Date: Tue, 7 Oct 2003 09:04:28 -0400
Reply-To: ILPI <info**At_Symbol_Here**ILPI.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Policy on Shorts and Open-Toed Footwear in Labs
In-Reply-To: <p05200f02bba7c853983e**At_Symbol_Here**[128.115.81.233]>


>What are your campus policies on these personal clothing items?

Most every major university that I've been at or visited prohibits
both.  Just about every lab safety expert will tell you that covering
exposed legs and feet will minimize potential exposure.

Consider OSHA regulations, if nothing else:

OSHA's PPE standard 29 CFR 1910.132 says:

     1910.132(d) Hazard assessment and equipment selection.

     (d)(1)(i)
     Select, and have each affected employee use, the types of
     PPE that will protect the affected employee from the hazards
     identified in the hazard assessment;

OSHA's Occupational foot protection standard 29 CFR 1910.136
generally only considers impacts of objects, but one can conceivably
read "danger from falling objects" to include corrosive chemicals
such as acids etc.:

1910.136(a)

General requirements.   The employer shall ensure that each affected
employee uses protective footwear when working in areas where there
is a danger of foot injuries due to falling or rolling objects, or
objects piercing the sole, and where such employee's feet are exposed
to electrical hazards.

The Laboratory Standard, 29 CFR 1910.1450 says:

     "Protective laboratory practices and equipment" means those
     laboratory procedures, practices and equipment accepted by
     laboratory health and safety experts as effective, or that
     the employer can show to be effective, in minimizing the
     potential for employee exposure to hazardous chemicals."

Based on the latter definition and the information above, closed-toes
shoes reduce the risk of chemical splashes, cuts from broken
glassware, tripping/snagging (especially for "flip-flops").  And
electrical hazards certainly exist in labs as well.  Long pants
reduce the rate at which a chemical can permeate the skin,
particularly inadvertent exposures such as leaning against a
contaminated benchtop.  They also provide protection from cuts etc.
from broken glass as well as some radiation exposures.

I'm not an attorney, but I suspect that failing to Officially
prohibit shorts and open-toed shoes sets you up for a tremendous
legal liability given these OSHA regs and standard prudent practices.
The operative word in your CHP should be "prohibited" and not
"discouraged" or "not recommended".  Period.

Best regards,

Rob Toreki
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