Chemical Hygene Plan

Introduction

Purpose

This Chemical Hygiene Plan describes policies, procedures, equipment, personal protective equipment and work practices that are capable of protecting employees from the health hazards presented by many hazardous chemicals used in laboratories.  This Plan is intended to meet the requirements of the federal Occupational Safety and Health Administration (OSHA) standard, Occupational Exposure to Hazardous Chemicals in Laboratories.

This Chemical Hygiene Plan is intended to safely limit laboratory workers' exposure to OSHA-regulated substances.  Laboratory workers must not be exposed to substances in excess of the permissible exposure limits (PEL) specified in OSHA rule 29 CFR 1910, Subpart Z, Limits of Exposure to Toxic and Hazardous Substances.  PELs refer to airborne concentrations of substances and are averaged over an eight-hour day.  A few substances (listed under Individual Chemical Standard in the Federal column in Other Standards & Guidelines also have "action levels". Action levels are air concentrations below the PEL which nevertheless require that certain actions such as medical surveillance and workplace monitoring take place.

An employee's workplace exposure to any regulated substance must be monitored if there is reason to believe that the exposure will exceed an action level or a PEL. If exposures to any regulated substance routinely exceed an action level or permissible exposure level there must also be employee medical exposure surveillance.

Scope and Application

This standard applies where "laboratory use" of hazardous chemicals occurs. Laboratory use of hazardous chemicals means handling or use of such chemicals in which all of the following conditions are met: i) the handling or use of chemicals occurs on a "laboratory scale", that is, the work involves containers which can easily and safely be manipulated by one person, ii) multiple chemical procedures or chemical substances are used, and iii) protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposures to hazardous chemicals.

At a minimum, this definition covers employees (including student employees, technicians, supervisors, lead researchers and physicians) who use chemicals in teaching, research and clinical laboratories at the University of Minnesota. Certain non-traditional laboratory settings may be included under this standard at the option of individual departments within the University. Also, it is the policy of the University that laboratory students, while not legally covered under this standard, will be given training commensurate with the level of hazard associated with their laboratory work.

This standard does not apply to laboratories whose function is to produce commercial quantities of material. Also, where the use of hazardous chemicals provides no potential for employee exposure, such as in procedures using chemically impregnated test media and commercially prepared test kits, this standard will not apply. When laboratory work is limited to use of these commercially available kits, a Chemical Hygiene Plan is not required.

This laboratory standard applies to the I.T. Characterization Facility.

Coordination With Other Standards and Guidelines

Although this standard deals only with use of hazardous chemicals, employees may also encounter potential physical, biological or radioactive hazards in the laboratory. Regulations and guidelines for these situations that are in effect at the University of Minnesota are listed in Appendix B.

In the unlikely event that there is a conflict between provisions of various standards, the Department of Environmental Health and Safety should be contacted to assist in resolving the discrepancy.

Users of the X-ray Scattering Facility and Ion Beam Analysis Facility must wear radiation monitoring devices and have additional safety training as outlined in Appendix B.

