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Environmental Health & Safety
MBI/ATAMI Chemical Hygiene Plan
Last Update 06/11/2010
I. Purpose & Scope
Oregon OSHA regulations covering the occupational exposure to hazardous chemicals in laboratories require Oregon State University (OSU) to develop and follow a Chemical Hygiene Plan (CHP) for laboratories. The CHP must include:
- procedures to assure safety and health in laboratories,
- criteria for implementation of control measures,
- provisions for training and information dissemination,
- provisions for medical consultation,
- designation of responsible personnel (to maintain safe conditions), and
- criteria for identification of particularly hazardous substances (i.e., labeling).
This document is the MBI Laboratory Chemical Hygiene Plan (LCHP). All laboratory personnel must understand and follow the guidelines outlined in this plan. In addition, each employee is expected to develop safe personal chemical hygiene habits aimed at minimizing chemical exposures to themselves and coworkers. This LCHP will be reviewed, evaluated and updated annually and must be made readily available to employees, their representatives and any representative of OR-OSHA.
It is important to follow this plan. OR-OSHA will monitor our laboratory operations. Following these procedures will assure that all OSU employees and students work in a safe and healthy environment.
This plan applies to all OSU employees engaged in the laboratory use of hazardous chemicals at the MBI facility.
"Laboratory use of hazardous chemicals" means the handling or use of such chemicals in which all of the following conditions are met:
- Chemical manipulations are carried out in containers designed to be easily and safely manipulated by one person.
- Multiple chemical procedures or chemicals are used.
- The procedures involved are not part of a production process, nor in any way simulate a production process; and
- Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
"Laboratory" is a room or group of rooms under the control of a lab supervisor or principal investigator (PI) where relatively small quantities of hazardous chemicals are used on a non-production basis. Rooms such as computer labs, electronic labs, reading labs are not considered "laboratories" under this Chemical Hygiene Plan.
II. Chemical Hygiene Responsibilities
A. OSU President
- The President of OSU has the ultimate responsibility for chemical hygiene throughout University laboratories, and, with assistance of other program administrators, provides ongoing support for safe use of chemicals at OSU.
B. OSU Chemical Hygiene Officer
The Senior Industrial Hygienist, Environmental Health and Safety (EH&S) shall serve as the OSU Chemical Hygiene Officer.
- This individual, or the members of their staff, shall have the responsibility and authority to:
- Work with administrators and other employees to develop and implement appropriate chemical hygiene policies and practices.
- Inspect any OSU facility and investigate any accident involving OSU employees, students or equipment.
- Temporarily suspend the operations in any OSU laboratory in which the practices represent an imminent health hazard.
- Monitor procurement of chemicals.
- Oversee the performance of regular, formal chemical hygiene inspections and inspections of emergency equipment in all OSU laboratories.
- Assist Lab Supervisors/PI and LCHOs to develop safety precautions and adequate facilities.
- Maintain current knowledge concerning the legal requirements of regulated substances in the laboratory.
- Review the OSU Chemical Hygiene Plan annually.
- Monitor chemical hygiene training for compliance with code-mandated items.
- Coordinate the chemical waste disposal program.
C. Site Superintendent
- The Site Superintendent will determine and designate the Laboratory Chemical Hygiene Officer (LCHO). One LCHO is required for the MBI facility.
- The names of the LCHO will be sent to EH&S. EH&S should also be notified of any change in these assignments.
D. Laboratory Chemical Hygiene Officer
- The LCHO will be knowledgeable of the operations in the MBI facility.
- The LCHO will perform the following:
- Update this LCHP as needed.
- Inspect stored chemicals, laboratory safety equipment, and labeling at least monthly.
- Evaluate procedures in each lab and determine those that are hazardous.
- Determine adequacy of ventilation systems for new chemicals/procedures.
- Provide information on proper handling of highly toxic chemicals to ordering labs.
- Provide information on chemical hygiene, as needed.
- Assist in or conduct chemical hygiene inspections in labs.
E. Lab Supervisor/PI
- The Laboratory Supervisor or Principal Investigator is the individual who has the primary responsibility for safety in the laboratories under their control.
