Chemical Hygiene Plan

1. Introduction

• 1.1. Purpose
  • 1.1.1 The purpose of this regulation is to provide a plan for East Carolina University to protect the health and safety of its laboratory users through compliance with applicable local, state, and federal regulations. The Occupational Safety and Health Administration (OSHA) promulgated 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories, on January 31, 1990, to provide guidelines for the safe use of chemicals in laboratories (OSHA 29 CFR 1910.1450, https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450).
  • 1.2. Application
    • 1.2.1 This standard* applies in locations where “laboratory use” of hazardous chemicals occurs. Laboratory use of hazardous chemicals means handling or use of chemicals in which all of the following conditions are met:
      • 1.2.1.1 Handling or use of chemicals occurs on a “laboratory scale” (work involves containers which can easily and safely be manipulated by one person);
      • 1.2.1.2 Multiple chemicals or chemical procedures are used;
      • 1.2.1.3 Procedures are not part of a production process or process simulation;
      • 1.2.1.4 Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposures to hazardous chemicals.
    • *Note: This standard does not apply where the use of hazardous chemicals provides no potential for employee exposure, such as in procedures using chemically impregnated test media and commercially prepared test kits
    • 1.2.2. The Chemical Hygiene Plan (CHP) is intended to provide the necessary framework for compliance with the OSHA Lab Standard.
    • 1.2.3. While non-paid laboratory users and students are not covered by this plan, University policy requires supervisors to share its content and promote compliance with the standard operating procedures.

