Seems to me the standard simply requires documentation for something any
laboratory would normally do as part of their safety program - determine
which procedures require the use of PPE.  The key word here might be
"documentation" - this is how an OSHA inspector would determine the
assessment has been made.  It is important to note that OSHA does not define
the experience or qualifications of the assessor - it could (and should) be
done routinely by the laboratory's Chemical Hygiene Officer or another
individual responsible for safety compliance.  The certification document
might read something like: "I have examined routine procedures in this
laboratory (or laboratories - define the area) and have determined that eye
protection and skin protection is necessary for all employees using
hazardous chemicals.  This requirement is incorporated by reference into the
laboratory's Chemical Hygiene Plan."

Russ Phifer

WC Environmental, LLC
PO Box 1718, 1085C Andrew Drive
West Chester, PA  19380
610-696-9220/610-344-7519 fax
rphifer**At_Symbol_Here**glasmesh.com


-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]On Behalf Of
Gordon Miller
Sent: Tuesday, August 31, 2004 5:06 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Certification of Hazards Analyses Used to Select PPE

How do you meet the requirement of 29 CFR 1910.132 (d)(2), "The
employer shall verify that the required workplace hazard assessment
(that guides the use and selection of PPE) has been performed through
a written certification that identifies the workplace evaluated; the
person certifying that the evaluation has been performed; the date(s)
of the hazard assessment; and, which identifies the document as a
certification of hazard assessment." (or its equivalent under state
OSHA regs)?

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