Chemical Hygiene Plan
| University of Arkansas at Little Rock | |
| Policy Name: Chemical Hygiene Plan | |
| Policy Number: 701.35 | |
| Effective Date: September 1, 2010 | |
Policy:
Introduction
The implementation of this Chemical Hygiene Plan provides employees with the information and training necessary to improve workplace safety and health and to prevent chemical-related injuries and illnesses in our laboratories. This plan will act as a supplement to the UALR Hazard Communication Program and provide more detailed information regarding the methods and practices necessary from the hazards associated with using chemicals at UALR.
OSHA standard 29 CFR 1910.1450, the Occupational Exposure to Hazardous Chemicals in Laboratories standard, requires a written Chemical Hygiene Plan. This document will serve as the Chemical Hygiene Plan for the University of Arkansas at Little Rock.
1.0 Chemical Hygiene Plan
1.1 ORGANIZATION OF PLAN
The Chemical Hygiene Plan (CHP) consists of the following elements, which are outlined in greater detail below:
• Standard operating procedures
• Employer criteria for control measures
• Fume hoods and other protective equipment
• Employee information and training
• Prior approval circumstances
• Medical consultation and medical examinations
• Designation of responsible personnel
• Employee protection provisions for particularly hazardous substances
1.2 RESPONSIBILITIES
The Assistant Director of Environmental Health and Safety (EHS) (also the Chemical Hygiene Officer- CHO) has been assigned the responsibility for implementing our Chemical Hygiene Plan. The CHO and Environmental Health and Safety Committee will review the CHP annually and update it as necessary. Copies of the written program may be obtained from the CHO at Facilities Management or online at http://ualr.edu/facilities/index.php/home/environmental-health-safety/ .
1.0 Standard Operating Procedures
2.1 UNIFORMITY OF PRACTICE
Uniformity of practice in the laboratory ensures safety and efficiency. Standard Operating Procedures (SOPs) create a standard of practice that is to be followed by ALL Faculty, Staff, and Students working in the laboratory at this University, to ensure the safety of all University personnel. The intent of the SOPs is to assure that work practices and procedures are in place that protect employees from chemical hazards.
The following guidelines represent the MINIMUM safe practices for the handling of hazardous chemicals at this University. Each laboratory MUST develop its own procedures that are more detailed as to their specific situations. In ALL situations individual faculty or staff will be responsible for enforcing safety measures in the laboratories under their supervision. SOPs for common laboratory practices are found in Appendix F. A template for the development of lab-specific SOPs is found in Appendix G.
2.2 SOP GUIDELINES
Accidents and spills:
Eye Contact: Promptly flush eyes with water for at least 15 minutes and seek medical attention.
Ingestion: Follow MSDS recommendations and seek medical attention.
Skin Contact: Promptly flush the affected area with water for at least 15 minutes and remove any contaminated clothing. Follow MSDS recommendations and seek medical attention.
Clean up: Promptly clean up spills, using appropriate protective apparel and equipment, and proper disposal.
Avoidance of “routine” exposure: Develop and encourage safe habits. Avoid unnecessary exposure to chemicals. Do not smell or taste chemicals. Vent apparatus (vacuum pumps, distillation columns, etc.) which may discharge toxic chemicals into local exhaust devices. Inspect gloves and test glove boxes before use. Do not allow release of toxic substances in cold rooms and warm rooms, since these have contained re-circulated atmospheres.
Choice of chemicals: Use only those chemicals for which the quality of the available ventilation system is appropriate. Whenever possible, use the least toxic chemical options.
Eating, smoking, etc.: Eating, drinking, gum chewing, or application of cosmetics in areas where laboratory chemicals are present is prohibited. Wash hands before conducting these activities elsewhere. Do not store, handle, or consume food or beverages in storage areas, refrigerators, glassware or utensils which are also used for laboratory operations.