- This individual, or delegated members of their staff, shall have the responsibility to:
- Propose changes to the LCHP that address their lab area.
- Inspect laboratories for unsafe conditions and practices and take appropriate corrective action.
- Ensure required safety training is provided for employees and students that work in their laboratories.
- Document all safety training provided.
- Investigate injuries to lab employees or overexposure events.
- Evaluate the need for protective equipment or chemical exposure monitoring.
- Request appropriate monitoring from EH&S if necessary.
F. University Chemical Safety Committee
- The University Chemical Safety Committee members are appointed by the Vice Provost for Research. The Committee is responsible for reviewing and approving any changes to the OSU Chemical Hygiene Plan.
- The Chemical Safety Committee may also investigate and discuss reported unsafe practices conducted in any OSU laboratory. Their recommendations for correction, including disciplinary action, are to be sent to the Vice Provost for Research.
III. Laboratory Chemical Hygiene Plan
- This LCHP must be easily accessible from each laboratory and must be reviewed by the LCHO annually.
IV. Laboratory Chemicals
A. Chemical Procurement/Receiving
- The decision to purchase a chemical shall be a commitment to handle and use the chemical properly from receipt to disposal.
- Chemicals that are already on the inventory can be purchased without review, assuming the combined quantities do not exceed those required by the facility occupancy limits as outlined in fire and building codes.
- Chemicals not on the inventory will be submitted to LCHO for review prior to ordering. For evaluation, a current MSDS will be required at time of request.
- EH&S will determine hazard classes, acceptable quantity, and potential effect on waste and sewer processes prior to authorizing purchase.
- Chemical containers must have appropriate labels that include the name of the chemical and hazard information.
- All chemicals in containers > 50 gal will be received through the loading dock area.
- Smaller size chemical containers may be received through the front door OR the loading dock.
- If OSU personnel are receiving chemical shipments, they must be trained as Department of Transportation hazmat employees.
B. Chemical Storage
- Chemical storage areas must have a standard OSU "CAUTION" sign that identifies emergency contact personnel. Signs are supplied by EH&S - see (Reference 5)
- Glass containers that contain more than 4 liters of flammable liquids are prohibited.
- Storage of chemicals will by hazard class. Segregate chemicals by hazard classification and compatibility (Reference 21).
- Separate oxidizers from flammable, combustible, or any organic material.
- Separate acids from acid-sensitive materials such as cyanides and sulfides.
- Place acid-resistant trays under bottles of mineral acids.
- Minimize storage of chemicals at the lab bench, in hoods, and at other work areas.
- Stored chemicals shall be inspected at least quarterly by the LCHO for deterioration and container integrity. The inspection should detect corrosion, deterioration, or damage to the storage facility as a result of leaking chemicals.
- Unneeded chemicals shall be discarded through the MBI waste disposal process coordinated by EH&S
- All reagent chemical storage will be protected by suitable lips on shelves to minimize movement in siesmic events.
- Other chemicals will be stored in appropriate chemical cabinets - either special lab chemical storage units with doors for general chemicals, or hazardous materials cabinets for more hazardous chemicals (flammable, reactive, toxic, corrosive - acids and bases separately).
C. Chemical Handling/Transport
Exposure to all chemicals should be minimized because all chemicals inherently present hazards in certain conditions and concentrations. General precautions that shall be followed for the handling and use of all chemicals are:
- Use the minimum convenient volume for the task at hand. Quantities of chemicals at the lab bench should be as small as practical.
- Avoid skin contact with all chemicals.
- Wash all skin which came in contact with chemicals before leaving the laboratory.
- When leaving the lab, stop all operations, or, for operations that do not require monitoring, make precautions for the interruption of utility service (e.g., loss of water pressure or electricity).
- Food or beverages shall not be stored in laboratories or in chemical or specimen refrigerators and lab utensils or glassware will not be used for non-laboratory operations such as food or liquid consumption.
- Treat substances of unknown toxicity as toxic. Any chemical mixture must be assumed to be as toxic as its most toxic component.
- Laboratory employees must be familiar with the symptoms of exposure for the chemicals with which they work and the precautions necessary to prevent exposure.
