OCCUPATIONAL EXPOSURE TO HAZARDOUS CHEMICALS IN LABORATORIES

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1 A P P E N D I X 16 OCCUPATIONAL EXPOSURE TO HAZARDOUS CHEMICALS IN LABORATORIES AP16.1. Purpose. AP16.2. Policy. The purpose of this policy is to establish requirements and procedures for the development and implementation of Chemical Hygiene Plans and chemical safety training for all CBP laboratories. The establishment of a Chemical Hygiene Plan and training is required for all CBP laboratories, in accordance with the requirements of the Occupational Safety and Health Administrationʼs (OSHA) Occupational Exposure to Hazardous Chemicals in Laboratories standard, 29 CFR (referred to as the OSHA Laboratory Standard). Each CBP laboratory shall develop a site specific Chemical Hygiene Plan that covers all CBP employees assigned to that laboratory. The plan shall describe the required safety and health practices common to all laboratories that use hazardous chemicals. The plan must list the criteria to determine control methods to reduce employee exposures, to assure the adequate performance of safety equipment such as fume hoods, standard operating procedures for chemical use, and training and information to be provided to employees. AP16.3. Background. The OSHA Laboratory Standard was promulgated in 1990 to provide laboratory employees with the same protection from exposure to toxic substances as the Hazard Communication standard provides for all other work sites. Laboratories differ from ordinary work sites in the large number of chemicals present and the variable and frequent use of chemicals. Also, laboratory employees generally use chemicals more often and are more knowledgeable of their hazards. As a result, the Laboratory Standard allows for more flexible compliance methods and is specific to safety in laboratory workplaces. The benefits expected from compliance with the Laboratory Standard include: Improved worker actions due to increased awareness; Reduction in incidence and level of exposure to toxic substances due to good work practices; Reduction in hazards presented by non-regulated substances due to improved work practices; 205

2 Improved protection against known carcinogens; Reduction in incidence and level of exposure due to appropriate use of personal protective equipment and engineering controls. The primary component of the Laboratory Standard is the development of a Chemical Hygiene Plan (CHP) and assignment of a Chemical Hygiene Officer (CHO) to manage and assure compliance with the plan. The standard allows employers to tailor an individualized CHP to the particular circumstances and practices in their laboratories. The Laboratory Standard does not apply to all places where hazardous chemicals are used in experiments and investigations. Only laboratories meeting the following four criteria are subject to compliance with the standard: Chemical manipulations are carried out on a laboratory scale (i.e., work with chemicals in containers of a size that could be easily and safely manipulated by one person); Multiple chemical procedures are used; Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals; and, The procedures involved are not part of a production process whose function is to produce commercial quantities of materials, nor do the procedures simulate a production process. AP16.4. Program Requirements. AP Management is responsible for the following: a) To keep and maintain records of employee exposure to hazardous chemicals. b) To provide employees with training and information regarding chemical and physical hazards; access to medical consultation and examinations; and, respirators when necessary. c) To not remove or deface labels on incoming hazardous chemicals, and keep and make accessible to employees the Material Safety Data Sheets (MSDSs) when received with incoming chemicals. d) When hazardous chemicals are generated in the laboratory, determine the hazard and follow requirements for informing downstream users of the hazards. e) If there is reason to believe that the OSHA permissible exposure limit (PEL) or action limit (AL) for air contaminants may be exceeded, then measure the concentration of that chemical in the air and the employeeʼs exposure. Follow the OSHA requirements if the PEL or AL limits are exceeded. (The OSHA PELs for air contaminants are found in Subpart Z of 29 CFR Part 1910) 206

3 f) Recognize the employeesʼ right to receive at no cost medical consultation and examination when: 1) an employee develops signs/symptoms of exposure; 2) a PEL or AL is routinely exceeded; or, 3) there is a spill, leak or explosion that makes employee exposure likely. g) If respirators are necessary to keep exposure below the PEL or AL, select and provide appropriate respiratory protection and follow the OSHA requirements for respirator use. h) If select carcinogens, reproductive toxins, or substances that have a high degree of acute toxicity are used in the laboratory, identify and post one or more areas as Designated Area(s). AP Management must appoint a Chemical Hygiene Officer (CHO) qualified by training and experience to provide technical guidance in the development and implementation of the CHP. This assignment will be collateral duties for a person who has other responsibilities. The CHO shall have the following duties: a) Prepare, implement, and maintain the written CHP. b) Assure the CHP describes appropriate work practices, procedures, personal protective equipment and other equipment that will protect employees from harm arising from hazards associated with hazardous chemicals. c) Assure procedures in the CHP maintain employee exposures below the OSHA PELs. d) Assure the CHP is readily accessible to employees. e) Assure the CHP is reviewed at least annually and updated if necessary. AP The content of the Chemical Hygiene Plan (CHP) must include: a) Standard Operating Procedures relevant to all laboratory operations to be followed by laboratory employees. b) Statements of the criteria used to determine and implement control measures to reduce employee exposure to hazardous chemicals, such as engineering controls (e.g., fume hoods), hygiene practices, personal protective equipment. Criteria to reduce exposure to extremely hazardous chemicals used in the laboratory should be particularly emphasized. c) Requirements and schedules for fume hoods and other protective equipment to function properly and the methods taken to assure such equipment is functioning properly. d) Provisions for required employee training and information as specified in the OSHA standard. 207