Responsibilities

  • Employer
    • University-Wide: The University of Minnesota, in conjunction with its colleges and departments, is responsible for developing and supporting a broad-based chemical hygiene program that will protect its laboratory employees from health effects associated with hazardous chemicals. Management is responsible for integrating safety into all of its activities, for promoting the same attitude among all levels of employment at the University, and for providing adequate time and recognition for employees who are given laboratory safety responsibilities.
    • I.T. Characterization Facility: The I.T. Characterization Facility will identify at least one laboratory safety officer, Michael Dupont dupon028@umn.edu, to serve as a focal point for laboratory health and safety activities within the unit and as liaison with the Department of Environmental Health and Safety. Colleges that are made up of a number of large laboratory-based departments are urged to assign laboratory safety officers within each department. (The laboratory safety officer is not to be confused with the Safety Coordinator system presently existing at the University. These are separate responsibilities, although they may be held by the same individual.) Each college and non-academic department will modify this generic Chemical Hygiene Plan to incorporate location-specific information and will submit a copy of the modified plan to the Chemical Hygiene Officer for approval. Each college and non-academic department will also identify the assigned laboratory safety officers within their units and will transmit that information to the Chemical Hygiene Officer.
  • Department of Environmental Health and Safety (DEHS): The Department of Environmental Health and Safety is responsible for preparing and updating the University's Chemical Hygiene Plan, for distributing it to departments who will implement the Plan, and for monitoring the progress of departments toward achieving compliance. Dawn Errede will serve as the Chemical Hygiene Officer for the University, and the entire DEHS staff will participate in providing resources for departments in the development of their individual health and safety programs.
    • Supervisor: The immediate supervisor of a laboratory employee is responsible for scheduling time for the employee to attend designated training sessions and for assuring that potential hazards of specific projects have been identified and addressed before work is started. The supervisor is also responsible for enforcing safe work practices and for reporting hazardous conditions to the college or departmental laboratory safety officer.
    • Employee: Each laboratory employee is responsible for attending safety training sessions, following safety guidelines applicable to the procedures being carried out, assuring that required safety precautions are in place before work is started, and reporting hazardous conditions as they are discovered. Employees who have significant responsibility for directing their own laboratory work are responsible for assuring that potential hazards of specific projects have been identified and addressed before work is started.

 

 

Standard Operating Procedure

Laboratory operating procedures

Found in Prudent Practices in the Laboratory: Handling and Disposal of Chemicals (National Research Council, 1995) are adopted for general use at the University of Minnesota. The table of contents, Chapter 1, "The Culture of Laboratory Safety", Chapter 6 "Working with Chemicals", and Chapter 7 "Working with Laboratory Equipment" of Prudent Practices are reproduced and can be accessed by University of Minnesota personnel electronically from the DEHS website . The following topics are covered in Chapters 6 and 7 of Prudent Practices:

The American Chemical Society's "Safety in Academic Chemistry Laboratories"

As another useful text. This manual presents information similar to that found in Prudent Practices, but in a considerably condensed format.

Selected standard operating procedures

have been adopted by the University of Minnesota specifically for its own laboratories. Extensive and detailed policies regarding hazardous waste management are specified in the University's guidebook, Hazardous Chemical Waste Management, 5th edition. During a chemical spill in the laboratory, workers should follow Part 3: Emergency Procedures of this guide book.

Laboratory-Specific Standard Operating Procedures

This section summarizes laboratory-specific SOPs. The full text of these SOPs is included in Appendix F, or can be obtained from the referenced PI, or from the Laboratory Safety Officer, Michael Dupont dupon028@umn.edu, for the I.T. Characterization Facility. Safety information is included in each SOP, and may be highlighted in a Laboratory Safety Information Sheet, similar to the one included in Appendix F.

 

Criteria for Implementation of Control Measures

Engineering controls, personal protective equipment, hygiene practices, and administrative controls each play a role in a comprehensive laboratory safety program. Implementation of specific measures must be carried out on a case-by-case basis, using the following criteria for guidance in making decisions. Assistance is available from the Department of Environmental Health and Safety.

When to Use Fume Hoods

The laboratory fume hood is the major protective device available to laboratory workers. It is designed to capture chemicals that escape from their containers or apparatus and to remove them from the laboratory environment before they can be inhaled. Characteristics to be considered in requiring fume hood use are physical state, volatility, toxicity, flammability, eye and skin irritation, odor, and the potential for producing aerosols. A fume hood should be used if a proposed chemical procedure exhibits any one of these characteristics to a degree that (1) airborne concentrations might approach the action level (or permissible exposure limit), (2) flammable vapors might approach one-tenth of the lower explosion limit, (3) materials of unknown toxicity are used or generated, or (4) the odor produced is annoying to laboratory occupants or adjacent units.

Procedures that can generally be carried out safely outside the fume hood include those involving (1) water-based solutions of salts, dilute acids, bases, or other reagents, (2) very low volatility liquids or solids, (3) closed systems that do not allow significant escape to the laboratory environment, and (4) extremely small quantities of otherwise problematic chemicals. The procedure itself must be evaluated for its potential to increase volatility or produce aerosols.

