Policy
The objective of the Chemical Hygiene Plan is to reduce exposure to hazardous chemicals to the lowest practicable level for employees working in the laboratory environment. The use of chemicals which have been classified as hazardous shall be planned and performed in compliance with applicable regulations and in a manner to ensure a safe and healthy work environment. All employees of the University of Kansas Medical Center who have assigned duties requiring the use of hazardous chemicals in the laboratory shall receive appropriate training and education prior to initial assignment. All employees shall adhere to the guidelines presented in this document as well as comply with all pertinent rules and regulations. In the event of noncompliance, disciplinary actions shall be taken in accordance with institutional policies. The Chemical Hygiene Plan shall be readily available to all employees working in laboratories in which hazardous chemicals are used or stored.
I. Introduction
Implementation of the Chemical Hygiene Plan is a critical element in achieving a safe and healthy work environment in laboratories. The Chemical Hygiene Plan defines a formal program for minimizing personnel and environmental exposures to hazardous chemicals in the laboratory. The principal purpose of the Chemical Hygiene Plan is to assist the laboratory investigator in the selection and use of safeguards that will serve to ensure safe working conditions. The plan is based on the provisions described in the OSHA regulation entitled "Occupational Exposure to Hazardous Chemicals in Laboratories".
II. Responsibilities
Specific actions required by this standard which are the responsibility of each department, employee and student are:
Hazard Reduction: It is the responsibility of the user of a hazardous chemical, or the generator of a hazardous chemical waste, to regularly review their activities, and to identify and implement any appropriate means of hazard reduction. Any plan for hazard reduction, however, shall first be reviewed by the appropriate safety committee, or the Safety Office, prior to being implemented.
Standard Operation Procedures: Principal Investigators shall be responsible for the development of standard operating procedures (SOPs) for specific hazardous chemicals to be used under their supervision. SOPs must be available for all carcinogens stored and used in labs.
Labeling: Employees shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced. All secondary containers shall be labeled with the chemical name, hazard information, and manufacturer.
MSDS: Material safety data sheets (MSDSs) that are received by the principal investigator with incoming hazardous chemical shipments shall be maintained and made readily accessible to all employees working in the laboratory. MSDSs must be available for all carcinogens stored and used in labs.
Training: Employees must participate in the Medical Center Hazard Communication (Right-to-Know) training sessions prior to initial assignment to work involving the use of hazardous chemicals in the laboratory and annually thereafter.
The principal investigator shall provide information and training regarding the specific hazards of chemicals with which employees and students under their supervision will be working. Annual refresher information and training sessions shall be provided and documented by each department.
Recordkeeping: Each department shall maintain records for each employee and student documenting participation in annual refreshers.
III. Definitions
Action Level - a concentration designated for a specific substance, calculated as an 8-hour time-weighted average, which initiates certain required activities
Chemical Hygiene Plan - a written program which sets forth procedures, equipment, personal protective equipment and work practices that are designed to protect employees from the health hazards presented by hazardous chemicals used in the workplace.
Designated Area - an area which may be used for work with "select carcinogens," reproductive toxins or substances which have a high degree of acute toxicity.
Hazardous Chemical - a chemical for which there is statistically significant evidence that acute or chronic health effects may occur in exposed employees
Medical Consultation - a consultation which takes place between an employee and a licensed physician for the purpose of determining what medical examinations or procedures, if any, are appropriate in cases where a significant exposure to a hazardous chemical may have taken place
Reproductive Toxins - chemicals such as mutagens and teratogens which affect reproductive capabilities
Select Carcinogen - any substance which meets one of the following:
III. Hazard Reduction
Every feasible effort shall be made to eliminate or reduce the degree of chemical hazard presented to patients, visitors, students, employees, staff, and the surrounding community. Techniques for reducing the degree of hazard, in order of descending preference, include:
A. Substitution of non-hazardous or less-hazardous materials or processes;
B. Engineering controls, such as the use of local exhaust ventilation, or isolation;
C. Administrative controls
D. Protective clothing and equipment
It is the responsibility of the user of a hazardous chemical, or the generator of a hazardous chemical waste, to regularly review their activities, and to identify and implement any appropriate means of hazard reduction. Any plan for hazard reduction, however, shall first be reviewed by the appropriate safety committee, or the Safety Office, prior to being implemented.
Criteria for requiring approval prior to implementation of a particular laboratory operation are outlined in "Guidelines for the Use of Toxic Substances."
IV. Standard Operating Procedures
Principal Investigators shall be responsible for the development of standard operating procedures for specific hazardous chemicals to be used under their supervision. General safety and health policy and procedure manuals outlining operating procedures and guidelines are listed in Appendix A. The principal investigator shall ensure that all pertinent manuals as well as specific SOP's are readily available to employees working with hazardous chemicals under their supervision.
V. Hazard Identification
All employees shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced.
Material safety data sheets (MSDS's) that are received by the principal investigator with incoming hazardous chemical shipments shall be maintained and made readily accessible to all employees working in the laboratory.