4 e) Describe the circumstances under which a laboratory practice requires prior approval from management before implementation. f) Provisions for medical consultation and examination. g) Designation of personnel responsible for implementation of the Chemical Hygiene Plan (Chemical Hygiene Officer). h) Provisions for additional protection for employees when working with particularly hazardous chemicals, such as select carcinogens (defined in OSHA standard), reproductive toxins, substances with a high degree of acute toxicity. i) Specific mention of the following provisions for particularly hazardous chemicals, when appropriate, will include: (1) Establishment of a designated area for use; (2) Mandatory use of containment devices such as fumehood/glove boxes; (3) Procedures for the safe removal of contaminated waste; and (4) Decontamination procedures. AP Employee training is required by the OSHA Laboratory Standard at the time of initial assignment of an employee in a work area where hazardous materials are present, and prior to assignments involving new exposure situations. The frequency of refresher training will be determined by the Laboratory Director. Training shall include the following: a) The contents of the OSHA Laboratory Standard and its appendices which is also made available to employees. b) The location and availability of the laboratory Chemical Hygiene Plan. c) The permissible exposure limits (PELs) for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is not applicable OSHA standard. d) Signs and symptoms associated with exposures to hazardous chemicals used in the laboratory. e) The location and availability of MSDSs and other reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory. f) Methods or observations that may be used to detect the presence or release of a hazardous chemical. 208

5 g) The physical and health hazards of the chemicals used in the laboratory. h) The measures employees can use to protect themselves for these hazards, including specific procedures such as appropriate work practices, personal protective equipment to be used, and emergency procedures. AP Medical Consultation and Medical Examinations a) Medical Consultation and Medical Examinations shall be provided to all employees under the following circumstances: (1) Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory. (2) Where exposure monitoring reveals an exposure level routinely above the action level for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements. (3) 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. b) All medical examinations and consultations shall be performed by or under the supervision of a licensed physician, provided without cost to the employee and at a reasonable time and place. c) Management shall provide the following information to the physician: (1) The identity of the hazardous chemicals to which the employer may have been exposed; (2) A description of the conditions under which the exposure occurred including exposure data if available; (3) A description of the signs and symptoms of exposure that the employee is experiencing, if any. d) Management shall receive the physicianʼs written opinion from the examining physician to include the following: (1) Any recommendation for further medical follow-up; (2) The results of the medical examination and any associated tests; 209

6 AP16.5. References. (3) 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 (4) 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. Occupational Safety and Health Act of 1970, Section 19, 29 U.S.C. 68; Executive Order (45FR 12769) dated February 26, 1980; 29 CFR Part 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs; 29 CFR , Occupational Exposure to Hazardous Chemicals in Laboratories Standard 210

7 CBP LABORATORY CHEMICAL HYGIENE PLAN TABLE OF CONTENTS 1. INTRODUCTION A. Description of Laboratory Activities B. History of the OSHA Laboratory Standard CHEMICAL HYGIENE RESPONSIBILITIES A. Laboratory Director B. Chemical Hygiene Officer (CHO) C. Responsibilities of Each Employee STANDARD OPERATING PROCEDURES A. General Rules B. Hazard Identification C. Chemical Procurement and Inventory D. Storage E. Housekeeping, Maintenance and Inspections F. Spills and Accidents CONTROL MEASURES A. Engineering Controls B. Personal Protective Equipment C. Personal Hygiene D. Environmental Monitoring PROCEDURE-SPECIFIC SAFETY RULES A. Procedures for Compressed Gases B. Procedures for Caustic, Corrosive Chemicals and Contact Hazard Chemicals C. Procedures for Toxic Chemicals D. Procedures for Flammable Chemicals E. Procedures for Use of Extremely Hazardous Chemicals TRAINING A. Training Content B. Frequency of Training C. Documentation Retention

8 TABLE OF CONTENTS (continued) 7. PRIOR APPROVAL A. Conditions for Prior Approval B. Unattended Laboratory Operations MEDICAL CONSULTATION AND MEDICAL EXAMINATIONS A. Conditions for Medical Consultation B. Information Provided to the Physician C. Physician Written Opinion CHEMICAL WASTE DISPOSAL RECORDKEEPING

