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).
Chapter 1: Purpose and Individual Chemical Hygiene Responsibilities
The Michigan Technological University Chemical Hygiene Plan (CHP) establishes a formal written program for protecting laboratory researchers against health and safety hazards associated with exposure to hazardous chemicals, as required by the Michigan Occupational Safety and Health Administration (MIOSHA) Laboratory Standard.
Safety is an integral part of laboratory research. The risks associated with laboratory research (e.g. injuries, chemical spills/exposures, environmental incidents, property loss/damage) are greatly reduced or eliminated when proper precautions and practices are observed in the laboratory. The CHP should be the cornerstone of the laboratory’s chemical safety program to manage and mitigate the risks associated with the use of chemicals in the laboratory. It is intended that this CHP be adapted for use as a laboratory-specific CHP by the addition of laboratory-specific Standard Operating Procedures (SOPs) to Chapter 9 of this document.
This CHP applies to chemical laboratories that use, store, or handle hazardous chemicals as defined by the following four elements from the MIOSHA laboratory standard: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.
This document includes general guidelines on safe practices for common laboratory operations as well as some specific laboratory hazards. In its original form, it does not cover all the hazards that are likely to be encountered in a laboratory. It is the responsibility of the laboratory’s principal investigator/supervisor to complete this chemical hygiene plan by evaluating the specific hazards and risks that are present in the laboratory and then developing standard operating procedures to mitigate those risks. A copy of the completed CHP must be readily available to all personnel working in the laboratory.
1.3 Implementation and responsibilities.
1.3.1 Employee rights and responsibilities
As part of the MIOSHA Laboratory Standard, employees and other personnel who work in laboratories have the right to be informed about the potential hazards of the chemicals in their workplace and to be properly trained to work safely with these substances.
While everyone at Michigan Tech has a role in creating and maintaining a culture of safety, implementation of the chemical hygiene plan is the joint responsibility of Deans, Directors, and Department Chairs. Under their direction, principal investigators, laboratory supervisors, laboratory professionals, student workers, and all others working in chemical laboratories have a responsibility to maintain a safe working environment. This includes but is not limited to:
- staying informed about the chemicals used in the laboratory;
- following safe work practices;
- adhering to standard operating procedures;
- employing effective engineering and administrative controls;
- wearing appropriate personal protective equipment (PPE) required for the safe performance of their work in the laboratory.
1.3.2 Responsibilities of Michigan Tech administration
- Departmental Chairs, Deans, Directors, and the Vice President of Research will ensure that a progressive disciplinary process is enforced for Laboratory Supervisors that do not comply with or adequately enforce the provisions of the Chemical Hygiene Plan (CHP).
- It is the responsibility of the Department Chair to assign the Chemical Hygiene Officer.
- It is recommended that departments also have a safety committee made up of faculty, staff, and graduate students to assist with the implementation of the CHP in departmental laboratories.
1.3.3 Responsibilities of the principal investigator and laboratory supervisor
The laboratory supervisor is the individual that is ultimately responsible for the overall laboratory operation, including the lab safety program and ensuring that the requirements of the CHP are followed by all who work in the lab. For most research laboratories, the Principal Investigator (PI) is the laboratory supervisor. In some cases, the laboratory supervisor may delegate some safety duties to a qualified individual or may hire an individual such as a lab manager or postdoctoral graduate to manage the daily operations of the lab. The laboratory supervisor must:
- ensure that individuals working in the lab receive CHP training before working with hazardous materials and subsequent CHP refresher training (CHP training must be documented);
- ensure that work conducted in the laboratory is in compliance with occupational and environmental health and safety regulations;
- actively enforce all applicable safety procedures and ensure that the CHP is followed by all individuals working in the laboratory, including having a progressive disciplinary process for lab staff members that do not comply with safety rules;
- observe the behavior of staff while working in the laboratory (the presence of the PI/lab supervisor in the research lab indicates a serious approach to safety);
- conduct hazard assessments to identify hazardous conditions or operations in the laboratory and establish SOPs to effectively control or reduce hazards;
- ensure that all laboratory personnel receive appropriate training and have access to Safety Data Sheets for the chemicals that are present in the laboratory;
- ensure documentation of lab-specific training (e.g., PPE training, safety training, training on specific experimental procedures);
- ensure that appropriate PPE (e.g., laboratory coats, gloves, eye protection) and engineering controls (e.g., chemical fume hood, equipment guards, shields, barriers) are made available, in good working order, and being used properly;
- conduct periodic lab inspections and immediately take steps to abate any hazards that may pose a risk to individuals working in the laboratory;
- designate a responsible person to oversee safe operations when the PI/lab supervisor is immediately unavailable or traveling.
1.3.4 Laboratory employee responsibilities
All individuals (e.g., lab technicians, graduate students, undergraduate students, postdoctoral researchers, and visiting scientists) in laboratories that use, handle, or store hazardous chemicals must:
- review and follow the requirements of the CHP;
- follow all verbal and written laboratory safety rules, regulations, and SOPs required for the tasks assigned;
- develop and practice good personal chemical hygiene habits such as keeping work areas clean and uncluttered;
- plan, review, evaluate and understand the hazards of materials and processes in the laboratory prior to conducting work;
- utilize appropriate measures to control hazards, including consistent and proper use of engineering controls, administrative controls, and PPE;
- understand the capabilities and limitations of PPE;
- immediately report all accidents, near misses, and unsafe conditions to the laboratory supervisor;
- complete all required safety training and provide written documentation to the laboratory supervisor;
- inform the laboratory supervisor of any work modifications ordered by a physician as a result of medical conditions, occupational injury, or chemical exposure.
1.3.5 Laboratory safety officer responsibilities
It is highly recommended that each PI/laboratory supervisor designate a member of the laboratory to act as a laboratory safety officer, to assist with managing the daily operations of the lab’s safety program. The laboratory safety officer may be empowered to make decisions on daily operations involving safety and compliance, including the authority to instruct other lab personnel in following all safety procedures (e.g., PPE use, hazardous waste procedures, etc.). This person should be familiar with how the lab operates and have demonstrated lab safety experience (e.g., senior graduate student, postdoc, lab manager).
Laboratory safety officer responsibilities should include:
- providing training to new lab personnel; ensure appropriate training is given and that the training is properly documented;
- enforcing lab safety rules;
- working closely with the departmental Chemical Hygiene Officer and Safety Liaison to ensure the laboratory complies with university safety programs/policies;
- reporting safety issues back to the PI when necessary.
1.3.6 Non-laboratory personnel / support staff responsibilities
Custodians and maintenance staff (support staff) often must enter laboratories to perform routine tasks such as cleaning and equipment maintenance. Support staff members are expected to follow the posted safety rules of each laboratory. Minimum PPE requirements for support staff working in a laboratory are safety glasses, long pants, and closed-toe shoes. If additional PPE is required or if other unique safety requirements must be followed, the laboratory must post a cautionary sign listing entry requirements at the entrance. When support staff will potentially be exposed to hazards for which they have not been previously trained, they must be provided with the necessary training before they begin the task. Custodial and maintenance staff are not responsible for clean-up after chemical or hazardous material spills. At no time shall custodial or maintenance personnel be asked to assist in cleaning up spills of laboratory chemicals.
