TABLE OF CONTENTS
The Laboratory Standard 4
What is Exempt? 5
Tulane's Chemical Hygiene Plan 6
Chemical Hygiene Responsibilities 7
Information and Training 9
The Laboratory Facility 11
Housekeeping, Maintenance, and Inspections 13
Protective Apparel and Equipment 13
Standard Operating Procedures 14
Chemical Procurement, Distribution, and Storage 14
Signs and Labels 15
Exposure and Environmental Monitoring 15
Spills and Accidents 16
General Safety Rules 17
Use of Hood 18
Waste Disposal 19
Prior Approval 19
Allergens and Embryotoxins 20
Chemicals of Moderate Chronic or High Acute Toxicity 20
Chemicals of High Chronic Toxicity 21
Animal Work with Chemicals of High Chronic Toxicity 21
Medical Program 22
Appendix A - Training Form 25
Appendix B - Inspection Procedures 29
Appendix C - Tulane's Chemical Hygiene Plan 45
Appendix D - Supplemental Information and Guidelines 63
Appendix E - Compliance Evaluation Form 73
The Federal "Occupational Exposures to Hazardous Chemicals in Laboratories" Standard (29 CFR Part 1910.1450), henceforth referred to as the Laboratory Standard, was developed because the government, after careful review of federal regulations and public objections, felt that laboratories typically differ from industrial operations in their use and handling of hazardous chemicals, and that a different approach than that found in the Occupational Safety and Health Administration's General Industry Standards (29 CFR Part 1910, Subpart Z) was warranted to protect laboratory workers from hazardous and toxic substances. The Laboratory Standard generally supersedes the general industry standards for laboratories meeting specified criteria.
Most laboratories use very small amounts of OSHA regulated toxic substances, and most laboratory work is done by or under the direct supervision of highly trained personnel. OSHA's General Industry Standards did not adequately address the risks associated with the use of multiple hazardous substances to which exposures were intermittent as is typically the case in the laboratory workplace. Instead these standards were designed to control regular exposures to a single substance (such as asbestos, vinyl chloride, benzidine, inorganic arsenic, and lead) used constantly and in large quantities. Often laboratory research including cancer research was obstructed by these tedious and inappropriate industrial regulations. OSHA realized that hazardous situations and potentially significant risks existed in laboratories using a variety of chemicals, and that there was a need for employee protection in the laboratory environment. Thus OSHA developed a separate Laboratory Standard more suitable for the laboratory workplace.
The Laboratory Standard, unlike the general industry standards, is performance based. Although it does not eliminate the requirement to maintain exposures to hazardous chemicals below the applicable permissible exposure levels (PELs), the standard provides greater flexibility in the methods of compliance. With the establishment of the Federal Laboratory Standard, OSHA has given institutions like Tulane a clear responsibility to protect their laboratory workers by formulating and implementing a chemical hygiene plan. The basic purpose of the Laboratory Standard is to develop and implement safety and health practices, procedures, and policies accepted as effective in minimizing laboratory employee exposures to toxic and hazardous chemicals used in their work area. Ultimately, protection of laboratory employees is the major goal. The Laboratory Standard also provides for employee training and information, medical consultation and examinations, hazard identification, respirator use, and recordkeeping. Tulane's Chemical Hygiene Plan is designed to explain the Laboratory Standard and to implement work practices and procedures which can effectively protect employees from those risks associated with using hazardous chemicals in their workplace.
TULANE OFFICE OF ENVIRONMENTAL HEALTH & SAFETY
Always remember the Tulane Office of Environmental Health & Safety (OEHS) is available for advice, consultation, and materials to assist in complying with the Laboratory Standard. Contact OEHS at 988-5486 at the Medical Center, 865-5307 on the Uptown Campus, 394-9815 or 988-5531 at the Hebert Center, and 561-8936 at the Tulane National Primate Research Center. In case of emergency always notify the Office of Environmental Health & Safety or the Tulane Police at 988-5555 or 865-5200 for assistance.
