Wittenberg University Chemical Hygiene Plan
|A. History of the OSHA Laboratory Standard||
|B. Role of the Chemical Hygiene Plan||
|II Facilities To Be Covered Under This Plan||
|C. Chemical Hygiene Officer||
|D. Department Chairs||
|E. Faculty & Staff||
|IV Standard Laboratory Procedures And Regulations||
|A. Basic Rules and Procedures||
|B. Control Measures and Equipment||
|C. Chemical Procurement, Distribution, and Storage||
|D. Housekeeping, Maintenance, and Inspections||
|E. Medical Program||
|F. Protective Apparel and Equipment||
|H. Spills and Accidents||
|I. Waste Disposal Program||
|A. Incident Report Form|
|B. Hazardous Waste Management Policy And Procedures|
The purpose of the written Chemical Hygiene Plan at Wittenberg University is to set forth procedures, equipment, personal protective equipment, and work practices that are capable of (1) protecting employees from the health hazards associated with hazardous chemical use in the laboratory and (2) keeping exposures below safe threshold levels. The intent of the program is to minimize risks associated with hazardous chemical use by reduction, elimination (where feasible), and adherence to the standard PEL and TLV values established for safe use.
Because knowledge concerning the hazards involved and the best means of reducing those hazards increases constantly, the University reserves the right to modify this document at any time as new information becomes available which would affect something contained within this plan. It shall be the policy of the University to review this document at least once per year.
On November 25, 1983, the Occupational Safety and Health Administration (OSHA) published the Hazard Communication Standard which applied to certain manufacturers and in part to certain laboratories. HazComm requires that employers inform employees about the presence and use of hazardous substances in the workplace. HazComm applies to all employees in all workplaces. OSHA received many comments regarding whether the procedures of the Hazard Communication Standard should apply to laboratories where the staff is highly educated. OSHA decided that although "...31.9% of all laboratory workers have bachelors degrees, 20.6% have masters degrees, and 20.9% have doctorates...there is some question as to whether laboratory workers actually make themselves as knowledgeable as they should be and some laboratory employees are not professionally trained." (51 CFR 2664). Thus, while HazComm may seem inappropriate for employees with scientific training, OSHA was not convinced that these workers should not fall under some (other) set of guidelines.
Other unique differences for laboratories (compared to production facilities) were noted: the small amounts of chemicals used, the vast number of different chemicals involved, and nearly half of the laboratories in one survey could not accurately predict their chemical needs even one month in advance.
OSHA decided "...Despite the existence of the unique characteristics of laboratory work places, in actual practice incidents of acute adverse health effects resulting from exposure to toxic substances in laboratories do occur. Furthermore, some studies...have shown increased risks of certain types of diseases for laboratory workers. In addition, although laboratory workers are, in general, a well educated work force, there is evidence that many laboratories do not have health and safety programs...". Therefore, OSHA proposed the Occupational Exposures to Hazardous Chemicals in Laboratories rule from which this Chemical Hygiene plan originates.
On January 31, 1990, The Department of Labor has published in the Federal Register an amendment to 29 CFR 1910, Subpart Z, identified as Section 1910.1450 (URL: http: //gabby.oshaslc.gov/ OshStd_data/1910.1450. html.) The title of that amendment is "Occupational exposures to hazardous chemicals in the laboratory", better known as the "Laboratory Standard".
A part of that standard is the requirement for the development of a Chemical Hygiene Plan. The fact that Wittenberg is primarily a teaching institution is irrelevant to the Lab Standard; the Lab Standard applies to (relatively small) companies that have labs that do not produce chemicals.
This Chemical Hygiene Plan describes the Wittenberg University safety program, including, but not limited to, standard operating procedures for safe use of hazardous chemicals, criteria for selecting control measures including personal protective equipment, engineering controls, control-equipment inventory and operations (such as vented hoods), employee training programs, medical programs, and safety inspections. This document is intended to comply with 29 CFR 1910.1450 as well as other applicable Federal and State regulations. Where references exist within this document to other documents, those documents will be considered fully applicable here as if those documents had been reproduced here. The Chemical Hygiene Plan is designed as a tool to coordinate safety procedures.
This Chemical Hygiene Plan shall be readily available to affected employees, their representatives, and upon request, to the Assistant Secretary of Labor for OSHA.