1.3.7 Departmental chemical hygiene officer responsibilities
The departmental Chemical Hygiene Officer (CHO) is responsible for implementation of the CHP within the department. Working closely with PIs/laboratory supervisors and the university’s chemical safety officer, the departmental CHO must:
- be familiar with the hazards in each laboratory in the department and the safety controls used to minimize risk (engineering controls, administrative controls, and PPE);
- conduct regular laboratory inspections (annual inspections are recommended, but may be more or less frequent depending on hazards present in the laboratory);
- ensure that hazard assessments and SOPs are being prepared and filed within each lab’s CHP;
- help develop and implement appropriate environmental health and safety policies and procedures;
- review and evaluate the effectiveness of the CHP within their department at least annually and update it as appropriate;
- ensure the contents of the CHP are followed;
- report instances of non-compliance with laboratory, departmental and university safety procedures and policies to the department chair and EHS.
1.3.8 Departmental responsibilities
Departments are expected to maintain a current listing of all laboratory personnel, their laboratory room numbers, and related phone numbers. These rooms include laboratories and other types of rooms such as temperature-controlled rooms, storage rooms and storage closets that contain hazardous chemicals). The department office should also know which groups share “common” rooms. This list is mandated by 29 CFR 1910.1450 and also serves as a readily available reference in emergency situations. Additionally, the department chair must designate the primary responsibility for safety and compliance in these common rooms to a specific individual.
1.3.9 Office of Environmental Health and Safety (EHS)
EHS works to ensure the health and safety of the campus community through compliance with all federal and state regulations governing workplace safety and environmental health. Many of these regulations apply directly to laboratory safety, the OSHA/MIOSHA Laboratory Standard in particular. To facilitate compliance with these regulations, EHS manages a variety of services such as safety training, laboratory inspections, access to safety data sheets (MSDSonline), and chemical, biological, and radioactive waste disposal. EHS oversight of laboratory safety follows an established line from the VP of Research to all individuals working in laboratories as well as to others with direct responsibility for safety in laboratories (eg. Deans, Chairs, CHOs, PIs, lab supervisors, etc). More detailed information regarding all of EHS’s resources and services can be found on the EHS website.
1.4 Additional resources
Additional information on safety in chemical laboratories can be found in the following publications.
- Identifying and Evaluating Hazards in Research Laboratories. These are the 2015 guidelines developed by the hazards identification and evaluation task force of the American Chemical society’s (ACS’s) committee on chemical safety.
- Prudent Practices for Handling Hazardous Chemicals in the Laboratory issued by National Research Council and published by National Academy Press.
- Safety in the use of chemicals at work by the International Labour Office in Geneva.
- The National Institute for Occupational Safety and Health (NIOSH) guide to Chemical Hazards published by the CDC.
- ACS publications Safety in Academic Chemistry Laboratories Vol 1Accident prevention for college and university students and Accident prevention for faculty and administrators.
- OSHA Laboratory Safety Guidance
- Hazard Assessment in Research Laboratories
Chapter 2: Hazard Assessment: Determination and Implementation of Control Measures in Research Laboratories
2.1 Hazard assessment in research laboratories
The need for appropriate control measures, when working in the laboratory, are determined by conducting a hazard analysis. A hazard analysis is the process of evaluating procedures in the laboratory, identifying the risks associated with the procedure and employing controls to minimize the risks. Results of the hazard analysis are then used to develop Standard Operating Procedures that define the controls, safe work practices and personal protective equipment (PPE) that are needed to work safely in the laboratory. It is essential to conduct a hazard analysis and create at least a basic SOP prior to working with any hazardous chemical for the first time.
The American Chemical Society (ACS) web page Hazard Assessment in Research Laboratories is an excellent source for information on different ways to identify and evaluate hazards in the laboratory:
Development of an effective SOP requires a comprehensive approach to hazard analysis. In addition to analyzing the hazards associated with each step of the experiment, an SOP must also consider other important aspects such as regulatory concerns, human factors (experience and training), the facility where the experiment will be performed, management of waste materials, emergency response, etc. Because of its comprehensive nature, development of an SOP requires more time and effort but results in a greater appreciation and understanding of the process of identifying potential hazards and mitigating associated risks. The following four methods of hazard analysis can be used as the first step in developing an SOP.
2.1.2 Job Hazard Analysis:
Job Hazard Analysis (JHA) focuses on a specific job or task performed in the laboratory. The job is broken down into individual steps. The possible hazards/risks associated with each step are considered and appropriate controls are identified to reduce or eliminate the risk. The steps of a completed JHA can be easily converted into SOPs for routine laboratory operations with known hazards.
2.1.3 What-if Analysis:
A what-if analysis is best suited to simple research applications. As the name implies, this analysis is structured around what if questions about the materials, the process or the equipment that will be used for the experiment. Controls to limit the identified risks are implemented based on the answers to these questions. This method of hazard analysis is easily understood and requires minimal training. However, it is essential that the person overseeing the analysis has sufficient knowledge and experience with the proposed research, to ensure that the right questions are asked.
A checklist provides convenient access to a list of criteria that can be easily checked and implemented by someone who is not familiar with the process of hazard analysis. However, a checklist is limited to the items on the list and may not be adequate for evaluating every hazard associated with your work. The gaps in a checklist may be filled by using other hazard analysis tools to identify other criteria to include on a customized checklist. Once customized for the task, process or working environment, a checklist is a very effective tool for ensuring that complex operations are safe.
2.1.5 Control Banding:
Control banding is best suited to laboratories performing routine procedures with known hazards. Using this approach, laboratory hazards are grouped into bands (categories) based on the nature of the hazard, the identified risks of working with or near the hazard, and the methods used to control the risks. For example chemicals in a laboratory can be grouped into four chemical safety levels (1-4) based on their chemical characteristics and the increasing risk associated with their use. Each successive safety level incorporates progressive implementation of controls and safe work practices to mitigate the increasing risks. After completing this process, a procedure or even an entire laboratory may be assigned to a specific safety level based on the chemicals being used. Everyone following this procedure or working in the lab understands the hazards and risks associated with the safety level and knows the controls and safe work practices that must be used.
2.2 Hazard analysis of chemical processes
Before beginning an experiment, consider all possible reactions, including side reactions, all reactants, intermediates, products, and wastes in terms of flammability, toxicity, and reactivity hazards. Consider the following:
- Does it decompose, and if so, how rapidly and to what products?
- What is its stability on exposure to heat, light, water, metals, or air?
- Is it impact sensitive?
- With what substances is this material incompatible?
- Is it toxic? look at the safety data sheet. If so, consider potential exposure routes such as inhalation, absorption, ingestion, and injection. Consider that exposure may occur by more than one of these routes.
- What is the recommended first aid treatment in case of an accidental exposure?
- What is the quantity and rate of the evolution of heat and gasses that may be released during the reaction?
- How will the waste products be handled and disposed?
2.2.1 Develop Contingency plans
Develop contingency plans that address the following:
- Electric power failure, including what will happen if power is restored when the device is unattended or being repaired;
- Cooling system failure;
- Exhaust system failure, including interruptions to laboratory exhaust, local exhaust, and filter/absorbent failures;
- Over pressurization;
- Interruptions of air, natural gas, or steam supply;
- Water leaks into the system;
- Air leaks into the system;
- A fire occurs due to the reaction;
- A reaction container breaks or contents spill;
2.2.2 During the process
Determine if any of the following are required:
- cooling, ventilation, pressure relief, and gas purging;
- isolation of the reaction vessel;
- warning signs near any dangerous processes and equipment;
- informing others working in the area about the possible hazards associated with chemicals and processes being used;
- evaluating safety of unattended operations -- processes that involve more serious or unusual hazards must be monitored continuously and should not be left unattended.
