conditioning Engineers.


Similarly, the ASHRAE standard on indoor air quality6 states:

5.4 Ventilating systems should be designed to prevent reentrainment of exhaust contaminants... Makeup air inlets and exhaust air outlets shall be located to avoid contamination of the makeup air. Contaminants from sources such as cooling towers, sanitary vents, vehicular exhaust from parking garages, loading docks, and street traffic should be avoided. This is a special problem in buildings where stack effect draws contaminants from these areas into the occupant space.

The exhaust hoods on the B Tower Penthouse are located below the highest point on the roof. Indeed, in at least one case, the hood exhausts even below the parapet line. Directly above the hood exhaust termini, are building vents of unknown purpose. According to NFPA 45:

A.6.4.11 Exhaust stacks should extend at least 3 m (10 ft) above the highest point on the roof to protect personnel on the roof. Exhaust stacks might need to be much higher to dissipate effluent effectively, and studies might be necessary to determine adequate design. Related information on stack height can be found in Chapter 14, Airflow Around Buildings, of the ASHRAE Handbook of Fundamentals.

Similarly, NFPA 45 states:

6.3.2 The location and configuration of fresh air intakes shall be chosen so as to avoid drawing in chemicals or products of combustion coming either from the laboratory building itself or from other structures and devices.

Based on our observations, the configuration of the laboratory fume hoods in general are contradictory to good management practices, ASHRAE standards, Prudent Practices guidelines and the NFPA 45 standard. Due to the unique shape of the Mesa Laboratory superstructure and the physical location of the building (vis-à-vis the mountain terrain) the resulting building envelope will be unusually complex, and it may be very difficult to satisfy the ASHRAE, ANSI and NFPA requirements.

5.4.2 Pressure Differentials Pressure differentials are an important aspect of controlling fugitive emissions from chemical laboratories into administrative or non laboratory areas. According to NFPA 45

6.3 Supply Systems. 6.3.1 Laboratory ventilation systems shall be designed to ensure that chemicals originating from the laboratory shall not be recirculated. The release of chemicals into the laboratory shall be controlled by enclosure(s) or captured to prevent any flammable and/or combustible concentrations of vapors from reaching any source of ignition.

6 ANSI/ASHRAE Standard 62-2001, Ventilation for Acceptable Indoor Air Quality


Similarly NFPA also states:

6.3.4 The air pressure in the laboratory work areas shall be negative with respect to corridors and nonlaboratory areas.

Approximately half of the chemical laboratories included in our walkthrough were under positive pressure with respect to non-laboratory areas; that is, general room air is moving from the laboratory interior into the adjoining corridors and administration offices. In at least one case, the air from the interior of the laboratory fume hood was entering the general laboratory, and from there migrating into the common corridor. Laboratory design and lay-out has changed dramatically over the last two decades. In the past, a laboratory has merely been a process placed in a standard building. Current thinking is such that laboratories should be designed to address unique ventilation and hazard control issues. Although the specific laboratory design may change to accommodate special laboratory needs, current thinking for health and safety considerations in laboratory designs include certain features that are common to the basic lay-out. For example, in the past, laboratory fume hoods were placed in the finished lab almost as an afterthought. Today’s laboratories are designed around the fume hoods and ventilation systems in general. The drawing below, styled after designs found in “Guidelines for Laboratory Design”7 contains some of the common features seen in state-of-the-art labs of today. For example, the lab(s) are isolated from office areas and are serviced by a central service corridor. The service corridor is used to transport equipment, anchor in-use cylinders (which are plumbed to equipment), and provide storage of equipment and chemicals. The corridors are used exclusively by lab personnel and are maintained under negative pressure with respect to the rest of the building.

7 DiBerardinis, Louis; Baum, Janet; et al Guidelines for Laboratory Design – Health and Safety Considerations Wiley & Sons, 1987, ISBN 0-471-89134-7


Figure 1 Generalized Laboratory Layout (not to scale)

Airflow is carefully controlled and the labs themselves are maintained under negative pressure with respect to the common hallways (“circulation corridors”). Laboratory fume hoods are located such that cross drafting is minimized and such that lab occupants do not need to pass in front of the hood to leave the lab. Egress is unrestricted and doors open in the direction of egress. Entry way doors are recessed to permit unrestricted flow of hall traffic.