The laboratories of the University and all of the work in these laboratories currently meets, and is expected to continue to meet, the definition of "Laboratory" and "Laboratory Scale" given in 29 CFR 1910 subpart Z. This plan covers all work in all laboratories in the Biology, Chemistry, Physics, Geology and Psychology Departments.
The President of the University has ultimate responsibility for implementation of the Chemical Hygiene Plan.
The Provost has the responsibility for approval of the Chemical Hygiene Plan and for the appointment of a qualified individual as the Chemical Hygiene Officer.
III.C. Chemical Hygiene Officer
The Chemical Hygiene Officer is the person responsible for overseeing the implementation of the Chemical Hygiene Plan at Wittenberg University. The Chemical Hygiene Officer has the responsibility to review the Chemical Hygiene Plan as circumstances warrant, but at least once every 12 months, and recommending changes to the Provost. The Chemical Hygiene Officer also has the responsibility for consulting regularly with faculty and staff regarding the use of hazardous substances in labs and for training all personnel who fall under the purview of this Standard.
III.D. Department Chairs:
The role of the Department Chairs are listed below (with references to specific sections of this document:
1. MSDS procurement (IV.C.1).
2. Arranging periodic cleaning of lab benches and areas (IV.D.1).
3. Disposal of hazardous waste (IV.D.1, IV.I.1, and Appendix B).
4. Informal lab inspections (IV.D.2).
5. Overseeing maintenance of safety equipment (IV.D.3).
6. Maintaining an inventory of all chemicals (IV.G.2).
Department Chairs are required to review the work of faculty members within their departments to insure that the work is done in a manner consistent with the policies and procedures contained in this Chemical Hygiene Plan. They are to review requests for faculty within their departments for variances and to recommend to the Chemical Hygiene Officer the acceptance or rejection of the request.
III.E. Faculty & Staff
University faculty and staff that supervise laboratory operations are expected to see that the provisions of the Chemical Hygiene Plan are carried out within the laboratories under their supervision. They (in concert with the Chemical Hygiene Officer) are responsible for making certain that all persons who work within the laboratories are aware of the hazards of the materials with which they are working and have received the training required by the Chemical Hygiene Plan, the Hazard Communications Plan and any other applicable Federal or State regulations prior to beginning work in the laboratory. Further, they are required to plan the work to be done in the laboratories under their supervision so that is done in a manner consistent with this Chemical Hygiene Plan. Where such work departs from the usual practices, either because a new procedure is to be used or especially hazardous materials are required to carry out the work, the lab supervisor should consult with the Chemical Hygiene Officer to be certain that the procedures to be followed will ensure the safety of the persons involved.
In this document, "laboratory supervisor" refers to the faculty or staff member who is most directly responsible for work performed in a lab or stockroom.
1. Definitions. OSHA has defined a "hazardous chemical" as "a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic harm may occur in exposed employees." The term "health hazard" includes "chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoetic systems, and agents which damage the lungs, skins, eyes, or mucous membranes."
The non-mandatory recommendations for a Chemical Hygiene Plan also include references to "moderately chronic," "highly chronic," and "highly acute" toxicity without defining these terms precisely. This Chemical Hygiene Plan places the burden on the lab supervisor, in consultation with the Chemical Hygiene Officer, to make informed decisions about the relative danger of various substances encountered in labs. Information supplied on MSDSs can assist in this process.
All workers shall follow these basic rules and procedures when working with hazardous chemicals within the laboratory. It is expected that all workers will abide by the guidelines listed below.
2. Avoidance of "Routine" Exposure. Never taste chemicals. Avoid contact with skin. As a general rule, one should avoid smelling chemicals, particularly as a means of identification. However, since it is prudent to know the odors of some common chemicals as a matter of safety, when smelling any chemical, waft the vapors very cautiously to avoid inhaling high concentrations and minimize the amount smelled.
3. Eating, Smoking, etc. Do not eat, drink, smoke, or apply cosmetics in areas where hazardous chemicals or preserved biological specimens are present. Wash hands before conducting these activities. Do not store or handle food or beverages in labs or storage areas. So not use refrigerators, glassware or utensils which are also used for laboratory operations for the storage or handling of food or beverages.
4. Equipment and Glassware. Handle and store laboratory glassware with care to avoid damage; do not use damaged glassware. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Do not use mouth suction for pipeting or starting a siphon. Use equipment only for designed purpose.