The Laboratory Standard which became effective on May 1, 1990 requires employers to develop a comprehensive Chemical Hygiene Plan by January 31, 1991 to implement safety and health practices accepted as effective in minimizing laboratory exposures to hazardous and toxic chemicals, thus protecting employees from adverse health effects that may result from work in the laboratory. The Laboratory Standard is applicable to all areas which meet the definitions of "laboratory use" and "laboratory scale" (see exemptions below). It supersedes all other health standards in 29 CFR 1910, Subpart Z, with three exceptions: (1) Only the requirement to limit employee exposure to the permissible exposure limit (PEL) specified in any OSHA health standard applies to laboratories, unless the particular standard states otherwise; (2) Prohibition of eye and skin contact specified by a substance-specific OSHA health standard must be observed; and (3) If the action level (or PEL if no action level is specified) is routinely exceeded for an OSHA-regulated substance with exposure monitoring and medical surveillance requirements, the exposure monitoring and medical surveillance requirements as specified in the relevant standard must be performed.
A "laboratory" is defined as a facility where laboratory use of hazardous chemicals occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a nonproduction basis. The expression "laboratory use" of hazardous chemicals has four components: (1) "laboratory scale," meaning that containers used for reactions, transfers, and other handling of substances are small enough to be easily and safely manipulated by one person; (2) multiple chemicals or chemical procedures are used; (3) procedures are not part of a production process; and (4) protective laboratory practices and equipment are available and in use. The component of laboratory use concerning protective laboratory practices and equipment is intended to mean that a body of knowledge is available, not to imply that such practices are implemented in a particular laboratory.
Other definitions that are important to understanding the Laboratory Standard include:
* Hazardous chemical is a chemical for which there is statistical evidence (based on at least one study) that acute or chronic health effects may occur in exposed employees. Appendices A and B of the Hazard Communication Standard (29 CFR 1910.1200) provide further guidance on defining the scope of health hazards.
* Chemical hygiene plan is a written program developed and implemented by the employer that sets forth procedures, equipment, personal protective equipment, and work practices capable of protecting employees from health hazards presented by hazardous chemicals used in a particular work place. A chemical hygiene plan must meet requirements specified in paragraph (e) of the Laboratory Standard.
* Chemical hygiene officer is an individual designated by the employer who is qualified by training or experience to provide technical guidance in the development and implementation of the chemical hygiene plan.
* Employee is an individual employed in a laboratory workplace who may be exposed to hazardous chemicals in the course of his or her assignments. This includes who may not actually work in a laboratory, but may be required to enter a laboratory where potential exposures could occur. Maintenance and custodial personnel are considered by OSHA to meet the definition of employee. Students are not covered unless they are paid by the institution for duties performed.
* Designated area is an area that may be used for work with "select carcinogens," reproductive toxins, or substances with a high degree of acute toxicity. The purpose is to focus attention on the use of particularly hazardous substances to ensure that appropriate measures are taken by employees in or near the vicinity. A designated area may be an entire laboratory, an area of a laboratory, or a device such as a fume hood.
* Permissible Exposure Limit (PEL) is an exposure level to a toxic substance which was established by OSHA to protect workers who are exposed to toxic substances over a working lifetime.
Any OSHA substance specific standard can require coverage to remain under that standard rather than under the Laboratory Standard. For example, formaldehyde in histology, pathology, and anatomy labs is covered by the Formaldehyde Standard rather than the Laboratory Standard. If a preemption statement is not made, the determination of whether the Laboratory Standard applies is dependent on "laboratory use" and "laboratory scale" criteria and whether permissible exposure limits for that substance are being met.
Many facilities commonly referred to as laboratories are not intended to be covered under the Laboratory Standard, such as quality control laboratories connected with production processes that perform repetitive tasks. If a facility does not meet the definitions of "laboratory use" and "laboratory scale," it must comply with the general industry standards found in Subpart Z rather than the Laboratory Standard. The Laboratory Standard also does not apply to uses of hazardous chemicals which provide no potential for employee exposure, such as medical labs which only use prepackaged test kits. Most labs here at Tulane will meet the criteria for coverage under the Laboratory Standard.
Tulane's written Chemical Hygiene Plan should be implemented for all Tulane laboratories using hazardous chemicals which can pose health hazards to the employees. It consists of a general chemical safety plan with specifics for individual laboratories added by the supervisors. It is available to all persons at Tulane and contains the following elements:
* Standard operating procedures
* Criteria to determine and implement control measures to reduce employee exposure to hazardous chemicals
* Measures to ensure proper performance of fume hoods and other protective equipment
* Provisions for employee information and training
* Circumstances requiring prior approval from the employer
* Provisions for medical consultations and examinations
* Designation of a Chemical Hygiene Officer
* Provisions for work with "select carcinogens," reproductive toxins and substances having a high degree of acute toxicity, including use of designated areas and containment devices, and procedures for removing waste and decontamination.