In specialized cases, fume hoods will contain exhaust treatment devices, such as water wash-down for perchloric acid use, or charcoal or HEPA filters for removal of, particularly toxic or radioactive materials.

When to Use Safety Shields or Other Containment Devices

Safety shields, such as the sliding sash of a fume hood, are appropriate when working with highly concentrated acids, bases, oxidizers, or reducing agents, all of which have the potential for causing sudden spattering or even explosive release of material. Reactions carried out at non-ambient pressures (vacuum or high pressure) also require safety shields, as do reactions that are carried out for the first time or are significantly scaled up from normal operating conditions.

Other containment devices, such as glove boxes or vented gas cabinets, may be required when it is necessary to provide an inert atmosphere for the chemical procedure taking place, when the capture of any chemical emission is desirable, or when the standard laboratory fume hood does not provide adequate assurance that overexposure to a hazardous chemical will not occur. The presence of biological or radioactive materials may also mandate certain special containment devices.

High strength barriers coupled with remote handling devices may be necessary for safe use of extremely shock-sensitive or reactive chemicals.

Highly localized exhaust ventilation, such as is usually installed over atomic absorption units, may be required for instrumentation that exhausts toxic or irritating materials to the laboratory environment.

Ventilated chemical storage cabinets or rooms should be used when the chemicals in storage may generate toxic, flammable, or irritating levels of airborne contamination.

When to Use Personal Protective Equipment

Eye protection is required for all personnel and any visitors whose eyes may be exposed to chemical or physical hazards. Side shields on safety spectacles provide some protection against splashed chemicals or flying particles, but goggles or face shields are necessary when there is a greater than average danger of eye contact. A higher than average risk exists when working with highly reactive chemicals, concentrated corrosives, or with a vacuum or pressurized glassware systems. Contact lenses should not be worn in the laboratory. Chemicals can be concentrated under contact lenses and contact lenses will interfere with eye flushing in case of emergency.

Lab coats or other similar clothing protectors are strongly encouraged for all laboratory personnel. Lab coats are required when working with select carcinogens, reproductive toxins, substances which have a high degree of acute toxicity, strong acids, and bases, and any substance on the OSHA PEL list carrying a "skin" notation. See Appendix B for chemical listings.

Gloves made of appropriate material are required to protect the hands and arms from thermal burns, cuts, or chemical exposure that may result in absorption through the skin or reaction on the surface of the skin. Gloves are also required when working with particularly hazardous substances where possible transfer from hand to mouth must be avoided. Thus gloves are required for work involving pure or concentrated solutions of select carcinogens, reproductive toxins, substances which have a high degree of acute toxicity, strong acids and bases, and any substance on the OSHA PEL list carrying a "skin" notation.

Gloves should be carefully selected using guides from the manufacturers. General selection guides are available (see Prudent Practices, p. 159); however, glove-resistance to various chemical materials will vary with the manufacturer, model, and thickness. Therefore, review a glove-resistance chart from the manufacturer you intend to buy, from before purchasing gloves.

Bare feet are not permitted in any laboratory. Sandals and open-toed shoes are strongly discouraged in all laboratories and are not permitted in any situation where lab coats and gloves are required.

Respiratory protection is generally not necessary in the laboratory setting and must not be used as a substitute for adequate engineering controls. The availability of respiratory protection for emergency situations may be required when working with chemicals that are highly toxic and highly volatile or gaseous. If an experimental protocol requires exposure above the action level (or PEL) that cannot be reduced, respiratory protection will be required. Rarely, an experimental situation may potentially involve IDLH (immediately dangerous to life or health) concentrations of chemicals, which will require the use of respiratory protection. All use of respiratory protective equipment is covered under the University of Minnesota Respiratory Protection Program.

Supervisors shall designate areas, activities, and tasks which require specific types of personal protective equipment as described above.