5. Horseplay. Avoid practical jokes or other behavior which might confuse, startle, or distract another worker.
1. Unattended Operations. Leave lights on, place an appropriate sign on the door, and provide for containment of hazardous chemicals and/or toxic substances in the event of failure of utility service (such as cooling water or electricity) to an unattended operation. No operations involving the use of extremely hazardous materials may be allowed to run unattended without prior approval of the Chemical Hygiene Officer. Such approval will only be granted if the Chemical Hygiene Officer is convinced that precautions have been taken to ensure the safety of others. All unattended operations involving the use of especially hazardous materials will require posting of a sign that such operations are being conducted and that the room may not be entered by persons other than the person(s) conducting the operation. This sign shall also include the name and telephone number of the individual(s) responsible for the laboratory.
2. Use of Hoods. Laboratory ventilation should be normally not less than 20 cubic feet per minute air flow through each room. This flow rate is not considered sufficient to prevent accumulation of chemical vapors. Work done with chemicals with low TLV's or high vapor pressure should be done in a fume hood. Fume hoods should provide 60 to 100 linear feet per minute of air flow. Confirm adequate hood performance before use; keep the hood sash at the indicated level at all times except when adjustments within the hood are being made; keep materials stored in hoods to a minimum and do not allow these materials to block vents of air flow. Leave the hood "on" when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is "off". Be alert to unsafe conditions and see that they are corrected when detected. The adequacy of hood performance shall be tested at least annually. To the extent feasible, each hood should have a continuous monitoring device to allow convenient confirmation of adequate hood performance before use. If this is not possible, work with substances of unknown toxicity should be avoided or other types of local ventilation devices should be provided.
1. Procurement. The department Chair will insure that MSDSs are received for all hazardous chemicals ordered in his/her respective department. The University, through the Provost and the Chemical Hygiene Officer, retains the right to require that specific permission be granted before chemicals which will pose significant risks are procured. It also retains the right to limit the quantities of such chemicals or to deny the acquisition of such chemicals if the conditions do not exist for the proper handling and/or disposal of the chemical. (See the Hazardous Waste Management Policy and Procedures in Appendix B).
2. Stockrooms/Storerooms. Chemicals should be stored, insofar as practical, in their original containers with labels intact. Labels shall not be removed or defaced. Bottles of chemicals should be placed of the storage shelves in such a way as to minimize the danger of bottles falling off the shelves. Chemicals may be stored in open shelves using alphabetical arrangement unless the properties such as odor or reactivity warrant segregated and/or vented storage. (The Chemical Hygiene Officer should be consulted anytime uncertainty arises regarding such storage.) Substances that pose a particularly high health risk should be stored in secured areas, with appropriate ventilation as needed. Research labs are considered to be secured areas. Flammable chemicals will be stored separately from other chemicals in special cabinets or rooms. All chemicals should be examined at least annually to determine the need for replacement and the integrity of the container and label. Quantities stored will not exceed recommended limits noted in "Prudent Practices in the Laboratory," 2nd edition, Table 4.3.
Amounts stored within a laboratory should be as small as practical. The chemicals are to be returned to the storeroom as soon as the need for the chemical no longer exists in the laboratory.
3. Distribution. When chemicals are needed in a laboratory and the chemical is to be placed in a secondary bottle, that bottle will be labeled as required by the Hazard Communication Program. When chemicals are hand carried between rooms, the container will be placed in an outside container or bucket. When several bottles of chemicals are to be moved at the same time, the use of a laboratory cart is permitted provided that the bottles are properly contained on the cart.
1. Cleaning. Floors within the laboratories are normally to be cleaned by the custodial staff. The regular cleaning of bench tops and tables is the responsibility of the lab supervisor. Periodic cleaning of bench tops and tables by custodial staff can be arranged in advance by the department Chair and the Manager of Building Services. In the event of spills, the faculty member in charge is required to supervise the cleaning and disposal of the spilled material. Disposal of chemical waste is handled by the department Chair in consultation with the Chemical Hygiene Officer.
2. Inspections. Formal housekeeping and chemical hygiene inspections will be held at least annually. These formal inspections are the responsibility of the Chemical Hygiene Officer. Informal inspections are to be carried out continually in order to correct any deficiency as quickly as possible. Informal inspections are the responsibility of the department Chair. In addition, inspections may be held from time to time by representatives of various Federal and State regulatory agencies. The Chemical Hygiene Officer, or his/her designee, should accompany these persons on the inspection tour.
