Chemical Hygiene Plan
It is the policy of Washington and Lee University ("W&L" or the "University") to provide a safe working environment for its employees. This policy encompasses the safety of faculty, staff, and student workers in University laboratories where the use of hazardous chemicals may occur.
The Virginia Occupational Safety and Health Administration's (VAOSHA) regulation for "Occupational Exposures to Hazardous Chemicals in Laboratories," 29 CFR 1910.1450 (the "Lab Standard"), requires each employer engaged in the laboratory use of hazardous chemicals to develop and implement a written Chemical Hygiene Plan that sets forth the procedures, equipment, personal protective equipment, and work practices that are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace and that is otherwise in compliance with the applicable laws1. This Chemical Hygiene Plan ("CHP") has been developed in accordance with the applicable federal and state regulations in order for Washington and Lee University (WLU) to satisfy the requirements of such regulations2
All faculty, staff, and student workers (collectively referred to as "employees") who work in laboratories and manipulate hazardous materials are to follow the procedures outlined in this CHP. Employees who work with hazardous materials in a non-laboratory setting (e.g. custodians, painters, facilities management) are covered by the Hazard Communications Standard set forth in 29 CFR 1910.1200. This Plan will be reviewed and evaluated for effectiveness at least annually and updated, as necessary3. Please contact the Chemical Hygiene Officer (CHO) with any ideas you might have to improve this CHP.
1. Emergency Telephone Numbers
|Local Emergency Dispatch||911|
|University Public Safety||540.458.8999|
|Environmental Health and Safety||Paul Burns||540.458.8175 or 540.460.6209|
|Chemical Hygiene Officer||Philip Trimmer||540.460.2421|
|Radiation Safety Officer||Philip Trimmer||540.460.2421|
|Biology Department||Bill Hamilton||540.458.8890|
|Chemistry Department||Steve Desjardins||540.458.8873|
|Geology Department||Christopher Connors||540.458.8170|
|Physics and Engineering Department||David Sukow||540.458.8881|
|Psychology Department||Robert Stewart||540.458.8837|
|Art and Art History Department||George Bent||540.458.8863|
|Sociology and Anthropology Department||Krzysztof Jasiewicz||540.458.8790|
|IQ Center||David Pfaff||540.458.8044|
|Carilion Stonewall Jackson Hospital||540.458.3300|
The Provost has delegated the responsibility for compliance with the Lab Standard and oversight of this CHP to the Dean of the College and the Chemical Hygiene Committee (CHC). However, in all cases, the Provost has retained the authority to review any unresolved chemical hygiene and safety issues presented by the Dean of the College and/or the CHO. The Provost must also approve the use of Select Agents and Toxins and Class II Biohazards, which must also be approved by the CHC and the Dean of the College.
2.2 Dean of the College
The Dean of the College has the authority to review and take action with respect to any chemical hygiene or safety issues presented by the CHC, subject to review by the Provost. The Dean of the College must also approve the use of Select Agents and Toxins and Class II Biohazards, which must also be approved by the CHC and the Provost.
2.3 The Chemical Hygiene Committee (CHC)
The CHC shall consist of the Department Chair, or his or her faculty designee, of each of the following departments: Chemistry and Biochemistry, Biology, Physics and Engineering, Geology, Art and Art History, and Psychology. The Director of Environmental Health and Safety (DEHS), the Chemical Hygiene Officer (CHO), and the Director of Public Safety will also be members of the CHP. Each member of the CHC will act as a safety liaison for his or her Department. The CHC will meet twice per year and have the following responsibilities:
- Elect a Chairperson to organize the meetings and to serve for a term of two years. Multiple consecutive terms are allowed.
- Assist the CHO in reviewing, evaluating, and updating the CHP annually.
- Provide the CHO with a list of all employees who work with hazardous materials, including those recently hired/transferred and in need of CHP training.
- Determine the frequency of refresher CHP training for those who have been previously trained.
- Assist in bringing labs into compliance, based on their safety audits. Members of the CHC are entitled, but not required, to attend laboratory safety audits.
- Present unresolved chemical hygiene and safety issues to the Dean of the College, with final review by the Provost.
- Approve all site-specific Standard Operating Procedures (SOPs).
- Approve the use of Select Agents and Toxins and Class II Biohazards, which must also be approved by the Dean of the College and the Provost.
- Approve the CHO's annual budget and submit it to the Dean of the College for approval.
- Review and approve the plans to renovate or construct buildings in which the use or storage of hazardous materials is contemplated.
- Review accident reports and make appropriate recommendations regarding changes in laboratory procedures.
- Periodically update the Safety Committee with respect to identified safety issues on campus that relate to the use of hazardous chemicals in University laboratories.
A quorum must be present, and decisions will be based on a simple majority vote. Voting by email is allowed.
2.4 Chemical Hygiene Officer (CHO)
The CHO shall exercise the authority to identify and minimize the dangers to all laboratory employees, the community, and the environment. The CHO has the authority to suspend operations which do not conform to the requirements of this Plan and will inform the CHC of any such actions. The CHO also has the following responsibilities:
- Review and evaluate the CHP annually, and update it as necessary.
- Provide technical expertise to the laboratory community with regard to health and safety issues and direct inquiries to appropriate resources.
- Ensure that laboratory employees are properly trained prior to working in any laboratory, including assisting the DEHS in training all laboratory employees in accordance with Section 7.4.
- Perform annual pre-announced safety audits of each lab, and report the results to the CHC and to the appropriate Principal Investigator (PI).
- Assist with any laboratory safety improvements.
- Annually inspect all built in engineered safety equipment in every lab for proper function, and document the results.
- Maintain the laboratory first aid kit contents and entry way warning signs during the annual inspection.
- Assist the PI and the CHC with the generation of site-specific SOPs, and maintain these documents.
- Assist with chemical spill clean-up and hazardous waste removal.
- Act as Secretary for the Chemical Hygiene Committee, take notes and send a summary to each member, the Dean of the College, and the Provost.
- Submit an annual operating budget to the CHC for approval.
2.5 Director of Environmental Health and Safety (DEHS)
The DEHS will provide the necessary resources and feedback required to make sure the CHP is in compliance with OSHA requirements. The DEHS has the authority to suspend laboratory operations if there is an imminent threat to the health or safety of the University community. The Chemical Hygiene Committee will be informed of any such actions. The DEHS also has the following responsibilities:
- Provide technical expertise to the laboratory community with regard to health and safety issues and direct inquiries to appropriate resources.
- Ensure that laboratory employees are properly trained prior to working in any laboratory, including assisting the CHO in training all laboratory employees in accordance with Section 7.4.
- Assist in laboratory safety audits and in making all necessary safety improvements.
- Maintain records associated with the training required under this CHP, lab accidents, and chemical inventories for a period of 30 years.
- Assume the lead role in any investigations related to chemical spills or releases, chemical exposure, environmental or medical monitoring, and licensed medical physician directives.
- Ensure that hazardous waste generated on campus is handled and disposed of in accordance with the applicable laws and regulations.
- Oversee the transport of hazardous chemicals.
2.6 Principal Investigators (PI), Lab Managers, Instructors, and Technicians
The PI has primary responsibility for chemical hygiene in his or her laboratory. Each PI also has the following responsibilities:
- Implementation of the procedures and requirements of this CHP.
- Complete routine laboratory inspections.
- Make sure that all employees are properly trained before working in his or her laboratory.
- Instruct all laboratory personnel about the potential hazards in his or her laboratory.
- Maintain a chemical inventory list and a collection of Safety Data Sheets (SDS) for all hazardous substances. Any experiments that involve the use of Select Agents and Toxins or Class II Biohazards must be approved in advance.
- Select the appropriate personal protective equipment (PPE) for use by employees in his or her laboratory. Make sure employees have access to the selected PPE and that they are informed when the PPE requirements change.
- Post emergency contact phone numbers on the outside every laboratory door. A laminating service is available from the DEHS.
- Notify employees of the locations of, and understand how to use, the built in, engineered safety equipment.
- If certain site specific hazards require additional site -specific standard operating procedures (SOPs), make sure the site -specific SOPs are in writing and that all laboratory employees are trained on these SOPs. (See Appendix A for a blank site- specific SOP form.)
- If any employee is injured, or show signs of chemical exposure that occurs in his or her laboratory, no matter how minor, fill out a First Report of Injury Form and follow the applicable instructions.
- Assist in investigating the cause of any employee injury or chemical exposure and in making improvements to avoid future incidents.
- Participate in laboratory safety audits and assist the CHO in developing and implementing a plan to provide a safer working environment. (See Appendix B for blank safety audit forms.)