 

Management of Fume Hoods and Other Protective Equipment

Monitoring Safety Equipment

Fume hoods must be monitored daily by the user to ensure that air is moving into the hood. Any malfunctions must be reported immediately to the appropriate Facilities Management zone office. The hood should have a continuous reading device, such as a pressure gauge, to indicate that air is moving correctly. Users of older hoods without continuous reading devices should attach a strip of tissue or yarn to the bottom of the vertical sliding sash. The user must ensure the hood and baffles are not blocked by equipment and bottles, as air velocity through the face may be decreased. DEHS staff will measure the average face velocity of each fume hood annually with a velometer or a Thermo anemometer. A record of monitoring results will be made.

Eyewashes must be flushed weekly by the user. This will ensure that the eyewash is working and that the water is clean, should emergency use become necessary. The user should coordinate with Facilities Management CSE Zone, phone 625-0008, to ensure that emergency showers and eyewashes are checked annually. Fire extinguishers will be checked annually by a University contractor. The user is responsible for checking regularly to ensure that other protective equipment is functioning properly. Environmental Health and Safety staff can assist with these evaluations, should assistance be necessary.

General laboratory conditions must be monitored periodically by the users. A generic laboratory audit form is included in Appendix J, and may be tailored for use by individual laboratories. The departmental Laboratory Safety Officer or the University's Chemical Hygiene Officer may also use this form for spot-checks of the laboratories.

Acceptable Operating Range

The acceptable operating range for fume hoods is 80 to 150 linear feet per minute, at the designated sash opening (usually 18 inches). If during the annual check, a hood is operating outside of this range, DEHS staff may request that you check to ensure the baffles are adjusted properly, and that the exhaust slots are not blocked by bottles and equipment. If these adjustments do not help, DEHS staff will report the deficiency to the appropriate Facilities Management zone office for service.

Maintenance

During maintenance of fume hoods, laboratories must clean out and if necessary, decontaminate the fume hood and restrict the use of chemicals to ensure the safety of maintenance personnel. See "Safe Practices During Servicing of Exhaust Systems in Research Facilities" in Appendix G.

Training

Training in the appropriate use and care of fume hood systems, showers, eyewashes and other safety equipment must be included in the initial and update training described in Section 5.

New Systems

When new ventilation systems, such as variable air volume exhaust, are installed in University facilities, specific policies for their use will be developed by the Department of Environmental Health and Safety and employees will be promptly trained on use of the new equipment.

 

Employee Information and Training

Information

It is essential that laboratory employees have access to information on the hazards of chemicals and procedures for working safely. Supervisors must ensure that laboratory employees are informed about and have access to the following information sources:

  • The contents of the OSHA standard: "Occupational Exposure to Hazardous Chemicals in Laboratories" and its appendices (29 CFR 1910.1450), a copy of which is found in Appendix A of this Chemical Hygiene Plan.
  • The University of Minnesota's Chemical Hygiene Plan which is available to all employees and can be found on the the Department of Environmental Health and Safety's web site and in the Learning Resource Centers of the various campus libraries. Individual department Chemical Hygiene Plans are available within those departments.
  • The Permissible Exposure Limits (PEL) for OSHA regulated substances, which can be found in Appendix B . Also included in Appendix B is the ACGIH Threshold Limit Value (TLV) list. A list of OSHA health hazard definitions, and lists of "select carcinogens", reproductive toxins, and chemicals having a high degree of acute toxicity, are included in Appendix B.
  • Signs and symptoms associated with exposures to hazardous chemicals. Laboratory Chemical Safety Summaries (LCSSs) for 88 commonly-encountered laboratory chemicals are included on pages 235-413 of the 1995 edition of Prudent Practices. LCSSs are similar to Material Safety Data Sheets (MSDS), but are tailored to the hazards of laboratory use of those chemicals. The LCSSs include toxicity information, and signs and symptoms of exposure to the chemicals.
  • Material safety data sheets (MSDS) for laboratory chemicals are available from the Department of Environmental Health and Safety and are also located in department offices and in many individual laboratories. Departments that receive MSDS directly with chemical shipments will make such information available to the employees using the chemicals, and will also send a copy of the MSDS to the Department of Environmental Health and Safety.
  • Information on chemical waste disposal and spill response is found in the University of Minnesota guidebook, Hazardous Chemical Waste Management, 5th edition .

