Laboratory Design Newsletter 2012 Selected Abstract

St John's University Challenge: Upgrade St. Albert Hall Science Building for Sustainability and OSHA Laboratory Standard

Robert Morris, Flow Safe

Abstract

The death of UCLA researcher Sheri Sangji and subsequent felony charges filed against UCLA, the principal investigator (PI), and others for failing to follow OSHA regulations has brought new challenges to chancellors and provosts of research universities, pharmaceutical/chemical laboratory owners, industrial hygienists, PIs, and laboratory design professionals because there is no "grandfather" allowance from OSHA's maximum achievable and affordable worker safety control requirements. The challenge is even greater for older laboratories such as the St. Albert Hall Science Building, which opened in 1957. The real issue is that 95 percent of hoods in service today fail to meet the 1990 Federal OSHA Lab 29 CFR Part 1910 standard requiring vapor, splash, and explosion worker protection from hazardous chemicals.

Fume hoods are laboratory workers' primary personal protective equipment (PPE) for hazardous chemicals as defined by OSHA. The OSHA federal law mandates that all state OSHA programs adopt federal standards protecting laboratory workers. The OSHA standard should have created a paradigm shift in laboratory worker safety by abandoning face velocity as the performance criterion protecting workers from hazardous chemicals, but it did not. The hood is designed and specified by architects and manufactured and installed by carpenters as furniture. They never complied with OSHA requirements and few employers, industrial hygienists, or laboratory design professionals ever read or understood the impact of this law and its changes on worker safety, until now. The use of fume hood face velocity as the hazardous chemical performance measurement has denied the workers their right under the law to medical evaluation.

Items Addressed

  • The federal OSHA laboratory standard is not prescriptive but a performance-based regulation. This is a departure from previous OSHA regulation based on anecdotal prescriptive safety myths. Why the change? As the preamble of the regulation details, these anecdotal safety myths were the cause for laboratory workers' increased morbidity rates including offspring deformities. To understand the subtlety of these changes, Flow Safe obtained clarification statements from the responsible people at OSHA and NIOSH.
  • Recent case law decisions reinforce the fact that the employer and chemical health officer shoulder the major responsibility for laboratory worker safety. The laboratory design professional with the singular responsibility to protect the public is responsible for supplying a laboratory environment where a feasible chemical safety plan following OSHA-published requirements protecting the laboratory worker is even possible.
  • Can a laboratory design professional redirect responsibility onto others even if licensed or certified? Who is responsible for following OSHA laws, codes, or ANSI standards? Can these responsibilities be passed on to a manufacturer? Case law differentiating performance and design specifications helps in understanding the legal responsibility.
  • St. John's is committed to reducing its greenhouse gas emissions. The St. Albert Hall Science Building was one of four projects in St. John's larger energy capital master plan, which was awarded an ARRA matching fund grant. St. John's goal is to lower carbon emissions by 15,000 tons annually from a base year 2007 inventory of 49,000 tons. Faced with OSHA and energy issues at St. Albert Hall, the St. John's plan successfully balanced OSHA environmental health and safety with sustainability.

The Solution
 
The "owner requiring zero risk guarantees" drove the answers: project cost, operational disruption, energy savings, and worker safety. Flow Safe has created a process where even existing asbestos hoods can be field-converted into "just like new" hoods that meet OSHA, fire code, and the AIHA Z 9.5 2012 laboratory standard. Flow Safe guarantees that the energy savings and the hood will meet OSHA vapor, splash, explosion, and tracer gas testing at zero spill, even in worker abuse conditions. The cost to demolish, install, re-balance, and test a new hood is between $27,000 and $37,000 with no guarantees and risk. It costs $11,000 to $13,000 to field-convert, balance, and test an old hood during off-hour operation. The converted hood will reduce exhaust air by 65 percent, saving $5,000 to $9,000 a year in energy cost without maintenance-intensive complicated controls. The picture illustrates the before and after results.

Figure 1