2.3 Additional resources for hazard evaluation
For information about a chemical, consult the manufacturer’s Safety Data Sheet (SDS) sheet. The following sources listed below may also provide additional information about the hazards associated with your proposed experiment.
PubChem database, hosted by the US National Library of Medicine, includes structural, physical and toxicological raw data, as well as chemical safety information form national and international agencies on over 90 million chemical compounds. Data provided by PubChem are intended to support, but not replace, laboratory risk assessments, Safety Data Sheets, and institutional guidance for safe laboratory practices and procedures.
OSHA Occupational Chemical Database 800 entries with information such as physical properties, exposure guidelines, and emergency response guidance.
NIOSH Pocket Guide to Chemical Hazards (information on several hundred chemicals commonly found in the workplace)
Environmental Protection Agency's (EPA's) Toxic Substance Control Act (TSCA) Chemical Substances Inventory information on more than 62,000 chemicals or chemical substances.
Chapter 3: Controls for Mitigating Laboratory Hazards
3.1 Hierarchy of controls
The hierarchy of controls prioritizes hazard mitigation strategies on the premise that the best way to control a hazard is to systematically eliminate it from the workplace or substitute a less hazardous technique, process, or material. If elimination or substitution are not feasible options, engineering controls, administrative controls, and PPE must be used to provide the necessary protection.
|Most Effective||Eliminate the hazard: design the hazard out of the project plan; use alternative work procedures.|
|Substitution: use a less hazardous material or find a less hazardous way to do the work.|
|Engineering Controls: any device that is used to prevent contact with or exposure to the hazard (e.g. chemical fume hoods; splash guards, guards on moving parts; barriers; monitoring devices, safety interlocks.|
|Administrative Controls: rules, regulations, warning signs, training, standard operating procedures, and emergency response procedures are all used to define hazards and describe methods for minimizing the risk of injuries and accidents.|
|Least Effective||Personal Protective Equipment (PPE): gloves, safety glasses, splash goggles, face shield, lab coat, protective apron, respirators, and anything else you wear or put on your body to provide additional protection.|
|Emphasis should always be placed on the most effective methods for reducing risk. For example, a respirator (PPE) would never be used for primary protection from chemical fumes, when fumes are more effectively managed by a chemical fume hood (engineering control).|
3.2 Engineering controls and safety equipment
The implementation of engineering controls to reduce risk should be the first consideration if a hazard cannot be eliminated or substituted. For example:
3.2.1 Chemical fume hood
Although laboratory spaces are designed with consideration for air circulation and ventilation, the general air handling system does not provide adequate worker protection when working with most hazardous chemicals. When used correctly, a chemical fume hood can prevent harmful exposures when working with hazardous chemicals in the laboratory. The need for a chemical fume hood can be determined by consulting the safety data sheet (SDS) for the chemicals you are working with. Some SDS terminology, as listed below, indicates a need for using a chemical fume hood or other ventilation control:
- use with adequate ventilation
- avoid vapor inhalation
- provide local exhaust ventilation
- use in a chemical fume hood
Proper use of a chemical fume hood requires:
- working with the sash at the correct height as determined by the most recent inspection;
- keeping all apparatus at least 6 inches back from the face of the hood and keeping the slots in the hood baffle free of obstruction;
- elevating large equipment at least two inches off the base of the fume hood, to allow for the passage of air underneath the apparatus;
- minimizing movement and other forms of potential air disturbances past the face of the hood while you are working;
- eliminating sources of ignition inside the hood when flammable liquids or gasses are present;
- limiting the storage of chemicals and apparatus in the hood to those that are required for current work;
- Keeping the hood sash closed at all times except when the hood is in use.
Contact Facilities Management if the hood does not appear to be operating correctly. Chemical fume hoods are inspected annually by Michigan Tech Facilities Management staff members. During the inspection, the maximum correct working height of the sash is marked to indicate the maximum sash height allowed while still maintaining the recommended safe air flow. Do not work in a chemical fume that has not been inspected within the past year or does not have the safe sash height marked.
Other types of chemical fume hoods
There are many other types of chemical fume hoods designed for specific functions and uses:
Perchloric acid fume hood: designed with a water wash-down system in the ductwork to prevent the build-up of corrosive and explosive perchlorates.
Radioisotope fume hood: designed with HEPA and charcoal filters to prevent radioactive particles from entering the ductwork.
Walk-in fume hood: extend to the floor to allow for large equipment to be easily moved into the hood. Despite their name they are not designed to allow you to "walk in" and do work inside the hood.
California or distillation hood: A free standing hood with access to equipment from two sides and designed to operate with the sashes in the closed position.
3.2.2 Glove box
A glove box is a sealed container that is designed to allow one to handle material in a defined atmosphere (typically inert). Gloveboxes can be used to protect sensitive items inside or the user on the outside, or both. The following recommendations should be followed by all personnel using a glove box:
- Before any work in a glove box occurs, all personnel must receive training and must understand the design features and limitations of a glove box before use. Training must include detailed instruction on elements such as the ventilation and vacuum controls that maintain a pressure differential between the glove box and outside atmosphere and atmospheric controls (e.g., controlling oxygen concentrations and moisture). Training records should be kept in the laboratory or department.
- Prior to use, a visual glove inspection must be performed. Gloves should not be used until they fail: they should be changed according to the glove box manufacturer’s recommendations or whenever necessary. Changing of a glovebox gloves should be documented (date, manufacturer, model of glove, and person performing change). Records of glove changes and other maintenance should be kept in the laboratory or the department.
- Plugging ports that are never or infrequently used is recommended. A properly plugged port should have a stub glove and a glove port cap installed.
- Chemical resistant gloves (e.g., disposable nitrile gloves) should be worn inside the glove box gloves to protect from possible contamination.
- If the glove box is equipped for pressure measurement, the pressure must be checked every day, before use and immediately after gloves are changed. The pressure check must be documented and kept with other records supporting the glove box.
- Keep sharps in an approved container while in the glove box.
- Do not work in the glove box unless the lighting is working.
- Follow all safe work practices for using and handling compressed gas that may be associated with working in the glove box.
- All equipment and chemicals in the glove box must be organized and all chemicals must be labeled. Do not allow items, particularly chemicals, to accumulate in the glove box.
3.2.3 Biological Safety Cabinet (BSC)
A biological safety (or biosafety) cabinet (Figure 3.2.3) is an enclosed, ventilated laboratory workspace for safely working with infectious and potentially infectious biological materials. All biological safety cabinets on campus must be certified by a trained technician on an annual basis. There are several different types of biological cabinets each designed for specific uses. All biological safety cabinets are designed to protect researchers from exposure to infectious materials. Some are also designed to prevent contamination of samples inside the cabinet. Most are not designed for use with chemical applications. If you are unsure about the type of biological safety cabinet you are using and its proper use, contact EHS.
