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