2. Responsibilities

• 2.1. ECU Chancellor, Vice Chancellors, Deans and Department Heads
  • 2.1.1 Establish laboratory safety as an institutional priority;
  • 2.1.2 Support and promote an active lab safety culture;
  • 2.1.3. Provide adequate financial and unbiased support for chemical hygiene at ECU;
  • 2.1.4. Include laboratory safety, chemical storage and disposal considerations in long-range facilities planning.
  • 2.1.5 Support EH&S and assist with compliance concerns.
  • 2.1.6 Contact EH&S to schedule lab closeout prior to PI leaving the lab space.
• 2.2. Safety and Security Committee:
  • 2.2.1. Review the Chemical Hygiene Plan not less than every 3 years;
  • 2.2.2. Support Environmental Health and Safety implementation of laboratory safety policy;
  • 2.2.3. Promote the safe use of laboratory facilities at ECU.
• 2.3. Environmental Health and Safety (EH&S):
  • 2.3.1. Appoint a Chemical Hygiene Officer (CHO) who is qualified by training to provide technical guidance (The Senior Industrial Hygienist with EH&S will be the University CHO);
  • 2.3.2. Prepare, implement, and maintain a written Chemical Hygiene Plan, setting forth general procedures, control measures, and information intended to assist Principal Investigators and Laboratory Supervisors in protecting employees from harm arising from chemical exposure;
  • 2.3.3. Provide employees with initial chemical hygiene training as scheduled and upon request;
  • 2.3.4. Assist laboratory users in locating and obtaining Safety Data Sheets (SDSs) upon request;
  • 2.3.5. Maintain a master chemical inventory;
  • 2.3.6. Maintain a master emergency contact list;
  • 2.3.7. Provide monitoring services for anticipated or suspected employee exposures and where required by chemical specific OSHA standards to determine proper protective measures upon request. (See the EH&S laboratory safety web site for a listing of chemical specific monitoring requirements, (https://oehs.ecu.edu/).
  • 2.3.8. Perform annual inspections of chemical fume hoods;
  • 2.3.9. Coordinate required medical surveillance, treatment, and exposure related recordkeeping through the Workers’ Compensation Program;
  • 2.3.10. Perform annual and follow-up laboratory inspections and use the lab safety software, OnSite) to submit a detailed report of identified deficiencies to Principal Investigators and Department Chairs;
  • 2.3.11 Perform new lab start-up inspections prior to Principal Investigator beginning work in their laboratory;
  • 2.3.12. Perform laboratory close-out inspections prior to principal investigators and/or laboratory staff leaving the University; and
  • 2.3.13. Provide grant review for hazardous chemical safety issues.
• 2.4. Principal Investigator, Laboratory Supervisor:
  • 2.4.1 Maintain a current copy of the ECU Chemical Hygiene Plan and ensure that laboratory personnel comply with the content of the Plan;
  • 2.4.2 Post Emergency Telephone Numbers (page 2 of this document) by the laboratory phone.
  • 2.4.3 Create and maintain appropriate standard operating procedures/laboratory safety plans to supplement this Plan and forward to EH&S;
  • 2.4.4 Obtain approval for biological and radioactive materials as well as animal work through the corresponding departments.
  • 2.4.5 Train and/or arrange for training of laboratory workers, including students and visitors, at the time of initial employment and each time new procedures or hazards are introduced in accordance with section 3.2;
  • 2.4.6 Maintain records of training (see Lab Specific Training Documentation Form) and make available to EH&S during annual inspections;
  • 2.4.7 Implement and enforce the use of safety procedures, including appropriate lab attire, necessary and appropriate personal protective equipment, engineering controls, or work practices;
  • 2.4.8 Assure that the areas where hazardous chemicals are used or stored are secured when not in use; lab doors are closed and locked when not occupied.
  • 2.4.9 Assure that all chemical containers are properly labeled and stored by compatibility;
  • 2.4.10 Participate in annual and follow-up inspections.
  • 2.4.11 Correct identified deficiencies on lab inspection reports and submit a written action plan with photos within the lab safety software system, in accordance with the established deadline, per the Lab Safety Compliance SOP;
  • 2.4.12 Review and update chemical inventory on required format and forward to EH&S at least
  • annually; at this time, review chemical storage to identify containers for disposal;
  • 2.4.13 Maintain current door posting with emergency contact information.
  • 2.4.14 Ensure availability of written emergency action plan in the lab (update annually). This plan must be communicated to all lab personnel at the time of lab specific training.
  • 2.4.15 Assure that interim (weekly, semester, and annual) laboratory inspections are conducted for rooms where chemicals are stored, using the lab self-inspection worksheets available on the EH&S lab safety web site. Individual rooms must be clearly identified.
  • 2.4.16 Assure that interim (semester) equipment room inspections are conducted for rooms where no chemicals are stored, using the Equipment Room Semesterly Inspection Checklist on the EH&S lab safety web site. Individual rooms must be clearly identified.
  • 2.4.17 Maintain employee exposure to hazardous chemicals below permissible exposure limits set forth in OSHA 29 CFR 1910 subpart Z. (See EH&S lab safety web page);
  • 2.4.18 Arrange for EH&S to conduct appropriate air monitoring when required by a chemical specific standard. Contact EH&S immediately when exposure is anticipated or suspected and notify affected lab users in a timely manner;
  • 2.4.19 Arrange for appropriate routine medical surveillance as required by OSHA regulation for specific hazardous chemicals through EH&S;
  • 2.4.20 Initiate medical surveillance review and follow-up of all exposure incidents;
  • 2.4.21 Maintain records of any student and/or employee exposure determinations and all lab related exposure incidents. Forward copies to EH&S;
  • 2.4.22 Provide necessary and appropriate personal protective clothing and equipment (at no charge to employees) Note: Respirator use must comply with requirements of the Respiratory Protection Standard. Users must be included in the ECU Respiratory Protection Program. Contact EH&S before purchasing or issuing respiratory protection;
  • 2.4.23 Assure that engineering controls are functioning properly and arrange for maintenance and certification if required;
  • 2.4.24 If carcinogens, reproductive toxins, or acutely toxic chemicals are used in the lab, identify “designated use areas” and post signage. It is advisable to keep the area as small as possible (use in the chemical fume hood or class II B2 biosafety cabinet only) and ensure designated area is listed in the lab safety plan. Train all lab personnel on substances, designated areas, and PPE requirements;
  • 2.4.25 Ensure the availability of Safety Data Sheets and relevant reference materials for each chemical used or stored in the lab;
  • 2.4.26 Collect, store, and dispose of chemical waste properly through the ECU hazardous waste disposal system;
  • 2.4.27 Contact EH&S for lab start-up instruction and inspection prior to beginning work in the lab;
  • 2.4.28 Notify and coordinate with EH&S any lab moves or close-outs. Complete the lab close-out form (see EH&S lab close-out model) and contact EH&S to schedule a final inspection within 10 business days prior to moving or vacating lab space;
  • 2.4.29 Submit all awarded grant(s) involving the use of hazardous chemicals to EH&S for approval (See EH&S Grant Review web page);
  • 2.4.30 Report all incidents and near misses to EH&S using the Lab Incident Investigation Form and Laboratory Near Miss Form;
  • 2.4.31 Include chemical hygiene and laboratory safety compliance in employee annual work plans for performance review.
• 2.5. Laboratory Users:
  • 2.5.1 Read and follow the guidelines in the Chemical Hygiene Plan and standard operating procedures/lab safety plans and sign documents indicating comprehension and adherence;
  • 2.5.2 Participate in initial and refresher CHP/lab safety training;
  • 2.5.3 Follow all safety procedures including appropriate lab attire, necessary personal protective equipment, engineering controls, and work practices.
  • 2.5.4 Do not remove or deface labels on incoming or stored chemical containers;
  • 2.5.5 Immediately label all secondary containers with the chemical constituents (no formulas or abbreviations), hazard warning, responsible party, and date of preparation;
  • 2.5.6 Report all exposure incidents or hazardous conditions to your Lab Supervisor;
  • 2.5.7 Use provided materials to become familiar with the hazards associated with the chemicals and procedures used in your lab (lab safety plans, SDS, lab safety resource index, etc.);
  • 2.5.8 Use prudent practices and prescribed hazard control measures;
  • 2.5.9 Request information or training when unsure about how to handle a hazardous chemical or procedure;
  • 2.5.10 Inform supervisor of any potential hazard, accident, or near miss; and
  • 2.5.11 Perform only authorized work, preparations, and experiments in the laboratory.

