Environmental Health and Safety (EHS)

Chapter 7: Employee protection from particularly hazardous substances

The OSHA Laboratory Standard requires that certain chemicals be identified as particularly hazardous substances (commonly known as PHSs) and handled using special additional procedures. PHSs include chemicals that are select carcinogens (those strongly implicated as a potential cause of cancer in humans), reproductive toxins, and compounds with a high degree of acute toxicity. A thorough hazard analysis should be conducted before working with any of these substances and the resulting SOP reviewed by the PI, department CHO, safety officer, EHS and/or other qualified individuals as needed.

7.1 The establishment of a designated area or areas that indicate the physical limits of exposure to particularly hazardous substances.

  • A designated area indicating the physical limits of exposure to particularly hazardous substances can be indicated by placing yellow caution tape on the floor, setting up physical barriers, or other clear demarcations. Lab workers can only enter this area if they are appropriately trained and suitably protected against the hazard. The area should be marked with a "danger (specific agent), authorized personnel only," or comparable warning sign.
  • An emergency response plan should be posted near the area.
  • Labs where highly toxic chemicals such as poisonous gases are used may require detection equipment.

7.2 The use of containment devices, such as laboratory-type hoods or glove boxes.

  • Work with carcinogens, reproductive toxins, and acutely toxic chemicals should be performed within a functioning hood, glove box, sealed system, or other containment device designed to minimize exposure to these substances. The exhaust air from the ventilation systems may require scrubbing before being released into the atmosphere. In all cases, work with these types of chemicals must be done in such a manner that ensures MIOSHA Permissible Exposure Limits or similar consensus standards for that substance are not exceeded.
  • The ventilation efficiency of the containment device, and the operational effectiveness of mechanical and electrical equipment used to contain or manipulate these special substances, should be evaluated according to manufacturer’s recommendation and the recommendations of applicable regulatory agencies. This should be done periodically by the laboratory personnel at intervals determined by the PI.
  • Compressed gas cylinders that contain acutely toxic chemicals should be kept in ventilated gas cabinets.

7.3 Procedures for the safe removal of contaminated waste.

EHS must be consulted prior to beginning work with any particularly hazard substance and a plan developed for handling the waste generated by the work. Hazardous waste cannot be commingled with non-hazardous waste. PI's must assure that all waste disposal follows the University Hazardous Waste Disposal Procedures.

7.4 Housekeeping, decontamination, and chemical spills.

  • All work surfaces and equipment must be immediately cleaned and decontaminated after completion of procedures involving the use of PHS, and other hazardous chemicals and materials. 
  • All equipment used with PHS and other hazardous chemicals and materials must be cleaned and decontaminated prior to repair, service or decommissioning. 
  • The procedure for cleanup and decontamination following chemical spills should be documented in operational SOPs for each chemical used in the laboratory. 
  • Chemical laboratories must be maintained in a clean and orderly manner to minimize the chances of accidental exposure to hazardous chemicals.

Chapter 8