The purpose of this booklet is to help the laboratory supervisor understand his/her role as a supervisor in making Tulane's Chemical Hygiene Plan work. A safe and healthy workplace for Tulane laboratory employees is, to a large part, dependent on the laboratory supervisor. This booklet describes the policies and standard operating procedures set forth in Tulane's written Chemical Hygiene Plan, and the supervisor's role in establishing and maintaining a healthy and safe working environment.
CHEMICAL HYGIENE RESPONSIBILITIES
Responsibility for chemical hygiene rests at all levels. The success of this Chemical Hygiene Plan depends to a great extent upon the cooperation of every laboratory supervisor and employee. Employees should be alert to the potential hazards of the materials in their work area, consult the Material Safety Data Sheets and other related literature for information concerning the hazardous chemicals with which they work, and follow the appropriate work practices that have been established by their supervisors and the administration to protect their health and safety. Active participation in this Chemical Hygiene Plan will result in the continued protection of employees from chemically-related illnesses and injuries at Tulane.
Those responsible for chemical hygiene at Tulane include:
1. Administration - The President, Chancellor, Deans, and other administrative officers here at Tulane have ultimate responsibility for chemical hygiene within the University and must provide continuing support.
2. Departmental Chairmen and Department Heads - Departmental chairmen and department heads are responsible for chemical hygiene in their respective departments.
3. Chemical Hygiene Officer - The Office of Environmental Health and Safety has employed a chemical hygiene officer whose duties include:
a) Working with administrators and other employees to develop and implement appropriate chemical hygiene policies and practices;
b) Giving guidance in the procurement, use, and disposal of chemicals used in the laboratory;
c) Performing periodic laboratory inspections and certifications of chemical and radiation fume hoods;
d) Helping project directors develop precautions and adequate facilities;
e) Knowing the current legal requirements concerning regulated substances; and
f) Seeking ways to improve the chemical hygiene program.
4. Laboratory Supervisors - Laboratory supervisors have the overall responsibility for chemical hygiene in the laboratory including responsibility to:
a) Compose and implement individual chemical hygiene rules specific for their laboratory;
b) Ensure that workers know and follow the chemical hygiene rules, that protective equipment is available and in working order, and that appropriate training has been provided and documented;
c) Provide and document regular, formal chemical hygiene and housekeeping inspections including routine inspections of emergency equipment;
d) Know the current legal requirements concerning regulated substances;
e) Determine the required levels of protective apparel and equipment; and
f) Ensure that facilities and training for use of any material being ordered are adequate.
5. Laboratory Worker - The laboratory worker is responsible for:
a) Planning and conducting each operation in accordance with Tulane's chemical hygiene procedures; and
b) Developing good personal chemical hygiene habits.
The aim of Tulane's information and training program for the Laboratory Standard is to assure that all individuals at risk are adequately informed about the work in the laboratory, its risks, and what to do if an accident occurs. Here at Tulane, the supervisor plays a key role in composing and implementing the Chemical Hygiene Plan. As in the Hazard Communication Standard, the supervisor receives information and training and in turn communicates this information to his workers. The supervisor uses the information on specific chemicals found in his laboratory to compose rules and safe procedures for his employees to follow. The supervisor is the actual instructor making sure that the workers know about the hazards they face in their specific work area and how to do their particular jobs safely.
The Laboratory Standard requires that Tulane provide employees information and training at the time of their initial assignment and prior to assignments involving new hazardous chemicals or new exposure situations. Training should be a regular, continuing activity - not simply an annual presentation.
SPECIFIC TRAINING GUIDELINES
The laboratory supervisor should train the employee in the following categories:
1. The methods and observations that may be used to detect the presence of hazardous chemicals in the work area. This should include how to recognize a chemical by appearance or smell. It should also cover any steps Tulane may take to detect the presence of hazardous chemicals, such as air monitoring systems.
2. The signs and symptoms associated with exposures to hazardous chemicals used in the lab. An employee should be aware if his health is being affected by exposure to a hazardous material so that proper medical attention can be obtained. Symptoms such as headaches, nausea, skin rashes, eye irritations, dizziness, etc. can have many different causes, but they may be warning signs of a particular chemical exposure. This early warning system could be the key to preventing serious health problems. Consult the Material Safety Data Sheet for signs and symptoms of exposure.