9 Chemical Hygiene Plan 1. Introduction A. Description of Laboratory Activities The CBP Laboratory is a full-service analytical laboratory serving the CBP area. The laboratoryʼs mission is to provide technical scientific advice and assistance to CBP officers in meeting the primary mission of collecting revenue based on import duties and enforcing CBP and related laws. (Note to CHP writer: You may add to this as needed, describing geographical area of coverage, number of laboratory employees, specialities, etc.; or may leave the above statement as simple as it is stated.) B. History of the OSHA Laboratory Standard (1) The OSHA Laboratory standard (29 CFR ) was published in January 1990, with an effective date of May A Chemical Hygiene Plan for each laboratory was required to be developed and implemented by January 31, Where laboratories had developed a Hazard Communication program, the Laboratory standard takes precedence where it applies. The CHP must be written, be readily available to employees, their representatives and, if necessary, representatives of OSHA. The Plan establishes two broad performance goals: (a) The Chemical Hygiene Plan must be capable of protecting employees from health hazards associated with hazardous chemicals in that laboratory; and (b) The Chemical Hygiene Plan must be capable of keeping exposures below... Permissible Exposure Limits: For laboratory uses of OSHA regulated substances, the employer shall assure that laboratory employeesʼ exposure to such substances do not exceed the permissible exposure limits specified in 29 CFR 1910, Subpart Z. (2) Four criteria determine if a laboratory must comply with the Laboratory standard: small container manipulation of chemicals; multiple chemical procedures used; protective laboratory practices and equipment are available but not necessarily used; and, the procedures involved are not part of a production process to produce commercial use of materials. Under the Laboratory standard, employers must develop a program to meet the following obligations: (a) Keep records of employee exposure to hazardous chemicals, including records of any exposure measurements made and any medical consultations and written opinions. (b) Provide employees with training regarding chemical and physical hazards and other hazards in the laboratory, and training on respirators and the availability of records. 213

10 (c) Maintain MSDSs and make them accessible, and not to remove or deface labels. (d) For chemicals generated in the laboratory, assure proper notification of content and hazards for downstream users. (e) If there is reason to believe permissible exposure limits (PEL) of air chemical concentrations are exceeded, measure the concentration of that chemical in the air. (f) Provide medical consultation at no cost when an employee develops signs or symptoms of exposure; a PEL or Action level is routinely exceeded; or there is a spill, leak or accident (e.g., explosion) that makes employee exposure likely. (g) If respirators are necessary, follow the OSHA requirements for respiratory protection. (h) If select carcinogens, reproductive toxins, or acute toxins that are highly toxic are used, identify and establish protective procedures and designated areas of use. (i) Appoint a Chemical Hygiene Officer responsible to implement the Chemical Hygiene Plan (CHP). (3) The procedures established in the CHP must be able to keep employee exposure to chemicals below the regulated permissible exposure limit (PEL). Additionally, the CHP must be readily accessible to employees, and it must be reviewed and updated annually. The CHP must describe specific content and procedures as mandated by the OSHA Laboratory standard. 2. Chemical Hygiene Responsibilities (Note to CHP writer: Many of the following points are taken directly from a sample appendix of the OSHA standard and should remain as responsibilities under each appropriate section. Other points have been added and recommended because of other statements or practices written in the CHP. For the Laboratory Director section, points (1), (2), (4), (5), and (7) should remain if changes or deletions are made to this section. For the Chemical Hygiene Officer section, points (1), (4), (5), (10), (12), and (13) should remain if changes or deletions are made.) A. Laboratory Director Has overall responsibility for chemical hygiene in the laboratory including responsibility to: (1) Ensure that employees know and follow the chemical hygiene rules, that protective equipment is available and in working order, and that appropriate training has been provided. (2) Provide regular, formal chemical hygiene and housekeeping inspections including regular inspections of emergency equipment. (3) Appoint a Chemical Hygiene Officer (Collateral Duty Safety Officer). (4) Know the current legal requirements concerning regulated substances. (5) Determine the required levels of protective apparel and equipment. 214

11 (6) Determines when a complaint of possible over-exposure is reasonable and should be referred for medical consultation. (7) Ensure that facilities and training for use of any material being ordered are adequate. (8) Obtain assistance, as appropriate, to investigate complaints. B. Chemical Hygiene Officer (CHO), (phone number), is the Chemical Hygiene Officer for the CBP Laboratory. The CHO is responsible for implementing and enforcing the provisions of this Plan, including the following: (1) Assists management and other employees in developing and implementing appropriate chemical hygiene policies and practices. (2) Develops and assures annual updates the CHP and appropriate policy practices. (3) Provides technical assistance in complying with the CHP and answers safety questions for employees. (4) Monitors procurement, use, and disposal of chemical wastes. (5) Ensure that appropriated audits are conducted and associated records are maintained. (6) Ensures that appropriate personal protective is available as needed. (7) Monitors proper functioning of protective equipment such as fume hoods and arranges for prompt repairs as needed. (8) Performs routine inspections of emergency equipment. (9) Gathers and maintains manufactureʼs Material Safety Data Sheets, and implements a container labeling program. (10) Know the current legal requirements concerning regulated substances. (11) Reviews chemical inventory to determine which chemicals are of high chronic or acute toxicity. (12) Help develop precautions and adequate facilities for new projects/ laboratory procedures. (13) Seek ways to improve the Chemical Hygiene Plan. C. Responsibilities of Each Employee (1) Each employee working with or around chemicals, having been trained, is responsible for remaining aware of hazards of those chemicals. (2) Each employee is responsible for knowing how to handle a hazardous chemical safely according to its type of hazards and according to this plan. Ask your CHO/safety officer if you have any questions. (3) All employees share the responsibilities of ensuring that all chemicals are used properly and all chemical containers are properly labeled with the identity of the chemical and its hazards. 215

