Laboratory Compliance, Roles & Responsibilities
Because laboratories continue to be a fast-growing market in Massachusetts, our team has created a blog series describing what clients need to know about building and fire code compliance. (Our last post about permit requirements can be found here.) In this post, we explain the responsibilities of a lab operator and what is needed to secure and maintain the appropriate permits.
UNDERSTANDING MATERIAL STORAGE & USAGE
A lab operator must understand which materials are used and stored in a lab and if they are considered hazardous by codes and code officials. Some building and fire code designations include flammable and combustible liquids, flammable gasses, explosives, combustible dusts, corrosives, and toxics. Before a lab can even open, a lab operator must communicate the projected inventory to the building department as part of the building permit and certificate of occupancy process. The local fire department also must be involved to issue the appropriate flammables permit.
UNDERSTANDING MAXIMUM ALLOWABLE QUANTITIES (MAQ)
A lab operator needs to coordinate with the building owner to understand the maximum allowable quantities (MAQ) in a tenant’s space. The MAQ is based on the construction of the building, the floor level of a space, how chemicals are stored and used, and the current quantities allotted to other chemical users in the building. Unless there is only one tenant in the building, a lab operator cannot ensure that the space is compliant without understanding this information.
When comparing the inventory to the MAQ, a lab operator determines if additional life safety enhancements or modifications to lab operations (such as chemical storage on a lower floor or in a detached structure) are required. These requirements are interconnected and complex, so the code specifically requires this report to be prepared by a qualified individual or firm.
ACCURACY IS CRITICAL
All requirements come from an operator’s chemical inventory, so accuracy is critical. The inventory determines design features and influences the storage and usage of hazardous chemicals in a lab. If an operator understates the inventory, a lab may be under-designed, causing issues obtaining a certificate of occupancy or fire department permits.
COMMUNICATION IS KEY
In a new laboratory design, operators must communicate to their team about current hazards, and whether they will be static or if different chemicals/increased quantities will be introduced. They must submit chemical inventories annually, and an increase in these numbers could create compliance issues long-term. A qualified consultant can help a lab operator understand these challenges and properly design a space.
ADDITIONAL TENANT REQUIREMENTS
Additional requirements for tenants include the preparation and maintenance of an emergency action plan (527 CMR 60.1.5) and a chemical hygiene plan. Enforcement may vary, but these often have a 24-hour contact list and a floor plan of the space with locations of the hazards identified. Additionally, chemical classifications and quantities dictate the ‘NFPA 704 Diamond’ signage required on a lab door. This signage is important to responding Fire Department personnel who run into a space during an emergency.
Stay tuned for our team’s next blog post in the series about Massachusetts laboratory code compliance!