Equipment and glassware: Use equipment only for its designed purpose. Handle and store laboratory glassware with care to avoid damage; do not use damaged glassware. Shield or wrap glassware used in procedures that have the potential for implosion or explosion. to contain chemicals and fragments.
Exiting: Thoroughly wash areas of exposed skin before leaving the laboratory.
Horseplay: Avoid practical jokes or other behavior, which might confuse, startle or distract another worker.
Mouth suction: Do not use mouth suction for pipetting or starting a siphon.
Personal apparel: Confine long hair and loose clothing to prevent contact with chemicals. Wear fully enclosed shoes at all times in the laboratory. When possible, choose fabrics such as cotton and wool that are not significantly flammable.
Personal housekeeping: Keep the work area clean and uncluttered, with chemicals and equipment being properly labeled and stored; clean up the work area on completion of an operation or at the end of each day.
Personal protection: Assure that all persons, including visitors to where chemicals are stored or handled, wear appropriate eye protection. Wear appropriate gloves when the potential for contact with toxic materials exists; inspect the gloves before each use, wash them before removal, and replace them periodically. Use appropriate respiratory equipment when air contaminant concentrations are not sufficiently restricted by engineering controls, inspecting the respirator before use. Use any other protective and emergency apparel and equipment as appropriate. Remove laboratory coats immediately on significant contamination. Do not wear gloves or lab coats into public areas or hallways.
Planning: Seek information and advice about hazards, plan appropriate protective procedures, and plan positioning of equipment before beginning any new operation.
Unattended operations: Leave lights on, place an appropriate sign on the door, and provide for containment of toxic substances in the event of failure of a utility service (such as cooling water) to an unattended operation.
Use of hood: Use the hood for operations which might result in release of toxic chemical vapors or dust. As a rule of thumb, use a hood or other local ventilation device when working with any appreciably volatile substance with a Threshold Limit Value (TLV) of less than 50 parts per million (ppm). Confirm adequate hood performance before use; keep hood closed at all times except when adjustments within the hood are being made; minimize storage of materials in hoods and do not allow anything to block vents or air flow. Leave the hood “on” when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is “off”.
Use of Vacuum (House System): Most labs are equipped with a house-vacuum system. This is a shared system whereby all connections lead to a central collection tank that is exhausted to the outside. Some building vacuum systems may be designed for chemical/biological usage and others may not. Any chemical or biological materials requiring vacuum processes must be filtered or trapped by using an appropriate means of collecting hazardous vapors and/or particulate prior to the substance entering the vacuum system. Appropriate methods may include the use of cold-traps, kill-traps, aspirators or individual vacuum pumps exhausted through a chemical fume hood.
Principal Investigators are required to develop appropriate SOPs to ensure safe vacuum usage. The Environmental Health and Safety Committee reviews and approves all SOPs.
Vigilance: Be alert to unsafe conditions and see that they are corrected when detected.
Waste disposal: Assure that the plan for each laboratory operation includes plans and training for waste disposal.
Working alone: Avoid working alone in a building; do not work alone in a laboratory if the procedures being conducted are hazardous.
3.0 Employer Criteria for Control Measures
3.1 CRITERIA
As part of the Chemical Hygiene Plan, we have developed criteria for determining and implementing control measures to reduce employee exposure to hazardous chemicals in the laboratory.
The criteria we use include the following:
1) The degree of toxicity of the substances to be used
2) The exposure potential of the chemical procedures to be performed and the capacity of the engineering controls
3) Administrative/work practices and/or protective equipment to control employee exposure effectively.
As part of the Chemical Hygiene Plan, employers must develop criteria for determining and implementing control measures to reduce employee exposure to hazardous chemicals in the laboratory. Traditionally, these measures have included:
4) Engineering: controls general ventilation, fume hoods, glove boxes, and other exhaust systems
5) Work practice: controls items such as restricting eating and drinking areas, prohibiting mouth pipetting, and performing work in such a manner as to minimize exposures to hazardous chemicals and to maximize the effectiveness of the engineering controls
6) Personal protective equipment (PPE): the type of PPE available and how it should be used.
