4.Responsibilities of the University, Employees, Students8
CHEMICAL HYGIENE PLAN
2nd Draft
APRIL21, 2008
by
Maury Riner
TABLE OF CONTENTS
1.Purpose7
2.Scope7
2.1Employees7
2.2Students7
3.Exclusions8
4.Responsibilities of the University, Employees, Students8
4.1President8
4.2Safety Committees8
4.21Chemical Safety Committee8
4.22Biological Safety Committee8
4.23Radiation Safety Committee9
4.3Research Proposal Review9
4.31Student Research Review9
4.32Faculty Research Review9
4.4Environmental Health Safety / Risk Management Support9
4.5Department Chairs10
4.6Principle Investigators (PI) / Research Lab Supervisors (RLS)10
4.7Employees11
4.8Students12
5.Classification of Chemical Hazards12
5.1Physical (Contact) Hazards12
5.11Corrosive Chemicals12
5.12Sensitizing / Irritant Chemicals12
5.2Flammable / Combustible (Fire) Hazards13
5.21Flammable / Combustible Liquids13
5.22Flammable Solids13
5.3Multiple Hazards13
5.31Highly Reactive / Unstable Chemicals13
5.4Particularly Hazardous Chemicals13
5.41 General SOPs14
5.42Highly (Acutely) Toxic Chemicals14
5.43Select Carcinogenic Chemicals14
5.44Reproductive / Developmental Toxins15
5.5Restricted Chemicals15
5.51EPA p-listed Chemicals15
5.52DEA Controlled Chemicals15
5.53DHS Chemicals of Interest16
5.6Cryogenic Liquids16
5.61Cold Burn Hazards16
5.62Asphyxiation Hazards16
5.63Fire and Explosion Hazards16
5.7Cryogenic Liquid SOP16
5.71Required PPE16
5.8Solid Carbon Dioxide (Dry Ice)17
5.81Cold Burn Hazards17
5.82Asphyxiation Hazards17
5.83Flammable Liquid Hazards17
5.9Solid Carbon Dioxide (Dry Ice) SOP17
5.91Required PPE17
5.10Compressed Gases17
5.11Compressed Gas Cylinder SOPs18
6.Reducing Hazardous Chemical Exposures 19
6.1Administrative Controls19
6.11Laboratory Inspections19
6.2Engineering Controls20
6.3Personal Protective Equipment (PPE)21
6.31Choosing PPE21
6.32Using PPE22
7.Laboratory SOPs22
7.1General Teaching Laboratory SOPs22
7.2General Research Laboratory SOPs25
8.Chemical Exposure Assessment and Medical Exams28
8.1Personal Exposure Monitoring28
8.2Frequency of Exposure Monitoring28
8.3Medical Exams28
9.General Chemical SOPs28
9.1Chemical Procurement29
9.2Chemical Inventories29
9.3Chemical Storage and Labeling29
9.4Controlled Substances / P-Listed Chemicals30
9.5Shipment of Chemicals31
10.Hazardous Waste Disposal31
10.1Hazardous Biological Waste32
10.2Chemical Waste32
10.3Radioactive Waste33
11.Safety Training and Information33
11.1General Teaching & Research Employee Training33
11.2Specific Teaching & Research Employee Training34
11.3Information Teaching & Research Employees35
12.Working Autonomously 35
12.1Working Autonomously35
13. Working Unsupervised36
13.1Working Unsupervised36
14.Equipment Operation37
15.Emergency Situations and Evacuations37
15.1Non-life Threatening Accidents37
15.11Non-chemical Burns37
15.12Cuts38
15.13Chemical Burns Eyes38
15.14Chemical Burns Skin < 10 %38
15.15Chemical Burns Skin > 10 %38
15.2Life Threatening Accidents or Situations39
15.3Small Chemical Spills39
15.4Large Chemical Spills39
15.5Natural Disasters or Building Evacuations39
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 HealthAdministration(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 SFAwillencourage and support the use of ‘Standard and Prudent Practices’ in allteaching and research laboratories that use chemicals on a laboratory scale in accordance with definitions provided in the OSHA Laboratory Safety Standard. The SFAwarrants the use of personalprotectiveequipment (PPE), and safeand prudent practices in the handling, storage anddisposal ofchemicals. In addition,the SFAwill include the appropriate use of all scientific equipment inteaching and researchlaboratories. The SFA should help to minimizeexposure risks by protecting employees and students from potential health hazards resulting from the use ofhazardouschemicals 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 inLaboratories as adopted by the State of Alaska. These sets of regulations are commonly known as the ‘Laboratory Standard.’