Fum

eH

ood

Service Corridor

Circulation Corridor

10' 0"x6' 3"Utility strip

Air Flow

Office Office OfficeOffice

Flammable Cabinets Gas Cylinders

Gas Cylinders

Laboratory

Air Flow

Util

ity s

trip

Utility strip

Utility strip

Instrument Bank

Instrument Bank

Air Flow

Air Flow


5.5 Personal Protection Equipment Due to the fact that very little actual chemical use was occurring during our visits, the use of personal protection equipment turned out to be a very minor consideration during this review. However, generally speaking, personal clothing was not protected; donning of aprons, lab coats, etc was not generally observed. Open-toed sandals were worn by some personnel in chemical laboratories. We believe that the clothing of choice may be part of the “culture” of the laboratory that needs to be addressed. Lab coats may not be fashionable, but they are an effective way to prevent the migration of laboratory chemicals into non-lab common areas such as the cafeteria where non-lab personnel may be exposed to fugitive compounds borne on the clothing of lab personnel.

5.6 Physical Plant Certainly the ventilation and fume hood considerations described above would be part of the physical plant. Additionally, issues of egress can speak to individual practices as well as administrative responsibilities and physical plant. For convenience, egress issues are exclusively described here. Throughout the areas we visited, either due to original design and construction of the building or through practiced of the occupants or, occasionally both, violations of egress occur. According to OSHA:

§1910.36(b)(1) Every building or structure, new or old, designed for human occupancy shall be provided with exits sufficient to permit the prompt escape of occupants in case of fire or other emergency.

Throughout the laboratories we visited, we encountered exits that were blocked, obstructed, or otherwise rendered inaccessible. Similarly, according to OSHA

§1910.36(b)(5) Every exit shall be clearly visible or the route to reach it shall be conspicuously indicated in such a manner that every occupant of every building or structure who is physically and mentally capable will readily know the direction of escape from any point, and each path of escape, in its entirety, shall be so arranged or marked that the way to a place of safety outside is unmistakable. Any doorway or passageway not constituting an exit or way to reach an exit, but of such a character as to be subject to being mistaken for an exit, shall be so arranged or marked as to minimize its possible confusion with an exit and the resultant danger of persons endeavoring to escape from fire finding themselves trapped in a dead-end space, such as a cellar or storeroom, from which there is no other way out.

Throughout the facility we observed exits which were not identified and we also observed non-exits that appeared to be exits.


Both OSHA and the NFPA 458 standard address egress in terms of prohibiting sole exits from passing high hazard areas during egress:

§1910.37(f)(5) Exit access shall be so arranged that it will not be necessary to travel toward any area of high hazard occupancy in order to reach the nearest exit, unless the path of travel is effectively shielded from the high hazard location by suitable partitions or other physical barriers.

Throughout the areas we visited, we observed several sole exits which required the occupant to move toward the location which had a potential for being the area containing the hazard the occupant is attempting to escape. According to OSHA:

29 CFR §1910.37(f)(6) The minimum width of any way of exit access shall in no case be less than 28 inches. Where a single way of exit access leads to an exit, its capacity in terms of width shall be at least equal to the required capacity of the exit to which it leads. Where more than one way of exit access leads to an exit, each shall have a width adequate for the number of persons it must accommodate.

In several places throughout the facility, the minimum width is not met. In one case, we measured an exit access of nine inches; in two cases, the exit access was approximately 18 inches. Both OSHA (§1910.37(f)(2)) and the NFPA 45 (§3.4.3) require the exit door(s) to swing in the direction of travel under specific circumstances. We observed several situations where these requirements apparently not being met.

1910.37(f)(2) A door from a room to an exit or to a way of exit access shall be of the side-hinged, swinging type. It shall swing with exit travel when the room is occupied by more than 50 persons or used for a high hazard occupancy.

NFPA 45 (3.1.6) requires all floor openings be sealed or curbed to prevent liquid leakage to lower floors. None of the visible floor penetrations appeared to meet this requirement.