3.2.4 Laminar flow clean bench
A laminar flow clean bench (Figure 3.2.4) DOES NOT provide worker protection and SHOULD NOT be considered as a method for controlling exposure to chemical or biological or other hazardous materials. These workspaces are specifically designed to prevent contamination of semiconductor wafers, samples, and other materials that are sensitive to contamination.
3.2.5 Other engineering controls
Other examples of engineering controls include splash guards and other barriers to prevent contact with the hazardous chemicals; tongs and other devices for manipulating hazards, self- closing containers; self-sheathing needles and scalpels; guards on moving parts and interlocks to automatically disconnect power when safety covers are removed.
3.3 Administrative controls
3.3.1 General rules for laboratory work with chemicals
Safe work practices are essential to laboratory safety. They must be understood and followed by all persons working with potentially hazardous chemicals and equipment in the laboratory. In addition to written SOPs, laboratories are required to develop or adopt general laboratory safety rules and policies and, like SOPs must also be written and enforced. General rules for laboratory safety taken from the OSHA/MIOSHA laboratory standard include:
- Regular work schedules should be followed unless a deviation is authorized by the laboratory supervisor;
- Unauthorized experiments should not be performed;
- Plan safety procedures before beginning any operation;
- Follow Standard Operating Procedures at all times;
- Always read the Safety Data Sheet and label before using a chemical;
- Wear appropriate lab attire: long pants, closed-toe shoes, no loose or baggy clothing, no scarves, neckties, jewelry, etc., long hair should be tied back and/or styled to prevent accidental contact with hazardous chemicals, materials, and equipment;
- Always wear appropriate PPE when working in the laboratory;
- Use appropriate ventilation when working with hazardous chemicals;
- Pipetting should never be done by mouth;
- Hands should be washed with soap and water immediately after working with any laboratory chemicals, even if gloves have been worn;
- Eating, drinking, gum chewing, applying cosmetics, and taking medicine in laboratories where hazardous chemicals are used or stored is strictly prohibited;
- Do not store food, beverages, cups, and other drinking and eating utensils in areas where hazardous chemicals and materials are handled or stored (if these items are used as part of an experiment, they must be clearly labeled with “NOT FOR HUMAN CONSUMPTION” or a similar warning);
- Laboratory refrigerators, ice chests, ice flakers, cold rooms, and ovens should not be used for food storage or preparation;
- Contact the laboratory supervisor/PI, departmental CHO/safety officer/liaison or EHS office with safety questions or concerns;
- Know the location and proper use of safety equipment;
- Maintain awareness of your surroundings (no listening to music using headphones, earbuds);
- Inform others working in the laboratory of the hazards associated with your work;
- Notify supervisors of chemical sensitivities or allergies;
- Report all injuries, accidents, incidents, near misses and unsafe conditions to the Laboratory Supervisor, the departmental CHO/safety officer/liaison or EHS;
- Unauthorized persons are not allowed in the laboratory;
- Properly dispose of chemical wastes.
These simple, somewhat "common sense" rules are important. If basic rules are followed, it is more likely that other, more complex and perhaps less intuitive, safety procedures will also be followed.
Examples of additional general safety rules and policies may be found in various sources including "Prudent Practices in the Laboratory" written by the National Research Council.
3.3.2 Laboratory security
All laboratory personnel have a responsibility to protect university property from misuse and theft of hazardous materials, particularly those that could threaten human health. The following minimum security measures pertain to all campus laboratories:
- The laboratory door must remain closed at all times and closed and locked when not occupied;
- Only individuals authorized by University policy and by the laboratory supervisor are permitted in laboratories (contact the Lab PI, Department Chair, or Public Safety and Police Services if unauthorized individuals refuse to leave the laboratory when asked);
- If you see anything suspicious or someone displays suspicious behavior, immediately report it to the Michigan Tech Public Safety and Police Services;
- Particularly hazardous chemicals must be secured at all times.
3.3.3 Labeling chemical containers in the laboratory
Every chemical container in the laboratory, whether hazardous or not, must be properly labeled.
184.108.40.206 Chemicals in original containers
The OSHA hazard communication standard (29CFR1910.1200.f) requires chemical manufacturers and distributors to label chemical containers with the following information:
- Product Identifier (name of the chemical);
- Signal Word (either “Danger” or “Warning” to indicate the relative severity of the hazards associated with the chemical);
- Hazard Statement(s) (a specific description of the nature and degree of the hazard);
- Precautionary Statement(s) (recommendations for minimizing/preventing exposure; responding to emergencies; proper storage and disposal of the chemical);
- Pictogram(s) (graphic symbols communicating information about the chemical’s hazards);
- Name, Address and Telephone Number of the manufacturer/distributor;
In the laboratory the following information shall be added to the label:
- The date the chemical is received in the laboratory;
- The name of the person receiving the chemical or other laboratory identifiers such as the PI's name or room location;
- The date the chemical is opened (this is extremely important for ethers and other potentially reactive chemicals);
Do not remove or deface the manufacturer’s original container label while the container is being used hold its original contents. If any information on the label becomes illegible, a new label with the same information must be created and affixed to the container.
220.127.116.11 Chemicals in secondary containers
All secondary chemical containers (e.g., bottles, beakers, flasks, sample vials, wash bottles, or any other container holding a chemical that is not for immediate use or is left unattended for any length of time) shall be labeled with:
- The full name of the chemical (abbreviations, chemical formulae, or structures are NOT acceptable unless there is a complete and up-to-date legend (e.g., MeOH = Methanol) prominently posted in the laboratory);
- The concentration of the chemical (e.g. 70% ethanol, 2M sodium chloride, 10% bleach in water, etc.,);
- A description of any hazards associated with the chemical (e.g. “flammable,” “corrosive,” “toxic,” etc.) using words or GHS pictograms;
- The date the chemical was placed into the container;
- The name of the person responsible for the chemical;
Secondary container labels must be legible and durable so that the information cannot be easily washed off or stained. If any information on the label becomes illegible, a new label with the same information must be created and affixed to the container.
NOTE: Hazardous Waste collection containers have their own set of labeling rules.
18.104.22.168 Research samples and chemicals developed in the lab
- Research samples, reagents, and chemicals created or used in the lab must be labeled as described above for secondary containers (chemical name, concentration, associated hazards, date created/collected/received, and responsible person).
- The labeling requirements for individual samples in a set or group of samples may be modified if the samples are stored together in larger containers that are labeled with all the information listed above. For example, samples in small tubes or vials may be consolidated and stored together in an appropriately labeled secondary container.
- Store samples in appropriate containers and according to compatibility and primary hazard class. At a minimum, determine the hazardous characteristics of the sample (flammable, corrosive, oxidant, reactive, etc.) and store accordingly. An example of a system for segregating chemicals according to compatibility can be found on the Grainger website.
- Properly dispose of samples as soon as they are no longer needed. The accumulation of unnecessary samples in the laboratory creates housekeeping issues, reduces laboratory efficiency and storage capacity, and may incur higher costs for disposal.
- If a chemical substance or sample is created or produced for another user outside of the lab, the laboratory supervisor must comply with the Hazard Communication Standard including the requirements for preparation of SDSs and container labeling.
