University of Rochester
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CHEMICAL HYGIENE PROGRAM



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  1. GENERAL PRINCIPLES

    The Chemical Hygiene Program (CHP) is written to comply with the Occupational Safety and Health Administration (OSHA) regulation set forth in 29 CFR 1910.1450, the Occupational Exposure to Hazardous Chemicals in Laboratories.  This regulation mandates a program of practices, procedures, and policies designed to protect employees that use hazardous chemicals in a laboratory setting.  These hazardous chemicals include not only those regulated in 29 CFR 1910, Subpart Z, but also any chemical meeting the definition of a hazardous chemical with respect to physical and health hazards as defined in OSHA's Hazard Communication Standard, 29 CFR 1910.1200.

    The CHP applies to all laboratories of the University of Rochester.  The purpose of the CHP is to provide the chemical user with basic safety information regarding the use of chemicals in laboratories.  Although a number of chemicals are mentioned in this plan, they are not the only chemicals that may be present.  They serve to illustrate hazards that may be present.  This plan also presents information on the safe storage, use, and disposal of chemicals in laboratories.

    It is the policy of the University of Rochester to provide an environment free from recognized hazards that could cause injury or illness.  To this end, employees may not be exposed at or above the Permissible Exposure Limits (PEL) of OSHA or the Threshold Limit Values (TLV) of the American Conference of Governmental Industrial Hygienists.

    Working with any chemical involves a degree of risk.  Even though a chemical may not be considered hazardous by today's standard, all employees are advised to minimize their exposure to chemicals by using established safe practices.  Three main categories exist to control exposure.  They include engineering controls, work practices, administrative controls, and personal protective equipment (PPE).

    Engineering controls, the preferred method of reducing exposure, should be used whenever the chemical hazard information on the chemical label or the material safety data sheet (MSDS) indicates "use local exhaust."  Examples of engineering controls include fume hoods, canopy hoods, slot hoods, and glove boxes.

    Work practices and administrative controls are another method in reducing employee exposure after the use of engineering controls.  MSDS and chemical labels should be reviewed for specific work practice instructions.  Additional work practices and administrative controls include items such as not working alone and compiling specific experimental protocols that include safe work practices, as listed in the appendices of this document.

    PPE should be used in addition to, but not as a substitute for engineering controls and work practices to reduce exposure.  PPE may consist of respiratory protection, eye protection, face protection, gloves, hearing protection, or protective clothing.  MSDS and chemical labels contain specific information on the PPE needed.  When PPE is selected, its use shall be in accordance with OSHA standard 29 CRF 1910 subpart I, sections 132-134, and in consultation with the Industrial Hygiene Unit of Environmental Health & Safety  (EH&S).

    The CHP is a continually evolving program.  The CHP can be modified by the approval of the University Chemical Hygiene Officer and the Director of Environmental Health and Safety, with the input from the Laboratory Safety Officers.  Updated copies of this document are available through the Industrial Hygiene Unit of EH&S.  Electronic copies of the CHP are available through the EH&S’s web pages.


  2. RESPONSIBILITY

    Responsibility for implementing the CHP resides with each department having laboratories.  EH&S was given the responsibility to develop the written CHP plan, implement the Program, and act as the University Chemical Hygiene Officer (UCHO).  Those departments that have labs also share in the responsibility.

    1. Principal Investigators / Supervisors:  Principal Investigators (PIs) and supervisors have primary responsibility for the safety of the labs under their jurisdiction.  These responsibilities include:

