Making Sense of OSHA Requirements for 29 CFR 1910 Cleanrooms

OSHA industry standards apply to most, if not all, cleanroom operations in the Code of Federal Regulations (CFR) 29 CFR. This standard is more commonly known as the General Industry Standard, 29 CFR 1910. (Not every cleanroom falls under standard 1910.) These standards are complex, so we have summarized the primary components to make them easier to understand.

OSHA Minimum Requirements 

At minimum, all cleanroom facilities must have the following:

  • 1. OSHA Poster – This informs workers of their rights and must be prominently displayed in the facility.
  • 2. OSHA 3000 Log – If you are not classified as a partially exempt industry and you have more than ten employees, you have to record work-related injuries and illnesses using OSHA forms 300, 300A, and 301. Covered employers must prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 log.
  • 3. Medical Services and First Aid – Employees must have readily available access to medical personnel. Where an infirmary, clinic, or hospital is not near the facility, you must train one or more people to administer first aid. You also have to make first aid supplies available. For all areas where anyone’s eyes or body is exposed to corrosive materials, you must provide emergency facilities to quickly flush affected areas.
  • 4. Exit Routes and Emergency Action Plans – You must display floor plans or workplace maps that clearly show emergency escape routes. The routes must be included in your emergency action plan. The emergency action plan is comprehensive. It should address all emergencies that one could reasonably expect, like fire, toxic chemical release, hurricanes, tornadoes, blizzards, and floods. The action plan must be written and available to employees at all times. At a minimum, your emergency action plan must contain:
    • Procedures for reporting an emergency
      Procedures for evacuation, including reasons and exit routes
      Procedures for employees who need to operate critical plant operations before evacuating
      Procedures to account for all employees after evacuation
      Procedures for performing medical or rescue duties
      Names or job titles of everyone who is available for employees to contact regarding information or explanation of the emergency action plan
      Designate and train employees to assist in safe, orderly evacuation of other employees

The emergency action plan, in particular, is a requirement that takes time and effort. However, putting together a safety committee to work on the plan as a team can make the process more efficient.

OSHA Fire Protection & Prevention Plan

OSHA standards require that you have a fire prevention plan and follow fire protection requirements. What needs to be included in the plan, and which equipment must meet the requirements?

Fire Prevention Plan

This is to control the accumulated flammable and combustible waste materials. A prevention plan must include:

    • • List of all major fire hazards
      • Proper handling and storage procedures for hazardous materials
      • Potential ignition sources and their control
      • Type of fire protection equipment necessary to control each major hazard
      • Procedures to control accumulations of flammable and combustible waste materials
      • Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials
      • Name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires
      • Name or job title of employees responsible for the control of fuel source hazards

An employer with more than 10 employees must keep this plan in writing, in the workplace, and available to employees for review. For fewer than 10 employees, the written plan may be communicated orally.

Fire Protection

This section contains the 29 CFR Part 1910 requirements for: fire brigades, portable and fixed fire suppression equipment, fire detection systems, and all fire or employee alarm systems installed.

 

Hazardous Materials, Substances, & Exposure

Hazardous Materials

Every employer must determine that compressed gas cylinders are in a safe condition; the safe condition must be determinable by visual inspection. Inspections of materials should be conducted as outlined in 49 CFR parts 171-179 and 14 CFR part 103. In the case those regulations are not applicable, conduct inspections according to Compressed Gas Association Pamphlets C-6-1968 and C-8-1962. They are referenced in Sec. 1910.6. Flammable liquids. A list of highly hazardous chemicals that present a potential for a catastrophic event at or above the threshold (flashpoint at or below 199.4 °F – 93 °C) is detailed in Hazardous Materials – 1910.119 App A List of Highly Hazardous Chemicals, Toxics and Reactives

Toxic & Hazardous Substances/Air Contaminants

Employee exposure to the substances listed in Tables Z-1, Z-2, or Z-3 of 1910.100 Subpart Z must be limited in accordance with the requirements of the section. To be compliant with paragraphs (a) through (d) of this section, you must determine and implement administrative or engineering controls whenever possible. If these controls aren’t feasible to achieve compliance, protective measures, like PPE, must be used to limit employee exposure to air contaminants. (Limits are prescribed in this section of the OSHA literature.) A competent industrial hygienist or other technically qualified person must approve all equipment and/or technical measures used for this purpose for each use. Respirators must comply with 1910.134.

Occupational Exposure to Hazardous Chemicals in Laboratories

“Laboratory” generally is where small quantities of hazardous chemicals are used in a non-production manner. It refers to any facility where the “laboratory use of chemicals” happens, meaning all of these conditions are met:

    • Chemical manipulations are carried out on a laboratory scale
      Multiple chemicals or chemical procedures are used
      The procedures involved aren’t part of a production process
      The procedures involved don’t simulate a production process
      Protective laboratory practices and equipment are available and used to limit employee exposure to hazardous chemicals

Ventilation

This is in the Occupational health and environmental control section. An exhaust ventilation system removes contaminated air from a space and is comprised of two or more of the following:

    • • Enclosure or hood
      • Duct work
      • Dust collecting equipment
      • Exhauster
      • Discharge stack

Whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level of 85 decibels measured on the A scale (slow response), or a dose of fifty percent, then an employer must administer a continuing, effective hearing conservation program (described in paragraphs (c) through (o) of this section in the standard.)

Personal Protective Equipment (PPE)

An employer must provide PPE, for the: eyes, face, head, and or extremities. It may include protective clothing, respiratory devices, and/or protective shields and barriers. The PPE must be maintained in a sanitary and reliable condition wherever it is necessary for the following reasons:

  • • Hazards of process or environment
    • Chemical hazards
    • Radiological hazards
    • Mechanical irritants encountered in a manner capable of causing injury or impairment through absorption, inhalation, or physical contact.

Materials Handling & Storage

Mechanical handling equipment may only be used with sufficient safe clearance for: aisles, at loading docks, through doorways, and wherever turns or passage must be made.

 

All aisles and passageways must be kept clear and in good repair. Permanent aisles must be marked appropriately. Secure storage cannot create hazards. Stack, block, interlock, or limit the height of all bags, bundles and containers so they are stable and unable to slide or collapse.

If you are ever unsure of how to translate OSHA requirements, contact your insurance broker or carrier. You may also hire a professional to assist you with inspection preparation or safety programs. For questions about cleanroom certification and verification, contact Gerbig Cleanrooms. We’ve expertly handled cleanroom equipment and services since 1985. Contact us at 888-628-0056 or email info@gerbig.com

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