- In all cases of chemical exposure, the OSHA Permissible Exposure Limit (PEL) is not to be exceeded.
- Movement of chemicals within the building will be on stable carts capable of containing a spill of the largest quantity of chemical in any individual container.
- Incompatible containers will be isolated within separate impervious trays or other adequate secondary containment.
- All labels on chemical containers will be retained until empty by definition.
- Empty chemical containers will be rinsed prior to disposal.
- The initial rinsate will be treated as waste; subsequent rinses may be required depending on chemical identity.
D. Waste Determination and Disposal of Chemicals
- The MBI facility will operate as a conditionally exempt small quantity generator.
- A DEQ generator ID number has been obtained for waste handling and disposal.
- All chemical waste produced at the facility must undergo a hazardous waste determination by EH&S prior to disposal.
- All hazardous chemical waste must be disposed of through the program coordianted by EH&S
- All hazardous wastes leaving the facility will do so using a hazardous waste manifest, and be sent to permitted facilities identified on the OSU waste contract.
- Waste shipments will occur at a minimum of once every year. Frequency of shipments will change if generator status changes or if the need arises.
- Initial rinses of all chemical containers may need to be included in the waste program.
- All chemical waste containers must be labeled "hazardous waste", plus the name of the waste, and have a tight fitting lid.
- Waste containers will be dated when first adding waste.
- Waste containers will be stored in a separate hazardous materials cabinet.
- Waste storage:
- Chemical wastes will be segregated from new chemicals and stored in a hazardous materials cabinet.
- Incompatible wastes will be separated.
- Wastes put in the cabinet will be labeled with chemical content, date of generation, and the words "hazardous waste".
- No hazardous chemical waste will be disposed down sinks.
- No chemical waste which fail to meet local wastewater guildelines will be disposed via the sewer system.
E. Chemical Spills
- Each laboratory research group is expected to maintain appropriate material to contain and clean up minor chemical spills that meet ALL the following criteria:
- less than five feet in diameter
- within the control of the operator of the process
- not flowing
- within the facility.
- OSU spill response team (SRT) will clean up large spills inside the facility that meet ANY of the following criteria:
- not within the control of the operator of the process
- greater than five feet in diameter
- call SRT (737-2273)
- HP Spill Emergency Response Team (SERT) will clean up all spills that meet the following criteria:
- outside the facility
- call CERT (715-2222)
- In the event of a major spill, a sign warning of the spill must be posted at each entrance to the area unless personnel are on duty to provide adequate warning .
F. Glassware and Containers
- All labs using glassware will have a clearly labeled broken glass container. Broken glassware will be immediately disposed of in this container.
- High-vacuum evacuated glass apparatus will be shielded to contain chemicals and glass fragments should implosion occur.
- All containers of chemicals shall be labeled.
- All labels on individual chemical containers will be retained until empty.
- Labels shall be informative, durable, and, at a minimum, will identify contents and hazards.
- The chemical name must be provided in addition to any desired abbreviations and chemical formula.
- The chemical source, receipt date, storage location and initials/identifier of person who prepared the container should also be placed on the label.
- Secondary containers (including beakers, flasks, bottles, etc. used in experiments) will bear a label which displays the chemical name, hazard information, date of transfer, and identity of person transferring chemical.
- Chemical storage cabinets and areas must be labeled as to their contents. The label must be displayed on the door and be visible.
G. Personal Protective Equipment
- ANSI approved safety glasses are required, at a minimum, when there is a need for eye protection because of handling highly toxic or corrosive chemicals.
- Chemical goggles and/or a full face shield should be worn during chemical transfer of large quantities of corrosive chemicals.
- Lab coats should be laundered periodically and shall be removed from the laboratory if there is significant contamination with a hazardous substance. Lab coats are considered protective gear and must not be worn outside laboratory areas (unless in transit between labs).
- Wear appropriate chemical-resistant gloves (Reference 4) at all times when hands may come in contact with chemicals. Discard damaged or deteriorated gloves immediately.
- Wear thermal-resistant non-asbestos gloves when handling heated materials and exothermic reaction vessels. Discard damaged or deteriorated gloves immediately.