12 3. Standard Operating Procedures A. General Rules (1) This section provides standard operating procedures relevant to safety and health when laboratory work involves use of hazardous chemicals. As a general rule, awareness is the most fundamental rule of chemical safety. When working with chemicals, everyone should remain constantly aware of: (a) The chemicalʼs hazard, as determined from the MSDS, training, and other appropriate references. (b) Proper use of personal protective equipment that is provided by the CBP Laboratory. Primary personal protective clothing is your normal clothing worn in the laboratory. Clothing should be worn to minimize exposed skin surfaces available for direct contact through splashing. Therefore, all employees should refrain from wearing short trousers, skirts, short sleeved shirts, and sandals or open-toed shoes. (c) Location and proper use of emergency equipment. (d) How and where to properly store the chemical when not in use. (Usually, the chemical is actually used for only minutes in an average workday; the rest of the time it is often found being stored on the laboratory bench or in the fume hood). (e) When working with flammable chemicals, be certain that there are no sources of ignition near enough to cause a fire or explosion in the event of a vapor release or liquid spill. (f) Always maintain appropriate proper personal hygiene practices. The four routes of entry are inhalation, ingestion, injection, and eye or skin contact. If we properly protect ourselves, we can eliminate the chemicalʼs ability to do harm. (g) The proper methods of transporting a chemical within the facility. (h) Appropriate procedures for emergencies, including evacuation routes, spill cleanup procedures, and proper waste disposal. (i) (j) Use a fume hood, or required use of face shields or eye protection when handling caustics and corrosives. Keep work area clean and uncluttered, with chemicals and equipment being properly labeled and stored. Clean up the work area on completion of task or at the end of each workday. (k) Glassware that is chipped or broken should be discarded in broken glass receptacles. (l) Employee lunches, snacks, drinks, etc., must not be stored in laboratory refrigerators. Eating and drinking is prohibited in laboratories, and is a major source of hand to mouth contamination. (m) Proper methods of waste disposal of chemicals. 216

13 (n) Hands should be washed frequently during the day, before leaving the laboratory, before and after handling chemicals or samples, and before eating or smoking. B. Hazard Identification (1) Material Safety Data Sheets (MSDSs) - MSDSs are documents containing hazard information on chemicals or products. The OSHA standard that requires the use and maintenance of MSDSs for general industry, is the Hazard Communication standard, 29 CFR (a) Material Safety Data Sheets received with incoming shipments must be maintained for the laboratory and be readily accessible to all employees. (b) For chemicals no longer used by the laboratory, the MSDSs will be saved and filed for possible future need (e.g., an MSDS dead file ). (Note to CHP writer: Here continue with maintenance of MSDSs at your laboratory. Provide information on the specific location(s) they are kept, in what order they are maintained (i.e., by trade name or chemical name), etc. Also provide information on your local procedures for requesting, receiving, responsibility, etc., for MSDSs for your laboratory.) (2) Container Labels All employees of the Laboratory shall ensure that labels on incoming containers of chemicals are not removed or defaced. Transfer containers containing chemicals ( e.g., a chemical poured into another container not the manufacturerʼs container), should be labeled with the name of the product or chemical (as referenced by an MSDS), and the appropriate hazard warning (brief description of hazard and target organ effect). Transfer containers used for immediate use by one employee within the same work shift do not have to be labeled. (Note to CHP writer: Provide here beginning with (a) any established procedures on labeling practices within your laboratory. Provide location where blank labels can be obtained.) (3) All employees should be aware of references available in the laboratory to assist in determining hazards of chemicals being used. (Note to CHP writer: Here describe references on hazard information available in the laboratory. It is not necessary to list individual references, but an overview of available references and where the references are located in the laboratory, or where additional information can be obtained.) C. Chemical Procurement and Inventory: (1) Before a chemical is received in the laboratory, information on proper handling, storage, and disposal should be known to those who will be involved. No container should be accepted without an adequate identifying label and a Material Safety Data Sheet either received with the material or already on file. Preferably, all substances should be received in a central location. 217