MSDS's for all hazardous chemicals in the laboratory should be obtained by the Department and made readily accessible to all employees working in the laboratory.
MSDSs are available from the manufacturer, on-line at http://www2.kumc.edu/safety, or from the Environment, Health and Safety Office. For further information regarding access to MSDS's, contact the Environment, Health and Safety Office at extension 8-1081.
VI. Chemical Substances Developed In The Laboratory:
If a chemical is produced exclusively for the laboratory's use and is classified as hazardous, the principal investigator shall provide appropriate training and information as outlined in Section IX.
If a chemical is produced exclusively for the laboratory's use and it is not known if it is hazardous or not, the principal investigator shall assume that the chemical is hazardous and shall carry out all provisions of the Chemical Hygiene Plan.
If a chemical is produced for another user outside the laboratory, the principal investigator shall comply with all provisions of the Hazard Communication Standard including the requirement for preparation of material safety data sheets and labeling.
VII. Hazard Controls
There are three methods that can be utilized to control hazards. The preferred way to reduce or eliminate exposures, or potential exposures, is to "Engineer" the problem out using measures of control which modify the source or reduce the amount of contaminant released into the work environment. The second preference, are methods of controlling employee exposure by job rotation, work assignment, time periods away from the hazard, or training in specific work practices designed to reduce the exposure. The use of personal protective equipment is the third way to control, and should always be used as a last resort since it relies on people to protect themselves.
Whenever possible, the employee shall ensure that all engineering controls and all protective equipment is functioning properly prior to use. The Safety Office shall conduct periodic surveys to observe work practices and to assess the operation of engineering controls and protective equipment such as laboratory fume hoods. Facilities Operations shall conduct periodic preventive maintenance for those engineering controls and protective equipment which comes under its purview. All employees shall ensure the integrity and adequacy of personal protective equipment prior to use.
VIII. Employee Information and Training
Employees and students who work with or near hazardous chemicals or who may respond to spills of hazardous chemicals are classified as participants. All participants must receive training.
The initial training is divided into two sessions. The first session is presented by the Safety Office and covers general definitions, the KUMC Chemical Hygiene Program, methods of detection, emergency procedures, MSDSs, personal protective equipment, and labeling. The second training session is presented in the employee’s/student’s department and it covers the hazards associated with chemicals used in that department or school.
Each department/school must designate a person(s) that is responsible for providing department-specific chemical hygiene training. The Safety Office shall provide training for the Designated Safety Representatives and assistance as needed in the development of departmental training programs. The Designated Safety Representative(s) should provide a format for the training that includes the elements of the training program. The program must provide training for new employees, periodic refreshers (at least annually), and training for all new hazards as they are introduced.
The information provided in this document must include the following:
A. The contents of 29 CFR 1910.1450 (Occupational Exposures to Hazardous Chemicals in Laboratories) including the appendices both of which shall be made available to the employee.
B. The location and availability of the Chemical Hygiene Plan.
C. The permissible exposure limits (PEL) per OSHA standards or the recommended exposure limits (REL) when OSHA standards do not exist.
D. Signs and symptoms associated with exposures to the hazardous chemicals used in the laboratory.
E. The location and availability of reference material.
Training shall include the following:
A. Methods and observations that may be used to detect the presence or release of a hazardous chemical.
B. The physical and health hazards of chemicals in the workplace.
C. The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals.
The Departments shall maintain written records showing employees participation in refreshers. On an annual basis the department shall submit this list to the Medical Center Safety Office.
IX. Medical Surveillance
Medical consultation and follow-up medical examinations which the physician deems necessary shall be provided without cost to the employee, without loss of pay, and at a reasonable time and place under the following circumstances:
A. Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory.
B. Whenever exposure monitoring reveals an exposure level routinely above the action level (AL) or in the absence of an AL, the permissible exposure limits for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements.
C. Whenever an event takes place in the work area resulting in the likelihood of a hazardous chemical exposure.
X. Respiratory Protection
If the use of respirators is necessary to maintain exposures below permissible exposure limits, such respiratory equipment shall be provided by the principal investigator at no cost to the employee or student. Respirators shall be selected and used in accordance with the institutional respiratory protection program.
XI. Recordkeeping
The Medical Center Safety Office shall maintain records for each employee and student for all monitoring and initial training activities. Employee Health Services shall maintain medical surveillance/examination records established for employees and students under the requirements of this policy. The Department shall maintain records for each employee and student documenting participation in annual refresher training.
XII. Availability and Updating
The Chemical Hygiene Plan (CHP) shall be readily available to employees working in a laboratory in which hazardous chemicals are used.
The Environment, Health and Safety Office shall be responsible for distribution of the Chemical Hygiene Plan to departments. The departmental chairperson or director shall ensure that the CHP is readily available to employees within their department.
Any new installation or renovation of protective equipment which must be integrated into existing facilities, must be approved through a joint review by Facilities Management, Design and Construciton, and the Environment, Health and Safety Office.
The Environment, Health and Safety Office shall review the Chemical Hygiene Plan annually and revise it as needed.
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