Training

Each laboratory supervisor is responsible for ensuring that laboratory employees are provided with training about the hazards of chemicals present in their laboratory work area, and methods to control exposure to such chemicals. Such training must 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 potential exposure situations. Refresher training must be provided annually.

Colleges and non-academic departments that engage in the laboratory use of hazardous chemicals are responsible for identifying employees who require training and for developing and delivering training programs for such employees. DEHS offers training on the third Thursday of each month that covers general laboratory safety issues, hazardous waste management, and biohazardous materials handling. Departments are welcome to send employees to this 'base' training at no charge. However, laboratory supervisors must provide additional training on laboratory-specific hazards to ensure all the OSHA-required training topics have been adequately addressed. Call DEHS at 626-6002 to register trainees.

Employee training programs will include, at a minimum, the following subjects:

  • Methods of detecting the presence of hazardous chemicals (observation, odor, real-time monitoring, air sampling, etc.)
  • Basic toxicological principles, including toxicity, hazard, exposure, routes of entry, acute and chronic effects, dose-response relationship, LD50, threshold limit values and permissible exposure limits, exposure time, and health hazards related to classes of chemicals
  • Good laboratory practice, including general techniques designed to reduce personal exposure and to control physical hazards, as well as specific protective mechanisms and warning systems used in individual laboratories. Appropriate use of fume hoods is to be specifically addressed;
  • Description of information available, including Material Safety Data Sheets;
  • Emergency response actions appropriate to individual laboratories;
  • Applicable details of the departmental Chemical Hygiene Plan, including general and laboratory-specific Standard Operating Procedures;
  • An introduction to the Hazardous Chemical Waste Management guidebook. The script for the training program, Laboratory Chemicals and Your Health, is included in Appendix I as an example of information meeting the requirements of items i-iii above. Laboratory Chemicals and Your Health is available in either slide-tape or video format. A list of audio-visual material available from the Department of Environmental Health and Safety, the University Library System, and other resources is included in Appendix H.

 

Required Approvals

There are no procedures and/or chemicals routinely used in the CSE Characterization Facility that require approval. Special cases may be presented in writing to the safety officer, Michael Dupont dupon028@umn.edu, for approval.

 

Medical Consultation and Examination

All employees who work with hazardous chemicals will have an opportunity to receive medical attention, including any follow-up examinations which the examining physician determines to be necessary, under the following circumstances:

  • Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory, the employee will be provided an opportunity to receive an appropriate medical examination.
  • Where exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance will be established for the affected employee as prescribed by the particular standard.
  • Whenever an event takes place in the work area such as a spill, leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure, the affected employee will be provided an opportunity for a medical consultation. Such consultation will be for the purpose of determining the need for a medical examination.

The Chemical Hygiene Officer will be contacted whenever the need for medical consultation or examination occurs, or when there is uncertainty as to whether any of the above criteria have been met.

All medical examinations and consultations

will be performed by or under the direct supervision of a licensed physician and will be provided without cost to the employee, without loss of pay and at a reasonable time and place. The University of Minnesota's Occupational Medicine Program is located in Boynton Health Service. If off-hours medical attention is required, the employee should be taken to the University Hospital Emergency Room. A University of Minnesota Incident Report form (see Appendix J) should be filled out for any incident resulting in a medical consultation or medical examination. In the event of a life-threatening illness or injury, dial 911 and request an ambulance.

The University of Minnesota will provide the examining physician with the following information:

  • The identity of the hazardous chemical(s) to which the employee may have been exposed;
  • A description of the conditions under which the exposure occurred including quantitative exposure data, if available; and
  • A description of the signs and symptoms of exposure that the employee is experiencing, if any.

The above information will be collected and transmitted by the employee's supervisor or department and will be submitted to the Department of Environmental Health and Safety as well as to the examining physician.

The examining physician will provide to the Department of Environmental Health and Safety a written report including the following:

  • Any recommendation for further medical follow-up
  • The results of the medical examination and any associated tests
  • 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 chemical found in the workplace
  • 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 or treatment.

