Notes about inspections: 

last update 03/22/2005 12:54 PM

  1. The rules are made by OSHA, EPA, DOT, NRC... and Purdue, not by Chemistry or anyone in Chemistry.  And not by REM.
  2. It is often not possible for REM staff or Dr. Swihart to spend time defending the rules but they will try to explain as times permits.  There are usually good reasons for the rules, but they are hard to see for people who are not in the occupational safety or regulatory compliance business.  And even when there are not good reasons, or we can't understand them, we still have to obey the rules.
  3. The inspections are about all kinds of safety, not just chemicals, not just labs.
  4. Inspections are conducted by REM staff, although Dr. Swihart commonly participates since she is a REM staff member as well as a Chem staff member.
Note #. "Quoted...." represents the standard wording REM uses for the "item of  concern."  Actual inspection reports may contain slightly different wording.
Note 1.  "Possible potable water supply cross connection exists."  Hose(s) from spigot placed inside drain and/or touch bottom of basin. Cut hose(s) to a length no more than halfway below flood plane."  (Cited xx times in BRWN, xx in WTHR) NPCW buttons on taps do NOT mean that the water is from a non-potable supply.  That's the same water that goes to the drinking fountains.  Indiana Board of Health rules state that you can't hang a hose into a place where contaminated water might pool.  Period. More, with photos and drawings...
Note 2.  "Containers of chemicals are inadequately labeled. If acronyms, formulae, or abbreviations are used, post a legend/key near inside of entrance to room." (Cited xx times in BRWN, xx times in WTHR) Labels must convey info that will allow a custodian, fire-fighter, emergency responder..... to look up chemical names in an MSDS collection.  No abbreviations, acronyms, or formulae will permit this unless somewhere near by, prominently, is a poster or multi-page document with a title that conveys the information:
    "HERE'S WHAT ALL OUR ABBREVIATIONS STAND FOR...."  
NaOH = sodium hydroxide
AlCl3 = aluminum chloride ....
The Acronyms.xls document from REM provides a starting point or you can simply print and hang it PROMINENTLY nearby.  Make sure it has all your acronyms, abbrevs, and formulae...
Note 3.  "Display written SOP for accessing extremely high containers of liquids, or move containers of liquids stored above eye level to eye level or below."

Click on photo to enlarge.  Some example photos are staged and many are of genuine (former) violations.  This photo is not to be interpreted as deriving from the particular building/room inspection link which led you here. 

Example SOP for high liquid storage.  [You also have the option of just moving the liquids down to eye level or below instead of writing and posting the SOP.  If you do this as your correction, note it on the corrections report as "moved liquids."]

  
Note 4.  "Chemical containers have labels that are deteriorating and/or unreadable."

Click on photo to enlarge.  Some example photos are staged and many are of genuine (former) violations.  This photo is not to be interpreted as deriving from the particular building/room inspection link which led you here. 
Note 5.  "Emergency telephone numbers (24 hours) must be posted on outside of
lab door(s)"  (Cited xx times in BRWN, x times in WTHR)

The room pictured at right is minimally, but adequately, posted with emergency info.  (It's a lot more like DoorPosterB below than DoorPosterA.)

Print and use one of the templates, or devise your own. [DoorPosterA.pdf] [DoorPosterB]

 
Note 6.  "Failure to designate areas for select carcinogens..."
 		The OSHA Laboratory Standard requires that if you use or store "select carcinogens, reproductive toxins or substances which have a high degree of acute toxicity,"  then you must designate an area or areas for their use.  Definitions and guidance relevant to these terms are given in the Lab Standard.  Also see Purdue's most up-to-date list, with further explanation. 

At left is the sticker which is available from Purdue for the purpose of designating an area if you don't want to invent your own sign.

Pay very close attention to what happens if you designate an entire room as the designated area.
Note 7.  "Unsecured or inadequately secured compressed gas cylinder(s).  Uncapped cylinders without regulators are unacceptable. Cylinders with regulators should be secured individually."

The standard text at left describes at least four different cylinder problems.  (completely unsupported, or supported with wrong means -- i.e. tied up with tygon/pantyhose/coat-hanger, or ganged up behind a single support when not capped, or not having a regulator while uncapped
   
Here are the most commonly violated rules
  1. All cylinders must be supported by a strap or chain made for the purpose, at all times except for the brief moments while you're moving it from cart to a secured location or vice versa. Strap or chain is to be slightly above the center of gravity, and not around the valve and delivery pipe area.  
  2. If it doesn't have a cap on it, then has to be supported separately -- has to have its very own chain or strap and not share it with anything else.
  3. If it doesn't have a regulator on it, it has be capped. If it isn't capped, it has to have a regulator on it.
  4. If it's on a cart it has to be capped. Dispensing from a cart is not safe, not allowed.  (Wording at left does not cover this one.)
Note 8.  "Obstructions, including storage, shall not be placed...."  "Means of egress are obstructed or impeded by...."   "Corridor obstructed. Remove equipment/box/papers/table......"  "Eyewash and/or shower is obstructed...." Commonly obstructed items often not entirely obvious to staff.
  

  
See some staged 
and some real
 photos of obstructions  
to egress, eyewash/shower, 
fire extinguisher...
   
  1. Egress - corridor, doorway, aisle.
  2. Corridor  (corridor generally = main building corridor)
  3. Aisle (aisle = any walking-thorough space in work area
  4. Eyewash/shower
  5. Fire extinguisher
Note 9.  "No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material."  THE MOST COMMON CIRCUMSTANCE under which this is cited in laboratory buildings (and which has nothing to do with toilet rooms but that's the wording of the regulation) is in a room which has the "designated area sticker" affixed to the door (see note 6 above).  Affixing the sticker to the door causes the entire room to be designated for "select carcinogens, reproductive toxins...." and therefore precludes any eating or drinking in the room.

If you wish to retain an area within a lab for a "break area," do not post the entire room as a designated area for chemicals requiring designated areas.  Post smaller areas within the lab as the designated areas -- hoods, particular benches -- and then abide by the designations.
Note 10.  "Excessive fire fuel loading (paper and/or other combustibles)." This is often ended with "Storage is unstable as well as a fire hazard."

Where there is a lot of loosely stored cardboard, paper, plastic, this violation will be cited.  Not because it guarantees a fire, but because it guarantees that a small fire will quickly become a large fire.
Note 11.  "Failure to post written Hazard Assessment Certification."  OSHA regulations require that hazards in each workplace be assessed and that a written certification of this hazard assessment be posted, which includes all required PPE and the conditions under which it is required.  There are are several formats which can be used to accomplish this and they are available: blank form, by task,   blank form, by position description,   modifiable template Word doc, and PDF version of same (not modifiable unless you have Acrobat Exchange).  

 

 

Fire doors, non-fire doors

 

 

 

  Compressed Air 30 psi nozzle.