CHEMICAL HYGIENE PLAN
2nd Draft
APRIL 21, 2008
by
Maury Riner
TABLE OF CONTENTS
1. Purpose 7
2. Scope 7
2.1 Employees 7
2.2 Students 7
3. Exclusions 8
4. Responsibilities of the University, Employees, Students 8
4.1 President 8
4.2 Safety Committees 8
4.21 Chemical Safety Committee 8
4.22 Biological Safety Committee 8
4.23 Radiation Safety Committee 9
4.3 Research Proposal Review 9
4.31 Student Research Review 9
4.32 Faculty Research Review 9
4.4 Environmental Health Safety / Risk Management Support 9
4.5 Department Chairs 10
4.6 Principle Investigators (PI) / Research Lab Supervisors (RLS) 10
4.7 Employees 11
4.8 Students 12
5. Classification of Chemical Hazards 12
5.1 Physical (Contact) Hazards 12
5.11 Corrosive Chemicals 12
5.12 Sensitizing / Irritant Chemicals 12
5.2 Flammable / Combustible (Fire) Hazards 13
5.21 Flammable / Combustible Liquids 13
5.22 Flammable Solids 13
5.3 Multiple Hazards 13
5.31 Highly Reactive / Unstable Chemicals 13
5.4 Particularly Hazardous Chemicals 13
5.41 General SOPs 14
5.42 Highly (Acutely) Toxic Chemicals 14
5.43 Select Carcinogenic Chemicals 14
5.44 Reproductive / Developmental Toxins 15
5.5 Restricted Chemicals 15
5.51 EPA p-listed Chemicals 15
5.52 DEA Controlled Chemicals 15
5.53 DHS Chemicals of Interest 16
5.6 Cryogenic Liquids 16
5.61 Cold Burn Hazards 16
5.62 Asphyxiation Hazards 16
5.63 Fire and Explosion Hazards 16
5.7 Cryogenic Liquid SOP 16
5.71 Required PPE 16
5.8 Solid Carbon Dioxide (Dry Ice) 17
5.81 Cold Burn Hazards 17
5.82 Asphyxiation Hazards 17
5.83 Flammable Liquid Hazards 17
5.9 Solid Carbon Dioxide (Dry Ice) SOP 17
5.91 Required PPE 17
5.10 Compressed Gases 17
5.11 Compressed Gas Cylinder SOPs 18
6. Reducing Hazardous Chemical Exposures 19
6.1 Administrative Controls 19
6.11 Laboratory Inspections 19
6.2 Engineering Controls 20
6.3 Personal Protective Equipment (PPE) 21
6.31 Choosing PPE 21
6.32 Using PPE 22
7. Laboratory SOPs 22
7.1 General Teaching Laboratory SOPs 22
7.2 General Research Laboratory SOPs 25
8. Chemical Exposure Assessment and Medical Exams 28
8.1 Personal Exposure Monitoring 28
8.2 Frequency of Exposure Monitoring 28
8.3 Medical Exams 28
9. General Chemical SOPs 28
9.1 Chemical Procurement 29
9.2 Chemical Inventories 29
9.3 Chemical Storage and Labeling 29
9.4 Controlled Substances / P-Listed Chemicals 30
9.5 Shipment of Chemicals 31
10. Hazardous Waste Disposal 31
10.1 Hazardous Biological Waste 32
10.2 Chemical Waste 32
10.3 Radioactive Waste 33
11. Safety Training and Information 33
11.1 General Teaching & Research Employee Training 33
11.2 Specific Teaching & Research Employee Training 34
11.3 Information Teaching & Research Employees 35
12. Working Autonomously 35
12.1 Working Autonomously 35
13. Working Unsupervised 36
13.1 Working Unsupervised 36
14. Equipment Operation 37
15. Emergency Situations and Evacuations 37
15.1 Non-life Threatening Accidents 37
15.11 Non-chemical Burns 37
15.12 Cuts 38
15.13 Chemical Burns Eyes 38
15.14 Chemical Burns Skin < 10 % 38
15.15 Chemical Burns Skin > 10 % 38
15.2 Life Threatening Accidents or Situations 39
15.3 Small Chemical Spills 39
15.4 Large Chemical Spills 39
15.5 Natural Disasters or Building Evacuations 39
LIST OF ABBREVIATIONS
1. Chemical Hygiene Plan (CHP)
2. Safety First Approach (SFA)
3. Personal Protective Equipment (PPE)
4. University of Alaska Anchorage (UAA)
5. Environmental Health Safety & Risk Management Support (EHS / RMS)
6. Occupational Safety and Health Administration (OSHA)
7. Standard Operating Procedures (SOPs)
8. Environmental Protection Agency (EPA)
9. Drug Enforcement Agency (DEA)
10. Dept. of Homeland Security (DHS)
11. Dept. of Environmental Conservation (DEC)
12. Municipality of Anchorage (MOA)
13. Centers for Disease Control (CDC)
14. National Institute of Health (NIH)
15. Nuclear Regulatory Commission (NRC)
16. Principal Investigators (PIs)
17. Research Lab Supervisors (RLS)
18. Material Safety Data Sheet (MSDS)
19. Particularly Hazardous Chemicals (PHC)
20. American Conference of Governmental Hygienists (ACGIH)
21.
