Introduction to the Chemical Hygiene Plan
Laboratories that meet the MIOSHA definition for laboratory use of hazardous chemicals must have a chemical hygiene plan for minimizing chemical exposures and protecting laboratory workers from the risks associated with the use of hazardous chemicals.
MIOSHA laboratory use of hazardous chemicals - R325.70103(12)
- Chemical manipulations are carried out on a laboratory scale where chemical and reaction containers are designed to be easily and safely manipulated by one person;
- Multiple (more than one) chemical procedures or chemicals are used;
- The procedures involved are not part of a production process, nor in any way simulate a production process;
- Protective laboratory practices and equipment are made available and in common use to minimize the potential for employee exposure to hazardous chemicals.
Departments with laboratories meeting the MIOSHA definition for the use of hazardous chemicals must appoint a chemical hygiene officer. The department chemical hygiene officer shall be qualified by training or experience to provide technical guidance in the development and implementation of the provisions of the chemical hygiene plan. This should include a knowledge of the regulatory requirements for laboratory work as well as chemical safety and related industrial hygiene practices; supervisory experience; knowledge of department-specific chemical operations (inventories, hazards, purchasing and disposal practices, and safety equipment); and good written and verbal communication skills.
The departmental chemical hygiene officer will assist with the implementation and customization of the University’s chemical hygiene plan to meet the needs of individual, departmental laboratories. The resulting laboratory-specific chemical hygiene plan(s) will contain procedures for procurement, storage, use, and disposal of laboratory chemicals as well as the use of emergency equipment, personal protective equipment, engineering controls, and administrative controls for student and employee protection against laboratory hazards. The laboratory-specific chemical hygiene plan must also contain laboratory-specific standard operating procedures, (SOPs) for each chemical procedure. The written laboratory-specific SOPs must include a list of chemicals used, the required personal protective equipment to be used for each procedure, and the safe work practices for each procedure. Spill response and waste disposal procedures should also be addressed in the SOP.
Chemical Hygiene Plan (CHP): the eight essential elements
As recommended by OSHA Laboratory Safety Guidance, the University’s CHP consists of the following eight essential elements:
- Designation of personnel who are responsible for implementing the Chemical Hygiene Plan, including the assignment of a Chemical Hygiene Officer (CHO) and, if appropriate, the establishment of a Chemical Hygiene Committee (See Chapter 1).
- Criteria that the employer will use to determine and implement control measures to reduce employee exposure to hazardous chemicals, including engineering controls, the use of personal protective equipment, and hygiene practices (See Chapter 2).
- A requirement that laboratory-type hoods and other protective equipment are functioning properly and the specific measures that shall be taken to ensure the proper and adequate performance of such equipment (See Chapter 3).
- Provisions for employee information and training as prescribed in R 325.70107 of the MIOSHA Laboratory Standard (See Chapter 4).
- Provisions for medical consultation and medical examinations in accordance with R 325.70108 of the MIOSHA laboratory Standard (See Chapter 5).
- The circumstances under which a particular laboratory operation, procedure, or activity shall require prior approval from the employer or the employer's designee before implementation (See Chapter 6).
- Provisions for additional employee protection for work with particularly hazardous substances, such as select carcinogens, reproductive toxins, and substances that have a high degree of acute or chronic toxicity (See Chapter 7).
- Standard Operating Procedures for laboratory work involving hazardous chemicals (See Chapters 8 and 9).