Overview
Entrances to areas where hazardous chemicals are stored are not identified with a laboratory door placard, or the placard and/or hazard assessment is illegible or inaccurate.
This checklist item comes primarily from two regulatory sources National Fire Protection Association (NFPA) 45 and the OSHA Hazard Communication Standard, 29 CFR 1910.1200. Most of the OSHA Haz Com standard does not apply to laboratories. However, laboratories are not exempt from paragraph (h), which pertains to employee information and training. This paragraph basically says that employees must be informed of the chemical hazards in the work area.NFPA 45, 13.1.1; 29 CFR 1910.1200(h)(2) and (3); UNL Chemical Hygiene Plan
NFPA requires signs to alert emergency response personnel of hazards. The NFPA diamond will not appear on laboratory door postings, only those for non-laboratory spaces where chemicals are used/stored. Other regulations and standards come into play. The bottom line is simply that the signage is an important means of communication, and it greatly facilitates response actions in the event of an emergency or other situation that could cause employee harm or property damage.
This checklist item should be cited when an EHS door posting is not present for a lab where chemical or physical hazards listed in Part I of the Lab Hazard Assessment (HA) Worksheet are present. Review the copy of the Lab HA worksheet you carry with you to ensure hazards not previously identified are.
This is also cited when the door posting does not accurately reflect the hazards within. If the deficiency is only in the contact information, then do not cite it as a deficiency in EHS Assist; rather just make a note on your survey form, update EHS Assist, and the Senior Specialist will send a new door posting with the updated contact information with the report email.
The door posting information is collected using the Laboratory Hazard Assessment worksheet. For new PIs, when entering the “responsible party” in EHS Assist for this violation, use “EHS Auditor” as we are the ones providing the door posting. For repeat violations where the door posting is either not posted or is incorrect, indicate “PI” as the responsible party. A new door posting will be sent by the Senior Specialist along with the report email.
Citations and Related Resources
EHS SOP Door Postings for Potentially Hazardous Locations
NFPA 45, 13.1.1: Entrances to laboratory units, laboratory work areas, storage areas, and associated facilities shall be identified by signs to warn emergency response personnel of unusual or severe hazards that are not directly related to the fire hazard of contents.
29 CFR 1910.1200(h)(2) Employees shall be informed of…(ii) any operations in their work area where hazardous chemicals are present; and (iii) the location and availability of the written hazard communication program
29 CFR 1910.1200(h)(3) Employee training shall include at least…(ii) the physical, health, simple asphyxiant, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of chemicals in the work area.