14 (2) Chemical Inventory All materials received, either new or additional stock quantities of a material, should be added to the inventory listing. The entire chemical inventory is updated annually, with unneeded chemicals discarded in an appropriate manner. (Note to CHP writer: Describe your current method of inventory listing for the laboratory. It is best to provide as much useful information as possible on a chemical inventory, such as chemical manufacturer, quantities currently stored, approximate quantities used per month/year, date of receipt, expiration of the material, where the material is stored, a notation of whether a MSDS is available and on file, etc. Separate individual inventories can also be maintained per laboratory with a separate inventory for the chemical storage room; or, you can maintain one inventory for the laboratory as a whole. There is not a strict requirement for content or manner of chemical inventory maintenance, as long as one is available and relatively current.) D. Storage (1) General (a) Toxic substances should be segregated in a well-identified area with local exhaust ventilation. Chemicals should be stored by reactive class (i.e. flammables with flammables, oxidizers with oxidizers, etc.). Incompatible chemicals must be physically segregated from each other during storage. (b) Stored chemicals should be examined periodically (at least annually) for replacement, deterioration, and container integrity. (c) Stockrooms/storerooms should not be used as preparation or repackaging areas, should be open during normal working hours, and should be controlled by one person. (d) Amounts permitted in the laboratory work area should be as small as practical. (e) Storage of chemicals on bench tops or in hoods is inadvisable. (f) (2) Flammables Exposure of chemicals to heat or direct sunlight should be avoided. (Note to CHP writer: Begin with point (g) or combine some of the above points, and provide specific information on the location and set-up of your central storage area, such as room number, employee access, etc. Also describe other storage practices such as the use and availability of storage cabinets in laboratories, allowable quantities in cabinets under hoods, etc.) (a) Quantities of one gallon or more must be stored in a safety can. If a reagent must be stored in a glass container for purity, the glass container must be placed in a bottle carrier to lessen the danger of breakage. 218

15 (b) The metal safety cans should only be used as recommended, including never disabling the spring-loaded closure, and always keeping the flame arrester in place and to replace if punctured or damaged. A safety can is designed to safely relieve internal pressure when subjected to fire exposure conditions. (c) The transfer of flammables from metal containers should be preceded by electrical bonding and grounding in order to avoid a static spark that may result from pouring the solvent. (d) Small quantities (working amounts) may be stored on open shelves, however bulk storage (5 gallons or more) must be stored in an approved flammable storage cabinet. (e) Cabinets designed for the storage of flammables should be properly used and maintained. Cabinets are generally made of double-walled construction and 18 gauge steel. The doors are two inches above the base and the cabinet is liquid proof to that point. Only compatible materials should be stored in each cabinet, with no paper or cardboard or other combustible packaging material stored in the cabinet. The cabinet manufacturer establishes quantity limits for various sizes of flammable liquid storage cabinets, and it should be assured that each cabinet is not overloaded. NFPA 30 states that not more than three storage cabinets can be located in any one fire area. (f) Storage of flammable in refrigerators shall be in approved, explosion proof refrigerators only. (g) Flammables should be stored away from caustics, oxidizing acids, and oxidizers. (3) Acids (Note to CHP writer: Although your bulk storage area may not currently meet all recommended design requirements, state of the art design is in accordance with NFPA Standard No. 30, Flammable and Combustible Liquids Code. Flammable liquid containers should be in compliance with the maximum container sizes found in Table H-12, 29 CFR ) (a) Large bottles of acids are stored on a low shelf or in acid cabinets. (b) Oxidizing acids are segregated from organic acids, flammable, and combustible materials. (c) Acids are segregated from caustics and from active metals such as sodium, magnesium, and potassium. (d) Acids are segregated from chemicals which can generate toxic gases on contact, such as sodium cyanide and iron sulfide. (e) Bottle carriers are used for transporting acid bottles. (f) Spill control pillows or acid neutralizers are available for acid spills. 219

16 (Note to CHP writer: You could add specificity to this document by describing specific areas for acid storage in the laboratory. Acid storage cabinets should be labeled Acid Storage Only ) (4) Caustics/Bases (a) Caustics/bases are stored away from acids. (b) Solutions of inorganic hydroxides are stored in polyethylene containers. (c) Spill control pillows or neutralizers should be available for spills. (5) Peroxide-Forming Chemicals (a) Peroxide-forming chemicals are stored in airtight containers in a dark, cool, and dry place. (b) Peroxide-forming chemicals are properly disposed of before the date of expected peroxide formation. (c) Suspicion of peroxide contamination is immediately evaluated by use of safe procedures. (d) Peroxide-forming chemicals are labeled with the date received, date opened and disposal date. (6) Water-Reactive Chemicals (a) Chemicals are kept in a cool and dry place. (b) In case of fire, a Class D fire extinguisher is used. (7) Oxidizers (a) Oxidizers are stored away from flammables, combustibles, and reducing agents (e.g., zinc, alkaline metals). (8) Toxic Compounds (a) Toxic compounds are stored according to the nature of the chemical, with appropriate security employed where necessary. (Note to CHP writer: Please feel free to add specific information relevant to your laboratory to the above, such as examples of toxic and peroxide-forming chemicals commonly used, specific location of storage of specific classes of chemicals, etc.) E. Housekeeping, Maintenance and Inspections (1) Housekeeping Common housekeeping practices contribute greatly towards chemical hygiene and safety. A clean work area is much safer than a cluttered or dirty one. Some appropriate housekeeping measures: (a) All working surfaces and floors should be cleaned regularly. The cleaning contractor employees are responsible for routinely cleaning all floors within the Laboratory Service. Laboratory staff should be considerate and aware of housekeeping staff. The typical housekeeping staff is not familiar with chemicals and their hazards. Therefore, all chemicals should be placed in proper storage areas 220