- Respirators may be required for certain procedures, as determined by the lab's supervisor/PI in consultation with the LCHP and based on the OSU Respirator Program (Reference 6).
H. Personal Work Practices
- Each OSU employee working in a laboratory must develop work habits consistent with this LCHP to minimize exposure to the chemicals. Laboratory Safety Rules should be understood and followed (Reference 25).
- Plan operations, equipment and protective measures based on knowledge of the chemicals in use.
- Use engineering controls (e.g., hoods, centrifuge rotor hoods) appropriately to minimize chemical exposure.
- Wear appropriate protective equipment as procedures dictate and when necessary to avoid exposure.
- Report unsafe laboratory practices or conditions to the Lab Supervisor/PI, who will correct unsafe practices or conditions promptly.
Each laboratory worker is responsible for maintaining a clean and uncluttered work space.
- Lab workers are jointly responsible for common areas of the laboratory.
V. Implementation of Sampling
A. Air Sampling
- EH&S (737-2273) will arrange for air sampling on request if there is reason to believe that exposure levels for regulated substances will exceed OSHA limits (Reference 8).
B. Biological Sampling
- When justified, biological samples (e.g., blood, urine) may be taken as requested by the employee or supervisor.
C. Sampling Records
- Results of area air sampling should be posted for at least one month in the Laboratory. A copy will be kept at EH&S.
- Results of personal or biological monitoring will be given to the monitored employee and their supervisor. A copy will be kept on file at EH&S.
VI. Safety Signs, Emergency/Safety Equipment, Engineering Controls, Special Rooms
A. Safety Signs
- Each main hallway entrance to a laboratory room/area, all chemical storage rooms and all cold rooms and warm rooms will have a standard "CAUTION" sign listing the individuals to contact in the event of an emergency. (Reference 5)
- The location of safety and emergency equipment within the laboratory, including spill kits, should be identified by signs.
- Warning signs are required in the event of engineering controls failure, failure of special rooms, or certain spills. There are no standard signs for such events--create bold, striking signs.
B. Emergency/Safety Equipment
- Emergency showers shall be inspected annually by LCHO. Records of inspections will be maintained at the facility.
- All laboratory personnel should be trained in the proper use of fire extinguishers if personnel are expected to use extinguishers.
- Eyewash stations shall be inspected weekly by laboratory employees to determine that they operate. Records of inspections shall be maintained in the laboratory.
- All laboratory safety equipment (e.g., safety glasses, gloves, noise earmuffs) shall be inspected at appropriate intervals by the lab workers for operational sufficiency. Records are not required.
- Keep access to fire extinguishing equipment, eye washes, showers, electrical disconnects and other emergency equipment unobstructed.
C. Engineering Controls
Engineering controls installed in the laboratory are intended to minimize employee exposure to chemical and physical hazards. Examples are laboratory fume hoods, exhaust ducts, centrifuge rotor lid.
- Inspection and Maintenance
- Improper function of building engineering controls (hoods, exhaust ducts) must be immediately reported to MBI facility manager. The system must be taken out of service until proper repairs have been completed. A sign should be posted indicating that it is out of service.
- Engineering controls are to be inspected periodically for operational sufficiency (e.g., air is moving in hoods, rotor lids are not cracked) by the Lab Supervisor/PI.
- Engineering controls will not be modified unless approved by the OSU Chemical Hygiene Officer.
- Fume Hoods
- Hoods shall be utilized for chemical procedures that might result in release of hazardous chemical vapors or dust. (Reference 15)
- Be certain that the hood is operating before using it. All hoods shall have a flow indicator (electronic flow sensro or magnahelic).
- Inform the LCHO of the use of unfamiliar chemicals or procedures to determine if the ventilation system is adequate to protect employees.
- Always keep the sash of the hood closed or below the height specified by the inspection sticker. When using the hood work space, maintain the sash height as low as possible.
- Place sources of air contaminants as close to the back of the hood as possible, and always at least 6" back from the sash.
- Minimize storage of chemicals and equipment inside the hood.
- Minimize interference with the inward flow of air into the hood.