- Take responsibility for student safety in the lab.
For purposes of this CHP, in the absence of a PI, the laboratory manager, instructor, or technician who is overseeing the particular laboratory or a particular project shall have the responsibilities conferred on the PI by this section and all other sections of this CHP.
2.7 Laboratory Employees, Students, Guests, Visitors, and Other Users
All laboratory employees, students, guests, visitors, and others who are working in or using a University laboratory shall:
- Follow the procedures and guidelines set forth in this CHP, as well as any other applicable department or University policies and procedures.
- Report any unsafe working conditions and faulty fume hoods or other emergency/safety equipment to the PI, laboratory instructor, or technician, and to the CHO and DEH.
- Report any hazardous chemical incidents to the PI, laboratory instructor, or technician, and to the CHO and DEHS.
3. Standard Operating Procedures for Laboratory Chemicals
3.1 Chemical Procurement and Inventory
- New chemicals shall be obtained only if the PI, has determined that the use of the new chemical is necessary and appropriate for the research or teaching procedure.
- The decision to procure a chemical shall be a commitment to handle and use the chemical properly from initial receipt to ultimate disposal.
- If possible, substitute hazardous materials for materials that are less hazardous.
- The individual who requested that the particular chemical be obtained (i.e., the requesting PI, faculty member, or laboratory instructor) shall ensure that information on proper handling, storage, and disposal is made known to all individuals who will be using the chemical, including students, prior to their use of the chemical.
- Chemical containers shall be accepted only when labeled and packaged in accordance with applicable regulations.
- All chemical containers shall be dated when received.
- A Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) must been obtained and properly filed according to departmental policy for each new chemical received.
- Every Department is responsible for reporting their hazardous chemical inventory to the DEHS upon request. The inventory must be in the form of an alphabetized Microsoft Excel spreadsheet. This inventory will assist Washington and Lee University to maintain its compliance with OSHA, the Department of Homeland Security, and our waste disposal licensing agreement.
3.2 Chemical Transport
- Received chemicals must be moved to the appropriate storage area as soon as possible.
- Always use a cart when transporting chemicals. Chemicals should never be transported from room to room by hand.
- Always transport hazardous chemicals in a secondary containment vessel such as a plastic bin, or specially designed rubber sleeve. A properly designed cart can serve as secondary containment vessel.
- Ensure the lids are secure on all containers before entering elevators or stairways.
- Always use a cylinder cart to transport pressurized gas cylinders.
- Gas cylinders should always have valve covers installed when moving.
- Any transport of chemicals that involves the use of a motor vehicle shall comply with all applicable Department of Transportation (DOT) requirements and other applicable laws, including those relating to labeling packaging, placarding the vehicle, and manifesting the shipment. Under no circumstances are employees allowed to transport hazardous materials in their personal vehicles. Contact the DEHS if you have any hazardous material transportation needs.
3.3 Chemical Storage
- Flammable and toxic chemicals should be stored in ventilated, fire resistant cabinets whenever possible. The metal cabinets built into the laboratory hoods are suitable for this purpose, as are several other designs of free standing metal cabinets approved by the National Fire Protection Association (NFPA).
- Sometimes it is necessary to store these materials on open shelves or bench tops. Storage in these locations should be kept to a minimum.
- Refrigerators and freezers that contain hazardous materials should be specially designed for this use, should be Underwriters Laboratories (UL) listed, and a "not for food" sign should be posted on the outside.
- Treat substances of unknown toxicity as if they were toxic.
- Heavy items should be stored on lower shelves.
- No items should be closer than 18 inches to the ceiling or sprinkler head.
- If items are stored above shoulder level, appropriate step stools should be available for use.
- No corrosives should be stored above eye level.
- Keep incompatible materials separated.
- Periodically examine all containers to confirm that they have not deteriorated.
- Particularly Hazardous Substances and Select Agents and Toxins must be securely stored in suitable designated areas (See Section 6.4 and 6.5).
3.4 General Precautions for Chemical Handling and Use
For each chemical, all users shall:
- Take personal responsibility to read the SDS for all chemicals they use and to be aware of and minimize the risks associated with their use.
- Take the time to locate emergency equipment such as fire extinguishers, showers, fire blankets, eye wash fountains, alarms, and spill kits.
- Always wear the appropriate clothing and PPE.
- Avoid startling or distracting other laboratory users.
- Avoid engaging in horseplay in the lab.
- Always inspect containers and equipment for damage.
- Always wash hands before exiting any lab.
- Never pipette by mouth.
- Never taste or smell hazardous materials.
- Be aware of the symptoms of chemical exposure and take immediate action.
- Avoid skin contact with chemicals.
- Be certain that there is no ignition source in the vicinity when working with flammable chemicals.
- Follow any additional precautions or special instructions that are necessary or appropriate based on the particular chemical(s) involved.
Proper assessment of the risk associated with manipulating hazardous chemicals is crucial to keeping employees healthy and safe. All employees must take personal responsibility for understanding the risks associated with their work. They should consult with their supervisors, with the SDS, or with the CHO if they do not understand with the potential hazards or risks of a particular chemical or process. Careful planning, following procedures, and wearing the correct PPE are all critical steps in the assessment process.
3.5 Procedures for Gas Cylinders and High Pressure
- Rooms that contain compressed gases (45 psi or greater) should have high pressure warning signs posted outside of the door.
- The contents of a gas cylinder must be labeled and may be hazardous. Always check recently installed cylinders for leaks.
- The protective valve cover must remain in place unless a regulator is attached.
- Gas cylinders must always remain upright, and should be strapped or chained securely to avoid tipping during transport.
- Never use oil or grease on an oxygen regulator. Make sure the regulator is designed for the gas used, as there are many sizes, designs, and material choices, some of which can lead to incompatibilities.
- Gas cylinders are very heavy and should not be rolled along, but must be transported on an appropriately designed gas cylinder cart.
- Do not use Teflon tape on any Compressed Gas Association ( CGA) fitting as such fittings are designed to seal by metal to metal compression.
- Toxic gases must be stored in a hood. Toxic and corrosive gas transport lines that are not contained in a hood must be purged after use.
- Always wear safety glasses when moving or using a pressurized gas cylinder.
3.6 Chemical Waste Disposal
The University is subject to certain federal, state, and local requirements regarding the disposal of chemical waste. Specific information on these requirements is available from the DEHS and the CHO.
- Employees should substitute less hazardous chemicals and recycle whenever possible.
- All organic chemical waste must be placed in clearly labeled, non-metallic organic waste containers. Except for minor amounts of acetone and ethanol used to clean glassware, no organic chemicals shall be poured down the drain.
- Halogenated organic chemical waste must be stored in a separate container from the non-halogenated organic chemical waste. These containers must be labeled and stored in a ventilated cabinet until they are full. The labels must include the name of every organic chemical in the waste container.
- When waste containers are full (maintain a 2 inch headspace), contact the CHO for removal. Full hazardous chemical waste containers are taken to a specially designed chemical waste bunker where they are securely stored. A licensed subcontractor will remove the waste for incineration at least annually and provide the appropriate paperwork to the DEHS.
- Fume hood evaporation of hazardous waste is prohibited.
- Heavy metal inorganics must also be stored in a properly labeled, non-metallic waste container. They may not go down the drain.
- Inorganic acids and bases may go down the drain with lots of flushing and with appropriate precautions.
- Concentrated acids and bases may spatter, get very hot, or give off caustic gases. These are best disposed of in one of the hood sinks with plenty of flushing water.
- Sharps and broken glassware should not be placed in garbage cans. Every lab should have a plastic bin for broken glassware and for disposable pipettes.
- Every lab that uses syringes, needles, or other sharp objects should dispose of these items in a special sharps receptacle.
- Segregate waste products of particularly hazardous substances (see Section 6.4) and select agents and toxins (see Section 6.5) from other waste products. Such waste products should be further protected by secondary containment using unbreakable containers, and their contents should be labeled.
Laboratory employees are directly responsible for the cleanliness of their own workspaces, and jointly responsible for the cleanliness of common areas of the laboratory. The PI shall ensure the maintenance of appropriate housekeeping standards. While Facilities Management is responsible for keeping the floors cleaned, they are not responsible for clutter, counters, hoods, shelves, bench tops, equipment, or other areas of the lab.
- Laboratory personnel should keep walkways clear, clean up any chemical residue, and maintain a tidy an uncluttered work place.
- Electrical cords on the floor are a tripping hazard. They should either be removed or covered.
- The floors become very slippery when wet. Wipe up any floor spills immediately.