5.7 Employee Information and Training Overall, occupants of the laboratories appeared conscientious and genuinely concerned about health and safety. But occasionally, occupants confessed that the federal regulations and safety standards sometimes appear insurmountable. Also observed were some individuals who expressed some degree of disenfranchisement with the health and safety process as a whole. By cultivating a culture of laboratory safety (see Prudent Practices, Chapter 1), the appearance of intrusive and restrictive health and safety regulations is greatly diminished,

8 The NFPA language in 3.4.1 is lengthy and is only referenced here.


and safety becomes second nature. Admittedly, there is usually an initial resistance to the development of health and safety protocols, but such resistance can be mitigated by the intimate involvement of those who know their jobs best; the occupants of the laboratories. By intimately involving the laboratory personnel in H&S issues, the administration can better address these types of obstacles to a healthy and safe work place culture. Almost without exception, each occupant was familiar with the MSDS files available for the compounds within their control. Many of the employees believed their safety training ended with the initial video training program. Only one of the occupants interviewed mentioned the fire drill which recently took place. None of the occupants discussed on-going training to meet today’s laboratory personnel needs. Most of the occupants were not cognizant of the uncontrolled hazards and safety violations within their areas.

5.7.1 Special Procedures and Areas Throughout the laboratories we visited, we observed compounds that would meet OSHA’s definitions of “particularly hazardous substances” as used in §1910.1450 (e)(3)(viii). Accordingly, OSHA requires provisions for additional employee protection for work with particularly hazardous substances. These “particularly hazardous substances” include select carcinogens, reproductive toxins and substances which have a high degree of acute toxicity. Specific consideration for work with “particularly hazardous substances” must be given to the following provisions which must be implemented where appropriate:

§1910.1450 (e)(3)(viii)(A) Establishment of a designated area; (e)(3)(viii)(B) Use of containment devices such as fume hoods or glove boxes; (e)(3)(viii)(C) Procedures for safe removal of contaminated waste; and (e)(3)(viii)(D) Decontamination procedures.

According to OSHA, "Designated area" means an area which may be used for work with select carcinogens, reproductive toxins or substances which have a high degree of acute toxicity. A designated area may be the entire laboratory, an area of a laboratory or a device such as a laboratory hood. During our visit, we noted that designated areas were not particularly well defined, possibly in violation of the OSHA requirements.


5.8 Emergency Response Egress issues have already been discussed above. According to OSHA, (§1910.151(c)), where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. In violation of this standard, we frequently encountered eye washes and showers that were inaccessible, or rendered unusable due to location of other materials in the laboratory. Eye washes must be immediately available and usable to a person in a state of pain and panic. The chemical hazards associated with each laboratory is not fully documented. Often, rooms contain un-documented materials which may pose extreme hazards to emergency response personnel; such rooms are not always posted according to the hazards they contain.

5.9 Individual Laboratories (partial list of general observations) 019

• Low chemical hazard. • Minimal UV exposure issues. • Canopy hood not included in NCAR’s evaluation process.

038 • Ventilation tie-in to laboratory hood. • Excessive cylinder storage in laboratory. • Unsecured cylinders in lab (tied in with bungee cord). • Acids and bases stored together.

198 • Fume hood duct has been modified. • Food and drink in the laboratory. • Excessive cylinders in lab.

Penthouse B tower • Excessive cylinder storage

047A • Limited egress, egress restricted, leads to another lab. • Alternate exits are either blocked or awkward. • Lecture bottles stored with acids. • Legacy compounds. • Unidentified compounds. • HClO4 stored with organics. • Legacy compound in container with completely corroded lid. • Direct reading instruments for the immediate detection of toxic gases have not

been calibrated, and the calibration has not been verified. On some occasions, the


alarm level for the instruments has been exceeded, indicating the potential for over exposures.

• Excessive compressed gases. • Clearance to spiral stairs exit is approximately 40 cm. • Boiler room exit approximately 100 cm width (convoluted rout, not marked) • O2 stored with CO and NO2

064 • Strong reverse flow in laboratory fume hood.

034

• Lasers activation is not interlocked with door. • Compressed gases stored in fume hood with mineral acids damaging the

cylinders. • Compressed gas cabinet not alarmed. • Nonstandard (old) chemical refrigerator (also not self defrosting). • Labels obscured by ice on containers. • Non-compatibles stored together (acetic, nitric and ammonium hydroxide all

together). • Alternate exit is blocked. • Shower is blocked.