3. Maintenance. The primary responsibility for noting the need for repair of malfunctioning equipment, including fume hoods and ventilation systems, rests with the laboratory supervisor. These persons are charged with prompt reporting of any malfunctions in the safety related equipment to the Physical Plant Department. In addition, a regular program of inspection of safety related equipment will be conducted. Eye wash devices will be tested or inspected before each semester and regularly flushed, as recommended by the manufacturer, by the department Chair or designee. Safety showers will be tested annually by Physical Plant personnel. Fume hoods will be inspected annually by Physical Plant personnel or the designee of the Director of Physical Plant in consultation with the department Chair. Out-of-service equipment will be plainly marked so that persons in the area of the equipment will be aware that it is not in service. Out-of-service equipment will be repaired and put back into service as quickly as possible. Appropriate lock out/tag out procedures will be followed.
4. Passageways. Stairways and hallways will not be used as storage areas for chemicals. Access to exits, emergency equipment, and utility controls will never by blocked by stored materials.
1. Compliance and Regulation. Regular medical examinations, consultations, and surveillance of personnel will be provided as required by law or regulation. The cost of this surveillance will be borne by the University.
2. Routine Surveillance. Anyone whose work involves regular and frequent handling of a hazardous chemical, any person showing symptoms which may have been caused by exposure to hazardous materials in the workplace, any person involved in an incident creating the likelihood of a hazardous exposure, any person who is routinely exposed to hazardous chemicals above the action level, or in the absence of an action level, the PEL of an OSHA-regulated substance for which there are exposure monitoring and medical surveillance requirements, or any persons having a medical condition which is known to be aggravated by exposure to hazardous materials within the workplace may consult a licensed physician qualified in the area of occupational exposure to hazardous materials to determine on an individual basis whether a regular schedule of medical surveillance is desirable. The cost of such surveillance will be borne by the University.
3. First Aid. In any situation requiring first aid attention, the Security Department should be contacted (Security Emergency #6363). When the emergency is such that severe impairment of function or death may result if help is delayed in arriving, Springfield Fire Department (9-911) should be called prior to Security. Hard copies of all relevant MSDSs should be secured as soon as possible. "Incident Report Forms" (Appendix A) should be readily available in all labs and completely as thoroughly as possible at the time of the accident.
4. Information Provided to and By the Physician. In the event of an event or condition requiring the consultation with or examination by a licensed physician, the employer shall provide the following information to the physician: (i) the identity of the hazardous chemical to which the employee may have been exposed, (ii) a description of the conditions under which the exposure occurred, including quantitative exposure data, if available, and (iii) a description of the signs and symptoms of exposure that the employee is experiencing, if any. The relevant MSDS(s) shall also be provided to the physician as quickly as possible. For any examination or consultation provided under this Plan, Wittenberg University shall obtain a written opinion from the examining physician which shall include the following: (i) any recommendation for further medical follow-up, (ii) the results of the medical examination and any associated tests, (iii) any medical condition which may be revealed in the course of the examination which may place the employee at increased risk as a result of exposure to a hazardous workplace, and (iv) a statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination of treatment.
1. All laboratories in which hazardous chemicals are used must be equipped with fire extinguishers, eye wash stations, and where feasible, drench showers. Persons using these laboratories must be informed of their locations and trained in the proper use of the equipment at the time they first begin working in the laboratory. Additional safety apparel is available in the Chemistry and Biology storerooms and in appropriate work areas.
2. Personal protective equipment (PPE) is provided by Wittenberg University to users of the laboratories when and where necessary (unless an individual already has appropriate PPE). Wittenberg University has the responsibility to assess if hazards are present or are likely to be present which necessitates the use of personal protective equipment. If such assessment reveals a need for personal protective equipment, the University will communicate selection decisions to each affected employee and select the PPE that properly fits each affected employee.
3. Appropriate eye protection must be worn by all persons, including visitors, in all laboratories where hazardous chemicals are used. Glasses must meet ANSI Z87.1-1989 standards. Safety glasses with side shields are the minimum protection; goggles are recommended in situations where splashes or projectiles are probably hazards. Full-face shields should be worn when conducting particularly hazardous operations. Special glasses are required when glassblowing or working with lasers. Laboratory supervisors, in consultation with the Chemical Hygiene Officer, are responsible for specifying which level of eye protection is appropriate for particular labs.
Employees who wear contact lenses in the lab must have a bright red dot in the form of a sticker on the side of their glasses, goggles or other face/eye protection. This can inform co-workers and emergency rescuers that they are wearing contact lenses.