      1. Establishing chemical hygiene procedures for all laboratories and projects under their direction.
      2. Appointing a Laboratory Safety Officer to oversee safety issues of the assigned spaces and activities under his/her direction.  Some departments may wish to designate a single individual as the Laboratory Safety Officer for the entire department.  Such a selection must be endorsed by the department chair and reported to EH&S.
      3. Informing employees of potential hazards associated with the use of hazardous chemicals.
      4. Directing laboratory employees to attend an EH&S Laboratory Safety Training session and providing specific training for all lab employees using hazardous chemicals in their labs.
      5. Selecting and employing engineering controls and laboratory practices to reduce potential exposure to the lowest practical level in accordance with the CHP.
      6. Completing a chemical inventory for the laboratory locations under their direction. Updated chemical inventories must be done at least annually.
      7. Completing a Job Hazard Assessment (JHA) for the employees under their direction to determine the personal protective equipment (PPE) needed.  The JHA is available on EH&S’s web site.
      8. Investigating and reporting incidents related to the use of hazardous chemicals.
      9. Selecting chemicals, making arrangements through EH&S for monitoring the use of chemicals, disposing of hazardous chemical wastes, and maintaining a record of chemicals posing a high chronic toxicity for all personnel under their direction.
      10. Providing emergency contact information on the entry to labs and on special equipment.
      11. Ensuring that proper decommissioning is performed on equipment to be serviced and when leaving a particular lab space.  Specific responsibilities for lab decommissioning are listed at http://www.safety.rochester.edu/ih/labdecommission.html.


    2. Laboratory Employees: - Laboratory employee responsibilities include:

      1. Attending an annual Laboratory Safety Training session.
      2. Planning and conducting laboratory procedure in accordance with the CHP.
      3. Developing and practicing good, personal hygiene habits.
      4. Reporting unsafe conditions to the principal investigator or the Laboratory Safety Officer.
      5. Reporting incidents of hazardous chemical exposure to the principal investigator or the Laboratory Safety Officer.
      6. Ensuring hazardous waste is collected at the point of generation and handled in accordance with protocols issued by the University’s Hazardous Waste Management Unit.


    3. Laboratory Safety Officers - Laboratory Safety Officers will assist the PI/Supervisor in maintaining a high level of safety in their lab spaces.  The Laboratory Safety Officers responsibilities include:

      1. Informing employees of the time/location of EH&S Laboratory Safety Training sessions. This information is available at http://www.safety.rochester.edu/ih/ihlabhome.html.
      2. Assisting in the development and implementation of chemical hygiene policies and practices within the PI/supervisor’s allocated spaces.
      3. Assisting in the procurement, inventory, use, and disposal of chemicals used in the laboratories in the PI/supervisor’s allocated spaces.
      4. Assisting employees in developing precautions, written procedures, and adequate facilities.
      5. Serving as a liaison between the department and EH&S.
      6. Seeking ways to improve the CHP.


    4. Deans, Administrators, and Department Heads: - Deans, administrators, and department heads have ultimate responsibility for administration of the University's Safety Policy (Appendix 1), the Reproductive Protection Program (Appendix 2), and the CHP.  The administrators shall assist in maintaining an accurate record of laboratory employees to assist in Lab Safety Training compliance, as listed in Section XI.B.

    5. University Chemical Hygiene Officer: - EH&S will serve in the capacity of University Chemical Hygiene Officer (UCHO).  The Unit's responsibility includes broad oversight in the implementation of the CHP and:

      1. Working with PIs, supervisors, administrators and Laboratory Safety Officers to develop and implement good chemical hygiene policies and practices.
      2. Providing general training to employees who work in laboratories.
      3. Providing additional training materials to assist the Laboratory Safety Officer in lab specific training efforts.
      4. Evaluating areas where regulated materials are used regularly and determining when monitoring of airborne contaminants is necessary.
      5. Knowing the current legal requirements concerning regulated substances and disseminating this information to the appropriate personnel.
      6. Performing periodic safety surveys of laboratories and fume hoods to ensure compliance with the CHP.  The results of the safety surveys will be sent to the PI/Supervisor, the Laboratory Safety Officer, and the Department Chair for corrective action.
      7. Seeking ways to improve the CHP.
      8. Issuing advisories or alerts on laboratory safety issues.
      9. Providing safety training to Facilities employees in the recognition of contaminated systems found in laboratories.
      10. Providing training to Facilities employees on the hazards that may be found in laboratories and actions that they can take to complete their work safely.
      11. Assisting in updating the CHP at least every two (2) years.