047A • Several legacy chemicals. • Shower is obstructed with equipment. • Egress is restricted. • Pressure differential is negative to the hall, but positive to Lab 047B.

021 • Domestic fridge used for chemical storage. • Refrigerator doesn’t close properly. • Greater than 27 cylinders on hand. • Convoluted exposed HVAC ducting.

022 • Large quantity of benzene stored (smaller quantities of benzene would suffice). • Back exit is restricted • Large quantity of MeOH stored on floor

027 • Assist fan on exhaust places exhaust line under positive pressure

066 • Acid work is being performed above eye level with no eye/face protection worn. • Substitution of O2 with an inert gas should be considered. • Egress restricted by narrow passage

020/010/090/042B Complex • This laboratory contained the only example of properly stored acetic acid • Food items in the laboratory


• Eye wash blocked 188

• Storage in hall wall. 190

• Acids and bases stored together. • Several legacy chemicals. • Blocked secondary egress.

194 • Unsecured cylinders • Several legacy chemicals • Open fire hazards • Unsecured cylinders • Unlabeled compounds

042F • Unidentified compounds

6.0 CONCLUSIONS Based on our observations, we believe that an extensive industrial hygiene and safety review of laboratory practices and procedures is required to bring those practices and procedures inline with currently held prudent practices and standard industry practices. Based on our review, we observed conditions in various laboratories that would be considered “intolerable” in other laboratories with similar missions to that of the NCAR Mesa Laboratory. Specifically, the eight conditions in need of immediate attention would be: 1) Presence of legacy chemicals 2) General storage of chemicals 3) General storage of compressed gas cylinders 4) General ventilation design deficiencies (including fume hoods) 5) Chemical inventory and tracking 6) Emergency egress 7) Emergency preparedness 8) Personal protection practices Based on our observations, the physical structure of the Mesa Laboratory may be obsolete as a viable structure for housing the types of laboratories currently present at the Mesa Laboratory. Based on our discussions with laboratory personnel, the laboratory staff at the Mesa facility are enthusiastic, conscientious and particularly cooperative but in need of guidance and direction vis-à-vis health and safety practices and procedures.


7.0 RECOMMENDATIONS We recommend that a comprehensive computerized chemical inventory tracking system be implemented at the Mesa Laboratory. A thorough and comprehensive chemical inventory should be conducted wherein every single container in the facility is located, identified and given a unique tracking number. All legacy chemicals and unidentified/unidentifiable compounds should be handled as hazardous waste and removed from the site and disposed of in a manner consistent with local and federal standards. We recommend an engineering audit of the physical plant to determine the feasibility of the continued use of the Mesa Laboratory as a viable laboratory facility. The audit should be capable of identifying all of the design deficiencies and the costs and feasibility of upgrading the structure to meet today’s standards. By encouraging more open lines of communication between the laboratory staff and the H&S staff, a better understanding of their respective goals can be reached and a better integration of roles can be achieved. Where necessary, appropriate encouragement and disciplinary actions should be considered by the laboratory staff for management of practices and procedures that occur in their areas. Prepared by Reviewed by

Caoimhín P. Connell James Rasmuson, PhD, CIH, DABT Senior Industrial Hygienist President

Mesa Review, July 2002 -Appendix A Page 1 CHEMISTRY & INDUSTRIAL HYGIENE INC.

UCAR/NCAR Laboratory Review Checklist

Date June 18 and 19, 2002 Independent Third Party Review Performed by: Caoimhín P. Connell, Senior Industrial Hygienist

Laboratory Room Number Contact Name 9 Jim Greenberg

010 Jim Greenberg 020 Jim Greenberg 019 Rick Shetter 20 Elliot Atlas

021 Elliot Atlas 022 Elliot Atlas 023 Roger Hendershot 027 Elliot Atlas 034 Geoff Tyndall 038 Fred Eisle

042A Roger Hendershot 042E Eric Apel 042F Roger Hendershot 047B Geoff Tyndall 047B Gavin Edwards 064 Alan Hills 066 Dave Hanson 174 Allan Fried 180 Brian Ridley 188 Frank Flocke 190 Brian Ridley 194 Brian Ridley 198 Fred Eisle