3. Training

• 3.1 Chemical Hygiene Training:
  • 3.1.1 EH&S staff provides initial Chemical Hygiene Training to all laboratory employees in general sessions.
  • 3.1.2 Chemical Hygiene Training is available on the EH&S laboratory safety web site for individuals unable to attend the class.
  • 3.1.3 Additional training sessions can be scheduled for groups upon request.
    • 3.1.3.1 To request training, send an email to safety@ecu.edu.
  • 3.1.4 All laboratory employees will be required to attend refresher training every three years.
  • 3.1.5 Content of Training:
    • 3.1.5.1 Methods and observations that may be used to detect the presence or release of a hazardous chemical;
    • 3.1.5.2 Permissible exposure limits and exposure guidelines;
    • 3.1.5.3 Physical and health hazards of chemicals;
    • 3.1.5.4 Measures employees can take to protect themselves from these hazards;
    • 3.1.5.5 The content of this Plan, its location and availability;
    • 3.1.5.6 Signs and symptoms associated with exposure to hazardous chemicals;
  • 3.1.6 Information:
    • 3.1.6.1 The entire text of the Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450) is available on the EH&S laboratory safety web page;
    • 3.1.6.2 Safety Data Sheets (SDS) detailing chemical or mixture specific physical and hazard assessment information are available on the MSDS web page at https://oehs.ecu.edu/chemical-hygiene/hazard-communication/safety-data-sheets/.
    • 3.1.6.3 Reference materials including access to SDS, chemical profiles and hazard information is located on the EH&S Lab Safety web page (https://oehs.ecu.edu/);
    • 3.1.6.4 How to Read a SDS – a short, section-by-section explanation of the SDS components available on the Laboratory Safety Resource Index at https://oehs.ecu.edu/chemical-hygiene/lab-safety/lab-safety-resource-index/)
• 3.2 Laboratory Specific Training:
  • 3.2.1 Each laboratory supervisor will provide laboratory-specific training. Training will include:
  • 3.2.2 Location and instructions for use of emergency equipment such as eyewash stations, fire extinguishers, fire pull stations, safety showers, etc.;
  • 3.2.3 How to locate and use personal protective equipment in the laboratory;
  • 3.2.4 Emergency Action Plan, including exits, evacuation routes, and designated meeting locations;
  • 3.2.5 Biosafety level guidelines when potentially biohazardous material is in use;
  • 3.2.6 Chemical labeling, storage, chemical/hazardous waste disposal, biohazardous waste disposal, spill procedures, and decontamination procedures;
  • 3.2.7 Location of designated areas for use of carcinogens, reproductive toxins, biohazardous material, and/or acutely toxic substances;
  • 3.2.8 Location and access instructions for a copy of the laboratory chemical inventory, Chemical Hygiene Plan, IBC Registration, safety data sheets and laboratory specific standard operating procedures/lab safety plans or methodologies; and
  • 3.2.9 Any other pertinent information deemed important by the laboratory supervisor;
  • 3.2.10 A record of lab specific training, including the trainee’s printed name and signature, and list of items covered, shall be maintained in each laboratory (see Lab Specific Training Documentation Form). A copy of all training records shall be available for review by EH&S during annual laboratory inspections.

4. Program Review

This document should be reviewed no less than every three years and whenever material changes in related laws and/or regulations occur.