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OSHA 1915.1450

Hazardous chemicals in laboratories

Subpart Z

26 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1450, what is a Chemical Hygiene Plan (CHP) and do I have to have one for my shipyard laboratory?

Yes. Under 1915.1450 employers must develop and implement a written Chemical Hygiene Plan (CHP) for laboratories where hazardous chemicals are used.

  • The CHP documents procedures, work practices, and policies to protect employees who work with hazardous chemicals. See the lab standard at 1915.1450 (requirements are identical to 1910.1450).
  • Include responsibility assignments (e.g., who is the Chemical Hygiene Officer), procedures for fume hood use, training, medical consultation, and exposure control measures in the CHP.

Under 1910.1450, who must be designated as the Chemical Hygiene Officer (CHO) and what are their basic duties?

Under 1910.1450 the employer must designate a Chemical Hygiene Officer (CHO) who is responsible for implementing the CHP and ensuring compliance.

  • The CHO should be someone knowledgeable about laboratory operations and hazardous chemicals and must have authority to implement safe work practices identified in the CHP; see 1910.1450.
  • Typical duties include developing procedures, training, monitoring fume hood performance, arranging medical consultations, and advising supervisors and workers on safe handling and controls.

Under 1915.1450, what kind of training do employees need before they work with hazardous chemicals in a shipyard laboratory?

You must train employees before they work with hazardous chemicals and whenever procedures or hazards change.

  • Training must cover methods to detect exposures, hazards of chemicals used, measures to protect themselves (PPE, engineering controls, work practices), and details of the CHP; see 1915.1450 and 1910.1450.
  • Keep training records and re-train when new hazards or procedures are introduced.

Under 1910.1450, when is medical consultation or medical examination required for laboratory workers?

Medical consultation or examination is required when an employee shows signs or symptoms from a chemical exposure, or when an exposure incident, spill, or overexposure occurs.

  • The lab standard requires employers to provide medical consultation and examinations at no cost when exposures occur, when monitoring indicates exposure above action levels, or upon request following symptoms; see 1910.1450.
  • Document referrals and follow-up; use the CHP to define when and how to obtain medical services.

Under 1915.1450, are laboratories required to use fume hoods for all hazardous chemicals?

Not for all hazardous chemicals, but the CHP must specify when local exhaust (like a fume hood) is required and ensure it is used when procedures can release airborne hazards.

  • The standard expects employers to use engineering controls such as fume hoods when they are the primary way to limit employee exposures; see 1915.1450 and 1910.1450.
  • The CHP should also include performance checks and procedures for hood use, and training so employees know when a hood is required.

Under 1910.1450, how should a lab decide whether to use PPE or rely on engineering controls like ventilation?

You must prioritize engineering controls and safe work practices, and use PPE as a supplement when those controls do not fully protect employees.

  • The lab standard requires employers to select controls in the order of preference: engineering controls (ventilation, enclosures), administrative controls (procedures, limits), and PPE last; see 1910.1450.
  • Your CHP should document how exposures are evaluated and why chosen controls (including PPE) provide adequate protection.

Under 1915.1450, what records must be kept for chemical exposures and training in shipyard labs?

Employers must keep records of employee training, medical consultations/examinations, and any exposure monitoring performed under the CHP.

  • The standard directs that training dates and content and medical records related to chemical exposure be maintained as part of compliance with 1915.1450 (see also 1910.1450).
  • Keep records in accordance with applicable OSHA recordkeeping rules and the CHP; medical records may be subject to the recordkeeping requirements in other OSHA standards.

Under 1910.1450, how do I identify which chemicals in the lab need special procedures in the CHP?

Identify chemicals that present significant health hazards—such as carcinogens, reproductive toxins, highly toxic substances, or substances that can generate airborne exposures—and include special procedures in the CHP.

  • The lab standard requires employers to evaluate the hazards of chemicals used and establish specific practices, engineering controls, and PPE when a chemical’s hazards merit it; see 1910.1450.
  • Use Safety Data Sheets (SDSs), hazard communication information, and workplace exposure data to decide which chemicals need written procedures in the CHP.