Penthouse B Jim Hannigan

Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

Administrative Issues 1. Is there a system in place to monitor changes to

regulations/guidelines? Site-wide

Program Management and Organization 2. Does the written Chemical Safety Program (CSP)

include requirements of the OSHA HazCom, Lab Standard and Prudent Practices such as:

Not evaluated

3. Is NCAR staff appropriately trained to follow the CSP?

Not evaluated

4. Are workers informed about the CSP? Site-wide

5. Are procedures reviewed regularly and changed when necessary?

Site-wide


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

6. Is an individual responsible for maintaining a central MSDS database and for filing MSDSs? Are MSDSs routed to this individual upon receipt for filing?

Site-wide However, employees can easily circumvent the MSDS routing procedure by purchasing chemicals outside the accepted procurement procedure.

7. Is the CSP reviewed and the effectiveness evaluated at least annually, and updated as necessary?

Not evaluated

Hazard Identification and Assessment

8. Is a process established and used to identify and evaluate the hazards of chemicals that are purchased, used, or stored at NCAR?

Site-wide See notes for # 6 above.

9. MSDSs: Are readily available to workers working with

hazardous chemicals in the workplace, and to emergency responders?

Is an individual responsible for maintaining the MSDS file in this lab?

Are MSDSs routed to this individual upon receipt for filing?

Site-wide

10. Is chemical safety integrated into the work planning process?

Site-wide

11. Is there a process to verify identified controls are implemented and operable?

Site-wide

12. Are hazard analyses conducted for chemicals and chemical processes?

Site-wide

13. Is identification and reduction of waste integrated? Site-wide

14. Are chemical hazards and controls identified and integrated into the design and construction of new projects and facilities?

Site-wide

15. Are hazards of legacy chemicals (e.g. abandoned, residual chemicals in tanks and pipes with inadequate controls) appropriately identified and addressed?

Site-wide

16. Are chemical hazard identification and assessment methods established for emergency response personnel?

Site-wide

17. Are work areas regularly inspected for chemical hazards and controls?

Site-wide


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

Procurement and Distribution 18. Are appropriate standard procedures established for

the purchase of hazardous chemicals? Site-wide

19. Do facility and warehouse control procedures appear to adhere to chemical management procedures?

Site-wide

20. Are proper chemical storage practices apparently followed in established chemical stockrooms (e.g. properly vented, chemicals stored by hazard class and compatibility, equipped with spill containment)?

Site-wide

21. Are secondary, non-breakable outer containers used to hand transport breakable containers outside of work areas?

Site-wide

22. Is sufficient storage available? (i.e. staff resorts to storage in the hallways)

Site-wide

Chemical Storage

23. Estimate the NFPA Fire Hazard Classification of this lab

198, 047B, 047E, 034,

047A, 022, 194

047A, 066

038, 064, 021

019, PHB, 027, 020, 188, 023, 180, 190, 042F, 174

24. Are there any NFPA Reactivity #4 compounds? Site-wide

25. Are inside chemical stockrooms: vented to the outside, equipped with spill containment

Site-wide

26. Are all storage compartments appropriately labeled? 021, 020 038, 198, 047B, 034,

047A, 066, 188, 023, 190,

194, 042F

019, PHB, 047E,

064, 021, 027, 180,

174

27. Are all stored chemicals appropriately labeled? 019, PHB, 047E,

064, 034, 021, 066, 020, 188, 023, 180,

174

038, 198, 047B,

022, 190, 194, 042F

027


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

28. Are containers labeled with an appropriate warning statement?

019, 038, PHB, 147E,

064, 034, 021, 020, 188, 023, 180, 174

198, 047B, 047A,

022, 190, 194, 042F

027

29. Are peroxide forming chemicals appropriately labeled as to the date received, opened, and date of last test? (e.g. aldehydes, ethers, etc.)