- Access to exits, fire extinguishers, eye wash fountains, or other emergency equipment cannot be blocked.
- Make sure incompatible hazardous materials are separated.
3.8 Laboratory Equipment and Glassware
Many laboratory devices are potentially hazardous. It is the responsibility of each PI to keep his or her equipment in good working order.
- Employees should be properly trained to use all laboratory equipment safely.
- The manuals for sophisticated equipment should always be readily available.
- Equipment warning labels should never be removed.
- Electrical cords should be in good condition.
- Any electrically energized equipment near sources of water must be plugged into a ground fault circuit interrupter.
- All glassware should be checked for cracks, chips, sharp edges, or deep scratches.
- All defective glassware should be disposed of in the broken glassware bins.
- Make sure the glassware is suitable for a particular application. Not all glassware is intended to be heated to high temperatures, is resistant to rapid changes in temperature, or appropriate for vacuums.
Regardless of what material a hose or tube is conveying, its failure can result in a hazardous situation.
- Inspect hoses and tubes for cracks, wear, and kinks and replace as appropriate.
- Connections should be checked for leaks.
- Critical components should be wired or clamped in place.
- Exercise caution when inserting tight fitting glass tubing.
- Consider using puncture resistant gloves and lubrication.
- All centrifuges must be carefully balanced in order to work safely and correctly.
- Operators should never use their hand to stop a centrifuge from spinning.
- If a centrifuge makes unusual noises, or vibrates, then it should be stopped and inspected.
- Each ultracentrifuge should have a log book that describes its use and maintenance.
- Rotors should be inspected regularly for signs of wear and repaired or replaced by a qualified expert, as needed.
Lasers are divided into four hazard classes. The average power of the laser, measured in milliwatts, is the primary criteria for entry in a particular hazard class. Class I lasers include cd players and laser printers. They are of such low power, they will not damage the eye. Class II lasers include bar code scanners, some laser pointers, and any laser with an output of 1 milliwatt or less. Class II lasers will damage the eye if they are deliberately stared into for prolonged periods of time. Class IIIA lasers have between 1 and 5 milliwatts of power and are hazardous when stared into, or focused into the eye. Class IIIB lasers are between 5 and 500 milliwatts, and can emit visible, infrared, or ultraviolet radiation. Class IIIB lasers will immediately damage the eye on contact. Class IV lasers have average continuous power above 500 milliwatts, and will immediately damage the eye and surrounding tissue.
- Each laser should be labeled with its class.
- Any room that contains Class IIIB or Class IV lasers must have a warning sign posted outside.
- Untrained personnel should not be allowed inside a room with an energized Class IIIB or Class IV laser.
- Employees should remove jewelry, and watches, and should exercise great care when reaching into the path of a laser beam.
- The PI shall always make available laser safety glasses that reduce the intensity of the laser at the appropriate wavelength and optical density.
E. X-rays and Ionizing Radiation
If you are working with or using radio isotopes or other radioactive materials, consult the University's Radiation Safety Manual and/or contact the Radiation Safety Officer at 540.458.8893.
Employees should use temperature resistant gloves when handling items from an autoclave and should exercise caution in case steam escapes upon opening the door.
G. Powerful Magnetic Fields
The Nuclear Magnetic Resonance (NMR) instrument contains an intense 9.4 tesla permanent magnet. This magnetic field is powerful enough to unexpectedly remove metal objects from the hand and turn them into projectiles. This field can also erase magnetic cards, and ruin watches or cell phones. Employees with pacemakers, metal implants, or other sensitivity to magnetism should not enter the NMR room. An appropriate warning sign shall be posted at the entrance. to the NMR room.
H. Disposal of Used Equipment
Any laboratory equipment that has been exposed to hazardous chemicals should be decontaminated with appropriate solvents or cleaning solutions before leaving the controlled environment of the laboratory.
3.9 Personal Protective Equipment
A. Eye and Face Protection
Select the appropriate eye and face protection based on the potential risks of the hazardous chemicals that you are using.
- Safety glasses are required whenever hazardous substances are being manipulated, and must conform to ANSI standard Z87.1-2003.
- Contact lenses should never be worn in any lab, as contact lenses may trap hazardous materials against the eye and make eye wash fountains less effective in the removal of those materials. There is a special configuration of safety glasses that are to be worn over normal corrective glasses.
- Goggles, and/or face shields worn over safety glasses, and/or glass barricades, provide an even greater degree of eye protection against fumes and splashes.
Absorption through the skin is the second-most common cause of chemical overexposure. Gloves should be worn to minimize the risk of skin contact any time hazardous chemicals are used. The use of gloves is mandated in the Federal Statute 29 CFR 1910.138.
- Most disposable gloves only provide a brief period of protection, often less than five minutes, so all reasonable efforts should be made to keep the gloves clean.
- Disposable gloves are easily abraded and should be inspected and replaced often when there is a possibility of developing tears.
- Cross contamination is often an issue with glove wearers. Exercise caution when handling keyboards, mice, door knobs, light switches, pens, etc.
- Gloves should be removed before leaving the lab.
Gloves are available in several different material compositions, thicknesses, and lengths. If prolonged exposure or total immersion is required, then use the appropriate gloves. Reusable gloves should be cleaned before removal so they are ready for use the next time.
Not all glove materials are an effective barrier against all chemicals. Select the appropriate gloves based on your particular needs. Glove manufacturers have compatibility information readily available. Some general guidelines are:
|Glove Composition||Useful Against|
|Nitrile (superior puncture resistance)||oils, petroleum products, some acids and bases|
|Latex||acids, bases, salts, good chemical resistance|
|Butyl||esters and ketones, good gas and water resistance|
|PVC||acids, fats, hydrocarbons, not petroleum solvents|
|Polyurethane||alcohols, hydrocarbons, organic solvents|
C. Lab Coats and Clothing
Laboratory coats are highly recommended. They offer an additional layer of protection, and there is less chance that you will leave the lab with hazardous materials on your clothing.
- Each PI should use his or her professional judgment on whether or not the individuals working in their laboratory should fully cover his or her arms and legs.
- Under no circumstances should an individual's midsection or any portion of his or her feet be exposed while working in a lab.
- Clothes that are overly tight should not be worn in the laboratory as such clothes may hold any spilled material against the skin.
- Long hair should be tied up to avoid contact with hazardous materials or flames.
- Neckties should be anchored to the shirt, or tucked in.
- Jewelry should be removed before working in a laboratory as it may get caught in mechanical equipment, wear through gloves, or reflect lasers.
- Do not wear polyester, nylon, or other flammable clothing when working with open flames.
D. First Aid Kits
Every lab should have a first aid kit located in a well-marked area. The minimum contents of these kits should include various size bandages, gauze, tape, and antibiotic ointment. The use of specific materials or processes, may affect the required contents of the first aid kit. The contents of the kits will be confirmed and restocked during the annual safety audit.
Respirator use is described in 29 CFR 1910.134. The University does not currently have an authorized respirator program, so the use of respirators is not permitted. Dust masks may be used upon previous approval by the DEHS. Contact the DEHS if the fume hoods and dust masks do not meet all of your breathing air quality concerns.
3.10 Personal Work Practices
- Use appropriate personal protective equipment.
- Do not eat, drink, or apply cosmetics in the lab.
- Do not smell or taste any chemicals.
- Do not pipette by mouth.
- Smoking is not allowed in any University building. Smoking should also be avoided adjacent to open windows, air intake manifolds, or entrance ways.
- Wash promptly and thoroughly anytime a chemical has contacted the skin. Wash hands well before leaving the lab.
- Be aware of long hair, neck ties, and loose fitting clothing.
- Do not use phones, touchscreens, keyboards, computer mice, or doorknobs while wearing gloves.
- Encourage safe work practices by setting a proper example.
- Horseplay is strictly forbidden.
- Do not sit on any surfaces other than chairs and stools.
- Repetitive motions can cause injuries. These risks can be reduced by changing posture, viewing angles, standing on cushioned mats, and taking occasional breaks. Obtain assistance when lifting heavy objects and keep the back straight. Consult the DEHS if there are ergonomic concerns.
- Consult the SDS and/or other appropriate resources for a complete understanding of the hazards associated with any particular chemical you are using.
- Appropriately label all containers that contain hazardous materials.
- Dispose of all hazardous waste properly.
A. Labels From Suppliers
Labels from suppliers often use the National Fire Protection Agency (NFPA) pictogram to describe hazards (See Appendix C). Suppliers have until June 1, 2015 to start using the Globally Harmonized System (GHS) of labeling (See Appendix D). Employees should expect a mixture of label protocols during the transition period, and until current inventories are depleted. All labels should include the name, address and telephone number of the supplier. They should also include a product identifier, signal word, hazard statement, precautionary statement, and pictogram.
