CHEMICAL HYGIENE PROGRAM
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- 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.
- 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.
- Principal Investigators / Supervisors: Principal Investigators (PIs) and
supervisors have primary responsibility for the safety of the labs under their jurisdiction. These
responsibilities include:
- Establishing chemical hygiene procedures for all laboratories and projects under
their direction.
- 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.
- Informing employees of potential hazards associated with the use of hazardous chemicals.
- 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.
- Selecting and employing engineering controls and laboratory practices to reduce potential
exposure to the lowest practical level in accordance with the CHP.
- Completing a chemical inventory for the laboratory locations under their direction. Updated
chemical inventories must be done at least annually.
- 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.
- Investigating and reporting incidents related to the use of hazardous chemicals.
- 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.
- Providing emergency contact information on the entry to labs and on special equipment.
- 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.
- Laboratory Employees: - Laboratory employee responsibilities include:
- Attending an annual Laboratory Safety Training session.
- Planning and conducting laboratory procedure in accordance with the CHP.
- Developing and practicing good, personal hygiene habits.
- Reporting unsafe conditions to the principal investigator or the Laboratory Safety
Officer.
- Reporting incidents of hazardous chemical exposure to the principal investigator or
the Laboratory Safety Officer.
- 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.
- 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:
- 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.
- Assisting in the development and implementation of chemical hygiene policies and
practices within the PI/supervisor’s allocated spaces.
- Assisting in the procurement, inventory, use, and disposal of chemicals used in the
laboratories in the PI/supervisor’s allocated spaces.
- Assisting employees in developing precautions, written procedures, and adequate
facilities.
- Serving as a liaison between the department and EH&S.
- Seeking ways to improve the CHP.
- 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.
- 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:
- Working with PIs, supervisors, administrators and Laboratory Safety Officers
to develop and implement good chemical hygiene policies and practices.
- Providing general training to employees who work in laboratories.
- Providing additional training materials to assist the Laboratory Safety Officer in lab
specific training efforts.
- Evaluating areas where regulated materials are used regularly and determining when
monitoring of airborne contaminants is necessary.
- Knowing the current legal requirements concerning regulated substances and
disseminating this information to the appropriate personnel.
- 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.
- Seeking ways to improve the CHP.
- Issuing advisories or alerts on laboratory safety issues.
- Providing safety training to Facilities employees in the recognition of contaminated
systems found in laboratories.
- 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.
- Assisting in updating the CHP at least every two (2) years.
- 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:
- Informing laboratory personnel in advance of scheduled utility or
maintenance shutdowns (gas, water, fume hoods, etc.).
- 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.
- 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.
- Informing EH&S when a major change of an air handler system (HVAC) is contemplated
and completed.
- Inspecting safety showers at the frequency specified by EH&S.
- Attending an annual Contaminated Systems training session offered by EH&S.
- EMPLOYEE INFORMATION AND TRAINING
- 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:
- The existence of the CHP and the requirements of OSHA’s Laboratory Standard.
- Control methods (engineering controls, work place practices, administrative controls,
and personal protective equipment) to minimize employee exposure to hazardous chemicals in
the laboratory.
- Signs and symptoms associated with exposure to common hazardous chemicals used in the
laboratory.
- The location and availability of known reference materials within the University -
including MSDSs, information on the hazards, safe handling, and storage of hazardous
chemicals.
- How to read and understand the material found on an MSDS.
- The proper use of emergency equipment and the limitations of PPE and safety equipment.
- Emergency procedures to follow in the event of a fire, exposure, or spill.
- 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).
- 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.
- 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.
- 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).
- Types of Health Hazards
- 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 |
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Phosphorous chloride |
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- 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 |
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Nitrous oxide |
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- Hepatototic agents: Hepatotoxic agents cause damage to the liver. Examples include:
- Carbon tetrachloride
- Nitrosamines
- Tetrachloroethane
- Nephrotoxic agents: Nephrotoxic agents damage the kidneys. Examples include:
- Halogenated hydrocarbons
- Uranium compounds
- 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
- 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
- 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.
- 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.
- 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.
- 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.
- Physical Hazards
- Flammable agents: Flammable agents are any solid, liquid, or gas that will ignite easily
and burn rapidly.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Consultations: Consultations and medical examinations for work-related
illnesses, injury, and exposure are made available under the following circumstances:
- When an employee develops signs or symptoms associated with a hazardous
chemical to which he/she may have been exposed in the laboratory.
- 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.
- 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.
- Pre-placement Assessments: Specific groups of employees receive pre-placement
health assessments and updates through UHS or Occupational and Environmental Medicine.
- 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.
This page last updated 2/17/2006. Disclaimer
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