17 by the end of each working day; all chemical containers should be labeled with both the identity of the chemical and its hazards; all spills must be promptly cleaned up and the spilled chemical properly disposed; and, chemicals should not be stored in aisles, stairwells, on desks or workbenches, on floors or in hallways, or left on shelves over workbenches. (b) All laboratory personnel are responsible for daily cleaning of bench tops and other areas such as fume hoods. (c) Access to emergency equipment, showers, eye washes and exits should never be restricted or blocked by temporary storage of objects or in any other way. (d) Keep all work areas, especially laboratory benches, clear of clutter and obstruction. (e) Keep all aisles, hallways, and stairs clear of all chemicals. (f) All chemicals should be placed in their assigned storage areas at the end of each workday. (g) Wastes should be properly labeled and kept in their proper containers. (h) Formal housekeeping and chemical hygiene inspections should be held at least quarterly for laboratories which have frequent personnel changes and semiannually for others; informal inspections should be continual. (Note to CHP writer: In addition to the general comments, provide specific requirements (if any) which are applicable to chemical safety in your laboratory. The more specific this plan is, the better it will be. Feel free to remove general comments and provide specific comments where applicable. Examples include providing specific information on the contract housekeeping such as working hours and limitations; describe formal in-house inspection schedules and documentation maintenance; additional routine cleaning needed in an area due to common spillage or process hazard; etc.) (2) Maintenance and Inspections (a) Fume hoods will be inspected and monitored on a quarterly basis by the CHO. Documentation will be maintained to provide flow rate and hood/local exhaust location being monitored. (b) Eyewash stations will be inspected quarterly to assure proper water flow. Documentation will be maintained to show quarterly testing. Consensus standards (e.g. ANSI) recommend weekly testing. In an effort to keep the water supply fresh and clear and to keep everyone well acquainted with eyewash locations, everyone should periodically operate the eyewash whenever nearby an eyewash station. (c) Safety showers will be tested on a routine basis (preferably at the same time as the eye wash stations). 221

18 (d) All other personal protective equipment should be inspected regularly. (e) Respirators maintained for emergency use will be inspected monthly in accordance with OSHA 29 CFR (Note to CHP writer: If respirators are used or maintained at your laboratory, reference here the policy established for Respiratory Protection at your laboratory.) (f) F. Spills and Accidents Fire extinguishers are required to be inspected monthly in accordance with Fire and Safety code requirements. (Note to CHP writer: Describe the procedure and responsibility for the above requirements specific to your laboratory. Describe the instruments used for fume hood checks; who is responsible for checks and documentation; and, describe the contract established for fire extinguisher inspections.) (1) Spills of toxic substances or accidents involving any hazardous chemical should be resolved immediately. Detailed procedures are provided in Appendix (the Laboratoryʼs Emergency Action Plan). (Note to CHP writer: Provide reference to your laboratory Emergency Action Plan and any supplement describing response to a chemical spill.) (2) General steps for handling an accident are as follows: (a) Notify your supervisor and your safety officer immediately. (b) If a spilled chemical is flammable, turn off all nearby sources of ignition. (c) If a person has been splashed with a chemical, wash with plenty of water for at least 15 minutes, remove all contaminated clothing, and get medical attention. (d) If a person has been overexposed by inhalation, the victim should be taken to fresh air and medical attention should be obtained. (e) In other cases of overexposure such as ingestion or skin contact, a medical specialist should be immediately contacted. (f) Secure proper medical attention for a chemically exposed victim. If the spill is small in size, (spill size and allowable response action defined in Note to CHP writer: add spill response policy) you should neutralize or absorb the spilled chemical with the proper spill cleanup materials and dispose of it in accordance with hazardous waste procedures. (g) There are some actions which are not appropriate when handling emergencies. Some of them include: Do not force any liquids into the mouth of an unconscious person. Do not handle emergencies alone, especially without notifying someone that the accident has occurred. 222