3.3.4 Laboratory safety culture
The goal of any experimental design is to deliver useful data in an efficient and timely manner, without delays or incident. Some of the first considerations for an experiment design or modification are the use of potentially hazardous chemicals; the use of potentially dangerous equipment; and the potential injury they may cause. One rule-of-thumb is to assume that incidents, e.g., chemical spills, fires, etc., will happen and plan accordingly. This will drive decisions to:
- Eliminate a particularly hazardous chemical or process;
- Substitute a hazardous material for one that is less hazardous;
- Minimize quantities of experimental chemicals;
- Enclose processes in fume hoods or provide other local ventilation;
- Place guards, screens, or barriers between the hazard and the researcher and other prudent practices;
- Mandate personal protective equipment;
Be fully aware of the risks in the laboratory. A good working knowledge about the hazards of chemicals used in the research and the potential dangers of any equipment is critical. Read and understand the product safety warnings on research equipment and hazardous chemical labels.
Principal Investigators / Laboratory supervisors must:
- Thoroughly review Safety Data Sheets for chemicals that staff, students, and postdocs are using, so that they can discuss specific hazards and safeguards;
- Consider how to train the staff, students, and postdocs to assure they retain the knowledge;
- Think about the response and performance expected from the staff, students, and postdocs if an incident occurs;
- Correct those who do not follow standard safety precautions, or disregard good laboratory practices.
The following tips reproduced verbatim from the National Academy of Sciences “Prudent Practices in the Laboratory” will help to create a culture of safety within an academic laboratory:
- Make [the] topic of laboratory safety an item on every group meeting agenda.
- Periodically review the results of laboratory inspections with the entire group.
- Encourage students and laboratory employees to contact the EHS office if they have a question about the safe methods of handling hazardous chemicals.
- Require that all accidents and incidents, even those that seem minor, are reported so that the cause can be identified.
- Review new experimental procedures with students and discuss all safety concerns. Where particularly hazardous chemicals or procedures are called for, consider whether a substitution with a less hazardous material or technique can be made.
- Make sure the safety rules within the laboratory (e.g., putting on eye protection at the door) are followed by everyone in the laboratory, from advisor to undergraduate researcher, including custodial and facility staff.
- Recognize and reward students and staff for attention to safety in the laboratory.
3.3.5 Hazard Communication
22.214.171.124 Signs and information
Labels and warning signs should be placed in the laboratory to alert lab workers and emergency response personnel to potentially hazardous materials and allow those unfamiliar with the laboratory surroundings to identify hazardous chemical use and storage areas, safety facilities, emergency equipment, and exits.
126.96.36.199 Safety Data Sheets (SDSs)
Chemical manufacturers and distributors are required to provide Safety Data Sheet (SDS) that describes the hazards associated with the chemical and provides information for the safe handling, storage, and disposal of the chemical. An SDS has 16 standardized sections. Those concerned with chemical safety in the laboratory should give special consideration to the following sections of the SDS: Hazard identification (2); Composition (3); First aid measures (4); Accidental release measures (6); Handling and storage (7); Exposure controls/personal protection (8); and Stability and reactivity (10). Additional SDS information is provided through the University’s Hazard Communication training.
The University’s online system, MSDSonline provides access to digital copies of safety data sheets and is the recommended method for the management of SDSs. A computer must be readily available to laboratory researchers for viewing SDSs. A link for accessing MSDSonline can be found at the bottom of most Michigan Tech web pages, listed under the “Need to Know”column. The MSDSonline web address can be found on the Emergency Response Poster posted at the entrance of each laboratory that uses MSDSonline for SDS management.
The Michigan Right-to-Know law requires that SDSs are kept in a systematic and consistent manner. The location of all SDSs for hazardous chemicals used in the laboratory must be indicated by the Michigan Right-to-Know Law poster or similar.
3.4 Personal Protective Equipment (PPE)
Appropriate Personal Protective Equipment (PPE) must be provided to all employees. Employees have the responsibility of properly using such equipment. Figure 3.4 illustrates the minimum PPE required when using hazardous chemicals in a laboratory. PPE should never be used in place of engineering and administrative controls when handling hazardous chemicals. Proper PPE selection can be determined by a combination of the following:
- Ask the laboratory supervisor about proper PPE selection.
- Review the SOP and associated hazard assessment for the task to be performed.
- Review Section 8 of the SDS, “Exposure Controls/Personal Protection” for each chemical(s) being used.
- Contact EHS for additional information.
3.4.1 Eye and face protection
Eye protection shall be required for everyone entering a laboratory where hazardous chemicals are used and stored. The minimum acceptable requirements are for ANSI-compliant safety spectacles with side shielding. All eye protective devices must be stamped with "Z87" by the manufacturer if they meet ANSI standards. Standard prescription eye glasses do not meet the eye protection requirements. See “Current Intelligence Bulletin 59: Contact Lens Use in a Chemical Environment” for guidance on wearing contacts in the laboratory.
Safety glasses with side shields offer protection against flying fragments, chips, particles (sand/dirt), and minor splashes. When a significant splash hazard exists, or if the chemical can cause significant eye damage, other protective eye equipment must be worn.
Safety goggles (impact goggles) offer adequate protection against flying particles. These should be worn when working with glassware under reduced or elevated pressure or with drill presses or other similar situations.
Chemical splash goggles have indirect venting for splash proof sides, which provide adequate protection against splashes.
Specialized eyewear is available for LASER, UV light, infrared light hazards.
Face shields protect the face and neck from flying particles and splashes. Always wear additional eye protection under face shields. Ultra-violet light face shields should be worn when working with UV light sources.
3.4.2 Hand protection
Appropriate hand protection must be worn when there is a potential for exposure of hands to hazardous chemicals, cuts, abrasions, punctures, or harmful temperature extremes.
Some gloves are more suitable for certain hazardous chemicals than others. When selecting appropriate gloves, it is important to evaluate the effectiveness of the glove in protecting against the specific hazardous chemical(s) that will be used in the laboratory. The SDS for the chemical and the glove manufacturer’s glove chart must be consulted to select the most appropriate glove.
The “all-purpose” disposable nitrile gloves used in many laboratories will generally provide adequate protection for incidental exposures to most hazardous chemicals but may or may not be suitable for prolonged contact with a chemical. For example, the 4 mils thick, nitrile glove (Solo Ultra 999) will provide protection for up to eight hours when working with concentrated sulfuric acid but will fail within one minute when working with acetone or toluene. Discard disposable gloves after they come into contact with a chemical and put on a new pair before continuing your work.
When handling materials or equipment with harmful temperature extremes such as liquid nitrogen or autoclaves, appropriate protection such as cryogenic gloves or heat-resistant gloves must be worn.
The sites listed below may be useful in selecting appropriate gloves for use in the laboratory. Note that the compatibility rating systems used by manufacturers vary. Make sure you understand the rating system before making a decision on the glove you will use.
|Ansell Protective Products||Showa||MAPA Professional|
Hand protection must not be worn outside of the laboratory (e.g., hallways, elevators, offices) to avoid contamination of public areas. Gloves should also be removed prior to handling anything that could likely result in cross-contamination (e.g., light switches, door knobs, elevator controls, water fountains, telephones, including cell phones, computer workstations). Disposable gloves must never be reused. Always wash hands after removing gloves. The practice of wearing gloves all day while in the laboratory should be discouraged.