1. PURPOSE
The Chemical Hygiene Plan (CHP) for the University of Alaska Anchorage provides written guidelines as required by law and for the establishment of a Safety First Approach (SFA). The SFA will encourage and support the use of ‘Standard and Prudent Practices’ in all teaching and research laboratories that use chemicals on a laboratory scale in accordance with definitions provided in the OSHA Laboratory Safety Standard. The SFA warrants the use of personal protective equipment (PPE), and safe and prudent practices in the handling, storage and disposal of chemicals. In addition, the SFA will include the appropriate use of all scientific equipment in teaching and research laboratories. The SFA should help to minimize exposure risks by protecting employees and students from potential health hazards resulting from the use of hazardous chemicals or while performing hazardous procedures while pursuing their education at UAA.
The CHP is designed to meet the requirements outlined in the U.S. Department of Labor, Occupational Safety and Health Administration, 29 CFR Part 1910.1450. This plan complies with any additional requirements outlined in Occupational Exposures to Hazardous Chemicals in Laboratories as adopted by the State of Alaska. These sets of regulations are commonly known as the ‘Laboratory Standard.’
2. SCOPE
2.1 Employees
The CHP covers all employees who use or are exposed to hazardous chemicals in teaching and research laboratories at UAA under the Laboratory Standard regulations. Current University policy is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section, statement #3 at: http://ehsrms.uaa.alaska.edu/TOCPolicies.htm
Non-laboratory, (custodial, electricians, etc.), employees are covered under the OSHA Hazard Communications requirements. Current University policy is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section, statement #2 at: http://ehsrms.uaa.alaska.edu/TOCPolicies.htm
2.2 Students
The coverage of students under the Laboratory Standard is not required by law; however, by establishing an SFA the university can voluntarily extend applications to students who often end up as employees or student researchers.
3. EXCLUSIONS
The CHP does not directly cover work with radioactive materials or infectious, medical, pathological (animal or animal carcasses), recombinant DNA, and all other types of biological agent wastes. These materials will be addressed by the Radiation Safety Committee and the Biological Safety Committee and those policies will be added to this CHP in the appendices.
4. UNIVERSITY RESPONSIBILITIES
4.1 President
The university president has the legal responsibility for the development and enforcement of the university CHP, program-specific lab Standard Operating Procedures (SOPs) and research-specific SOPs. The president provides support for the Chemical, Biological and Radiation Safety Committees for the administration and development of the university-wide CHP and program specific lab SOPs.
4.2 Safety Committees
Current University policy for the establishment and rules governing safety committees is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section, statement #1 at: http://ehsrms.uaa.alaska.edu/TOCPolicies.htm
4.21 Chemical Safety Committee
The Chemical Safety Committee has the delegated responsibility of developing the university CHP related to the use of hazardous chemicals on a laboratory scale and promoting the adoption of a SFA in all policies. This committee has the responsibility of reviewing and updating the CHP annually, or as changes in Environmental Protection Agency (EPA), Drug Enforcement Agency (DEA), Department of Homeland Security (DHS), Department of Environmental Conservation (DEC), or Municipality of Anchorage (MOA) regulations require.
4.22 Biological Safety Committee
The Biological Safety Committee has the delegated responsibility of developing general and lab protocol-specific SOPs with regard to the handling, use and disposal of infectious, medical, pathological (animal or animal carcasses), recombinant DNA, and all other types of biological agent wastes, and promoting the adoption of a SFA in all biological policies. This committee has the responsibility of reviewing and updating the biological program specific lab SOPs annually, or as changes in Centers for Disease Control (CDC) or National Institute of Health (NIH) regulations require.
. 4.23 Radiation Safety Committee
The Radiation Safety committee has the delegated responsibility of developing general and lab protocol-specific SOPs with regard to the procurement, handling, use and disposal of all radio nuclides, and compounds possessing radio nuclides, and promoting the SFA to all adopted radiation policies. This committee has the responsibility of reviewing and updating the radiation lab specific SOPs annually, or as Nuclear Regulatory Commission (NRC) regulations require.
4.3 Research Proposal Reviews
4.31 Student Research Proposal Review
The Student Research Review Committee has the delegated responsibility of reviewing all under graduate / graduate student research grants / proposals. This committee ensures that each proposal has a complete SOP outlining chemical usage, methodology, waste generation, and disposal for all research projects prior to the ordering of any chemicals.