- Labels should be read carefully each time a new chemical is received.
- Follow all special handling requirements, such as refrigeration.
- Peroxides should be labeled with the date they were received and with the date by which they should be used, tested, or disposed of.
- Special care should be given to maintaining a "first in first out" policy regarding peroxides or peroxide forming compounds.
B. Secondary Container Labels
A secondary container is created any time a chemical is removed from its original container.
- Unlabeled secondary containers should never be left out overnight. This includes beakers or any other temporary storage vessels.
- Secondary containers must be labeled by the individual who first uses the container. Employees should use their professional judgment on what information should be included on their labels. At the very minimum, the chemical name, date, hazard class, and hazard number must be included. Add whatever information is necessary to each label until there is no doubt as to the toxic nature of the contents of any container.
- NFPA labels are fully compliant with the newer GHS standards on secondary containers. Because of their smaller size, and because a generic NFPA label is suitable in all situations, the University has decided to use them for all secondary container labeling. See Fisher Catalog number 18-999-797.
3.12 Unattended Operations
Unattended operations may be required from time to time. All unattended operations using hazardous materials must be preceded by a site-specific SOP (See Appendix A).
- The PI responsible for the unattended operation must submit the appropriate paperwork to the CHO.
- Special consideration must be given to the implications of a loss of utilities.
- Public Safety must be made aware of the process in advance, and should be given clear written instructions on how often to inspect the operations, and what to do if an abnormality is discovered.
- The lab lights must be left on for unattended operations.
- If potentially hazardous conditions exist, then the site-specific SOP must also include corrective measures.
3.13 Working Alone
Experiments should not be performed while working alone. Arrangements should be made to have a knowledgeable person assisting, nearby, or checking in on a regular basis.
3.14 Laboratory Security
- Laboratories should be locked when not in use.
- Laboratory doors should be closed at all times to assist with ventilation design.
- Particularly hazardous substances and Select Agents and Toxins should be properly secured within the laboratory, and in a designated area (See Section 6.4 and 6.5).
- Unauthorized individuals should not be allowed in any laboratory.
- Employees should politely decline to answer questions about inventory and operations from unknown individuals, and should contact Public Safety if they witness any unusual behavior.
- Visitors must be accompanied by an authorized laboratory employee.
- Visitors must be informed of any possible hazards, and should always wear appropriate PPE.
- Minors are not permitted to have any contact with hazardous materials without prior written parental consent.
- Minors may not handle particularly hazardous substances, select agents and toxins, gas cylinders, or lab animals.
- Minors may never be left unattended in any lab.
- Pets are not permitted in any lab. If an employee requires the use of a service animal, then a site-specific SOP (See Appendix A) should be submitted so that the appropriate arrangements can be made.
3.16 Signs and Emergency Contacts
Every room that contains hazardous materials must have a warning sign posted outside and visible to employees entering these rooms. This will also assist emergency responders in using the appropriate precautions.
3.17 Site-Specific SOP
- If laboratory hazards are present that are not covered by this document, then the PI must complete Appendix A and submit it to the CHO. These additional hazards might include processes, select agents and toxins, etc.
- The site-specific SOP should carefully consider all the possible risks, and take steps to minimize them.
- All employees must be trained on the contents of all appropriate SOPs. Special consideration should be given to PPE, SDS, inventory, employee monitoring, and how to handle emergencies.
- Site-specific SOPs that have been submitted to the CHO are listed in Appendix E, and are a part of this document.
4. Implementation of Control Measures and Emergency Response
4.1 Air Sampling
It is the University's policy that employees are never exposed to any hazardous chemical at or above the Permissible Exposure Limit (PEL) or Threshold Limit Value (TLV). It is the responsibility of the PI to make sure that employees have the training and resources required to minimize overexposure risk. It is the responsibility of each employee to understand the SDS and to take appropriate preventative safety precautions.
The DEHS has the equipment necessary to monitor the quality of the breathing environment, and will assist with any concerns. Monitoring results must be provided to the laboratory personnel in writing within 15 days. The monitoring for airborne concentrations of hazardous materials may be required if any of the following situations occur:
- It is required by a site-specific SOP.
- If it is suspected that any PEL or TLV has been met or exceeded.
- When large quantities of a hazardous chemical are used for a long period of time.
- There was an accident or spill which released contaminants into the air.
- An odor has been detected and the chemical used has a PEL or TLV lower than the odor threshold.
- An employee shows symptoms of exposure.
- Any employee requests monitoring.
If any employee believes that he or she may have been over exposed to any hazardous chemicals, or if he or she is experiencing any exposure related symptoms, then the employee should contact the DEHS as quickly as possible. See Section 8: Medical Consultations and Examinations for more information.
4.2 Spill Response
A. Spill Kits
Every lab or suite of labs should be stocked with a spill kit for responding to chemical spills. These spill kits are supplied by, and their contents are inventoried annually by, the CHO. These kits consist of large plastic drums that contain absorbent materials, neutralizers, plastics bags, PPE, and instructions. The drums act as a receptacle for the absorbent materials after they are used. All laboratory employees should be aware of the location of these spill kits, their contents, and how to use them.
B. Incidental or Simple Chemical Spills
Signs of a chemical spill include, but are not limited to, broken glass, a puddle of liquid, unusual fumes, fog, odor, smoke, fire, or unusual sounds. A chemical spill is incidental or simple if it is does not endanger people or the environment. If the hazardous nature of the spill is understood by the employee who is familiar with the spilled chemical and has been property trained pursuant to this Plan, the Chemical Spill Response Plan, and/or the Radiation Safety Manual, as applicable, and if the spill can be contained by using the spill cleanup kit, then they should do so. The following procedures should be used to clean up incidental spills:
- Notify all people in the immediate area. They can assist, if qualified, or should leave, if not.
- Close all doors.
- Avoid breathing hazardous vapors.
- Put on the appropriate PPE.
- Use the spill kit.
- If a floor drain is nearby, use the rolls of absorbent to keep the spill from reaching the floor drain. The included absorbents can be used for acids, bases, or organics. All used absorbents should go into a labeled and sealed plastic bag. These bags should go into the plastic drum that contains the spill kit, and it should be sealed.
- Clean the area thoroughly with water. Exercise caution if the spill was a strong acid or base as such substances may give off toxic fumes, or generate heat upon contact with water or neutralizing substances.
- Contact the CHO for removal and replacement of the spill kit.
- Any spill to the outside environment requires immediate clean-up and notification to the DEHS.
C. Other Chemical Spills or Release
A chemical spill is not an incidental or simple spill if it poses a significant threat to people or the environment. The threat can either be a result of the quantity or toxicity of the chemical spilled. When responding to such a spill or release, follow the procedures set forth in the University's Emergency Management Plan and the University Emergency Response Plan. Any spill to the outside environment requires immediate notification to the DEHS.
D. Mercury Spill
All laboratories that have mercury or mercury containing devices (e.g. mercury thermometers) should have mercury-specific spill kits on hand.
- The responder should put on safety glasses and gloves.
- The spilled mercury should be swept up or suctioned up using a disposable pipette and placed into the waste receptacle.
- The spill area should be covered with a thin layer of mercury absorbent powder, and the absorbent should be swept up, and placed into the waste receptacle as well.
- Contact the CHO for removal of the waste and for replenishment of the mercury-specific spill kit.
4.3 Utility Outages
All utilities can fail without warning. If running water, lights, or functioning fume hoods are critical in maintaining a safe working environment, then advance planning is required.
- If there is a power outage, close all hoods, turn off or unplug heaters, place lids on volatile chemicals, close the door and leave.
- Take any other actions that are required to ensure that utility recovery does not have any negative impact.
- In the event of an emergency caused by a utility outage, follow the procedures set forth in the University's Emergency Management Plan.
4.4 Medical Emergencies and Symptoms of Exposure
Exposure symptoms for any particular substance will be described in the SDS. Symptoms from chronic exposure may develop slowly over time and be more difficult to detect. Symptoms may also vary depending on whether the exposure occurred through inhalation, ingestion, skin contact, or by some other means. It is possible that sensitivity to certain chemicals can increase over time and repeated exposure. Some common symptoms of exposure include: inflammation, rashes, shortness of breath, dizziness, slurred speech, irritation, or a change in concentration or alertness. Consult the SDS and report any possible symptoms of chemical exposure to the PI and DEHS.