19 Do not apply medical aid procedures without some training in that area (except to wash with water for 15 minutes and to take the victim to fresh air). If you are not trained in fundamental first aid, you should get medical instruction before inducing vomiting, giving antidotes or applying a neutralizer to the skin or eyes of the victim. Do not linger at the accident scene if you are not one of the emergency responders. (3) Evacuation Procedures refer to (Laboratory Emergency Action Plan). (Note to CHP writer: Provide reference to appropriate evacuation plan.) 4. Control Measures A. Engineering Controls (1) Ventilation System In the general ventilation system, 4-12 room air changes/hour is normally adequate general ventilation if local exhaust systems such as hoods are used as the primary method of control. General air flow should be relatively uniform and not turbulent throughout the laboratory, with no high velocity or static areas. (2) Fume Hoods The following is required for fume hood performance and use: (a) Sash height should be labeled to show the closure point level where the desired air flow (100fpm) is achieved. This level should be maintained while working with hazardous chemicals inside the hood. (b) Fume hood performance should be thoroughly evaluated and documented periodically for proper air flow. At least quarterly monitoring will be performed, with proper documentation maintained. (c) An indicator will be placed on the hood to provide the user with quick confirmation of adequate hood performance. This can be a simple flutter strip attached to the hood sash to show inward flow of air, or placement of a vane anemometer inside the hood showing continuous measured air flow levels. (d) As a general rule, when a TLV or PEL of a chemical is less than 50 ppm or 100 mg/m 3, the user must use it in an operating fume hood. (e) A fume hood should not be used to dispose of chemicals by evaporation. (f) Apparatus inside the hood should be placed on the floor of the hood at least six inches away from the front edge. (g) Fume hood sashes should be lowered at all times except when necessary to raise in order to adjust the apparatus inside (i.e., organic chemistry operations). 223

20 (h) Minimize as much as possible foot traffic past the face of the hood. (i) (j) Do not place electrical receptacles or other spark sources inside the hood when flammable liquids or gases are present. No permanent electrical receptacles are permitted in the hood. The hood fan should remain on whenever a chemical is inside the hood, whether or not any work is being performed in the hood. (k) Personnel should be aware of the steps to be taken in the event of power failure or other hood failure. (l) Hood vent ducts and fans must be inspected at frequent intervals to be sure they are both clean and clear of obstructions. (m) Hoods are never to be used as primary storage areas for chemicals, apparatus, or other materials. Materials stored in them should be kept to a minimum, and the chemicals should not block vents or alter airflow patterns. B. Personal Protective Equipment Personal Protective Equipment (PPE) includes gloves, goggles, face shields, aprons, and respirators. Although the use of such equipment is generally the least desirable way to control workplace hazards because it places the burden of protection on the worker, the equipment must be available for situations when an unexpected exposure to chemical substances or physical agents could have serious consequences. A Hazard Assessment for PPE has been completed and is available in accordance with 29 CFR (Note to CHP writer: The Hazard Assessment could be added and noted as an appendix to this CHP here, or referenced as a separate document, depending on length.) (1) Safety Eyewear (a) The basic eye protection in the laboratory is safety glasses with side shields. Goggles should be used if there is a significant possibility of a harmful chemical splash. Goggles also give protection against flying particles. (b) Protective eyewear must be available in all areas where hazardous chemicals are utilized. (c) Protective eyewear should be easy to clean and disinfect, and be maintained in a clean state. (d) For employees who wear glasses, goggles or face shield must fit over the glasses. (e) Contact lenses should not be used in the laboratory. If contact lenses cannot be avoided, the CHO should be notified so special precautions can be taken. 224

21 (f) Other specialized eyewear may be needed for such things as laser hazards, ultraviolet and other intense light sources. (Note to CHP writer: Describe any special need to protective eyewear related to specific operations. Also describe above any requirements or routine procedures relevant to your laboratory, such as the central area/room to pick-up protective eyewear, required procedures for visitors, etc.) (2) Contact Prevention Skin contact is a major concern when using chemicals. The proper gloves are the first defense against skin contact, or injury to the hands. Other PPE such as laboratory coats and aprons should be used based on the hazard of the chemical being used. Laboratory coats should be used by all laboratory employees, and should not be worn outside of the laboratory area. (a) Gloves should be worn whenever corrosive materials, rough or sharp-edged objects, very hot or very cold materials are handled, or whenever protection is needed against accidental chemical exposure. Gloves also protect the hands from chemicals entering the body through a cut from broken glassware, or a cut that occurred away from work. (b) Various glove compositions and thicknesses are available which should be selected based on the specific material being handled. (Note to CHP writer: A Glove Chemical Resistance Chart could be added and noted here as an appendix to this CHP.) Common materials are neoprene, polyvinyl alcohol, polyvinyl chloride, nitrile and natural rubbers. These materials differ in their resistance to various substances. (c) Gloves should be inspected carefully for discoloration or damage. Gloves with even a small pinhole will not give adequate protection. Glove materials are eventually permeated by chemicals and should be discarded when contaminated. (Note to CHP writer: Provide information here regarding specific glove requirements, availability, and any special procedures requiring specialized glove use in your laboratory.) (3) Respirator Use Where respirators are available and used by employees of the Laboratory, a program of fit-testing, medical surveillance, and training must be established. All uses of respirators must be approved by the CHO. Appendix provides the written Respirator Program, describing the entire program, as required by OSHA standard 29 CFR The following describes all respirators used and the conditions of use at the Laboratory. (Note to CHP writer: Describe all procedures where respirator use is required in your laboratory. Include all use of double-strapped disposal respirators, up to emergency use Self-Contained Breathing Apparatus available.) 225