- Leave the hood operating when it is not in active use if chemical hazards are contained inside the hood or if it is uncertain whether there is adequate general laboratory ventilation.
- Hoods shall be inspected on installation and annually or on request, by EH&S. The hood face velocity shall be tested at each inspection to ensure that it is maintained between 100 to 120 feet per minute. A record of the most recent inspection shall be placed on the hood, and historical records will be retained by EH&S.
- Each employee shall receive training at the time of initial assignment to the laboratory, before assignments involving new exposure situations, and at a regular frequency as determined by the LCHO. Training is mandatory and OR-OSHA inspections are likely to include a survey of random individuals about the knowledge required to be presented in this training. Training will include:
- Location and details of the OSU and Laboratory Chemical Hygiene Plans;
- A review of the Laboratory Safety Rules;
- How to use MSDS’s and their utility in the laboratory
- Location of the Permissible Exposure Limits (PELs) for OSHA-regulated substances;
- Chemical hazards in the laboratory, including medical signs and symptoms associated with acute and chronic exposure to those chemicals present in the laboratory that are potentially hazardous to the employee's health given quantities in use. Quantities may include very small amounts for carcinogens such as benzidine or large quantities for solvents with PELs over 500 ppm such as acetone;
- Location and availability of reference material on chemical safety;
- Location and proper use of emergency showers and eye washes for employees who might be exposed to chemical splashes and discussion of chemicals in the lab requiring urgent medical action. Exceptions to 15-minute flushing with water (e.g., hydrofluoric acid) must be discussed;
- Location and use of fire extinguishers and other lab safety equipment and personal protective equipment relevant to the employee's work;
- Building escape routes for use in the event of a fire or serious release of agents that are hazardous.
- Supervisors are required to document all training.
B. Hazard Information
- The Hazard Communication booklet is available in the EH&S workspace.
- Material Safety Data Sheets (MSDS's) for chemicals used in the laboratory are available in a binder in the EH&S workspace. An MSDS describes relevant safety and health information for a chemical.
VIII. Special Precautions
A. Hazardous Work
- Procedures in each laboratory will be evaluated by the Lab Supervisor/PI and the LCHO, and those that are deemed hazardous (e.g., use of significant quantities -- ten times the LD50 -- as defined on MSDS's), or as determined by the LCHO, will be identified below:
- All hazardous operations are to be performed while at least two people are present at the lab building.
B. Allergens, Embryotoxins and Teratogens
- Areas where such agents are used will be identified by a standard caution sign and are listed below:
- Wear suitable gloves to prevent hand contact and wear other protective gear (e.g., lab coats) when exposed to allergens.
- Allergens and embryotoxins will be stored in adequately ventilated areas in unbreakable secondary containers.
- Handle reproductive toxins only in a hood with a current inspection label and use protective equipment to prevent skin contact as prescribed by the Lab Supervisor/PI and the OSU CHO.
- The Lab Supervisor/PI and the Laboratory and OSU Chemical Hygiene Officers will be notified of significant spills and other personal exposure incidents.
C. Chemicals of High Acute Toxicity
- Areas where these chemicals are stored and used will have restricted access and have specific warning signs naming the hazard types.
- Vacuum pumps when used with these chemicals must have scrubbers or High Efficiency Particulate Absolute (HEPA) filters.
- Approval of the Lab Supervisor/PI will be obtained before initiating a new procedure using these chemicals.
D. Chemicals of High Chronic Toxicity
- Such chemicals will be maintained in labeled, unbreakable, chemically resistant containers and stored in a limited-access area appropriate for the chemical.
- Areas where such agents are used shall be identified by a sign on the hood, glove box or lab area.
- The Lab Supervisor/PI will be knowledgeable of chemicals in use and will approve new procedures prior to implementation.
- Vacuum pumps when used with these chemicals must have scrubbers or High Efficiency Particulate Air (HEPA) filters.
- Any contaminated equipment or glassware will be decontaminated as soon as possible and before further use.
- For powders, a wet mop or vacuum with a HEPA filter will be used for cleanup, and the waste will be immediately disposed of.