2.SCOPE
2.1Employees
The CHPcovers allemployeeswho use or are exposed to hazardous chemicals in teaching and researchlaboratories 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:
Non-laboratory, (custodial, electricians, etc.), employees are covered under the OSHA Hazard Communications requirements. Current University policy is outlined in theAdministrative Services Manual, EHS / RMS, policies and procedures section, statement #2 at:
2.2Students
The coverage of students under the Laboratory Standard is not required by law; however, by establishing an SFAthe 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 beaddressed by the Radiation Safety Committee and the Biological Safety Committee andthose policies will be added to this CHP in the appendices.
4.UNIVERSITY RESPONSIBILITIES
4.1President
The university president has the legal responsibility for the development and enforcement of the university CHP, program-specific lab Standard Operating Procedures (SOPs) andresearch-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.
4.2Safety 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:
4.21Chemical Safety Committee
The Chemical Safety Committee has the delegated responsibility of developingthe university CHP related to the use of hazardous chemicals on a laboratory scale and promoting the adoption of aSFAin all policies. This committee has the responsibility ofreviewing 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.
4.22Biological Safety Committee
The Biological Safety Committee has the delegated responsibility of developinggeneral and lab protocol-specific SOPs with regard to the handling, useand 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 SFAin all biological policies. This committee has theresponsibility of reviewing and updatingthe biological program specific lab SOPs annually, or as changes in Centers for Disease Control (CDC) or National Institute of Health (NIH) regulations require.
. 4.23Radiation Safety Committee
The Radiation Safety committee has the delegated responsibility of developing general and labprotocol-specific SOPs with regard to the procurement, handling, useand disposal of all radio nuclides, and compounds possessing radio nuclides, and promotingthe SFA to all adopted radiation policies. This committee has theresponsibility of reviewing and updating the radiation lab specific SOPs annually, or as Nuclear Regulatory Commission (NRC) regulations require.
4.3Research Proposal Reviews
4.31Student Research Proposal Review
The Student Research Review Committee has the delegated responsibility of reviewing all under graduate / graduate student research grants / proposals. Thiscommittee ensures that each proposal has a complete SOP outlining chemical usage, methodology, waste generation, anddisposal forall research projects prior to the ordering of any chemicals.
4.32Faculty 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 Universitypolicy is outlined in theAdministrative Services Manual, EHS / RMS,policies and proceduressection, statement #23 at:
4.4Environmental 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 assessmentsarecompleted. EHS / RMSassists 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.
4.5Department Chairs
The Department Chairs and / or Lab Coordinators of each department are responsible for development and enforcement (through department chairs) of program-specific labSOPs for teaching labs at the department level. The Department Chairs are responsible for complianceand enforcement of all EPA, DHS, DEA, CDC, NIH, DEC, and MOA regulations and policies applicable to each department.
4.6Principle 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 prudentsafety practices.
- Establishment of general and protocol-specific SOPs for allhazardousactivities in their lab.
- 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 aperiod of five years.
- Maintaining an online-chemical inventory for their laboratory.
- Providing laboratory personnel access to the UAA CHP, protocol-specific SOPs, and all other prudent safety information, including reference materials and MSDS sheets.
- 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.
- Reporting malfunctioning facilities equipment (eye washes, fume hoods, leaking sinks, light bulb replacement etc.) to appropriate personnel for scheduling repairs or testing asneeded in a timely manner.
- Reporting all accidents or injuries to appropriate personnel andEHS / RMS immediately. Accident forms must be filled out and sent to EHS / RMS within 48 hours.
- Complianceand enforcement of all EPA, DHS, DEA, CDC, NIH, DEC, and MOA regulations and policiespertaining 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 whenchanging or scaling upexperimental procedures which increase the risks / hazards to laboratory personnel.
4.7Employees
Employees are responsible for participating in department-specific safety trainings annually. Employees should be aware of the healthand 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 appropriatepersonnel immediately.
4.8Students
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.
5.1Physical (Contact) Hazards
5.11Corrosive Chemicals
Corrosive chemicals are those that chemically react with living tissue at the point of contact causing destruction and irreversible alterations resulting in permanent damage or scarring. This is most common in the case of skin exposure (visible), but can occur in the respiratory tract (invisible) due to inhalation of corrosive fumes.
5.12Sensitizing / Irritant Chemicals
Sensitizers are those chemicals that cause an allergic response in individuals upon repeated exposure usually by skin contact. This allergic response can be delayed and not be apparent until after a number of repeated exposures.
Irritants are those chemicals when in contact with the skin cause reversible effects at the site such as itching, redness or an inflammatory response.