An incident should be considered a medical emergency if the injured or exposed person cannot be treated by simple first aid procedures provided by non-medically trained personnel. In the event of such an emergency, follow the procedures set forth in the University's Emergency Management Plan, as well as the procedures outlined below.
4.5 First Aid
Section 4 of every SDS will contain specific first aid information that can be applied by people without medical training. In general, the following procedures can be followed to assist an injured person:
- Remain calm.
- If the injury might be serious, call 911.
- Inspect the area and avoid, or if possible, remove the hazard.
- Apply lifesaving measures.
- Do not move an injured person unless necessary.
- Take reasonable and appropriate steps to stop any bleeding.
- Assist with eyewash fountains or showers as required.
- Keep the person warm.
- Seek immediate medical attention.
4.6 Chemical Splashes
- If it can be done safely, remove the victim from the splash site.
- Escort the victim to either an eyewash fountain or safety shower.
- Rinse the chemical from the body for 15 minutes while removing contaminated clothing.
- Assist in getting immediate medical attention to the victim.
4.7. Ingestion of a Hazardous Material
- If the victim ingested a hazardous material and is conscious and not convulsing, have the individual drink large amounts of water to dilute the chemical.
- Seek immediate medical attention.
4.8 Inhalation of Chemical Fumes
- As the rescuer, use caution not to inhale toxic fumes yourself.
- Transport the victim to fresh air.
- Provide CPR or artificial respiration as required.
- Seek immediate medical attention.
All employees who work with flammable materials must receive fire extinguisher training from the DEHS. Employees should not attempt to extinguish a fire unless they have been trained and doing so will not put them or others at risk of injury.
- If you have completed fire extinguisher training and you feel you can do so safely and quickly, put out the fire with a fire extinguisher. After the fire has been extinguished, call 911 and contact Public Safety.
- If the fire cannot be extinguished safely and quickly, follow the procedures set forth in the University's Emergency Management Plan.
5. Engineering Controls
5.1 Fire Extinguishers and Fire Alarms
Every lab has fire extinguishers and fire alarms. Each employee using the lab should be aware of the location of all fire extinguishers and fire alarms. The functionality of these devices is checked annually by Facilities Management, and the attached inspection tag is updated. Training in the proper use of a fire extinguisher is required for all lab personnel, and is available from the DEHS.
5.2 Fire Blankets
Fire blankets are stored in metal housing and are made of fire retardant materials. To use a fire blanket to protect yourself, simply open the housing, grab the blanket and wrap it around your body while you roll to the ground and wait for help to arrive. The blankets may retain heat against the body. If possible, use the shower after the fire blanket to remove burn residues and cool the body. Seek immediate medical attention.
Employees should locate the nearest shower prior to using any lab. Showers are generally located in the lab or an adjoining lab, or in the main hallway. The showers may be used to put out fires, or to wash corrosives or other hazardous chemicals off the body. To operate the showers, simply pull down on the metal triangular handle. Push the handle back up to turn off. All showers are checked for proper operation annually during the lab safety audit. If hazardous chemicals have soaked into the clothing, it may be most effective to remove that clothing while showering to make sure there is no further contact between the hazardous chemicals and the skin.
5.4 Eye Wash Fountain
Eye wash fountains must be within a 10 second walk of every room where hazardous materials are manipulated. If a hazardous material gets in someone's eye, it is important to wash the eye for 15 minutes. This will seem like a long time, and the cold water will be painful, but a thorough rinsing is crucial for the well-being of the individual.
Contact lenses should never be allowed in any lab since harmful liquids may get underneath and will be difficult to remove. If a victim of an eye splash incident is wearing contacts, they must be removed.
Eye washing is only effective if the eye is held fully opened during washing. The victim may need assistance holding his or her head in the stream of water with the eye opened.
When 15 minutes of eye rinsing is over, the victim must be escorted to the Health Center or hospital for further medical evaluation.
All eye wash fountains in the science buildings are tested for proper function annually by the CHO. Each employee should be aware of their location and should understand how they work before using any lab.
5.5 Fume Hoods and Ventilation
Laboratories are designed to have an overall negative room pressure relative to adjoining rooms and hallways. This helps minimize toxic vapors from diffusing into non-laboratory areas, and is one reason why lab doors and windows should remain closed. Proper fume hood use is critically important in keeping lab employees safe. Fume hoods are effective in removing hazardous gases, mists, vapors, and dusts from the laboratory breathing environment. Because inhalation is the most common means of bodily absorption of hazardous chemicals, volatile hazardous compounds should be manipulated in a fume hood at all times. There are three significant positions for hoods with sliding glass windows. The first one is fully closed. This is the safest position, and all hoods should be fully closed when not in use. The second position is opened to the mechanical stop (about half opened) or indicator arrow if there is no mechanical stop. This position enables the user access to the hood contents, but still maintains the OSHA standard of approximately 100 feet per minute face velocity. There is a tolerance of 15% on the flow specification. The third significant position is fully opened. While it may be necessary to fully open a fume hood occasionally, this should never be standard procedure. If the fume hood must be used fully opened, there is a red emergency button that will increase hood flow when pressed. The hood flow should be returned to normal as soon as the sash can be lowered to the sash stop.
The proper function of each hood and the location of the mechanical stop or indicator arrow will be confirmed annually by the CHO. Inspection stickers will be applied to the hood and results will be maintained as part of the laboratory safety audit.
The hoods can self-diagnose certain faults. The alarm button will flash and a beeping sound will be emitted. The CHO should be notified if any hood goes into alarm, and stays there, or if the user suspects that the hood is not operating properly. A suspect hood should be tagged for non-use until inspected and repaired, as appropriate.
Turbulence can significantly reduce the proper function of a fume hood. Therefore the contents of the fume hood should be kept to a minimum. A large apparatus should be located as close to the back of the hood as possible, but the rear baffles should never be blocked. The purpose of hood baffles is to distribute the hood suction such that there is uniform airflow at the face or opening.
When work is performed using extremely volatile or low density compounds, the baffle adjusting lever can be moved to the fully upward position. The middle lever position is for normal operation. If work is being performed with compounds whose vapors are significantly heavier than air, then the baffle adjusting lever can be pulled down to the lowest position.
Under no circumstances should any laboratory user place his or her head inside a hood.
When planning an experiment, consideration should be given to the implications of a loss of power and the resulting failure of fume hood operation.
6. Hazards and Special Substance Requirements
6.1 Definition of Hazardous Chemicals
Any chemical or mixture of chemicals which is classified as a health hazard or simple asphyxiant in accordance with the Hazard Communication Standard 1910.1200 is a hazardous chemical. A mixture is considered to be as hazardous as its most hazardous component. If laboratory workers are generating novel compounds of unknown toxicity, then it should be assumed these compounds are toxic, and precautionary measures should be used. Otherwise, familiarize yourself with all of the potential hazards relating to every chemical in use in the lab.
Always read the SDS for information related to physical and health hazards and safety procedures related to specific hazardous chemicals.
6.2 Physical Hazards
The following classes of materials may pose physical hazards unless proper care is used.
A. Flammable or Combustible Materials
Flammable materials have a flash point below 100 degrees F, or 38 degrees C. Combustible materials have a flash point above 100 degrees F. The flash point is defined as the temperature at which the material gives off enough vapors to form an ignitable mixture with air.
B. Compressed Gases
A gas is considered compressed if it has an internal pressure equal to or greater than 276 Kpa (40psi) at 70 degrees F. Some gas cylinders have an internal pressure exceeding 2200 psi.
Corrosive materials cause an immediate and acute degradation of human tissue. While broad in definition, corrosives include inorganic acids and bases, organic acids and bases, acid salts, group VII elements, and phosphorus. An aqueous solution is considered corrosive if its pH is below 2 or above 12.5.
D. Reactive or Unstable Materials
Unstable materials can undergo a highly energetic or unexpected reaction with certain other incompatible materials. Self-polymerization is also a possibility. Any compound with an NFPA rating of 3 or 4 is considered reactive or unstable. Read the appropriate SDS carefully in order to avoid incompatible mixtures. Sometimes these materials can react vigorously with water or air.
E. Organic Peroxides
Organic peroxides can initiate unexpected free-radical reactions. These substances are sensitive to friction, light, impact, and strong oxidizing or reducing agents.
These substances can react violently with air or water. Be sure to wear the appropriate PPE and take extra precautions to maintain an inert environment when working with pyrophorics. This category includes some metal powders, metal hydrides, and iron sulfides.
Explosives undergo rapid chemical change resulting in the production of large volumes of gas (pressure) and heat. This reaction can be initiated through heat, light, shock, or some other catalyst.