The written opinion will not reveal specific findings of diagnoses unrelated to occupational exposure. The Department of Environmental Health and Safety will notify the employee's department of the results of the medical consultation or examination.

 

Personnel

The following individuals and groups have responsibilities for implementation of various aspects of the University of Minnesota's Chemical Hygiene Plan.

Chemical Hygiene Officer

The University of Minnesota's Chemical Hygiene Officer is Dawn C. Errede, Department of Environmental Health and Safety. Ms. Errede is a Certified Industrial Hygienist (CIH) and chemical hygiene specialist with an M.S. in Environmental Health. Address: W-140 Boynton Health Service. Phone: 612-626-2330.

College or Departmental Laboratory Safety Officer

Call the CharFac main office (phone: 626-7594) for the Safety Officer. A generic description of a laboratory safety officer's duties is included in Appendix L.

College or Departmental Safety Committee

The I.T. Characterization Facility has a safety committee comprised of all full-time employees.

Department of Environmental Health and Safety

The Department of Environmental Health and Safety offers assistance in a wide range of health and safety issues. A departmental organizational chart, list of services offered, and staff phone numbers are included in Appendix M. Address: W-140 Boynton. Phone: 612-626-6002.

Occupational Physician

The University of Minnesota's Boynton Health Service provides occupational medicine services. The phone number for the Occupational Medicine program, which covers Research Animal Resources, respiratory protection, and pesticide exposures only, is 612-625-4906. Non hospital employee chemical exposures should go through Boynton's urgent care.

Additional Employee Protection for Work with Particularly Hazardous Substances

Additional employee protection will be considered for work with particularly hazardous substances. These include select carcinogens, reproductive toxins and substances which have a high degree of acute toxicity (see Appendix B). Pages 90-93 of the 1995 edition of Prudent Practices provide detailed recommendations for work with particularly hazardous substances. These pages may be accessed from DEHS's web site . Also, DEHS has hard copies of the entire 1995 edition available for departmental Laboratory Safety Officers. Laboratory supervisors and principal investigators are responsible for assuring that laboratory procedures involving particularly hazardous chemicals have been evaluated for the level of employee protection required. Specific consideration will be given to the need for inclusion of the following provisions:

  1. Planning
  2. Establishment of a designated area
  3. Access control
  4. Special precautions such as:
    • use of containment devices such as fume hoods or glove boxes;
    • use of personal protective equipment;
    • isolation of contaminated equipment;
    • practicing good laboratory hygiene; and
    • prudent transportation of very toxic chemicals.
  5. Planning for accidents and spills
  6. Special storage and waste disposal practices

Record Keeping, Review, and Update of Chemical Hygiene Plan

Record keeping

  • Exposure evaluation: Any records of exposure evaluation carried out by individual departments (including continuous monitoring systems) will be kept within the department and also sent to the Department of Environmental Health and Safety. Results of exposure evaluations carried out by DEHS will be kept by DEHS and sent to the affected department. Raw data will be kept for one year and summary data for the term of employment plus 30 years.
  • Medical consultation and examination: Results of medical consultations and examinations will be kept by the Boynton Health Service for a length of time specified by the appropriate medical records standard. This time will be at least the term of employment plus 30 years as required by OSHA.
  • Training: Individual employee training should be recorded on form BA 725A (see Appendix K) and should be kept in the individual's department or college for five years. These forms may be audited by the University Audit Department.
  • Fume hood monitoring: Data on annual fume hood monitoring will be kept in the Department of Environmental Health and Safety. Fume hood monitoring data are considered maintenance records and as such the raw data will be kept for one year and summary data for 5 years.

Review and Update of Chemical Hygiene Plan

On an annual basis, this Chemical Hygiene Plan will be reviewed and evaluated for effectiveness by the Department of Environmental Health and Safety and updated as necessary. Any changes in the Chemical Hygiene Plan will be transmitted to college and departmental laboratory safety officers, who are responsible for carrying out a similar review and modification of their plans, and submitting a revised copy to the Chemical Hygiene Officer.