Re: OSHA Regs

From:Dave Low

Hi Thomas,

  I tried to pull up the OSHA reg via and with no luck.  It was my understanding
the nfpa diamond codes is not needed, but a label that
will interpret the target organ is acceptable.  The
reason is a layman would not understand the coding,
but a label describing the effects would.  Don't laugh
but I did what your safety committee requested.  Now
picture putting those diamond labels on a bottle of
Gomori's Trichrome!
  The only idea I have is to have a poster or a word
document with the chemical hazards,target organ, and
Personal Protective Equipment (PPE).  An example;

Chemical          Hazard    Target organ    PPE
Absolute Alcohol  Flammable Liver      Nitrile &
                                       gloves  glasses

Posting this in your special stain area will save on
purchasing new jars but more effective than a diamond
with numbers that you will have to interpret. You can
also e-mail and recommend to get
information from the nsh safety officer.  In any
case,Good luck!

Dave Low
Elmendorf Med Ctr

--- "Jasper, Thomas"  wrote:
> My fellow histonetters,
> I have some OSHA regulations questions. However, I
> would first like to join
> my fellow Americans in thanking all of our
> international colleagues for the
> kind words and support following the unbelievably
> insane events of last
> Tuesday. When the chips are down you really find out
> who your friends are
> and you people are great!
> My lab just had an internal safety
> inspection(laboratory safety committee).
> I was informed that we were in violation of OSHA
> regulations{Sec.1910.1200(g)(2)(viii)}referring to
> items 5, 6 and 7 in
> particular, dealing with the hazardous labeling of
> secondary containers.
> This totally took me by surprise. We were just CAP
> inspected in June and
> passed with flying colors. I know CAP and OSHA stand
> on their own, but we
> went to great lengths to have everything properly
> labeled, stored etc.
> We have huge 3 ring binders with MSDS sheets for
> every chemical, dye and
> reagent in use here. Our cupboards have notices on
> them(black lettering on
> yellow paper). The notices read "Warning: Chemical
> Hazard. All
> solutions/reagents contained herein are for daily
> use and are handled by
> trained personnel only." The MSDS sheets are on a
> book shelf within 10 feet
> of the farthest cupboard. All staff are registered
> HT(ASCP),one is registry
> eligible(the only exception).
> The rub is on the special stain set-ups that we
> leave out on our counter.
> Some in Coplin jars(GMS i.e., except for the silver
> of course), some in
> smaller slide jars(20 ml, 4 slide max., for
> Trichhrome, AFB, etc). These are
> all properly labeled, dated and changed out as
> needed, sometimes daily at
> the most weekly, all in a clean properly ventilated
> area. The interpretation
> of the OSHA regs from the safety committee is that
> we need to be putting the
> hazard rating diamonds that you see on all reagent
> and chemical containers
> on everyone of these little jars that we make up and
> change out so
> frequently. The exception being a solution that is
> discarded after one use
> or for sure daily.
> I am wondering what people out there think about
> this? I am all for safety
> and would never knowingly violate an OSHA reg. On
> the other hand I do not
> believe in creating busy work for my staff, I feel
> this is overkill. I used
> to sit on the safety committee and believe in
> compliance with all regulating
> agencies. I also believe in the common sense of my
> properly trained staff,
> safe laboratory practices(we have an annual safety
> compliance requirement
> for all staff)and letting people work responsibly
> without holding their
> hand. Perhaps I am all wet, I don't claim to be an
> expert on OSHA reg
> interpretation and will comply in whatever way is
> required. I'm just
> wondering if some of you out there are more expert
> than myself. I appreciate
> the feedback. Sorry about rambling so long.  
> Thomas Jasper HT(ASCP) BAS
> Histology Team Leader
> SMDC Clinical Laboratory
> Duluth, MN

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