Spilled Some Salt? Call OSHA
THE WALL STREET JOURNAL
By Michael M. Segal
9 July 1991
Decent people believe we should warn employees about hazardous materials on the job. Governments at all levels have endorsed such a "right to know" for employees, and the Occupational Safety and Health Administration (OSHA) has written laboratory safety rules with this in mind. Unfortunately, the results of the rules provide some textbook cases of how good intentions can go awry.
I first became aware there was a problem when I read the label on one of my laboratory chemicals. It read: "WARNING: CAUSES IRRITATION. Avoid contact with eyes, skin or clothing. Avoid breathing dust. Wash thoroughly after handling." This "hazardous" chemical was sodium chloride, ordinary table salt. The supplier was carrying out its OSHA obligation to warn of potential hazards.
There is nothing wrong with careful handling of sodium chloride. The danger comes from a situation in which hazardous and safe substances carry similar warnings, leading to scant attention being paid to all.
As an example, a warning about skin contact is also provided with tetrodotoxin, the highly potent poison present in some fish that is rumored to be the active ingredient in the "zombie powder" Haitian voodoo practitioners throw to paralyze victims. For many years, tetrodotoxin was one of the few substances to come with a sheet of paper warning about hazards.
Now, OSHA requires chemical suppliers to prepare and provide a two-page "Material Safety Data Sheet" for all chemicals that might be hazardous. There are even such sheets for sodium chloride, advising the laboratory worker to "Wear [a] respirator, chemical safety goggles, rubber boots and heavy rubber gloves" in the event that some salt spills. Although the warning on tetrodotoxin is more severe than that for salt, the effect of turning up the intensity of warnings on low-risk chemicals is to blur the distinction between high and low risk.
The warnings about salt are not an isolated example of one chemical supplier worried about liability. Here's another company's advisory about a different chemical: "After contact with skin, wash immediately with plenty of soap and water. . . . Special Firefighting Procedures: Wear self-contained breathing apparatus and protective clothing to prevent contact with skin or eyes. . . . Waste Disposal Method: Dissolve or mix the material with a combustible solvent and burn in a chemical incinerator equipped with an afterburner and scrubber. Observe all federal, state and local environmental regulations." This "hazardous" chemical is paraffin wax -- what ordinary candles are made of.
Now over-labeling is spreading from individual chemicals to entire labs. I am currently being asked to hang a sign on my laboratory door reading "RESTRICTED AREA: CARCINOGENS, REPRODUCTIVE TOXINS AND ACUTELY TOXIC CHEMICALS IN USE."
A warning of acutely toxic chemicals is reasonable for my research lab, but the warning about birth defects and cancer is overblown. It is required because my lab contains a bottle of the drug phenytoin. Phenytoin is one of the most commonly prescribed anti-seizure medications. It is on the OSHA warning lists because pregnant women taking several hundred milligrams of the drug a day have a small danger of having children with birth defects and there may be a small danger of tumors in the child. But these risks are low compared with the risks to the fetus of maternal seizures. So, although it is recommended that I, as a neurologist, continue to prescribe phenytoin through a woman's pregnancy, I must now post an alarming notice on my door warning of cancer and birth defects because the same substance is used in tiny quantities in my lab.
An institution can choose not to post room signs for certain drugs on the OSHA warning lists. To do this, however, the institution would have to make a determination that such a warning is not "appropriate." An OSHA spokeswoman cautioned that since enforcement is done by OSHA inspectors, it would be "prudent" to label all rooms that contain any drugs on the OSHA lists. If the labeling of salt and wax by chemical companies is any guide, we can expect to see a lot of over-labeling of labs at corporations and universities.
There are several positive features of the OSHA rules: The best example is the mandated "Chemical Hygiene Plan" safety books that are a welcome addition to the information that employees receive about hazards.
There are also costs to the regulations: New administrators are being hired to carry them out. The taxpayers are signing a blank check to pick up the tab for the increased costs at university labs, because such "indirect costs" get tacked onto federal research grants. The large indirect costs billed by universities have less to do with cedar closets for presidents' houses than they do with universities lacking incentives to agitate for cost effectiveness of regulations.
I'm sure that those who drafted the OSHA rules don't put hazard labels on their salt shakers and don't wash their hands after touching candles. But when "right to know" rules are combined with vague regulations, corporations and universities will limit their liability by overwarning. Such "Crying wolf" over trivial risks lowers our vigilance for real risks. It is important to restore a sense of proportion.
Dr. Segal is a neurologist and neuroscientist at Harvard Medical School.
Copyright © 1991 Michael Segal