Analyzing the Role of the Chemical Hygiene Officer in Scientific Laboratories: A Professional Position on Regulations, Function, and Needs for Program Effectiveness

ABSTRACT

Work-related hazards and risks continue to be a challenge in workplaces across industry. It is no secret thatengineering and administrative control measures are critical for protecting employees, and despite thisknowledge, protecting employees using properly implemented occupational safety and health (OSH)programs remains to be a continuous challenge. Although fatality rates have decreased over the past severaldecades, the overall numbers of occupational accidents and work-related diseases occurring globallycontinues to be a serious problem. Globally, there are hundreds of millions of occupational injuries anddiseases, both fatal and non-fatal, every year, even in the United States, which has a prevalent and activeagency, the Occupational Safety and Health Administration (OSHA) that addresses OSH. Nevertheless,injury and illness occurs in a great multitude of professions, job tasks, and industries, including in scientificresearch and academic laboratories, which are often left out of the conversation about high-risk industrialenvironments, despite the traditional uses of highly hazardous chemicals and processes. Although twentyyears have elapsed since OSHA refined the scope of the 29 Code of Federal Regulations (CFR) 1910.1200 –Hazard Communication, and promulgated a second right-to-know (RTK) standard, CFR 1910.1450 –Exposure to Hazardous Chemicals in Laboratories to specifically address requirements for limiting chemicalexposure at laboratory scale, the required designation within the OSHA Lab Standard of a chemical hygieneofficer (CHO) is singularly insufficient to implement an effective chemical hygiene plan (CHP).