6.3 Health Hazards
Substances which lead to detrimental acute or chronic health effects are considered to be health hazards. Possible symptoms are listed in Section 4.4: Symptoms of Exposure. Acute health effects result from a sudden and severe exposure. Chronic health effects result from prolonged or repeated exposure. Symptoms of chronic exposure may not immediately be apparent.
Substances which are health hazards can be grouped according to the area of the body affected. Always consult the SDS for information related to health hazards, required PPE, and appropriate first aid. The following classes of materials may pose health hazards unless proper care is used.
Irritants cause swelling and redness of human tissue. The skin, eyes and lungs are most commonly affected.
An allergen has an adverse effect on the body's immune system. Repeated exposure can often lead to a heightened sensitivity to a particular compound. Anaphylactic shock or poison ivy rash are examples of allergen response.
Asphyxiants often interfere with the transport of oxygen throughout the body. Carbon monoxide and certain cyanide containing compounds bind with the hemoglobin in the blood. Even inert gases can cause asphyxiation if they displace the required oxygen from the breathing environment.
It has already been mentioned that corrosives degrade human tissue. They can be solid, liquids, or gases. Their impact is usually immediate. While a more severe form of irritant, this class of compounds is usually prevalent in the laboratory environment.
Carcinogens are cancer-causing substances. Whether through direct or indirect influence on DNA, carcinogens alter the growth of new cells. Since the impact of carcinogens on the body is rarely immediate, take special precautions to avoid chronic, repeated exposure.
F. Teratogens and Mutagens
This class of substances is also called reproductive toxins. They can have a negative effect on fertility, gestation, lactation, or post natal functionality. The embryo and fetus in pregnant women are particularly vulnerable. If you are pregnant, or are trying to become pregnant, you should take extra precautions to minimize your exposure to these compounds. Feel free to consult with your PI or Human Resources for additional assistance or special accommodation.
There are many other organs of the body which can be targeted by toxic substances. The liver, nervous system, kidneys, and blood are all examples. There are too many to list in this CHP. Always consult the SDS for information related to the toxicity of whatever compounds you are working with.
6.4. Particularly Hazardous Substances
Certain substances are highly toxic. Their effects can be acute, or chronic, or both. The current OSHA Standard, is to consider any chemical with a lethal dose (LD50) of 50 mg per kilogram or less, to be highly toxic when administered orally. The maximum allowed exposure becomes 200 mg per kilogram with skin contact, and 200 ppm when inhaled. The LD50 dose implies a lethal response in 50% of the test animals. The National Toxicology Program considers their list of Group 1 carcinogens to be highly toxic. OSHA also lists particularly hazardous substances in 29 CFR 1910.1200 Appendices A and B, and in 29 CFR 1910.1450. These lists have been combined into Appendix F of this document.
The exact toxic nature of these substances can vary. Permitted exposure levels may be much lower than those listed at the beginning of this section. Detailed information is available in the appropriate SDS. Under no circumstances should any employees purposely be exposed to any compound above OSHA's Permissible Exposure Limit (PEL), or above the Threshold Limit Value (TLV) as determined by the American Conference of Governmental Industrial Hygienists (ACGIH).
All reasonable efforts should be made to minimize the risk associated with the use of these particularly hazardous chemicals. This can be accomplished by:
- Minimizing the amount of time that employees use and/or manipulate these compounds.
- Consulting the SDS for special PPE requirements and following any specifications or recommendations. At the minimum, employees who are working with particularly hazardous substances should wear gloves, eye protection, lab coats, and perform all work in a designated hood.
- Storing and using particularly hazardous substances must be done in suitable designated areas. This area may be a particular hood, glove box, or the entire lab, but everyone in the lab should recognize that this area requires special training, precautions, and safety discipline. The designated areas should be decontaminated by a thorough cleaning to remove all toxic residue immediately after each use.
- Segregate waste products of particularly hazardous substances from other waste products. Any waste products from particularly hazardous substances should be further protected by secondary containment using unbreakable containers, and the contents of such containers should be labeled.
Every department must maintain an accurate annual inventory of particularly hazardous substances. A copy of this inventory must be on file with the DEHS, and any inventory irregularities should be reported immediately.
6.5. Select Agents and Toxins
The United States Department of Health and Human Services (HHS) and the United States Department of Agriculture (USDA) have compiled a list of select agents and toxins. A copy of this list is included in Appendix G. Due to the extreme toxicity of these compounds, the purchase or use of these substances requires a site-specific SOP to be prepared by the PI in collaboration with the CHO and CHC. Further approval must be obtained by the Provost, the Dean of the College, and the CHC (or their respective designees) prior to purchasing or obtaining any select agent or toxin. These substances must be stored and used in secure designated areas. At a minimum, all of the procedures listed for particularly hazardous substances also apply.
No employees are permitted to obtain any of the chemicals listed on Appendix G without having a previously approved site-specific SOP and prior approval by the CHC, the Dean of the College, and the Provost (or their respective designees).
6.6 Flammable or Combustible Materials
- Flammable and combustible materials should be stored in an NFPA approved container or cabinet which is labelled "flammable", or in an appropriately designed storage room.
- Large drums of these materials should be electrically bonded to ground potential.
- Fire extinguishers should always be present in rooms containing these materials.
- Care should be taken to remove possible sources of ignition when working with flammable and combustible compounds. These sources might include open flames, hot surfaces, electrical equipment and static electricity.
Since the SDSs refer to NFPA classifications, a brief description of these classifications is included below. Note that the flash point is defined as the minimum temperature at which a material has sufficient vapor pressure to ignite near its surface.
|Class||Flash Point||Boiling Point|
|IA||Less than 73 F||Less than 100 F|
|IB||Less than73 F||Greater than 100 F|
|IC||Between 73 and 100 F|
|II||Between 100 and 140 F|
|IIA||Between 140 and 200 F|
|IIIB||Greater than 200 F|
Some common laboratory corrosives include:
- Organic Acids
- Acetic Acid
- Acetic Anhydride
- Acetyl Chloride
- Acetyl Bromide
- Benzoyl Bromide
- Benzoyl Chloride
- Benzyl Bromide
- Benzyl Chloride
- Butyric Acid
- Chloroacetic Acid
- Chloroacetyl Chloride
- Dimethyl Sulfate
- Formic Acid
- Methyl Chloroformate
- Oxalic Acid
- Propionic Acid
- Propionyl Bromide
- Propionyl Chloride
- Salicylic Acid
- Trichloroacetic Acid
- Organic Bases
- Tetramethylammonium Hydroxide
- Inorganic Acids
- Bromine Pentafluoride
- Chlorosulfonic Acid
- Hydriodic Acid
- Hydrobromic Acid
- Hydrochloric Acid
- Hydrofluoric Acid
- Nitric Acid
- Perchloric Acid
- Phosphoric Acid
- Phosphorus Pentachloride
- Phosphorus Pentoxide
- Phosphorus Tribromide
- Phosphorus Trichloride
- Sulfuric Acid
- Sulfuryl Chloride
- Thionyl Chloride
- Fluorine (gas)
- Chlorine (gas)
- Bromine (liquid)
- Iodine (solid)
- Phosphorus (solid)
- Inorganic Bases
- Ammonium Hydroxide
- Ammonium Sulfide
- Calcium Hydride
- Calcium Hydroxide
- Calcium Oxide
- Potassium Hydroxide
- Sodium Hydride
- Sodium Hydroxide
- Tin Bromide
- Tin Chloride
- Titanium Tetrachloride
- Acid Salts
- Aluminum Trichloride
- Ammonium Bifluoride
- Antimony Trichloride
- Calcium Fluoride
- Ferric Chloride
- Sodium Bisulfate
- Sodium Fluoride
- Corrosives can burn the skin, can degrade metals, and should never be stored in metal containers.
- Always wear the appropriate gloves and safety glasses when working with corrosives, and take note of the nearest eye wash fountain and safety shower.
- It is important when diluting corrosives that the corrosive is added to the water or solvent, and not the other way around.
Some common laboratory oxidizers include:
- Hydrogen Peroxide
- Peracetic Acid
- Mineral Acid
- Nitric Acid
- Perchloric Acid
- Nitrous Oxide
- Chromic Acid
- Sodium Borate Pentahydrate
- Sulfuric Acid
- Oxygen Difluoride
- Oxidizers react with reducers through electron transfer. This reaction can be extremely vigorous depending on the reduction potential of the reactants.
- Extra precautions should be used when reactions can be vigorous.
- Consideration should be given to cooling, lowering reactant concentration, additional shielding, and removing extraneous reactants.
6.9 Organic Peroxides
Organic peroxides can be produced by exposure of certain organic compounds (such as ethers) to air.
