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Robert J. Alaimo and Kenneth P. Fivizzani
If you were responsible for selecting a chemical hygiene officer (CHO) for your facility, what would be on your list of requirements? To answer this question, you might consult the OSHA Laboratory Standard, 29 CFR 1910.1450, which defines the CHO as "an employee who is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan."
What did OSHA intend when it used the terms "qualified by training or experience" and "provide technical guidance" in this definition? When the standard was written, OSHA did not provide much detail in its definition and assumed that someone in the organization would be familiar with the hazards in the laboratory and have the authority to take some action to ensure safe operation. This assumption is both reasonable and appropriate for the wide variety of laboratory facilities that must comply with the Laboratory Standard.
Companies and institutions designate CHOs in various ways. In many cases the CHO role is simply added to an individual's other responsibilities. Newly designated CHOs often ask numerous questions, such as
In this article, we present our opinions of the answers to these and other questions related to the qualifications, training, and experience required for the CHO.
Education and training. The CHO should hold at least a bachelor's degree in chemistry or have equivalent laboratory experience. Safety professionals who have a good working knowledge of chemistry would meet this requirement. Such nonchemist professionals who may have this knowledge of chemistry might include safety engineers, industrial hygienists, occupational health nurses and physicians, and toxicologists.
Safety and industrial hygiene experience is desirable but not required. The CHO should know what the regulations require regarding good laboratory practices, exposure control, and medical monitoring and must be willing to learn chemical safety and industrial hygiene practices.
Supervisory experience. Because the CHO must be able to manage and advise lab employees and maintain a high degree of credibility, we believe that one or more years of experience in supervising others is essential.
Specific laboratory experience. The CHO must know and understand the operation of the specific facility (e.g., what hazardous materials are used and stored; what are the hazards for the individual tasks; what equipment is currently available or likely to become available; and what purchasing, transportation, and disposal procedures exist for chemicals and other lab supplies). In addition, knowing the employees and the practices that predominate at a specific facility greatly improves communication.
Communication skills. Good written and verbal communication skills are important for almost any job today, but they are essential for a CHO. Because the OSHA Lab Standard mandates that the CHO "develop and implement the Chemical Hygiene Plan," this person must interact appropriately with several diverse audiences: the lab staff, site managers, regulatory agencies, and possibly the media.
Stability. Continuity is needed to ensure good control of the program, and a long-term commitment of at least three years is needed to justify any training and certification investments by management.
The first is visibility and respect. Regulators will expect the CHO to be known and respected by employees and managers alike. Thus, the corporate culture needs to reflect the value that the organization places on a safe workplace. It must encourage the CHO to be assertive in matters of safety and do what is needed to ensure that management understands what the law requires for compliance.
Second, the CHO needs the time to do the job well. This role can't be assigned and then forgotten; daily management and observation are absolutely necessary. This requirement can be particularly difficult for individuals who serve as CHOs on a temporary or part-time basis. The organization must provide sufficient support for this important function.
Finally, the CHO needs to be rewarded and recognized for contributions to the organization. Without a strong and effective CHO and chemical hygiene plan (CHP), the organization is at risk. Although the laboratory manager has the ultimate responsibility for employee safety, the CHO who facilitates an effective, successful program should be encouraged, recognized, and rewarded.
In addition to the basics listed, CHO training should cover the history and purpose of the regulation (29 CFR 1910.1450), including the material in the preamble and the nonmandatory appendixes. Other OSHA standards such as the personal protective equipment (PPE) standard and the respirator standard, applicable DOT and EPA regulations, and the standard's preapproval process should be covered. The interactions and purposes of these standards and regulations are important, as are the hazard assessment process and PPE selection.
The principles of chemical safety must be an integral part of any CHO training. Development and implementation of a CHP should be stressed, along with an example of a good CHP. Information sources (i.e., labels, MSDSs, safety databases, texts, magazines, and other resources) should also be made available. The respective responsibilities of the company, CHO, and employees as outlined in the standard should be identified.
A basic understanding of toxicology and routes of exposure is important, as is a discussion of target organ effects and signs and symptoms of overexposure. Guidance on when industrial hygiene exposure monitoring is needed and how it is done should be included.
Chemical procurement, storage, and inventory control are vital parts of any CHP. To ensure compliance with safety standards, the CHO must know what chemicals are in the laboratory and how they are stored, used, and disposed of as waste. An understanding of the operation of fume hoods is essential, and a maintenance schedule should be established to ensure compliance and accurate record keeping.
The CHO should learn how to conduct a safety inspection, what to look for, and how to prepare the inspection report. Knowledge of what needs to be recorded (e.g., training, medical, maintenance, standard operating procedures) and how records are retained are clearly important. A definition of special conditions and instruction on how to implement precautions for the use of particularly hazardous chemicals are important pieces of a CHO's knowledge base.
It is the knowledge of chemical health and safety that differentiates the CHO from other safety and health professionals. This important position is best filled by highly qualified people who are chosen not only for their current level of knowledge and awareness but also for their willingness to learn a range of material crucial to the lives and safety of the people in their organizations.
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