3. The concept of OSHA's permissible exposure limits and the importance of eliminating unnecessary exposures to hazardous substances. OSHA has established safe exposure levels (PELs) for certain chemicals to which employees may be exposed for a working lifetime. The permissible exposure level of a particular chemical can be found on the Material Safety Data Sheet for that chemical. Employee exposures should not exceed these limits. If it is felt that the recommended limits are being exceeded, OEHS should be contacted for monitoring and advice.
4. The physical and health hazards associated with the chemicals in the work area. Health hazards of various chemicals used in the laboratory should be emphasized and the route of exposure explained. Physical hazards would include the toxic, corrosive, flammable, reactive, and radioactive properties associated with different chemicals. Not only is this information required for the Laboratory Standard, but it is almost identical to the requirements of the Hazard Communication Standard. The Material Safety Data Sheet and the chemical label are two good places to look for this information.
5. Appropriate protection measures including available protective apparel and equipment and proper emergency procedures. Once employees understand the hazards, they should take steps to protect themselves. This part of the training should be detailed and customized to the individual work area. Employees should be informed regarding engineering controls (hoods, etc.), work procedures, protective clothing and equipment, respirators if applicable, and emergency procedures. Protective apparel and equipment needed for a particular chemical can be found on the Material Safety Data Sheet.
6. The details of the Laboratory Standard and Tulane's Chemical Hygiene Plan. The written program Tulane has developed along with the supervisor's individualized operating procedures should be reviewed with emphasis placed on protecting the laboratory worker from health and other hazards associated with the laboratory.
7. Availability of reference material on hazards, safe handling, storage, and disposal of hazardous chemicals. This should include, but not be limited to, Material Safety Data Sheets. Literature and consulting advice concerning chemical hygiene should be readily available to laboratory personnel, who should be encouraged to use these information resources.
Receiving and stockroom/storeroom supervisors should train their personnel regarding the possible hazards of the chemicals they are handling, and give instruction on proper protective apparel and handling techniques. Personnel in these areas should be aware of the relevant regulations imposed by the Laboratory Standard.
All training should be documented for content as well as attendance (see training record form) with a copy being sent to OEHS and the safety committee having jurisdiction over the laboratory. Specific tasks and standard operating procedures should be discussed. Although training requirements seem extensive and time consuming, they are well worth it in the long run.
The Office of Environmental Health & Safety will be happy to assist with training aides or speakers on special topics (if available). Please call at 988-5486 to discuss training materials and questions you may have.
The design and maintenance of a laboratory facility is very important. Proper ventilation is needed, as well as other safety items such as emergency showers and eyewashes. The work conducted in a laboratory and its scale must be appropriate for the physical facilities available and for the quality of the ventilation. Chemical-hygiene-related equipment (hoods, glove boxes, incinerator, etc.) should undergo continuing appraisal and be modified if inadequate. The laboratory supervisor should communicate and work closely with OEHS as well as with maintenance or physical plant personnel to create a safe chemical environment for the laboratory projects to be performed.
The laboratory facility should be designed with the following features:
* An appropriate general ventilation system with air intakes and exhausts located so as to avoid intake of contaminated air.
* Adequate, well-ventilated stockrooms/storerooms.
* Laboratory hoods and sinks.
* Other safety equipment including eyewash fountains and safety showers.
* Proper fire code and life safety code requirements such as automatic sprinklers and fire alarm systems
In addition, requirements for proper ventilation include:
1. General laboratory ventilation - This system should provide a source of air for breathing and for input to local ventilation devices. It should not be relied on for protection from toxic substances released into the laboratory. It should ensure that the laboratory air is continually replaced, preventing increase of air concentrations of toxic substances during the working day. The general ventilation should direct air flow into the laboratory from non-laboratory areas and out to the exterior of the building.
2. Hoods - A laboratory hood with 2.5 linear feet of hood space per person should be provided for every 2 workers if they spend most of their time working with chemicals. It is recommended that each hood have a continuous monitoring device to allow convenient confirmation of adequate hood performance before use. If this is not available, work with substances of unknown toxicity should be avoided or other types of local ventilation devices should be provided. Airflow into and within the hood should not be excessively turbulent. Hood face velocity should be adequate (typically 100 lfm for chemical fume hoods, 125 lfm for radiation fume hoods). The OEHS will provide annual certification of all chemical and radiation fume hoods as well as biological safety cabinets and should be contacted if there is a problem with a particular hood.