    6. Facilities - Facilities personnel have direct control over the laboratory's general and local ventilation systems, and utility system.  Facilities personnel must be informed of the hazards that are present in the laboratory before beginning any work in a laboratory, sanitary waste lines, or the HVAC system.  Facilities responsibilities include:

      1. Informing laboratory personnel in advance of scheduled utility or maintenance shutdowns (gas, water, fume hoods, etc.).
      2. Maintaining local exhaust (fume hoods, slot hoods, ducted biological safety cabinets, etc.) blowers and ducts to provide the engineering controls necessary to maintain safe laboratory conditions.
      3. The internal blowers of biological safety cabinets are NOT to be serviced by Facilities personnel.  Only an outside contractor who has attended special training on the servicing of these units in accordance with the National Sanitation Foundation Standard 49 may work on the internal blowers or filters of these special units.  Activities such as the repair of external electrical outlets, gas outlet repairs, and light bulbs are permitted. Contact EH&S for additional information.
      4. Informing EH&S when a major change of an air handler system (HVAC) is contemplated and completed.
      5. Inspecting safety showers at the frequency specified by EH&S.
      6. Attending an annual Contaminated Systems training session offered by EH&S.


  3. EMPLOYEE INFORMATION AND TRAINING

    1. Required Training and Purpose

      EH&S provides general laboratory safety training to laboratory and Facilities personnel. Live sessions and web-based lab safety training will be utilized in these training efforts. It is the responsibility of the PI/supervisor to have new employees attend the next available training session. This training will include:
      1. The existence of the CHP and the requirements of OSHA’s Laboratory Standard.
      2. Control methods (engineering controls, work place practices, administrative controls, and personal protective equipment) to minimize employee exposure to hazardous chemicals in the laboratory.
      3. Signs and symptoms associated with exposure to common hazardous chemicals used in the laboratory.
      4. The location and availability of known reference materials within the University - including MSDSs, information on the hazards, safe handling, and storage of hazardous chemicals.
      5. How to read and understand the material found on an MSDS.
      6. The proper use of emergency equipment and the limitations of PPE and safety equipment.
      7. Emergency procedures to follow in the event of a fire, exposure, or spill.
      8. Requirements for the collection, storage, emergency response, and disposal of hazardous waste in laboratory locations.

      The PI/supervisor must provide employees with training/orientation for the laboratories under their direction.  This information is to include departmental safety policies and special procedures followed in the employees work location(s).  When a new hazard(s) is/are introduced in the workplace, the PI/supervisor must train the employees to these hazard(s).

    2. Documentation of Training

      Documentation of general training is the responsibility of the EH&S. EH&S issues quarterly training reports to those departments that have laboratories to better track compliance with the annual training requirement.  Site specific and continuing employee training is the responsibility of the PI/Supervisor.  The Industrial Hygiene Unit (IH Unit) of EH&S can provide reference and videotape materials to assist the PI/supervisor and the Laboratory Safety Officer (LSO) in the required site specific training for chemicals or procedures that may introduce a risk to the employees.  The LSO will assist in maintaining departmental training records.

    3. Frequency of Training

      All laboratory employees are required to attend a Laboratory Safety Training session annually. This training is offered through EH&S in live and web-based sessions.  These sessions will include information on the University's Chemical Hygiene Program, the hazards in laboratories, how these hazards may enter and effect the body, how to read a MSDS, the disposal of wastes, and emergency information.


  4. Hazardous Chemicals
    The term “hazardous chemical” refers to a chemical for which there is statistical evidence that acute or chronic health effects may occur in exposed employees, or if it is listed in any of the following:
    • OSHA, 29 CFR 1910 Subpart Z, Toxic and Hazardous Substances;
    • “Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment”, ACGIH (latest edition); or,
    • “The Registry of Toxic Effects of Chemical Substances”, NIOSH (latest edition).