E. Animal Research
No animal research is expected at the MBI facility
- EH&S Radiation Safety is responsible for all radioactive substances and places additional restrictions on chemical substances or agents referred to in this Plan that are also radioactive.
- No unsealed sources will be used at the MBI facility.
G. Recombinant DNA
No recombinant DNA work is expected at the MBI facility.
H. Infectious Agents
No infectious material work is expected at the MBI facility.
IX. Medical Attention and Surveillance
A. Medical Attention
- An opportunity to receive medical attention from a licensed physician is available to all employees who work with hazardous chemicals in the laboratory.
- The opportunity for medical attention will be made available to employees at no cost and without loss of pay under the following circumstances:
- Whenever an employee develops signs or symptoms associated with a hazardous agent to which the employee may have been exposed in the laboratory;
- Whenever there is a spill, leak, explosion or other occurrence resulting in the likelihood of an exposure hazardous to health or if a PEL is exceeded. A medical examination must be provided in the event a PEL is exceeded in a personal exposure.
B. Medical Surveillance Programs
Medical surveillance will be established when exposure monitoring determines a need or if it is likely that an exposure to a hazardous chemical has occurred.
X. Laboratory Accidents
This section includes overexposures to hazardous agents.
A. Injuries or Overexposures (Aid to Employees)
- An exposure exceeding an OSHA PEL is an "overexposure."
- If an employee is seriously injured or incapacitated, call 911 to obtain emergency medical treatment.
- Never enter an enclosed space where a person appears unconscious; contact 911 for assistance.
- Chemical splashes require immediate flushing of the affected areas. Fifteen minutes of flushing for significant splashes or any splash in the eye is recommended. Eye wash stations and lab deluge showers are intended for this purpose. There are exceptions that should be covered in training, if relevant.
- For minor injuries, treat with the laboratory first aid kit or take the person to the hospital or their personal physician. Treatment should prevent exposure to chemicals if the injured person will continue to work in the lab prior to healing (e.g. , a cut on the finger will be covered by a bandage and the person will wear a plastic glove until the cut is fully healed).
- Most injuries or overexposure events require completion of a Report of Accident form.
B. Accident or Overexposure Investigations
Accident or overexposure investigations will be conducted by the immediate supervisor with assistance from other personnel as deemed necessary.
XI. Laboratory Inspections
- The LCHO will inspect each laboratory at least annually.
- The purpose of the inspection is to verify that this Plan is being followed and to identify needed changes in procedures. The form entitled "Laboratory Inspection Checklist and Report" (Reference 2) can be used for this inspection and could be used for a self-inspection by laboratory staff. Alternate lab self-audit forms.
- A written inspection report (the checklist with notations) will be provided to the Lab Supervisor/PI and maintained on file in the Laboratory Chemical Hygiene Plan.
- The Lab Supervisor/PI is responsible for taking corrective action for deficiencies when indicated in the written inspection report in a timely manner and prior to the next inspection.
- Follow-up inspection will monitor correction in cases of serious deficiencies.
- An inventory of all chemicals will be in the EH&S database accessible on-line.
- The inventory will be checked and updated periodically; at a minimum, every month.
- The inventory will be updated each time a new chemical is received, and when significant quantities of chemicals are put into a process that may end up in the waste program.
- The inventory will include names of chemicals, hazard classes, amounts, and location.
- In all cases, the inventory will be limited to maintain the facility as a B-occupancy designation.
- All chemical acquisitions (shipments) will be entered into the inventory immediately on receipt at the lab.
- Accident or overexposure incident reports must be sent to EH&S and must be retained for 5 years.
- Records of exposure to personal or biological monitoring of hazardous chemicals and other harmful agents will be maintained in EH&S for the duration of employment of the exposed employee, plus 30 years.
- Medical records for employees developed as a result of exposure to hazardous chemicals or harmful agents will be maintained for the duration of employment, plus 30 years, in EH&S.
- Results of area air sampling will be maintained by EH&S for 5 years.
- Records of employee training will be maintained for 5 years in the employees departmental personnel record and as instructed in Reference 24.
- Records of laboratory inspections will be maintained for 5 years in EH&S.