3. Other local ventilation devices - Ventilated storage cabinets, canopy hoods, etc. should be provided as needed. Each canopy hood should have a separate exhaust duct. OEHS must be contacted before the purchase and installation of such equipment.
4. Special ventilation areas - Exhaust air from glove boxes and isolation rooms should be passed through scrubbers or other treatment before release into the regular exhaust system. Cold rooms and warm rooms should have provisions for rapid escape in the event of electrical failure. OEHS must be contacted before the purchase and installation of such equipment.
5. Modifications - Any alteration of the ventilation system should be made only if thorough testing indicates that worker protection from airborne toxic substances will continue to be adequate.
6. Performance - A rate of 4-12 room air changes per hour is normally adequate general ventilation if local exhaust systems such as hoods are used as the primary method of control.
7. Quality - General air flow should not be turbulent and should be relatively uniform throughout the laboratory, with no high velocity or static areas.
8. Evaluation - Quality and quantity of ventilation should be evaluated on installation, regularly monitored, and reevaluated whenever a change in local ventilation devices is made.
As required by law, supervisors must make inspections of the areas under their jurisdiction once every three months. These inspections are to be documented and retained on file for at least one year and copies sent to Tulane's School and Administrative Unit Safety and Health Committees with plans for corrective action. The School and Administrative Unit Safety Committee should review and forward the report to the University Safety Committee and OEHS. Section 20-01-05 of Tulane University's EHS Policy and Procedure Manual discusses inspections in detail. A copy of Section 20-01-05 and the laboratory inspection form is attached for reference.
Eye wash fountains should be inspected at least every three months by the laboratory supervisor and safety showers should be tested routinely by maintenance or physical plant personnel. Respirators and other safety equipment should be inspected periodically by the laboratory supervisor. Out-of-service or damaged equipment should be repaired or discarded. Stairways and halls are not storage areas; fire extinguishers are not coat racks. Access to exits, emergency equipment, and utility controls should never be blocked.
A laboratory should be kept neat and orderly. Keep aisles clear and work areas uncluttered. The cleaning of areas where toxic materials are handled, used or stored is the responsibility of those who use the area. The janitorial crew should not be expected to clean areas contaminated with hazardous materials. Proper protective equipment should be worn during cleaning. Floors should be cleaned regularly. Good housekeeping is essential to good laboratory technique.
Protective equipment that should be available to a laboratory should include the following:
* An easily accessible safety shower
* An eyewash fountain
* A fire extinguisher
* Respiratory protection for emergency use, if applicable
* A fire alarm nearby
* A nearby telephone for emergency use
* Protective apparel compatible with the required degree of protection for the substances being handled (eye protection, gloves, aprons, labcoats, etc.)
* Other items designated by the laboratory supervisor
All protective apparel and equipment should be in good working order. If damaged or defective, the supervisor should see that it is fixed or replaced.
The Supervisor's Role
The following section is a synopsis of safety precautions that should be observed when working with hazardous and toxic chemicals. The supervisor should act as a role model for his employees making sure that the safety message gets across. These are chemical safety basics that should be followed all the time. For concerns about specific chemicals, the supervisor should consult the material safety data sheets and other reference materials available to him. He then must relay this information to his workers. In other words, the laboratory supervisor should develop and compose laboratory-specific operating procedures based on the materials with which his particular laboratory is working, and ensure that his employees are familiar with these procedures. These standard operating procedures must be updated annually. In effect, the supervisor will be developing his own specific chemical hygiene plan for his laboratory. Copies of these operating procedures and the annual updates should be forwarded to OEHS.
Before a substance is received, information on proper handling, storage, and disposal techniques should be known and communicated to all those who will be involved. There is no substitute for adequate planning and knowledge. All hazardous properties of the material including any mutagenic, carcinogenic, and/or teratogenic potential should be determined. Large surpluses of chemicals should not be ordered, and less hazardous substances should be substituted if possible. Use only those chemicals for which the facilities and the quality of the available ventilation system is appropriate. No container should be accepted without an adequate identifying label. Material Safety Data Sheets should be obtained and kept on file for all chemicals used in the laboratory. Copies can be obtained through the Office of Environmental Health & Safety (see Tulane's Policy on the Hazard Communication Standard).