OSHA policy dictates that engineering and work practice controls be used to reduce employee exposure below the PEL (permissible exposure limit).
4.0 Respiratory protection:
4.1 RESPIRATORY PROTECTION
Respiratory protection is to be used only as an interim measure or when engineering or work practice controls are infeasible. Use of respiratory equipment must comply with the requirements of Title 29 CFR 1910.134, which specifies factors such as selection, medical clearance, fit, use, and maintenance. Other personal protective equipment that must be used in laboratories, if appropriate, includes items such as safety glasses, whole body coverings, and gloves. The criteria may be based on the degree of toxicity of the substances to be used, the exposure potential of the chemical procedures to be performed and the capacity of the engineering controls, administrative practices or protective equipment to control employee exposure effectively. Additional requirements must be included in the CHP where appropriate to protect employees working with particularly hazardous chemicals such as select carcinogens, reproductive toxins and chemicals exhibiting a high degree of acute toxicity.
4.2 CONTROL MEASURES:
1) To be determined by specific experimental use and by the type of chemical involved. These must be cleared by the CHO.
2) OSHA policy dictates that engineering and work practice controls be used to reduce employee exposure below the PEL (permissible exposure limit).
3) Respiratory protection is to be used only as an interim measure or when engineering or work practice controls are infeasible.
5.0 Fume Hoods and Other Protective Equipment
5.1 FUME HOODS AND OTHER PROTECTIVE EQUIPMENT
Fume hoods and other protective equipment must function properly at all times. Specific measures are taken to ensure proper and adequate performance of such equipment as listed below.
Specific Measures to Ensure Proper and Adequate Performance
The following are recommended elements of this section. Each laboratory will be responsible for having the appropriate SOP.
1) Hoods: A laboratory hood with 2.5 lf (linear feet) of hood space per person is required when handling chemicals.
2) If a fume hood does not have a continuous monitoring device to verify proper performance, then substances of unknown toxicity must be avoided or other types of local ventilation provided.
3) Other local ventilation devices: Ventilated storage cabinets, canopy hoods, snorkels, etc. are provided as needed by each department. Each canopy hood and snorkel should have a separate exhaust duct. Exceptions to this requirement must be cleared by EHS.
4) Modifications: Any alteration of the ventilation system may be made only if thorough testing indicates that worker protection from airborne toxic substances is adequate.
5) Performance: A rate of 4-12 room air changes/hour is adequate ventilation if local exhaust systems, such as hoods, are used as the primary method of control.
6) Quality: General airflow should not be turbulent and should be relatively uniform throughout the laboratory, with no high velocity or static areas; airflow into and within the hood should not be excessively turbulent; hood face velocity should be 80-120 linear feet per minute (lfm) at any point with an average face velocity of 100 lfm.
7) Evaluation: Quality and quantity of ventilation must be evaluated upon installation, monitored, and reevaluated whenever a change in local ventilation devices is made. EHS will certify that fume hoods meet flow requirements at least annually or as needed.
6.0 Employee Information and Training
6.1 INFORMATION AND TRAINING
UALR provides all persons affected by 29 CFR 1910.1450 with information regarding how to protect themselves when working with hazardous chemicals. This section outlines the training and information in effect at this workplace. Training will be provided to new employees upon hire, if working with a new hazard, and at least annually. The CHO will provide training. Each department will contact the CHO for training dates. The training shall include:
1) The components of the Chemical Hygiene Plan and how it is implemented in the workplace.
2) The hazards of the chemicals in the work area and the protective measures.
3) Specific procedures put into effect by the employer to provide protection, including engineering controls, work practices and PPE.
4) Methods and observations e.g., continuous monitoring procedures, visual appearance, or odors that workers can use to detect the presence of hazardous chemicals.
7.0 Laboratory Approval
7.1 TO OBTAIN APPROVAL
Laboratory activities require prior approval from the CHO and department head.