5.2Flammable / Combustible (Fire) Hazards
5.21Flammable / Combustible Liquids
Substances that readily burn in air are considered flammable. Flammable / combustible liquids are classified according to their flash points. The degree of flammability depends on various factors including flashpoint, boiling point, vapor pressure, fuel-to-air ratios and the available ignition source. Current University policy is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section, statement #35 at:
5.22Flammable Solids
Substances that may cause a fire through friction,spontaneously ignite upon contact with air, (pyrophoric)and / or self heat to a temperature that supports spontaneous combustion are classified as flammable solids. This includes chemicals labeled ‘Dangerous when Wet.’
5.3Multiple Hazards
5.31Highly Reactive / Unstable Chemicals
Substances that under the right conditions may polymerize, decompose violently or react violently upon contact with another chemical or substance are classified as highly reactive or unstable. These types of chemicals may also react violently under conditions of shock, pressure,temperature, light and other energy sources.
5.4Particularly Hazardous Chemicals (PHC)
High risk materials defined as: highly toxic, select carcinogens, or reproductive toxins are classified as particularly hazardous substances and require additional provisions to ensure employee and student safety when working with these types of chemicals.To ensure the safety and minimize the risks associated with theusage, storage, handling and disposal of PHC and carcinogenic chemicals thefollowing standard and prudent practices outlined below are required. Where warranted, the use of special PPE, techniques or protocols will beaddressed in the lab specific SOPs.
5.41General SOPs
1.Use only the minimum amount of chemical needed for the procedure.
2.Perform all work in a fume hood, glove box, or a designated area when performing the following operations
2.1Volatilizing or dissolving PHCs.
2.2Any manipulation that produces aerosols or fines.
2.3Weighing out PHCs using the tare method with a sealed container.
2.4Use hepa filters, carbon filters or scrubber systems with containment devices to protect effluent and vacuum lines / vacuum pumps.
2.5Decontaminate the area if necessary when done.
2.6Report all exposures of carcinogenic materials immediately.
5.42Highly (Acutely) Toxic Chemicals
Substances that are acutely toxic fall into the exposure values listed:
1.OralLD50 values from 5 50 mg / kg of body weight forhumans.
2.Skin contact < 200 mg / kg body weight.
3.Inhalation LC50< 200 ppm for 1 hr, and inhalation LC50< 2,000 mg / m3for 1 hr, or has OSHA defined permissible exposure limits and thresholdlimit value of 50 ppm used by the American Conference of Governmental Hygienists (ACGIH).
5.43Select Carcinogenic Chemicals
Substances that meet one of the following criteria are regulated by OSHA as carcinogens:
- Listed as a known carcinogen by the National ToxicologyProgram (NTP).
- Listed under groups 1, carcinogenic to humans, 2A, probably carcinogenic to humans, 2B, possibly carcinogenic to humans.
- Listed as reasonably anticipated to be a carcinogen to humans is classified asa select carcinogen.
Current University policy is outlined in the Administrative Services Manual, EHS / RMS, policies and procedures section statement #16 at: See the current list of carcinogenic chemicals at:
5.44.Reproductive / Developmental Toxins
Substances that cause chromosomal damage (mutagens) and are lethal or cause malformations in fetuses (teratogens) both fall under reproductive / developmental toxins as defined by OSHA.
5.5Restricted Chemicals
Chemicals that fall under the restricted category are all p-listed chemicals, controlled substances and other chemicals that require very specialized safety / hazard assessments to ensure safety to employees and students when used. All chemicals that fall in this category must be approved by EHS / RMS prior topurchase.
5.51EPA P-Listed Chemicals
Those chemicals defined by the EPA as acutely hazardous substances.See the current p-listed chemical list at:
5.52DEA Controlled Substances
Those chemicals listed by the DEA as chemicals that are used in the illegal manufacture of controlled substances (drugs).See the current DEA list at:
5.53DHS Chemicals of Interest
Those chemicals listed by the DHS as chemicals of interest that are used in terrorist activities by internal or external groups. See the current DHS list at:
5.6Cryogenic Liquids
Cryogens are liquefied gases with a boiling point of 110K (-160 °C). The two most common cryogenic liquids are nitrogen and helium. These compounds have additional hazards and require additional safety precautions as outlined below.
5.61Cold Burn Hazards
Skin contact with cryogenic liquids or non-insulated equipment (metallic) parts can cause frostbite or cold burns. Eye contact with cryogenic liquids can cause permanent eye damage.
5.62Asphyxiation Hazards
When large amounts of a cryogen are spilled or are released by failure of a large Dewar, asphyxiation can result due to oxygen deficiency which is undetectable in an unventilated or enclosed room. Thevolumetric expansion rate from the liquid to gaseous phaseranges from 690 – 750 times. Dewars containing liquid nitrogen cannot to be stored or used in any cold room.
5.63Fire and Explosion Hazards
Liquid nitrogen and liquid helium are not flammable; however, they are capable of condensing liquid oxygen out of the air creating an oxygen rich environment which could ignite anyflammable materials in the immediate area.