22 C. Personal Hygiene (1) Wash promptly whenever a chemical has contacted the skin. (2) Avoid inhalation of chemicals; do not attempt to identify chemicals by odor. (3) Do not use mouth suction to pipette anything; use suction bulbs or other mechanical devices. (4) Wash skin well with soap and water before leaving the laboratory; do not wash with solvents; use soap. (5) Do not drink, eat, smoke, or apply cosmetics in the laboratory. (6) Do not bring food, beverage, tobacco or cosmetic products into chemical storage or use areas. (7) Do not wear your lab coat when leaving the laboratory. (8) Hair should be secured back and off the shoulders in such a manner to prevent contact with hazardous chemicals and contaminated materials. (9) Keep work area clean and uncluttered, with chemicals and equipment being properly labeled and stored. Clean up the work area on completion of task or at the end of each day. (10) Contact lenses should not be worn in laboratories. (11) Do not wear open-toed shoes, sandals, etc. (Note to CHP writer: Provide any additional hygiene requirements already established or specific to your laboratory.) D. Environmental Monitoring (1) Regular instrumental monitoring of airborne concentrations is not usually justified or practical in laboratories because of the brief or transient use of individual chemicals, but may be appropriate when testing or redesigning hoods or other ventilation devices or when a highly toxic substance is stored or used regularly (such as use three or more times per week). (2) Use of benzene, formaldehyde, lead materials, and other chemicals with OSHA designated standards or Permissible Exposure Limits (Subpart Z of 29 CFR Part 1910) will require monitoring if used frequently, as defined above. If used frequently, requirements for training, medical surveillance, etc., of these standards are required, including maintenance of documentation for the required elements. If not used often, the requirements of the OSHA Laboratory Standard (following this Chemical Hygiene Plan) supersede the requirements of the separate standards. HOWEVER, extreme care should be taken during use of extreme toxic chemicals such as those described in section 5.C. of this plan. (3) Records of baseline monitoring and interpretation should be maintained where it has been completed, in the event of a regulatory or departmental/ agency review of the hazards of specific operations. The laboratory will strive to conduct monitoring for each procedure with potential hazard if there is reason to believe that exposure levels for the chemical used routinely 226

23 exceed regulatory limits. (Note to CHP writer: Provide details of where documentation will be found in the laboratory for exposure monitoring.) (4) The employer must notify affected employees of the results of any monitoring performed within 15 days (5 days for lead monitoring)of receipt of monitoring results. This notification must be in writing. (Note to CHP writer: Describe monitoring which has been completed or determined to be needed for your laboratory. For highly toxic materials such as benzene, formaldehyde, lead, known or suspect carcinogens, etc., used three or more times per week, baseline monitoring will need to be performed and documentation maintained ) 5. Procedure-Specific Safety Rules A. Procedures for Compressed Gases (1) Cylinders must be secured at all time so that they cannot fall. Earthquake prone areas should consider double chains to secure cylinders. (2) Valve safety covers should be left on until pressure regulators are attached. (3) Cylinders must be clearly labeled indicating the contents and the hazards. A Material Safety Data Sheet (MSDS) for each type of compressed gas must be readily accessible. (4) When moving cylinders, hand trucks or dollies with a securing device must be used. (5) Use of oil, grease, or lubricants on valves is prohibited. (6) Do not attempt to repair damaged cylinders or use force on frozen cylinder valves. (7) No more than two cylinders of flammable gases should be manifolded together; however, several instruments or outlets are permitted for a single cylinder. (8) When more than one cylinder of a highly flammable gas is to be used in one room, specific approval by the Laboratory Director, or Chemical Hygiene Officer must be obtained. (9) Standby cylinders of a flammable gas (full or empty) are not to be stored in the laboratories. (10) Valves on all flammable gas cylinders shall be shut off when the unit is unattended. B. Procedures for Caustic, Corrosive Chemicals and Contact Hazard Chemicals (1) Corrosivity, allergenic, and sensitizer information is sometimes given in manufacturersʼ MSDSs and on labels. A corrosive chemical is one which: (a) Fits the OSHA definition of corrosive in Appendix A of 29 CFR (b) Fits the EPA definition of corrosive in 40 CFR (has a ph greater than 12 or less than 2.5), or which (c) Is known or found to be corrosive to living tissue. 227