4 Appropriate gloves will be worn when the potential for contact with toxic materials exists. Inspect gloves before each use.
5. Any experiment or procedure that necessitates the use of a respirator under 29 CFR 1910.132 shall be conducted in a sufficiently well-ventilated environment such that the use of a respirator is not required. Lab supervisors should consult with the Chemical Hygiene Officer as necessary.
1. Records of all accidents will be written and retained for at least ten years following the accident. Reports of all accidents are to be made on a the Office of Academic Safety "Incident Report Form." (Appendix A.) The Security Department, the Office of Academic Safety, and Human Resources will maintain copies of all Incident Report Forms.
2. Inventory records for all substances will be maintained by the department Chair in order to know the identities, locations, and quantities of all chemicals on hand. Laboratory notebooks should be maintained in such a fashion as to record the usage of substances which pose a particularly high health risk and these notebooks are to be retained by the lab supervisor indefinitely.
3. Medical records will be maintained by Human Resources Department of the University for thirty years or as otherwise required by state and/or federal regulations in accordance with the requirements of state and federal regulations.
1. All laboratory operations are to be carried out in accordance with accepted laboratory practices to ensure the prevention of accidental spills. Should a spill occur, immediate attention is required of the person causing the spill to minimize the spread of the spilled material. It is the responsibility of the person causing the spill to report the spill to the lab supervisor. Except for the most minor spills, the lab supervisor will notify the Chemical Hygiene Officer who will arrange for the cleanup of the spilled material according to accepted practices. Outside help will be called in to clean up the spill when the extent of the spill or the material involved in the spill are such that inside help is not capable of handling the situation.
2. The fire alarm system is available to signal people to evacuate the building in the event of an emergency requiring that action. This alarm system is tested annually by the Physical Plant Department. As with all fire alarms, the Fire Department and campus Security will be notified and appropriate corrective action taken.
3. After the emergency, an Office of Academic Safety "Incident Report Form" (Appendix A) will be completed by lab supervisor and/or Chemical Hygiene Officer. All accidents or near accidents will be carefully analyzed by the Safety Committee and the recommendations arising from the analysis will be distributed to all who might benefit from the information. Also, as a follow up to any safety related Incident Reports, a written recommendation will be sent to the Chemical Hygiene Officer and a copy filed with the Incident Report for a permanent record. If corrective action is necessary, the Vice President of Business and Finance will also be copied with the recommendation.
The proper disposal of chemical wastes is necessary to protect people, plants, and animals from the harm that could be caused by the improper and careless disposal of these wastes.
1. Disposal of wastes from laboratories shall conform to the regulations outlined in the document "Hazardous Waste Management Policy and Procedures" (Appendix B). All department Chairs under the purview of this Chemical Hygiene Plan are responsible for the collection of these wastes from each of the respective laboratories, the identification of the wastes, and the storage of the wastes pending removal of the wastes by the chemical waste disposal company contracted by the University.
2. Outdated chemicals and those which bear no label will be placed, in their bottles, with the laboratory waste to be removed by the commercial waste disposal company.
3. The University shall contract with a reputable waste disposal contractor who will show evidence that the disposal means used by that contractor are means that fall within the legal requirements and provide due consideration of the environmental consequences of waste disposal.
The following section is taken directly from 29 CFR 1910.1450, with minor editorial changes.
"Employee information and training.
(1) The employer shall provide employees with information and training to ensure that they are apprised of the hazards of chemicals present in their work area.
(2) Such information shall be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations. The need for refresher information and training will be determined by the Chemical Hygiene Officer based on significant changes in the Chemical Hygiene Plan and/or other safety-related issued on campus.
(3) Employees shall be informed of:
(i) the contents of 29 CFR 1910.1450 and its appendices which shall be made available to employees;
(ii) the location and availability of the employer's Chemical Hygiene Plan;
(iii) the permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard;
(iv) signs and symptoms associated with exposures to hazardous chemicals used in the laboratory; and
(v) the location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier.
(i) Employee training shall include:
(A) Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
(B) The physical and health hazards of chemicals in the work area; and
(C) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
(ii) The employee shall be trained on the applicable details of this Chemical Hygiene Plan."
Laboratory personnel should consult the literature and/or use the services of knowledgeable persons regarding the hazards of the chemicals being used and proper procedures to be followed in the laboratory. Knowledgeable people include, but are not limited to, faculty members who have special expertise in the hazards and use of certain chemicals or classes of chemicals and the Chemical Hygiene Officer.