Under 1915.1450, does the shipyard lab standard require exposure monitoring (air sampling) for hazardous chemicals?

The standard requires exposure monitoring when necessary to determine the adequacy of control measures or when employees show signs of exposure.

  • 1915.1450 (identical to 1910.1450) indicates employers must evaluate exposures and may need monitoring to verify controls provide protection.
  • Use monitoring results to update the CHP, add controls, or provide medical follow-up as needed.

Under 1910.1450, are work with small-scale lab quantities exempt from the lab standard?

No. The lab standard covers hazardous chemical use in laboratory settings regardless of quantity, as long as the work is laboratory-scale and uses hazardous chemicals for research, teaching, or analysis.

  • 1910.1450 applies to laboratories that meet the standard’s definition of laboratory facilities and laboratory-scale operations; it is not a blanket exemption for small quantities.
  • The CHP must describe safe procedures even for small-scale operations and evaluate whether specific controls or PPE are needed.

Under 1915.1450, can the shipyard lab standard cover non-routine tasks, like maintenance or cleaning that involve hazardous chemicals?

Yes. Non-routine tasks that involve hazardous chemicals must be evaluated and controlled and should be addressed in the CHP.

  • The standard requires that the CHP include provisions for handling non-routine tasks and emergency situations; see 1915.1450 and 1910.1450.
  • For maintenance or cleaning, document procedures, required PPE, and any special engineering controls in the CHP prior to starting work.

Under 1910.1450, how should a lab handle a chemical spill or emergency involving hazardous laboratory chemicals?

The CHP must include written emergency procedures for spills, exposures, and evacuations and ensure employees are trained to follow them.

  • Include spill response steps, required PPE, who to notify, decontamination procedures, and medical follow-up in the CHP; see 1910.1450.
  • Train employees to use spill kits and follow emergency procedures and coordinate with building emergency services when required.

Under 1915.1450, do shipyard laboratories have to follow the Hazard Communication Standard for chemical labeling and SDSs?

Yes. Labs must follow hazard communication for labeling and access to Safety Data Sheets (SDSs); the lab standard is consistent with the Hazard Communication Standard.

  • 1915.1450 aligns with requirements found in 1910.1450 and the broader hazard communication requirements in 1910.
  • Ensure chemicals are labeled, SDSs are accessible to employees, and training covers interpreting SDS information.

Under 1910.1450, do laboratory supervisors need to document why they chose a control method (for example, why a fume hood instead of gloves)?

Yes. The CHP should document how control measures were selected, including why engineering controls were chosen and where PPE is used as supplementary protection.

  • 1910.1450 expects the CHP to describe methods and rationales for controlling exposures and the procedures employees must follow.
  • Keeping written justification helps demonstrate compliance and supports training and audits.

Under 1915.1450, are compressed gas cylinders used in shipyard labs covered by the lab standard or other OSHA standards?

Compressed gas cylinders are subject to the lab standard for chemical hazards but also must comply with specific standards that address cylinder storage, securing, and handling.

  • Use the CHP to address safe handling, storage, and use of cylinders as required by 1915.1450 and reference relevant general industry standards in 1910.
  • For large quantities of flammable gases stored on site, consult the PSM interpretation on flammable gas aggregation because aggregating pre-charged equipment or cylinders may trigger 29 CFR 1910.119 coverage.

Under 1910.1450, when should a lab consider respirators for chemical protection?

Respirators should be used when engineering and administrative controls cannot reduce exposures to safe levels or during certain non-routine operations; they must be part of a formal respiratory protection program when required.

  • The lab standard requires employers to select controls that protect employees and to use respirators only as needed; see 1910.1450.
  • When respirators are necessary, follow the Respiratory Protection Standard and guidance about oxygen-deficient or IDLH atmospheres from the Oxygen-deficient atmospheres interpretation and applicable 1910 requirements.

Under 1915.1450, does the lab standard require medical records to be kept for employees who use respirators or are exposed to hazardous chemicals?