Stockrooms/storerooms should not be used as preparation or repackaging areas. Stored chemicals should be examined periodically for replacement, deterioration, and container integrity. Toxic substances should be segregated in a well-identified area with local exhaust ventilation. Chemicals which are highly toxic or extremely hazardous should be in unbreakable secondary containers. When chemicals are carried, they should be placed in an outside container or bucket. Freight-only elevators should be used if possible.
Amounts of chemicals stored in a laboratory should be as small as practical. Chemicals should be stored according to their hazard and compatibility class as found on the Material Safety Data Sheet. Flammables should be stored in flammable storage cabinets. Storage on bench tops and in hoods is not advised. Exposure to heat or direct sunlight should be avoided. Periodic inventories should be conducted, with unneeded items being discarded following proper disposal procedures. Contact OEHS for more information on hazardous waste or inventory procedures.
Prominent signs and labels of the following types should be posted:
* Emergency telephone numbers of emergency personnel, supervisors, and laboratory workers
* Identity labels showing contents of containers and associated hazards
* Location signs for safety showers, eyewash stations, other safety and first aid equipment, exits, and areas where food and beverage consumption and storage are permitted
* Warnings at areas or equipment where special or unusual hazards exist
Safe habits should be developed and encouraged to minimize unnecessary exposure to chemicals by any route. Avoid underestimation of risk. Do not smell or taste chemicals. Vent apparatus which may discharge toxic fumes (such as vacuum pumps, distillation columns, etc.) into local exhaust devices. Inspect gloves and test glove boxes before use. Do not allow release of toxic substances in cold rooms and warm rooms since these have contained recirculated atmospheres. Under no circumstances should an unprotected person be knowingly subjected to a hazardous environmental condition above the PELs established by OSHA.
Laboratories must comply with permissible exposure limits in effect for general industry. (This includes any established OSHA exposure limit whether it be a time-weighted average over an 8-hour work day, a ceiling value, or a short term exposure limit.) Regular instrumental monitoring of airborne concentrations of toxic substances is not usually justified or practical in laboratories, but may be appropriate when testing or redesigning hoods or other ventilation devices, or when a highly toxic substance is stored or used regularly. Exposure must be monitored if there is reason to believe that exposures routinely exceed the action level (or PEL if no action level is established for the substance) for a substance regulated by a standard which requires monitoring. If the initial monitoring shows exposure above the action level or PEL for a substance, the employer must immediately comply with the monitoring provisions of the relevant standard. The employer must notify the employee in writing of monitoring results within 15 days of receipt of those results. Contact OEHS for more information on monitoring or if you feel there is an exposure problem in your laboratory.
If monitoring is done and it is found that the action level or permissible exposure limit (PEL) is routinely exceeded (e.g., 3 times per week), then monitoring and medical provisions of the relevant industrial standard must be done until the exposure level is brought to or below that prescribed by the particular standard, or until the substance is no longer used in the same procedure. Engineering controls, personal protective equipment, and good hygiene practices should be used to control exposures. If exposure monitoring discloses a level below the action level or PEL, then no further monitoring is required and the Laboratory Standard is in effect.
Chemical accidents and spills can be dangerous and destructive, possibly causing bodily harm and/or property damage. If a chemical should get into the eyes, promptly flush the eyes with water for a prolonged period (15 minutes) and seek medical attention. If a chemical should get on the skin, remove any contaminated clothing and flush the affected area with water. If symptoms persist after washing, seek medical attention. If a chemical is ingested, consult the material safety data sheet and/or seek medical advice. Be sure to contact OEHS for assistance and advice in cleaning up the spilled material.
Spills should be cleaned up promptly using appropriate protective apparel and equipment. In the event of a chemical spill at Tulane:
1. Alert all personnel in the immediate area and your supervisor. Notify OEHS or University Police and provide them with information including: name and type of material, known hazards, amount spilled, actual location of spill, name of caller and telephone number, and department with responsibility over area where spill occurred. ;
2. If possible, without endangering yourself or others, confine the spill in a safe and cautious manner to help prevent further contamination (i.e., close doors, pull down sash of hood, etc.).