3.4.3 Body protection
Protective clothing must be worn to protect the body from recognized hazards. All unprotected skin surfaces that are at risk of injury should be covered. The upper torso must be fully covered, with no bare midriffs. Full-length pants or full-length skirt must be worn at all times by all individuals that are occupying the laboratory area; shorts are not permitted.
Lab coats, coveralls, aprons, or protective suits must be worn while working on, or adjacent to, all procedures using hazardous chemicals. Laboratory coats must be appropriately sized for the individual and be fastened (snap buttons are recommended) to their full length. Laboratory coat sleeves must be of a sufficient length to prevent skin exposure while wearing gloves. Flame resistant laboratory coats, sometimes referred to as “FR lab coats,” must be worn when working with pyrophoric materials, open flames, or flammable liquids greater than 1 liter in volume. It is recommended that 100% cotton (or other non-synthetic material) clothing be worn under the lab coat during these procedures to minimize injury in the case of a fire emergency.
Laboratory coats should not be worn outside of a laboratory unless the individual is traveling directly to an adjacent laboratory work area. Laboratory coats should not be worn in common areas such as break rooms, offices, or restrooms. Each department is responsible for providing laundry services as needed to maintain the hygiene of laboratory coats. In most cases a bucket and laundry detergent should suffice for a lab coat to be cleaned within a lab. They may not be cleaned by staff members at private residences or public laundry facilities. Alternatives to laundering lab coats include routinely purchasing new lab coats to replace contaminated lab coats, or using disposable lab coats.
3.4.4 Respiratory protection
Respirators may not be used unless they are approved through the Michigan Tech EHS “Respiratory Protection Program.” This program includes a review of the process to ensure that proper equipment is selected for the job; training of all users concerning the methods for proper use and care of equipment; fitting of respirator users and medical surveillance of respirator users. Contact EHS with questions about the Respiratory Protection Program.
3.4.5 Other PPE
In addition to eye, hand and body protection some laboratories may require additional PPE. See the University Safety Manual for additional requirements for head (hard hat), foot (steel toed shoes), and hearing protection. In some special cases such as spill cleanup, working with potentially infectious materials, or clean rooms disposable over-the-shoe booties may be required.
3.4.6 Minimum PPE requirements for support staff and visitors
Support staff (e.g., custodians, maintenance workers) and visitors often enter laboratories to perform routine maintenance tasks or tour the lab. To enter the laboratory, the minimum PPE requirements include safety glasses, fully covered torsos, long pants, and closed-toe shoe. If additional PPE is required or if other unique safety requirements must be followed, it is the lab personnel’s responsibility to notify support staff and/or visitors of the additional requirements.
3.5 Safety equipment
3.5.1 Safety showers and eyewash stations
All laboratories using hazardous chemicals must have access to safety showers and eye wash stations. All lab personnel must be aware of the location and know how to properly use the safety shower and eyewash stations. Eyewash and safety showers must be located:
- 100 feet or less from the hazardous operation – for chemicals that are injurious or corrosive (pH > 2 and ≤ 4 or pH ≥ 9 and < 11.5).
- 25 feet or less from the hazardous operation – For chemicals that are considered highly corrosive (pH ≤ 2.0 or ≥ 11.5.) and for certain organic materials capable of causing severe tissue damage.
- Within 100 feet of the work area for HIV and HBV research laboratories.
- The location of the shower and/or eyewash shall be easily accessible (i.e., no obstacles, closeable doorways, or turns) and should be clearly marked and well lighted. The shower and/or eyewash shall not have a protective covering that requires removal prior to use.
If lab personnel are exposed to a hazardous chemical, they should call for assistance and proceed immediately to use the safety shower or eyewash unit (ideally, someone else in the lab that is not exposed should dial 911 and assist with the decontamination of the affected individual). The affected area should be flushed with water for at least 15 minutes or until emergency response personnel arrive and begin treatment. An exposed eye(s) should be held open to ensure an effective wash behind the lids. Contaminated clothing should be removed immediately after exposure or while under the shower. It is highly recommended that laboratories have blankets or lab coats available for modesty.
Lab personnel are responsible for the recommended weekly flushing of eyewash (NOT safety showers) stations. Michigan Tech Facilities Maintenance staff performs annual inspections of all campus safety shower and eyewash stations. This inspection evaluates the basic mechanical functionality of each station. Any deficiencies are repaired by facilities staff.
3.5.2 Fire extinguishers
All fire extinguishers should be mounted on a wall in an area free of clutter. Each fire extinguisher on campus is inspected on a monthly basis. All laboratory personnel should be familiar with the location, use, and classification of the extinguishers in their laboratory. Ensure that the fire extinguisher available in the laboratory is appropriate for the anticipated type(s) of fire that may occur.
In the event of a fire, DO NOT put yourself in danger to extinguish the fire. DO NOT attempt to extinguish a fire:
- if you have not been trained to use a fire extinguisher
- if it is larger than a small garbage bin in size
- if you cannot extinguish within 5 seconds using a fire extinguisher
- Pull the fire alarm (usually located near exits)
- Exit the building
- Call 911. The 911 phone call is answered by a dispatch service located in Negaunee, MI which dispatches emergency response services for the entire UP. You will need to provide them with specific information about your location: Houghton, MI; Michigan Tech campus; Building and room number.
If you are successful at extinguishing the fire, you must still call 911 to report the incident. It is possible, depending on the nature of the incident that flare-ups may occur.
Chapter 4: Required Employee Training
Effective training is crucial to a successful laboratory safety program. Laboratory Supervisors must actively participate in the training process to ensure that all lab employees are effectively trained before any work with hazardous materials occurs. This chapter details the minimum training requirements for all Michigan Tech chemical laboratories
All training activities must be documented. Some general training requirements, such as Hazard Communication, General Safety Awareness, and Bloodborne Pathogen training, are available through a Michigan Tech on-line training course. There are additional topics in the on-line library that may also be relevant to a worker’s job responsibilities. Note that these courses are broad overviews and may require additional laboratory or task specific training. Additional departmental wide, laboratory-specific, and task specific training can be documented at the departmental level, laboratory level, or at the specific piece of equipment, as appropriate.
4.1 Safety Training
General hazard communication training is required for all individuals that handle or use chemicals as part of their work/research responsibilities. Training is available online by contacting your departmental safety liaison or safety coordinator.
Additional online training for general laboratory safety is available through DOW chemical’s Lab Safety Academy.
4.2 Chemical Hygiene Plan (CHP) training
All laboratory employees (graduate students, lab technicians/managers, postdocs, visiting scientists, etc.) must receive documented CHP training before working with hazardous materials. The laboratory supervisor (or Principle Investigator) is responsible for providing CHP training. Initial CHP training should include review of the following:
- the lab-specific CHP, with emphasis on laboratory policies, procedures and responsibilities;
- lab-specific hazard assessments;
- lab-specific SOPs including chemical spill and lab emergency response procedures;
- chemical waste disposal;
- proper use of lab equipment (e.g. chemical fume hoods, lab furnaces, vacuum pumps, eye washes, safety showers, etc);
- other lab-specific protocols or requirements.
4.3 Annual CHP refresher requirements
After receiving the initial documented CHP training, all lab employees must receive annual CHP refresher training as well. This annual refresher training can be a condensed version of the initial CHP training, but should include review of the following elements:
- lab-specific hazard assessments (review of PPE requirements);
- lab-specific SOPs;
- any additional lab-specific rules and requirements;
- laboratory chemical spill and other emergency procedures.