038, 198, 047B, 034,

047A, 021, 022,

194

019, PHB, 147E,

064, 027, 066, 020, 188, 023, 180, 190, 042F, 174

30. Are carcinogens labeled with a prominent cancer-warning label?

021, 020, 188

038, 198, 047B, 034,

047A, 022, 194,

042F

019, PHB, 064, 027, 066, 023, 180, 190,

174

31. Is process piping labeled with the name of the hazardous contents?

Site-wide

32. Are chemicals appropriately stored and segregated by hazard class and compatibility? (e.g. is acetic acid separated from HNO3)

019, 064, 022, 066, 020, 023,

174

038, 198, 047B, 034,

047A, 021, 188, 190, 194,

042F

PHB, 147E,

027, 180

33. Are chemical storage containers periodically inspected for replacement, deterioration, container integrity, etc.

019, PHB, 147E,

020, 188, 023, 174

038, 198, 047B,

064, 034, 047A,

021, 022, 066, 190,

194

027, 180, 042F

34. Are all flammable chemicals stored in approved flammable storage cabinets with self-closing doors?

047B, 022, 066,

020

019, 038, 198, 064,

034, 047A,

021, 188, 023, 194

PHB, 147E,

027, 180, 190,

042F, 174

35. Are containers not in use closed? Site-wide


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

36. Are refrigerators used for cold storage of flammable chemicals UL listed?

034 021, 020, 188

019, 038, 198, PHB,

047B, 147E, 064,

047A, 022, 027, 066, 023, 190, 194, 042F, 174

034 actual UL listing was not identified.

37. Are corrosive chemicals properly stored in chemical resistant cabinets with secondary containment?

022, 066, 020, 174

038, 198, 047B, 034,

047A, 021, 180, 190, 194

019, PHB, 147E,

064, 027, 188, 023,

042F

38. Are cryogens appropriately stored and managed? 038, 198, PHB, 047B, 147E,

064, 034, 047A,

021, 022, 020, 188,

174

019, 064, 027, 066, 023, 190, 194, 042F

39. Are volatile chemicals presenting an inhalation hazard stored under LEV?

038, 198, 047B, 034,

047A, 022, 194

019, PHB, 147E,

064, 021, 027, 066, 020, 188, 023, 180,

190, 042F, 174

40. Are age sensitive and peroxide forming chemicals properly stored and managed?

038, 198, 047B, 034,

047A, 022, 194

019, PHB, 147E,

064, 027, 020, 188, 023, 180,

190, 042F, 174

41. Are compressed gas cylinders properly stored, secured, and quantities limited to that immediately “in use?”

064, 047A, 066

038, 198, PHB, 047B, 147E,

034, 021, 022, 020, 180, 190, 194, 174

019, 027, 023, 042F


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

42. Are cylinders with NFPA 3, 4 (or 2 with poor warning properties) stored under continuous ventilation?

198, PHB, 047B, 147E,

064, 034, 180, 194

019, 038, 047A,

021, 022, 027, 066, 020, 188,

023, 042F, 174

190 Unknown

43. Are inventories maintained at acceptable levels in work areas?

019, 064, 027, 188, 023, 190,

042F

038, 198, PHB, 047B, 147E, 034,

047A, 021, 022, 066, 020, 180, 194,

174

Chemical Use

44. Are work areas where chemicals are dispensed and used kept clean of chemical residues, and in an orderly condition? Are housekeeping conditions adequate?

019, PHB,

038, 064, 047A,

021, 027, 020, 188, 023, 180,

190, 042F, 174

198, 047B,

034, 066, 194

45. Is there a mechanism to initiate exposure monitoring when necessary?

Site-wide

46. Is there a mechanism in place to conduct employee exposure monitoring when elevated exposures are suspected or of concern?

Site-wide

47. Is there a medical surveillance program established for work with hazardous chemicals?

Site-wide

48. Are outside researchers informed of potential chemical hazards in the workplace, and required to conform to NCAR’s chemical safety requirements?

Site-wide

49. Is there a mechanism in place to address excess and/or waste chemicals?

Site-wide See text

Engineering Controls

50. Are engineering controls used in the appropriate hierarchy for preventing overexposure to chemicals?

Site-wide

51. Is there an appropriate local exhaust ventilation (LEV) hood testing and inspection protocol?

Site-wide


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

52. Is the performance of LEV systems evaluated annually, after maintenance activities that may affect performance, and for new construction areas?

