Saturday, January 19, 2013

OSHA Address Laboratory Security

The Monday Federal Register (available on-line today) will contain (78 FR 4324-4331) an OSHA technical amendment to their laboratory safety standard (29 CFR 1910.1450). That amendment revises Appendix A, the National Research Council Recommendations Concerning Chemical Hygiene in Laboratories (Non-Mandatory).

According to the Background section of the technical amendment:

“This new revision addresses current laboratory practices, security, and emergency response, as well as promoting safe handling of highly toxic and explosive chemicals and their waste products.”

Appendix A

This appendix to the OSHA lab safety standard is based upon the National Academy of Sciences publication entitled, “Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards”. This technical amendment is based upon the latest version of that publication, the 2011 edition.

The summary of the technical amendment contains a misleading statement about this revision. It states that: “All revisions being made are minor and non-substantive.” Since this is a complete re-write of Appendix A, I can only assume that it means that changes being made from the 2011 NAS publication are minor and non-substantive.

Laboratory Security

For the first time, Appendix A addresses lab security issues (78 FR 4331). It is not an attempt to provide specific guidance on security procedures, but rather a broad overview of security issues that should be taken into account when establishing a laboratory security plan. For example it provides a brief list of security risks:

• Theft or diversion of chemicals, biologicals, and radioactive or proprietary materials, mission-critical or high-value equipment;

• Threats from activist groups;

• Intentional release of, or exposure to, hazardous materials;

• Sabotage or vandalism of chemicals or high-value equipment;

• Loss or release of sensitive information; and

• Rogue work or unauthorized laboratory experimentation.

It notes that a good lab security program will achieve three goals:

• Increase overall safety for laboratory personnel and the public;

• Improve emergency preparedness; and

• Lower the organization's liability.

Given the short coverage (210 words) to lab security and the wide variety of organizations potentially affected by the Appendix, this is not a bad overview of the topic. And since it is the first time that the lab safety standard actually addresses the topic, it is a good introduction to the topic.

Effective Date

This technical amendment goes into effect upon publication on Monday without any provisions being made for public comments and agency response. OSHA notes that this is possible because “the amendment does not modify or revoke existing rights or obligations, and does not establish new rights or obligations”, making it ‘unnecessary’ under 5 USC §553(b)(3)(B).

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