Yes. When medical examinations or consultations are provided under the CHP or other standards (such as for respirator fit or exposure incidents), employers must keep appropriate medical records.

  • 1915.1450 (and 1910.1450) require medical follow-up and recordkeeping related to exposures addressed in the CHP.
  • Respirator medical evaluations and fit-testing are governed by the Respiratory Protection Standard; keep records in line with that standard and your CHP.

Under 1910.1450, can routine equipment maintenance that requires power be done without lockout/tagout in a laboratory?

Not automatically; if the minor servicing exception does not apply, you must follow lockout/tagout procedures or the temporary re-energization steps in the LOTO standard for testing or positioning.

Under 1915.1450, how should a lab address hazards from chemicals that may form explosive atmospheres or flammable gases?

The CHP must identify flammable or explosive hazards and require engineering controls, safe procedures, and storage limits; large on-site quantities may trigger other standards.

  • Address safe handling, ventilation, and storage in the CHP under 1915.1450 and 1910.1450.
  • If aggregated quantities of a Category 1 flammable gas exceed thresholds, consult the PSM aggregation interpretation because Process Safety Management (29 CFR 1910.119) may apply.

Under 1910.1450, does the lab standard require routine inspection or certification of fume hoods, and how should that be documented?

Yes. The CHP should include regular checks and performance tests of fume hoods and document maintenance and functional testing.

  • The lab standard expects employers to ensure engineering controls remain effective; include hood inspection frequency and performance verification in the CHP as required by 1910.1450.
  • Keep records of inspections, repairs, and face-velocity or smoke tests to show the hood provides required protection.

Under 1915.1450, are shipyard laboratory workers covered if they perform laboratory-type duties on a ship?

Yes. The shipyard lab standard at 1915.1450 applies to laboratory operations in shipyard employment and is identical in requirements to 1910.1450.

  • If laboratory chemicals are used in shipyard settings, employers must implement a CHP and applicable protections for employees as described in the standard.

Under 1910.1450, what must be included in laboratory employee training regarding Safety Data Sheets (SDS)?

Training must teach employees how to read and use SDSs to learn about hazards, safe handling, required PPE, and emergency measures.

  • 1910.1450 requires training that covers the hazards of chemicals used in the lab and the information employees need from SDSs.
  • Make SDSs readily accessible and include exercises in training that show employees where to find exposure limits, first-aid measures, and spill response instructions.

Under 1915.1450, what should a CHP say about working alone in a laboratory with hazardous chemicals?

The CHP must address policies for working alone if it increases risk and include measures to ensure employee safety, such as limits on lone work or added controls and emergency contact procedures.

  • 1915.1450 requires the CHP to consider hazards that occur during normal and non-routine operations; working alone with hazardous chemicals is a scenario that should be evaluated.
  • If lone work is permitted, document additional controls, communication checks, and emergency procedures in the CHP.

Under 1910.1450, must a laboratory include provisions for pregnant workers or reproductive hazards in the CHP?

Yes. The CHP should identify reproductive hazards and include measures to reduce exposures and provide medical consultation options for affected employees.

  • 1910.1450 requires evaluating chemical hazards and protecting employees; reproductive toxins warrant special consideration in the CHP.
  • Provide information in training, control measures, and access to medical advice when exposures are possible.

Under 1915.1450, how should labs manage controlled substances or highly toxic chemicals that have special regulatory controls?

The CHP must address the special handling, storage, access controls, and disposal measures for highly toxic chemicals and controlled substances in accordance with applicable laws and regulations.

  • 1915.1450 requires specific procedures for highly hazardous chemicals; include restricted access, inventory controls, and training.
  • Coordinate with institutional compliance offices and follow any additional federal or state regulatory requirements beyond the lab standard.

Under 1910.1450, how often should the CHP be reviewed and updated?

The CHP should be reviewed periodically and updated whenever there are changes in procedures, new hazards, or when monitoring or incident results indicate the plan is inadequate.

  • 1910.1450 expects employers to maintain an effective CHP, which implies regular review and updates as conditions change.
  • Document reviews, the reasons for updates, and employee re-training when the CHP changes.