Site-wide

53. Are fume hoods uniquely identified and contain NFPA inspection information?

038, 198, 047B,

064, 034, 022, 066, 020, 188, 180, 194

019, 190, 042F, 174

PHB, 147E, 047A,

021, 027, 023

54. Are fume hoods properly used with the sash at the proper height?

Site-wide

55. Are fume hoods cluttered? 038, 198, 047B,

064, 034, 022, 066, 188, 180,

194, 042F

020, 190, 174

019, PHB, 047A,

021, 027, 023

Personal Protective Equipment (PPE)

56. Is there a PPE selection process which ensures that the appropriate equipment is selected?

Not evaluated

57. Are such gloves, eye protection, and respirators provided, easily accessible, and appropriately worn?

Not evaluated

58. Are eye and/or face protection in common use and properly used?

Not evaluated

59. Does the lab occupant wear a respirator? Not evaluated

60. Is the lab occupant aware of the NCAR written respirator program?

Not evaluated

61. Has the occupant properly selected an appropriate respirator and have fit-test protocols been followed?

Not evaluated

62. Is protective clothing such as aprons and lab coats properly worn?

Site-wide

63. Is footwear appropriate? Site-wide Chemical Inventory and Management 64. Is there a chemical inventory system readily

available listing hazardous chemicals in the workplace by name, location, and quantity?

Site-wide

65. Is the chemical inventory updated at sufficient intervals as the inventory changes?

Site-wide

66. Is the inventory used to manage chemicals such as disposing of excess/expired chemicals or determining if any less hazardous chemicals may be substituted?

Site-wide


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

67. Is the inventory used to identify and evaluate types and quantities of hazardous chemicals in the workplace?

Site-wide

Physical Plant 68. Are electrical needs being met? 019, 038,

198, PHB, 047B, 147E,

064, 034, 047A,

022, 027, 066, 020, 023, 180, 190, 194,

042F, 174

021, 188

69. Are electrical outlets appropriately placed? (e.g. are the outlets away from possible liquid contact)

019, PHB, 047B, 147E,

064, 034, 047A,

022, 027, 066, 020, 188, 023, 180, 190,

194, 042F

038, 198, 021, 174

70. Is the laboratory under negative pressure? PHB, 047B, 034,

047A, 066, 174

038, 198, 147E,

064, 021, 022, 027, 020, 188, 180, 190,

194, 042F

023 019 not checked

71. Is the laboratory purposely built as a lab? 198, PHB, 047B, 147E, 047A,

021, 066, 020, 023,

190, 042F, 174

019, 038. 064, 034

194, 180, 022, 027 unknown


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

72. If applicable, are the entries interlocked with laser activation or otherwise appropriately labeled with special hazards?

047A, 042F, 174

019, 038, 198, PHB,

047B, 147E,

064, 021, 022, 027, 066, 020, 023, 190,

194

174, 034 Labeled not interlocked

73. Are supply-air vents properly placed (ignoring fume hoods).

019, 038, 198, PHB, 047B,

064, 034, 047A,

021, 022, 027, 066, 020, 023, 180, 190,

194, 042F, 174

188

74. Are return-air vents properly placed? Site-wide

75. Are the lab hoods properly placed? (e.g. are hood located away from exits or under supply vents)?

064, 034, 022, 066

038, 198, 047B,

020, 188, 180, 190,

194, 042F, 174

019, PHB, 047A,

021, 027, 023

76. Is the laboratory sprinklered? 198, 047B, 147E,

064, 034, 047A,

021, 066, 188, 180, 190, 194,

174

038, 022, 020, 023

019 027 unknown

77. Are the floor openings sealed or curbed? 038, 047B, 147E,

034, 022, 020, 042F

019, 198, PHB, 064,

047A, 027, 066, 188, 023, 180, 190, 194, 174


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

78. Number of exits in the lab? (Do the exits meet any of the following conditions):

019, 038, 198,

047E, 064, 021, 027, 066, 188, 023,

180, 042F, 174

PHB, 034,

047A, 022, 020, 190, 194

047B

79. Does the work area contain an explosion or fire hazard so that an incident would block escape from or access to the laboratory work area?