4.4 PPE training
Laboratory supervisors must ensure that all employees receive PPE training before any work with hazardous materials occurs. This training must be documented in the relevant SOPs. Each lab employee must be trained to know at least the following:
- when PPE is necessary and how to select it;
- how to properly put on and remove, adjust, and wear PPE;
- the limitations of the PPE;
- the proper care, maintenance, storage, and useful life of PPE.
Everyone working in the laboratory must demonstrate an understanding of the training provided, and the ability to use the PPE properly, before performing any work that requires the use of PPE. Retraining is required if laboratory workers show a lack of understanding of the purpose or appropriate use of PPE (e.g., the worker is seen handling hazardous materials without wearing proper PPE).
4.5 Environmental Health and Safety (EHS) safety documents
The CHP focuses on work with hazardous chemicals in the laboratory. However, other common types of hazards are present in many research labs as well (e.g., biological hazards, lasers, etc.). EHS has developed various Safety Documents as a tool to assist researchers with compliance and training requirements for a broad range of common hazards and regulatory programs found in the laboratory.
Chapter 5: Medical Consultations and Examinations
Employees must notify their laboratory supervisor of all work-related injuries and illnesses regardless of the magnitude; the laboratory supervisor must then complete the Michigan Tech Incident and Injury Report form.
Consultations and examinations
All employees who work with hazardous chemicals must have an opportunity to receive medical attention, including any follow-up examinations which the examining physician determines to be necessary, under the following circumstances:
- when an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory;
- where exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the Permissible Exposure Limit) for an OSHA/MIOSHA regulated substance for which there are exposure monitoring and medical surveillance requirements;
- whenever an event takes place in the work area, such as a spill, leak, explosion, or other occurrence resulting in the likelihood of a hazardous exposure.
All medical consultations and examinations must be performed by or under the supervision of a licensed health care provider and must be provided without cost to the employee, without loss of pay, and at a reasonable time and place. The University, in conjunction with the lab PI, shall provide the following information to the health care provider:
- the identity of the hazardous chemical(s) to which the employee may have been exposed;
- a description of the conditions surrounding the exposure, including available quantitative exposure data;
- a description of any signs and symptoms of exposure that the employee is experiencing.
The University shall obtain a written opinion from the examining health care provider which shall include the following:
- any recommendation for further medical follow-up;
- the results of the medical examination and any associated tests;
- any medical condition which may be revealed in the course of the examination which may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace;
- a statement that the employee has been informed of the results of the consultation or medical examination and any medical condition that may require further examination or treatment;
- any work restrictions.
NOTE - The written opinion of the health care provider shall not reveal specific finding of diagnoses unrelated to occupational exposure.
Chapter 6: Laboratory Work Requiring Prior Approval
Prior to conducting any work in the laboratory, the Principle Investigator or laboratory supervisor must review the appropriate Standard Operating Procedure with the lab worker. Some specific research areas also require additional prior review and approval. Depending on the activity the approval may be required by the PI, a review board or EHS personnel.
6.1 Special provisions for particularly hazardous substances
MIOSHA mandates special provisions for handling particularly hazardous substances. A lab worker using one of these substances listed below for the first time is required to get prior approval from the PI.
- Any chemical designated as highly toxic by oral, dermal or inhalation routes of exposure as defined in the MIOSHA Hazard Communication Standard.
- Any chemical designated as a carcinogen based on the following:
6.2 Hazardous procedures
Hazardous procedures involving radioactive or biohazardous materials, recombinant DNA, humans, or animals, require prior University or external approval. Consult with the appropriate Review Board before proceeding with these experiments.
6.3 Hazardous Waste
Generation of wastes with the following characteristics: large volumes (more than 5 gallons per project), wastes with mixed hazards (chemical, radioactive, biological), and projects that will result in leftover, unused acutely hazardous waste (those designated as a “P” listed waste in table 205a in the EPA hazardous waste listing). Consult with EHS in advance of doing these experiments or purchasing these reagents so that proper waste disposal methods may be devised and written into the SOP.
6.4 Working Alone
Working alone in a laboratory can be dangerous and should generally be avoided. If working alone on nonhazardous tasks workers must set up a check in/check out notification system with workers in other labs or another responsible adult that knows how to activate emergency contacts if the worker fails to check out.
Before working alone with hazardous chemicals or, performing other hazardous activities that require an SOP, a hazard analysis for working alone must be conducted and incorporated into the SOP. The updated SOP may: indicate that the procedure cannot be conducted safely by a lone worker; limit or specify the time of day when the work may be conducted; define additional check in/check out procedures or implement new emergency signaling requirements.
6.5 Unattended operations
Unattended laboratory operations involving hazardous substances should be avoided if possible. When experiments must run continuously or overnight with no one present, prior planning and arrangements must be made to prevent the unintended release of hazardous materials. For example, planning should include contingencies for interruption of electricity, cooling water, and/or the flow of inert gas. Additional precautions should include posting the emergency contact information for the responsible individual as well as signs that identify the nature of the experiment and the hazardous substances in use. If appropriate, arrangements should be made for other workers to periodically inspect the operation.
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: Writing Standard Operating Procedures
The OSHA/MIOSHA Laboratory Standard requires that written SOPs are developed for all laboratory work that involves hazardous chemicals or physical hazards. SOPs are written documents that provide step by step instructions for completing laboratory procedures. A well- written SOP will also include information about potential hazards associated with the procedure and how the risks associated with these hazards will be mitigated. For this reason, a hazard analysis is the first step in developing an effective SOP (see section 2.1 ). Laboratory-specific SOPs must be prepared by laboratory personnel who are knowledgeable and involved with the experimental process/or procedure. The laboratory supervisor/PI is ultimately responsible for approving SOPs regardless of who prepares them. Laboratory-specific SOPs for laboratory work involving hazardous chemicals and physical hazards will comprise Chapter 9 of the laboratory’s CHP. These SOPs must be followed without deviation by faculty, staff, and students working in the laboratory.
A template for developing laboratory-specific SOPs is provided below. Note: Some laboratory equipment may present special hazards that will require a written SOP to assure safety. A similar approach for developing equipment SOPs may be followed though outside the requirements of the CHP.
In addition to promoting safety and helping ensure consistent experimental results, SOPs can also be used as a tool for instruction and training in the laboratory. As a standardized document, a written SOP can be used to effectively communicate the risks associated with research in the laboratory, helping to ensure that one person is not over-trained while another is under-trained. A written SOP also provides for continuity in laboratory training, making sure that instructions are not distorted or weakened over time and by staff turn-over. SOPs should be updated as necessary and as part of the CHP should be included in annual lab-specific CHP training/retraining.
8.1 Standard Operating Procedure template:
A standard Operating Procedure is shown below. This template can be downloaded as a word document.
Standard Operating Procedure (Form to be used)
Name of Procedure: (Identify the intended scope of the SOP here) ____________________________
Lab Location _____________________________________
1. Type of SOP: (Select what the SOP addresses)
Procedural _____ Hazardous Material_______ Equipment Specific_______ Other_______
Prepared by:__________________ Date Established___________ Revision date: ____________
2. Prior Approval Required: This procedure is considered hazardous enough to warrant prior approval from the laboratory supervisor. Yes_____ No_____
3. Hazards- The following materials and equipment associated with this procedure present exposure
or physical health hazards and must be mitigated:
Write here the nature of the hazards, be they chemical, physical, equipment, electrical, lasers, ect.