    1. Types of Health Hazards
      1. Irritants:  Irritants are agents that can cause inflammation of the body surface with which they come in contact.  Irritants can also cause changes in the mechanics of respiration and lung function.  Common irritants include:

        Common Skin Irritants

        Common Respiratory Irritants

        Ammonia

        Acetic acid

        Alkaline dusts and mists

        Acrolein

        Hydrogen chloride

        Formaldehyde

        Hydrogen fluoride

        Formic acid

        Halogens

        Halogens

        Nitrogen dioxide

        Sulfur dioxide

        Ozone

        Sulfuric acid

        Phosgene

         

        Phosphorous chloride

         


      2. Asphyxiants:  Ashpyxiants are broken into two groups. Simple asphyxiants deprive the tissue of oxygen.  Chemical asphyxiants render the body incapable of maintaining an adequate oxygen supply.  Examples include:

        Simple Asphyxiants

        Chemical Asphyxiants

        Carbon dioxide

        Carbon monoxide

        Helium

        Cyanides

        Nitrogen

         

        Nitrous oxide

         


      3. Hepatototic agents:  Hepatotoxic agents cause damage to the liver.  Examples include:
        • Carbon tetrachloride
        • Nitrosamines
        • Tetrachloroethane

      4. Nephrotoxic agents: Nephrotoxic agents damage the kidneys.  Examples include:
        • Halogenated hydrocarbons
        • Uranium compounds

      5. Neurotoxic agents: Neurotoxic agents damage the nervous system.  Generally, the nervous system is sensitive to organometallic compounds and sulfide compounds.  Examples include:
        • Carbon disulfide
        • Manganese
        • Methyl mercury
        • Organic phosphorous insecticides
        • Tetraethyl lead
        • Thallium
        • Trialkyl tin compounds

      6. Hematopoietic System Effects: These agents act on the blood.  The blood cells can be directly affected or the bone marrow can be damaged.  Examples include:
        • Analine
        • Benzene
        • Nitrites
        • Nitrobenzene
        • Toluidine

      7. Carcinogens:  A carcinogen is any agent that can initiate or speed the development of malignant or potentially malignant tumors, or malignant neoplastic proliferation of cells.  Select carcinogens are those substances that meets one of the following criteria:
        • It is regulated by OSHA as a carcinogen;
        • It is listed under the category” known to be carcinogens”, as listed in the latest edition of the National Toxicology Program’s  (NTP) “Annual Report of Carcinogens”.
        • It is listed under Group 1, “carcinogenic to humans” by the International Agency for Research on Cancer Monographs (IARC); or,
        • It is listed under Group 2A or 2B by IARC or under the category “reasonably anticipated to be carcinogens” by the NTP, and causes tumors in experimental animals according to any of the following criteria:
          • After inhalation exposures of 6-7 hours per day, 5 days per week, for a significant portion of a lifetime, to doses of less than 10 mg/m3.
          • After repeated skin application of 300 mg/kg of body weight per week; or,
          • After oral doses of less than 50 mg/kg of body weight per day.

        Lists of carcinogens are listed in the appendix of this document.

      8. Reproductive hazard: Reproductive hazards are those chemicals that affect the reproductive capabilities including chromosomal damage (mutagens) and effects on the fetus (teratogens).  Such a chemical affects the chromosome chains of the exposed cells.  The change becomes part of the genetic pool passed on to future generations. A teratogen is an agent that interferes with normal embryonic development without damage to the mother or lethal effects on the fetus.  Any effect would not be hereditary.

      9. Sensitizer:  A sensitizer is an agent that causes a majority of the exposed population to develop an allergic reaction in normal tissue after repeated exposures to the chemicals. Reactions can range from mild, such as a rash, to severe, such as anaphylactic shock.