- The shelf life of these compounds can vary greatly and they can become explosive if exposed to impact, friction, or heat. Consult the SDS for shelf life, and date the compounds accordingly.
- These compounds should be used, disposed of, or inhibited by the date listed on the SDS.
- To avoid metal contamination, never use metal spatulas or uncoated magnetic stirrers with organic peroxides. Inspect coated magnets for abrasions.
6.10 Water Reactive Substances
Some common water reactive laboratory chemicals include Lithium Aluminum Hydride, Phenyl Magnesium Bromide, Tin Chloride, Sodium Metal, and Potassium Metal.
- Water reactive substances can react with water to produce a flame or toxic gas. Often the natural humidity in the air is enough to initiate the reaction.
- Employees working with water reactive substances should be trained in the proper use of inert environments, or dry boxes.
- Contact the DEHS if these materials require a Class D fire extinguisher.
6.11 Unstable Substances
Examples of unstable substances include peroxides, perchlorates, picric acid, and azides.
- Unstable substances may form explosive mixtures when exposed to light.
- These substances should be stored in a cool, dark place in amber colored bottles.
- Some unstable substances can become increasingly shock sensitive with age.
- Careful labeling and extra barrier protection should be used.
6.12 Nitric Acid
Nitric acid requires special attention because of its prevalence in labs. It is a powerful oxidizer, a strong acid, and a corrosive. It will form oxides of nitrogen when exposed to air, some of which can be extremely toxic.
- Eye contact with nitric acid will cause severe burns.
- Nitric acid can react violently with easily oxidized organics and with metal powders.
- Store nitric acid in glass containers since it is not compatible with certain plastics.
6.13 Perchloric Acid
Perchloric acid is similar to nitric acid in that it is a strong acid, and a powerful oxidizer. Historically, perchloric acid was used to completely digest samples so they could be analyzed. It has since been discovered that perchloric acid can condense inside a fume hood and form explosive metallic salts. It can also react with grease and oil present in mechanical exhaust systems.
Perchloric acid digestions require specially designed hoods with built-in sprinkler systems for washing the inside residue. Since no such hoods currently exist at Washington and Lee University, perchloric acid digestions are not allowed. In order to use perchloric acid for any reason, the PI must submit a site-specific SOP in advance.
6.14 Hydrofluoric Acid
Although Hydrofluoric Acid (HF) is a particularly hazardous substance, and not a select agent or toxin, its use requires a site-specific SOP.
- HF gives off pungent and dangerous fumes when exposed to air.
- HF causes very deep burns upon contact with human tissue.
- The victim may not feel any pain as HF continues to degrade tissue.
- Death may result when as little as 2% of the body is exposed to HF.
- HF should not be stored in glass containers.
- In addition to a site-specific SOP, any labs using HF must have calcium gluconate gel in their first aid kits.
6.15 Ethidium Bromide
Ethidium Bromide is a powerful mutagen used to stain nucleic acid polymers.
- Users should avoid contact with the skin.
- Fume hoods, eye protection, and chemical resistant gloves must be used.
- Ethidium Bromide is incompatible with strong oxidizing agents.
6.16 DNA and RNA
Whether inside or outside of a living cell, the toxicity of DNA and RNA molecules is considered to be equivalent to their natural counterparts. They should be treated as hazardous waste and disposed of in appropriately labeled waste containers.
Cryogens such as dry ice, liquid nitrogen, and liquid helium can cause severe burns upon contact with the skin. Those that are cold enough to condense the oxygen out of air can lead to a hazardous oxygen rich environment. There can be a significant pressure build up as these materials evaporate into large volumes of gas.
- All sealed containers of cryogens should have pressure relief valves installed.
- Cryogens should not be stored in unsuitable containers, since many materials can become brittle or crack under extreme temperature changes.
- Always wear safety glasses and thermal barrier gloves when handling cryogens.
- Glass dewars should always be checked for cracks before use. They should also be shielded or wrapped in electrical tape since they can implode vigorously upon failure, sending glass shards towards the user.
6.18 Radioactive Substances
Washington and Lee University has a separate Radiation Safety Manual. All employees who work with radioactive materials must comply with the contents of this document.
6.19 Biological Material Hazards
- Biosafety level 1 research involves organisms that are not known to cause disease in healthy adults.
- Standard laboratory equipment and techniques are sufficient at this risk level.
- Work surfaces and spills should be decontaminated after each use.
- Employees with immunodeficiencies may be at a higher level of risk.
- Biosafety level 2 research involves organisms with a moderate potential to be hazardous to healthy adults. Biosafety level 2 or higher research requires a site-specific SOP, and advance approval of the CHC, Dean of the College, and the Provost.
Formaldehyde is extremely flammable and toxic. Its pungent odor can be detected as low as 1 ppm concentration. Any exposure of between 0.1 and 5 ppm can result in severe eye, nose, and throat irritation. Exposures above 25 ppm can be fatal. It is also a suspected carcinogen. With a flash point of 50 degrees C, it should be handled in a fume hood away from ignition sources.
6.21 Nano Materials
Nano particles and nano materials have different reactivities and interactions with biological systems than bulk materials. The risks and hazards associated with exposure to these engineered materials are not well known. Consult trusted sources for the most up to date information available. Their small size and increased reactivity mean they can act as sources of ignition, acceleration, or fuel.
Easily dispersed dry nano materials may pose the greatest health hazard because of the risk of inhalation.
- Avoid handling nano materials in the open air in a free-particle state.
- Use a hood.
NOTE: Those particles that are encapsulated or dispersed in a liquid may not require engineering controls.
7. Employee Information and Training
7.1 Hazard Information
General principles of chemical hygiene and annual changes to the CHP will be provided to all appropriate departments by the CHO. All laboratory employees must have access to hard copies of this CHP and to current SDSs. Each department should decide whether this information is stored in the individual labs, or in some other central location. The current CHP can also be found at the following website: http://go.wlu.edu/chemicalhygieneplan.
7.2 Material Safety Data Sheets (MSDS)
The MSDS requirement is being phased out, and will soon be replaced with Safety Data Sheets (SDSs). All Departments should keep their MSDSs and SDSs for 30 years. Other than a global initiative towards uniformity, there are few differences between an MSDS and an SDS.
7.3 Safety Data Sheets (SDS)
Every hazardous chemical must have a SDS on file. Chemical suppliers are required to provide SDSs for all hazardous materials ordered. In addition, this information is often available online. Fisher Scientific and Sigma Aldrich both provide this free service at their websites. Hard copies must still be printed and retained for 30 years.
Safety data sheets (SDS) must be provided by your chemical supplier. These documents describe the specific properties, hazards, and health related information for each hazardous chemical purchased or obtained. The SDSs should be considered the primary source of this information.
OSHA requires that the SDS for each hazardous chemical be available to all employees working with such chemical. OSHA has also incorporated the Globally Harmonized System (GHS) into its SDS requirements. The GHS system changes some of the language and pictograms that are used to describe hazardous chemicals. These changes will be described in the following sections.
All SDSs should contain the following 16 sections:
- Identification. This section must include the company address and phone number.
- Hazards(s) Identification.
- The hazard classification must be stated (e.g. flammable liquid).
- A signal word (e.g. danger).
- A hazard statement (e.g. causes skin irritation).
- Pictogram or hazard symbol. Some of the GHS pictograms are different than other systems already in use. Appendix D lists all the GHS pictograms. Since it may take several years for SDSs to fully replace MSDSs, Appendix C shows the pictograms from the National Fire Protection Association (NFPA), which are often used in MSDSs.
- Precautionary statements (e.g. keep away from heat)
- Composition/information on Ingredients. This section includes the chemical name, and common names. The Chemical Abstract Service (CAS) number should also be listed. All hazardous components of a mixture should be included.
- First Aid Measures. This section describes the initial care that should be given regardless of medical training. It includes symptoms and what further medical treatment should be given.
- Firefighting Measures. Important information includes what kind of fire extinguisher is required, advice on specific hazards such as combustion products, and special firefighting PPE.
- Accidental Release Measures. The appropriate response may include evacuation, selection of special PPE, containment, neutralization, etc.
- Handling and Storage. This section considers potential container incompatibilities such as glass versus certain plastics. It will also describe other chemical incompatibilities and advice on storage such as ventilation or fire resistance.