047B, 047A

019, 038, 198, PHB, 147E,

064, 034, 022, 027, 066, 020, 188, 023, 180, 190,

194, 042F, 174

80. Is there a hood in a laboratory work area located adjacent to the primary means of exit access?

038, 047B,

020, 188, 180, 190,

194, 042F, 174

019, 198, 147E,

064, 034, 047A,

022, 066, 023

PHB, 027

81. Are all exits free and clear? (Free egress from all points in the lab?)

038, PHB, 147E,

064, 021, 027, 020, 023, 180,

042F, 174

019, 198, 047B, 034,

047A, 022, 066, 190, 194

82. Are exits properly identified? 042F 019, 038, 198, PHB, 047B, 147E,

064, 034, 047A,

021, 022, 027, 066, 020, 188, 023, 180, 190, 194,

174


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

83. Does an egress lead into another lab? 047B, 047A,

020, 190, 194, 042F

019, 038, 198, PHB, 147E,

064, 034, 022, 027, 066, 188, 023, 180,

174

84. Do the egress doors swing in the direction of egress?

042F 038, 198, PHB, 047B, 147E,

064, 034, 047A,

021, 022, 066, 020, 188, 023, 180, 190, 194, 174

019, 027

85. Are non-exists identified? 047B, 034,

047A, 021, 022, 020, 023, 180, 190, 194, 174

019, 038, 198, PHB, 064, 027, 066, 188,

042F

86. Does the emergency lighting work? Not evaluated

87. Are fire extinguisher visible/accessible? 019, 038, 198, PHB, 047B, 147E,

064, 034, 021, 022, 027, 066, 020, 188, 023, 180, 190, 194,

042F, 174

047A,

88. Are fire alarms accessible in the lab? Site-wide

89. Have plans for laboratory emergencies been developed (including clothing fires)?

Site-wide

90. Is the lab being continuously ventilated? Site-wide

91. Are all exhaust/return ducts negative? Not evaluated


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

92. Has the exhaust termini from this lab been observed?

Unknown – site wide

Employee Information and Training

93. Are workers aware of the locations of MSDSs? Site-wide

94. Are workers informed about the presence of hazardous chemicals in their work area, and the required protective measures to be used?

Site-wide

95. Is a procedure established in case of an accidental spill or release?

Are workers informed on the procedures?

Site-wide

96. Are “Designated Work Area” signs posted in laboratories where extremely hazardous (highly toxic, select carcinogens) chemicals are used?

Site-wide

97. Have fire drills been conducted in the last 12 months?

Site-wide

Emergency Response and Equipment 98. Are safety showers and/or eye washes

appropriately identified and:

located in areas where workers may be exposed to spills or splashes of hazardous chemicals?

Access is unobstructed and within 10 seconds travel time of the hazard?

Inspected and flushed at sufficient intervals with the date of inspection posted?

038, 198, 064, 021, 022, 020, 180, 190,

194, 042F, 174

047B, 147E, 047A,

066, 188

034, 021

064, 034, 047A,

022, 020, 194

019, 027, 023

Not checked

99. Are chemical spill kits readily available and appropriate?

038, 198, 047B, 034,

047A, 021, 066, 188, 180, 190, 194,

174

019, PHB, 147E,

064, 027, 023


Condition

Yes or

A or 1

No or B or 2

NA or C or 3

Comment or D or 4

100. Is an appropriate emergency chemical spill procedure established?

Site-wide

101. Are emergency telephone numbers posted at each work location?

Not evaluated

Special Procedures for Laboratories 102. Is a written plan established and available for

unusual procedures? Site-wide Lab 034

apparently has a written procedure, however, the occupants may have neglected to recall the documents in the interview.

Are additional provisions provided for work with extremely hazardous (highly toxic) chemicals?

Site-wide

103. Are Safe Operating Procedures available for work with extremely hazardous (highly toxic) chemicals?

Site-wide

104. Are procedures established for work with laboratory equipment?

Site-wide

Documents

Select Industrial Hygiene Assessment at the NCAR/UCAR ......Select Industrial Hygiene Assessment at the NCAR/UCAR Mesa Laboratory Boulder, Colorado Submitted to Melinda Powers, CIH