      10. Acutely Toxic Chemicals:  These chemicals are substances falling into the following categories:
        • A chemical that has a median lethal dose (LD50) of 50 mg/kg or less of body weight, when administered to rats weighing 200 to 300 g each;
        • A chemical that has a median lethal dose (LD50) of 2000 mg/kg or less of body weight, when administered by continuous contact for 24 hours to the bare skin of rabbits weighing 200 to 300 g each; or,
        • A chemical that has a median lethal concentration (LC50) in air of 200 ppm by volume or less when administered by continuous inhalation for one hour to rates weighing 200 to 300 g each.

        A list of acutely toxic chemicals is listed in the appendix of this document.

    2. Physical Hazards
      1. Flammable agents:  Flammable agents are any solid, liquid, or gas that will ignite easily and burn rapidly.
        1. Flammable solids can include dusts or fine powders (metallic or organic substances such as cellulose, flour, etc., those that ignite spontaneously at low temperatures (white phosphorous), those in which internal heat is built up by microbial or other degradation activities, or films, fibers, and fabrics of low-ignition point materials.
        2. Flammable liquids are classified by the NFPA and the DOT as those having a flash point less than 100F and a vapor pressure of not over 40 psia at 100F.
        3. Flammable gases are ignited very easily and the flame and heat propagation rate is so great as to resemble an explosion, especially if the gas is confined.  Common examples of flammable gases include hydrogen, carbon monoxide, and acetylene.
      2. Combustible agents:  Combustible solids are those solids that are relatively difficult to ignite and that burn relatively slowly.  Combustible liquids are those liquids that have a flash point greater than 100F.

    3. Special Hazardous Chemical Groupings

      Some locations may use some chemicals for research or clinical purposes that EH&S has developed safe work practices.  These include but are not limited to Antineoplasic Agents, Hydrogen fluoride, formaldehyde, compressed gases, and cryogenic liquids.  Consult the Industrial Hygiene Unit’s web pages at http://www.safety.rochester.edu/ih/ihlabindex.html for these special handling and work practice information sheets.  Standard Operating Procedures (SOPs) for classes of chemicals is provided in Appendix 12 of this document.


  5. MEDICAL CONSULTATION AND EXAMINATIONS

    Medical consultations and examinations are available from University Health Service (UHS).  In the event of a serious injury or after hour emergency, care is available at Strong Memorial Hospital's Emergency Department.  All required medical examinations and consultations are performed by and under the direct supervision of a licensed physician and are provided without cost to the employee.

    1. Consultations: Consultations and medical examinations for work-related illnesses, injury, and exposure are made available under the following circumstances:

      1. When an employee develops signs or symptoms associated with a hazardous chemical to which he/she may have been exposed in the laboratory.
      2. Where exposure monitoring reveals any exposure levels routinely above the OSHA Action Level (AC) or Permissible Exposure Limit (PEL) for which there are exposure monitoring and medical surveillance requirements.
      3. Whenever an unusual event takes place in the work area such as a spill, leak, an explosion, or other occurrence resulting in the likelihood of a hazardous chemical exposure.

      For chemical exposures during working hours of 8 AM to 4:30 PM:  Phone the University Health Service (UHS) Occupational Health Nurse at x5-1164 (or by pager by calling x5-1616 x4153).  Identify yourself, state that a person has been exposed to a chemical (identify the chemical, the extent of the exposure, etc.), what preliminary precautions have been taken, and that the exposed patient is on the way to UHS.  Send with the patient the name of the chemical(s) they were exposed to, and if possible, a copy of the MSDS.

      For chemical exposures occurring at other times or those sustaining serious injuries:  Call x13 (Security) and request a MERT Response.  SMH’s Emergency Department should be utilized for these types of serious injuries.

      For other concerns, call the UHS Occupational Health Program at x5-4955.

    2. Pre-placement Assessments: Specific groups of employees receive pre-placement health assessments and updates through UHS or Occupational and Environmental Medicine.

    3. Special Programs:  Special medical surveillance programs are provided when indicated by a department or unit's unique needs and are available through UHS or Occupational and Environmental Medicine.  The department is to contact the medical care provider for department charges and other information.


QUESTIONS? Contact EH&S at (585) 275-3241 or e-mail EH&S Questions.

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