8.0 Medical Consultations and Examination
8.1 AVAILABILITY
All employees who work with hazardous chemicals will have an opportunity to receive medical attention, including any follow-up examinations, which the examining physician determines to be necessary, under the following circumstances:
1) Whenever an employee develops 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 or PEL for a regulated substance for which there are exposure monitoring and medical surveillance requirements.
3) Whenever a spill, leak or other incident results in the likelihood of a hazardous exposure.
8.2 ARRANGING FOR EXAMS
All medical examinations and consultations shall be coordinated through Health Services. In the event of a life-threatening illness or injury, dial 911, and request an ambulance.
9.0 Designation of Responsible Personnel
9.1 CHEMICAL HYGIENE OFFICER
The CHO is qualified by training and/or experience to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan required by OSHA 1910.1450 Laboratory Standard.
10.0 Employee Protection Provisions
10.1 PROTECTION PROVISION FOR PARTICULARLY HAZARDOUS SUBSTANCES
To protect employees when working with select carcinogens, reproductive toxins, and/or substances having a high degree of acute toxicity, there are special provisions in place, including designated work areas, special containment devices in those work areas, decontamination procedures, waste removal procedures, and specific safe operating procedures. These special provisions will be determined by the department head and the CHO after receipt of the required forms (see appendices).
10.2 WORKING WITH ALLERGENS AND EMBRYOTOXINS .
1) Allergens and Sensitizers (examples: diazomethane, isocyanates, bichromates): Wear suitable gloves to prevent hand contact with allergens or substances of unknown allergenic activity.
2) Embryotoxins (examples: organomercurials, lead compounds, formamide): Women of childbearing age must only handle these substances in a hood whose satisfactory performance has been confirmed and use appropriate protective apparel (especially gloves) to prevent skin contact. Review uses annually or whenever a procedural change is made.
10.3 WORK WITH CHEMICALS OF MODERATE, CHRONIC OR HIGHLY ACUTE TOXICITY.
1) Examples: Diisopropylfluorophosphate, hydrofluoric acid, hydrogen cyanide.
2) Location: Use and store these substances only in areas of restricted access with special warning signs.
3) Always use a hood or other containment device for procedures which may result in the generation of aerosols or vapors containing the substance; trap released vapors to prevent their discharge with the hood exhaust.
4) Personal protection: Avoid skin contact by use of gloves and long sleeves and other protective apparel as appropriate. Wash hands and arms immediately after working with these materials.
5) Records: Maintain records of the amounts of these materials on hand, amounts used, and the names of the workers involved. The records will be maintained according to state and federal guidelines.
6) Prevention of spills and accidents: Be prepared for accidents and spills. Assure that at least 2 people are present at all times if a compound in use is highly toxic or of unknown toxicity. Store breakable containers of these substances in chemically resistant trays; also work and mount apparatus above such trays or cover work and storage surfaces with removable, absorbent, plastic-backed paper. If a major spill occurs outside the hood, evacuate the area; assure that cleanup personnel wear suitable protective apparel and equipment.
7) Waste: Thoroughly decontaminate or incinerate contaminated clothing or shoes. If possible, chemically decontaminate by chemical conversion. Store contaminated waste in closed, suitably labeled, impervious containers (for liquids, in glass or plastic bottles half-filled with vermiculite.
10.4 WORK WITH CHEMICALS OF HIGHLY CHRONIC TOXICITY.
1) Examples: dimethylmercury and nickel carbonyl, benzo-a-pyrene, N-nitrosodiethylamine, other human carcinogens or substances with high carcinogenic potency in animals.)
2) Access: Conduct all transfers and work with these substances in a controlled area: a restricted access hood, glove box, or portion of a lab designated for use of highly toxic substances, for which all people with access are aware of the substances being used and necessary precautions.
3) Approvals: Prepare a written safe operating procedure for use and disposal of these materials and obtain the approval of the laboratory supervisor.