4.32 Faculty Research Proposal Review
The Faculty Research Review Committee has the delegated responsibility of reviewing all Faculty research grants / proposals. This committee ensures that each proposal has a complete SOP outlining chemical usage, methodology, waste generation, and disposal for all research projects prior to the ordering of any chemicals. Current University policy is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section, statement #23 at: http://ehsrms.uaa.alaska.edu/TOCPolicies.htm
4.4 Environmental Health Safety Risk Management Support (EHS / RMS)
The EHS / RMS department is responsible for compliance assurance of EPA, DHS, DEA, CDC, NIH, DEC, OSHA, NRC and MOA regulations and policies. Department Heads, Deans and Directors are responsible for enforcement of regulations and policies. The department reviews research SOPs to ensure that appropriate risk / hazard assessments are completed. EHS / RMS assists and advises departments, committees, instructors, and researchers with selection of appropriate PPE, evaluation of the suitability of facilities for performing projects, approving waste generation plans and disposition of approved waste streams. The Chemical Hygiene Officer and Radiation Safety Officer facilitate EHS / RMS in carrying out departmental duties. EHS / RMS authority is vested through Department Heads, Deans and Directors except in cases of imminent threats to life, limb and property when it may become impractical or impossible to consult with normal administrative chains of command in a timely manner.
EHS / RMS will serve on the chemical, biological and radiation safety committees in an ex-officio capacity to provide advice and to assist with identifying physical and training resources as well as to review issues for regulatory compliance.
4.5 Department Chairs
The Department Chairs and / or Lab Coordinators of each department are responsible for development and enforcement (through department chairs) of program-specific lab SOPs for teaching labs at the department level. The Department Chairs are responsible for compliance and enforcement of all EPA, DHS, DEA, CDC, NIH, DEC, and MOA regulations and policies applicable to each department.
4.6 Principle Investigators (PI) / Research Lab Supervisors (RLS)
The PI is responsible for the health and safety of all persons working in their research laboratory. The PI may delegate safety duties to a RLS. Responsibilities for ensuring that any delegated duties are carried out remain with the PI. Additional responsibilities of the PI / RLS are as follows:
1. Implementing and enforcing a SFA for activities in their laboratory by applying all applicable standard and prudent safety practices.
2. Establishment of general and protocol-specific SOPs for all hazardous activities in their lab.
3. Safety training of all laboratory personnel working with hazardous chemicals / procedures, and operation of potentially dangerous equipment. Written records of safety trainings must be kept on file for a period of five years.
4. Maintaining an online-chemical inventory for their laboratory.
5. Providing laboratory personnel access to the UAA CHP, protocol-specific SOPs, and all other prudent safety information, including reference materials and MSDS sheets.
6. Providing necessary and appropriate PPE to all laboratory personnel working in their lab. (ANSI Z87.1-2003 approved goggles, non-permeable gloves etc.). Providing additional recommended PPE by EHS / RMS for specific hazards / risks related to their individual research projects.
7. Reporting malfunctioning facilities equipment (eye washes, fume hoods, leaking sinks, light bulb replacement etc.) to appropriate personnel for scheduling repairs or testing as needed in a timely manner.
8. Reporting all accidents or injuries to appropriate personnel and EHS / RMS immediately. Accident forms must be filled out and sent to EHS / RMS within 48 hours.
9. Compliance and enforcement of all EPA, DHS, DEA, CDC, NIH, DEC, and MOA regulations and policies pertaining to lab waste disposal.
10. Correct all deficiencies in a timely manner after a lab inspection by EHS / RMS and other internal or external inspection or audit groups.
11. Inform non-laboratory personnel of any lab-specific hazards prior to working on or repairing any building facilities, (electrical, plumbing etc.) or specialized equipment (refrigerators, freezers etc.). Any identified hazard should be minimized to provide a safe working environment for non-laboratory personnel.
12. Consult EHS / RMS when ordering and using any chemical in the following categories: restricted, particularly-hazardous chemicals, carcinogens, acutely-toxic chemicals, p-listed chemicals, highly reactive chemicals or controlled substances.
13. Consult EHS / RMS for special safety precautions needed when changing or scaling up experimental procedures which increase the risks / hazards to laboratory personnel.
4.7 Employees
Employees are responsible for participating in department-specific safety trainings annually. Employees should be aware of the health and safety hazards presented by the chemicals and equipment they are working with, or may come in contact with in the laboratory. All accidents or injuries should be reported to the appropriate personnel immediately.
4.8 Students
Students should observe and practice all safety procedures outlined in the UAA CHP, and any teaching or research lab-specific SOPs. Students should be aware of the health and safety hazards presented by the chemicals and equipment they are working with, or may come in contact with in the laboratory. All accidents or injuries should be reported to the appropriate personnel immediately.
5. CLASSIFICATION OF CHEMICAL HAZARDS
Laboratory personnel must have a clear understanding of the associated physical, chemical, and toxicological properties of any chemical they are using or come in contact with. In addition, compressed gases and cryogenic liquids present unique hazards.
5.1 Physical (Contact) Hazards
5.11 Corrosive Chemicals