4. Engineering Controls- Prior to performing this procedure, the following safety equipment must be accessible
and ready for use:
(ex. Chemical fume hoods, laminar flow hood, chemical spill kits) Describe the procedure that would ensure proper operation and efficacy.
5. Protective Equipment-Prior to performing this procedure, the following personal protective equipment must
be obtained and ready for use:
(ex. Acid resistant gloves, safety eyewear, lab coat, chemical splash apron)
6. Storage and Handling Requirements – describe any specific storage or handling requirements of any hazardous chemicals:
State the precise methods of storage and handling issues that are pertinent to this procedure.
7. Waste disposal- List the wastes products that will be generated, how they will be collected, and
how the container will be labeled.
What waste products are likely to be produced with this procedure and how will they be disposed?
8. Accidental Spill- In the event that a hazardous material used in this procedure are spilled, be prepared
to execute the following emergency procedure:
What method will be employed if any of the chemicals used in this procedure are spilled during use or during transport?
9. Procedure: List the step-by-step procedure, including any specific safety steps:
Provide an exact description of the procedure that you will be conducting.
10. Certification- I have read and understood the above SOP. I agree to contact my Supervisor if I plan to modify this procedure.`
Signature _______________ Name (print)
Supervisor Signature_____________________ Name (print)_________________
Chapter 9: Laboratory Specific Standard Operating Procedures
9.1 Every Laboratory under the MIOSHA laboratory standard must:
- Conduct hazard assessments for the activities conducted in the laboratory and uses these assessments to develop written Standard Operating Procedures.
- Make these procedures available to employees and train them to follow these procedures.
- Document this training.
The laboratory specific Chemical Hygiene Plan, written Standard Operating Procedures, and training documentation, may be available in either printed or electronic formats. However, they need to be readily available to anyone that enters the laboratory including all employees, Environmental Health and Safety personnel, and MIOSHA inspectors.
Glossary of Terms
- Action level means a concentration which is designated in established MIOSHA health standards for a specific substance, calculated as an 8-hour, time-weighted average, and which initiates certain required activities, such as exposure monitoring and medical surveillance.
- Chemical Hygiene Officer (CHO) means an employee who is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan. This definition is not intended to place limitations on the position description or job classification that the designated individual shall hold within the employer's organizational structure.
- Chemical Hygiene Plan (CHP) means a written program which is developed and implemented by the employer, which sets forth procedures, equipment, personal protective equipment, and work practices that are capable of protecting employees from the health hazards presented by the hazardous chemicals used in a particular workplace, and which is in compliance with R 325.70106
- Emergency means any occurrence, such as equipment failure, the rupture of containers, or the failure of control equipment, that results in an uncontrolled release of a hazardous chemical into the workplace.
- Employee means a person who is assigned to work in a laboratory workplace and who may be exposed to hazardous chemicals in the course of his or her assignments.
- Hazardous chemical means any chemical which is classified as a health hazard or simple asphyxiant (see below) in accordance with the Occupational Health Standard Part 430 “Hazard Communication,” as referenced in R 325.70102a.
- Health hazard means a chemical that is classified as posing 1 of the following hazardous effects:
- Acute toxicity, any route of exposure.
- Skin corrosion or irritation.
- Serious eye damage or eye irritation.
- Respiratory or skin sensitization.
- Germ cells mutagenicity.
- Reproductive toxicity.
- Specific target organ toxicity, single or repeated exposure.
- Aspiration hazard.
- The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A of Occupational Health Standard Part 430 “Hazard Communication,” as referenced in R 325.70102a, rule §1910.1200(c) which includes the definitions of "simple asphyxiant".
- Laboratory means a facility where the laboratory use of hazardous chemicals occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a nonproduction basis.
- Laboratory scale means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by 1 person. "Laboratory scale" does not mean those workplaces whose function is to produce commercial quantities of materials.
- Laboratory-type hood means a work chamber which is used in a laboratory, which is enclosed on 5 sides and has a moveable sash or fixed partial closure on the remaining side, which is constructed and maintained to draw air from the laboratory and prevent or minimize the escape of air contaminants into the laboratory, and which allows chemical manipulations to be conducted in the enclosure without inserting any portion of the employee's body other than hands and arms. The term includes walk-in hoods with adjustable sashes if the sashes are adjusted during use so that the airflow and the exhaust of air contaminants are not compromised and so that employees do not work inside the enclosure during the release of airborne hazardous chemicals.
- Laboratory use of hazardous chemicals means the handling or use of such chemicals in which all of the following conditions
- Chemical manipulations are carried out on a laboratory scale.
- Multiple chemical procedures or chemicals are used.
- The procedures that are involved are not part of production process, nor in any way simulate a production process.
- Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
- Medical consultation means a consultation that takes place between an employee and a licensed physician to determine what medical examinations or procedures, if any, are appropriate.
- Mutagen means chemicals that cause permanent changes in the amount or structure of the genetic material in a cell. Chemicals classified as mutagens in accordance with Occupational Health Standard Part 430 “Hazard Communication,” as referenced in R 325.70102a, shall be considered mutagens for purposes of these rules.
- Physical hazard means a chemical that is classified as posing 1 of the following hazardous effects:
- Flammable, gasses, aerosols, liquids, or solids.
- Oxidizer as a liquid, solid, or gas.
- Pyrophoric as a gas, liquid, or solid.
- Organic peroxide.
- Corrosive to metal.
- Gas under pressure.
- In contact with water emits flammable gas.
- Combustible dust.
- The criteria for determining whether a chemical is classified as a physical hazard are in Appendix B of Occupational Health Standard Part 430 “Hazard Communication,” as referenced in R 325.70102a, rule §1910.1200(c) which includes the definitions of "combustible dust" and "pyrophoric gas."
- Protective laboratory practices and equipment means those laboratory procedures, practices, and equipment that are accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals.
- Reproductive toxins mean chemicals that affect the reproductive capabilities, including adverse effects on sexual function and fertility in adult males and females, as well as adverse effects on the development of the offspring. Chemicals classified as reproductive toxins in accordance with the Occupational Health Standard Part 430 “Hazard Communication,” as referenced in R 325.70102a, shall be considered reproductive toxins for purposes of these rules.
- Select carcinogen means any substance which meets one of the following criteria:
- It is regulated by OSHA/MIOSHA as a carcinogen; or
- It is listed under the category, “known to be carcinogens,” in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or
- It is listed under Group 1 (“carcinogenic to humans”) by the International Agency for Research on Cancer Monographs (IARC) (latest editions); or
- It is listed in either Group 2A or 2B by IARC or under the category, “reasonably anticipated
to be carcinogens” by NTP, and causes statistically significant tumor incidence in
experimental animals in accordance with any of the following criteria:
- After inhalation exposure of 6-7 hours per day, 5 days per week, for a significant portion of a lifetime to dosages of less than 10 mg/m3;
- After repeated skin application of less than 300 (mg/kg of body weight) per week; or
- After oral dosages of less than 50 mg/kg of body weight per day.