4) Non-contamination/Decontamination: Protect vacuum pumps against contamination by scrubbers or HEPA filters and vent them into the hood. Decontaminate vacuum pumps or other contaminated equipment, including glassware, in the hood before removing them from the controlled area. Decontaminate the controlled area before normal work is resumed.
5) Exiting: On leaving a controlled area, remove any protective apparel (placing it in an appropriate labeled container) and thoroughly wash hands, forearms, face, and neck.
6) Housekeeping: Use a wet mop or a vacuum cleaner equipped with a HEPA filter instead of dry sweeping if the toxic substance is a dry powder.
7) Medical Surveillance: If using toxicologically significant quantities on a regular basis (e.g., 3 times per week), consult a qualified physician concerning desirability of regular medical surveillance.
8) Records: Keep accurate records of the amounts of toxic substances stored and used, the dates of use, and names of users.
9) Signs and labels: Assure that the controlled area is conspicuously marked with warning and restricted access signs and that all containers of these substances are appropriately labeled with identity and warning labels.
10) Spills: Assure that contingency plans, equipment, and materials to minimize exposures of people and property in case of accident are available.
11) Storage: Store containers of these chemicals only in a ventilated, limited access area in appropriately labeled, unbreakable, chemically resistant, secondary containers.
12) Glove boxes: For a negative pressure glove box, ventilation rate must be at least two volume changes/hour and pressure at least 0.5 inches of water. For a positive pressure glove box, thoroughly check for leaks before each use. In either case, trap the exit gases or filter them through a HEPA filter and then release them into the hood.
13) Waste: Use chemical decontamination whenever possible; ensure that containers of contaminated waste (including washings from contaminated flasks) are transferred from the controlled area in a secondary container under the supervision of authorized personnel.
10.5 ANIMAL WORK WITH CHEMICALS OF HIGHLY CHRONIC TOXICITY.
1) Access: For large-scale studies, special facilities with restricted access are preferable.
2) Administration of the toxic substance: When possible, administer the substance by injection or gavage instead of in the diet. If administration is in the diet, use a caging system under negative pressure or under laminar air flow directed toward HEPA filters.
3) Aerosol suppression: Devise procedures that minimize formation and dispersal of contaminated aerosols, including those from food, urine, and feces (e.g., use HEPA filtered vacuum equipment for cleaning, moisten contaminated bedding before removal from the cage, mix diets in closed containers in a hood).
4) Personal protection: When working in the animal room, wear plastic or rubber gloves, fully buttoned laboratory coat or jumpsuit and, if needed because of incomplete suppression of aerosols, other apparel and equipment (shoe and head coverings, respirator).
5) Waste disposal: Dispose of contaminated animal tissues and excreta by incineration if the available incinerator can convert the contaminant to non-toxic products; otherwise, package the waste appropriately for burial in an EPA–approved site.
11.0 Recordkeeping
11.1 MAINTAINING SAFETY RECORDS
1) The University maintains records as required by OSHA.
2) Accident reports will be conducted by the CHO with assistance from the lab supervisor as deemed necessary. Accidents reports will be written and maintained for five years. Records will be kept at the CHO office in the Facilities Management building.
3) Any records of exposure evaluation carried out by individual departments will be kept within the department and sent to the CHO office. Raw data will be kept for one year and summary data for the term of employment plus 30 years.
4) Results of medical consultations and examinations will be maintained by Health Services for the term of employment plus 30 years as required by OSHA.
5) Individual employee training records will be kept in the CHO office.
6) Records of inspections of equipment will be maintained for five years. Data on annual fume hood monitoring will be kept in the CHO office. Fume hood monitoring data are considered maintenance records and as such the raw data will be kept for one year and summary data for five years.
12.0 Annual Chemical Hygiene Plan Review
12.1 REVIEW
The CHO and the University EHS Committee will review the University’s Chemical Hygiene Plan annually.
Source: Environmental Health and Safety Committee
Revised: November 24, 2010
Approved By: Environmental Health and Safety
Custodian: Environmental Health and Safety