- Exposure controls/personal protection. This may be the most important section for employees to read and understand before working with toxic substances. OSHA has developed Permissible Exposure Limits (PELs) for many hazardous substances. The American Conference of Governmental Industrial Hygienists (ACGIH) has developed a similar Threshold Limit Value (TLV). TLVs describe the maximum exposure for an 8 hour day. Any substance with a TLV or PEL of less than 200 ppm should be handled in a fume hood at all times. PELs and TLVs will vary depending on the whether they are absorbed through inhalation, skin contact, or some other means. This section will also include special PPE required for each particular material, including eye, face, skin, and respiratory protection.
- Physical and Chemical Properties. Depending on the nature of any given compound, this section may only include a few characterizations, or it may include many.
- Stability and Reactivity. If the reactivity of a substance may present a hazard, then it will be listed here. The stability at room temperature is also discussed, as is any stabilization techniques. Sometimes conditions that are to be avoided are mentioned such as excess heat, shock, static charge, or polymerization initiators.
- Toxicological information. The likely routes of exposure to a hazardous substance include inhalation, ingestion, and eye or skin contact. The toxicity of a compound will likely be different depending on the route taken. This section will often provide a meaningful numeric measure of the toxicity whether it be TLV, PEL, LD50, or some other measure. The health effects will be listed as either acute or chronic, along with possible symptoms.
- Ecological (not mandatory). Consideration here is given to the environmental impact of hazardous substances. It may include aquatic or terrestrial organisms, the chemical persistence, bioaccumulation, ozone layer impact, and possible groundwater contamination.
- Disposal considerations (not mandatory). This section might contain container compatibility, recycling, and landfill or incineration recommendations.
- Transport information (not mandatory). Information here will include the four digit United Nations number and proper name, along with the transportation hazard class.
- Regulatory information (not mandatory). If other regulatory agencies that were not previously mentioned have guidelines concerning a particular substance, then it will be mentioned here.
- Other information. This section will mention the original SDS version date, and revision dates. It may also point out which sections were revised.
All employees are expected to consult the SDS so they are familiar with the properties of all the hazardous materials they manipulate, and to take appropriate precautions to minimize risk.
7.4 Employee Training
All employees who work with hazardous chemicals in a laboratory environment must receive training on the content of the CHP, as well as the following:
- The contents of the Lab Standard and its appendices, which shall be made available to all employees;
- The location and availability of the CHP;
- Signs and symptoms associated with exposure to hazardous chemicals used in the laboratory;
- The permissible exposure limits for OSHA-regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard;
- Location and availability of known reference materials on the hazards, safe handling, storage, and disposal of hazardous chemicals found in the laboratory, including, but not limited to, SDSs;
- Methods and observations that may be used to detect the presence or release of hazardous chemicals (such as monitoring conducted by the University, continuous monitoring devices, visual appearance or odor of hazardous chemicals when released, etc.);
- The physical and health hazards of chemicals in the workplace; and
- The measures employees can take to protect themselves from the physical and health hazards of chemicals in the workplace, including specific procedures the University has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used4.
Each employee must be trained in accordance with this Section at the time of initial assignment to the laboratory and prior to any assignments that involve new exposure situations. Refresher training will occur on a frequency to be determined by the CHC. No employees, regardless of title, are exempt from this requirement. Training will be conducted by the DEHS and/or the CHO. Training records will be maintained by the DEHS for 30 years.
8. Medical Consultations and Examinations
8.1 Opportunity to Receive Medical Attention
All employees who work with hazardous chemicals are provided an opportunity to seek medical attention, including any follow-up examinations which the examining physician deems necessary, whenever:
- An employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed to in the laboratory, the employee shall be provided an opportunity to receive an appropriate medical examination.
- A medical surveillance program is established after exposure monitoring reveals an exposure level routinely above the action level for an OSHA regulated substance which has exposure monitoring and medical surveillance requirements.
- If an event takes place in the laboratory, such as a spill, leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure, the employee will be provided an opportunity for a medical consultation. Such consultation shall be for the purpose of determining the need for a medical examination.
8.2 Costs and Other Specific Provisions Related to Medical Consultations and Examinations
All medical examinations and consultations must:
- Be performed by or under the direct supervision of a licensed occupational physician. Every effort shall be made to refer employees to licensed physicians who have been trained to recognize signs and symptoms of chemical-related exposure and disease.
- Be provided at no cost to the employee.
- Be provided without loss of pay to the employee.
- Be performed at a reasonable time and place for the employee. Every effort shall be made to schedule medical examinations and consultations during the employee's regularly scheduled work hours, provided there is no undue delay in medical attention.
8.3 Information Provided to Physician
The University will provide the physician with the following information:
- The identity of the hazardous chemicals(s) to which the employee may have been exposed, including a copy of the appropriate SDS.
- A description of the conditions under which the suspected exposure occurred, including quantitative exposure data, if available.
- A description of the signs and symptoms of exposure that the employee is experiencing, if any.
8.4 Physician's Written Opinion
The University, through Human Resources, must obtain a written opinion from the examining physician. The written opinion must include the following:
- The results of the medical examination and any associated tests.
- Any recommendation for further medical follow-up.
- Identification of any medical condition which may place the employee at increased risk as a result of exposure to a hazardous chemical in the workplace.
- A statement that the employee has been informed of the results or the consultation or medical examination and any medical condition that may require further examination or treatment.
The written opinion shall not reveal specific findings or diagnoses unrelated to the occupational exposure.
After initial medical treatment, any chemical exposure or laboratory injury should be immediately reported to the PI and to the DEHS. The PI should fill out an OSHA-approved First Report of Injury form and submit a copy to the DEHS. This form is also available at: http://www.wlu.edu/document/employeraccidentreport.
9. Audits and Recordkeeping
9.1 Laboratory Safety Audits
Every lab or other area where hazardous materials are manipulated or stored is subject to annual safety audit by the CHO, DEHS, and/or CHC members. All built-in safety equipment will be inventoried and tested. Since the goal is to create a safe working environment, these inspections are likely to be by appointment, but the CHO, DEHS, and CHC reserve the right to conduct such safety audits at any time.
The PI is encouraged to get all employees and involved in the inspection and improvement process. Students may also be involved, as appropriate.
Appendix B shows the format used for these audits and is a valuable resource for those who are responsible for maintaining compliance.
Copies of safety audits will be maintained by the CHO for 30 years, and sent to the PI and CHC.
There are quite a few recordkeeping responsibilities listed throughout this document. A summary based on employee title is as follows.
- Provide a list of all laboratory employees to the CHO annually.
- Determine the frequency of CHP refresher training.
- Approve the CHO annual budget.
- Act as CHC Secretary and maintain meeting notes.
- Update the CHP annually.
- Perform annual safety audits of every lab.
- Inspect all built in engineered safety equipment annually.
- Maintain site specific SOPs.
- Maintain all training completion forms for 30 years.
- Maintain all First Report of Injury forms for 30 years.
- Maintain all environmental monitoring and air sampling results for 30 years.
- Maintain all medical monitoring and medical consultation paperwork for 30 years.
- Submit a First Report of Injury form to the DEHS whenever an employee has been injured or exposed.
- Maintain chemical inventories and make available to the DEHS upon request.
- Get site specific SOP approval whenever appropriate.
10. References and Resources
This section contains additional resources that are in possession of the CHO. These materials are available to anyone who wants additional information.
- Occupational Exposure to Hazardous Chemicals in Laboratories (the "Lab Standard"), 29 CFR 1910.1450
- Developing a Chemical Hygiene Plan, Jay Young, American Chemical Society, Washington, DC, 1990
- Educating for OSHA Savvy Chemists, Paul Utterback, Ed., ACS, Washington, DC, 1998
- Eye Protection, ANSI Standard Z87.1-2010
- Handbook of Laboratory Safety, 3rd Edition, A. Keith Furr, Ed., CRC Press, Ann Arbor, 1990
- Hand Protection, 29 CFR 1910.138
- Hazard Communication Standard, 29 CFR 1910.1200
- Hazardous Materials Chemistry for Emergency Responders, 2nd Edition, Robert Burke, CRC Press, New York, 2003
- Journal of Chemical Health and Safety, American Chemical Society, Volume 20, Number 5, 2013
- Laboratory Health and Safety, 2nd Edition, R. Scott Stricoff, John Wiley & Sons, Inc., New York, 1995
- Prudent Practices in the Laboratory, National Academy Press, Washington, DC, 2011
- Respiratory Protection, 29 CFR 1910.134
129 CFR 1910.1450(b) (definition of Chemical Hygiene Plan)
2Portions of this CHP are modeled after or taken from the same or similar provisions in the Amherst College Chemical Hygiene Plan and the Middlebury College Chemical Hygiene Plan.
329 CFR 1910.1450(e)(4)
429 CFR 1910.1450(f)