I. Introduction
The central component of the OSHA Lab Standard and the EPA Laboratory Environmental Management Standard are the Chemical Hygiene Plan and the Environmental Management Plan (EMP), respectively. These are 'action plans' which describe in detail the methods to be employed in reaching the goals set by the Standards. The CHP establishes appropriate work practices, standard operating procedures, methods of control, measures for appropriate maintenance and use of equipment, medical examinations, and special precautions for work with particularly hazardous substances. The EMP establishes minimum performance criteria, environmental objectives, and targets standard operating procedures for waste material, identification of waste material, transport of waste material, control measures, pollution prevention and inventory management.
Minimum requirements for the three key elements of the Chemical Hygiene Plan, Administrative, Operational, and Instructional are stipulated in the OSHA Standard: (see 29 CFR 1910.1450, EHS Manual 4.1). Additionally, Minimum Performance Criteria for the Environmental Management Plan are stipulated in the EPA Standard (see 40 CFR 262 Subpart J, EHS Manual 4.2).
A. THE OSHA LABORATORY STANDARD AND THE CHEMICAL HYGIENE PLAN
Prior to 1991, federal regulations regarding the potential exposure to chemical hazards were primarily directed toward the manufacturing and industrial sector. Since exposures in these sectors result from continuous and repetitive processes, control procedures prescribed under existing Standards are often ill-suited to the highly dynamic laboratory setting. To rectify this situation, in 1991 the Occupational Safety and Health Agency (OSHA) enacted the Lab Standard ("Occupational Exposure to Hazardous Chemicals in Laboratories Standard", 29 CFR 1910.1450), which states:
"The Laboratory Standard...is designed to provide a comprehensive approach for the protection of laboratory workers which is more appropriate to laboratory conditions than compliance with the substance specific standards in 29 CFR part 1910, subpart Z. The Laboratory Standard requires that employers protect workers through the development and implementation of work practices and control measures expressly tailored to the individual laboratory workplace."
The University of Massachusetts Boston, as an institution of the Commonwealth of Massachusetts, is not formally bound by federal occupational health standards. Nonetheless, it is the intent of UMB, in order to achieve clarity, consistency, and efficient integration of policies and procedures necessary to ensure the health and safety of the workplace population, to model its programs on the federal standards wherever feasible. In addition, while the intent of the Chemical Hygiene Plan and its associated standard is to prevent negative health effects arising from exposure to toxic and hazardous chemicals, procedures to control negative physical effects will also be addressed, either directly or by reference to the appropriate UMB policy, plan or program.
THE UMB CHEMICAL HYGIENE PLAN
The central component of the standard is the requirement for a Chemical Hygiene Plan. The Chemical Hygiene Plan (CHP) is an 'action plan' which describes in detail the methods to be employed in reaching the goals set by the Lab Standard. Specifically, the CHP establishes appropriate work practices, standard operating procedures, methods of control, measures for appropriate maintenance and use of equipment, medical examinations, and special precautions for work with particularly hazardous substances.
Minimum requirements for the three key elements of the Chemical Hygiene Plan-- Administrative, Operational, and Instructional--are stipulated in the OSHA Standard: (All references are to 29 CFR 1910.1450, which is located in the EHS Manual, section 4.1).
Administrative:
Section (e)(3)(vii) - Designation of Responsible Parties for Implementation of the Chemical Hygiene Plan.
Operational:
Section (e)(3)(vi) - Provisions for Medical Consultation
Section (e)(3)(iii) - Monitoring and Maintenance of Engineering Controls
Sections (e)(3)(i,ii,v,viii) - Standard Operating Procedures
Instructional:
Section (e)(4); Section (f).
B. THE EPA ENVIRONMENTAL MANAGEMENT STANDARD AND THE ENVIRONMENTAL MANAGEMENT PLAN
In September of 1999, the Environmental Protection Agency and three academic institutions (Boston College, University of Massachusetts-Boston and University of Vermont) signed an agreement under the EPA's Project XL program to pilot a new system of managing hazardous wastes in laboratories. Similar to OSHA's Laboratory Standard, the Environmental Management Standard was developed to replace EPA's hazardous waste requirements that are more applicable to industrial facilities. Coinciding with the agreement, the EPA promulgated new regulations under 40 CFR Subpart J (University Laboratories XL Project - Laboratory Environmental Management Standard), which states:
"This subpart provides a framework for a new management system for wastes that are generated in University laboratories. This framework is called the Laboratory Environmental Management Standard. The standard includes some specific definitions that apply to the University laboratories. It contains specific requirements for how to handle laboratory waste that are called Minimum Performance Criteria. The standard identifies the requirements for developing and implementing an environmental management plan."
UMass Boston is bound to this agreement for the four year duration of the pilot program.