3. Do not reenter spill area without proper personal protective equipment, or as directed by OEHS.
4. Isolate area until clean up is complete.
5. Avoid contact with any spilled material.
6. Avoid breathing vapors.
7. If the spill is small and the hazards of the material are known, put on the proper protective equipment and absorb the spilled material with towels, spill pillows, or other absorbents as directed by OEHS. Do not use sand, newspaper, or other materials which have poor absorbent properties. Place the absorbed materials in a container, seal, and save for disposal by OEHS. If spill is too large, proceed to the next step.
8. Evacuate the area and close all exits to the area.
9. If needed, OEHS personnel will respond to contain, remove, and dispose of the spilled material. Personnel from the responsible department are required to provide support to OEHS personnel in the uncontaminated area.
10. Radioactive spills should be cleaned up in accordance with the Radiation Safety Manual.
1. Any chemical whose composition is unknown shall be assumed to be hazardous and should be handled accordingly.
2. Avoid eating, drinking, smoking, gum chewing, or application of cosmetics in areas where laboratory chemicals are present. Do not store food or beverages in refrigerators used for the storage of biological agents or hazardous chemicals. Avoid storage, handling, or consumption of food or beverages in storage areas, refrigerators, glassware or utensils which are also used for laboratory operations.
3. Handle and store laboratory glassware with care to avoid damage. Do not use damaged glassware. Do not remove rubber stoppers or rubber tubing by forcing. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Clean and decontaminate contaminated glassware. Use equipment only for its designed purpose.
4. All supplies of syringes and needles should be kept in a secure location to prevent theft. These should be disposed of in labeled, rigid, puncture resistant containers designed for that purpose and not in the regular trash. Contact OEHS for more information on proper disposal of sharps.
5. Wash hands and areas of exposed skin well with soap and hot water before leaving the laboratory.
6. Avoid practical jokes or other behavior which might confuse, startle, or distract another worker.
7. Do not use mouth suction for pipetting or starting a siphon. Suction bulbs or other mechanical devices should be used. Do not leave pipettes sticking out of bottles, flasks, or beakers, as this invites danger of tipping over.
8. Keep the work area clean and uncluttered, with chemicals and equipment being properly labeled and stored. Do not obstruct exits and aisles. Clean up the work area on completion of an operation or at the end of each day.
9. Clothing should be worn which protects as much of the body as possible. Confine long hair and loose clothing. Wear shoes at all times in the laboratory. Sandals are not recommended. It is recommended that laboratory coats be either worn in the laboratory or worn over the uniform when out of the laboratory and removed when working. (This is to reduce the spread of microorganisms from the laboratory to other areas.) Lab coats should be removed if contaminated. Safety screens and shields should be used when there is a potential for explosion or apparatus implosion. Wear appropriate eye protection where chemicals are stored or handled. Wear appropriate gloves when the potential for contact with toxic materials exists. Gloves should be inspected before use and replaced periodically. They should be appropriately resistant to the type of chemical being used.
10. Respiratory protection may be needed when effective engineering controls are not feasible, during emergencies, for certain maintenance operations, or while controls are being instituted. All personnel requiring respiratory protection should be properly trained in the procedures for use. Contact OEHS for more information and review Tulane's Policy and Procedure Manual on provisions for respiratory protection.
11. Seek information and advice about hazards, plan appropriate protective procedures, and plan positioning of equipment before beginning any new operation. If an operation will be left unattended, provide for containment of toxic substances in the event of a utility service failure (such as cooling water). Heat materials which liberate flammable vapors only in steam heated ovens. Avoid working alone in a laboratory, particularly if the procedures being conducted are hazardous. Unauthorized experiments and unauthorized use of laboratory equipment are prohibited at all times.
12. Do not operate centrifuges unless covers are closed being sure to keep dangling items such as neckties or ribbons out of the way. Do not centrifuge uncovered tubes of specimens or flammable liquids. Centrifugation creates a vacuum and volatilizes liquids into vapors and aerosols. Use caps or parafilm. Do not leave the tops of centrifuges in the open position.
13. Do not operate autoclaves unless trained in their proper operation. Do not open the autoclave door until both temperature and pressure are back to normal as indicated by the gauges. Be sure all supply system valves are in the OFF position before opening. Beware of steam which will permeate gloves. Loosen caps of any containers to allow equalization of pressures inside containers thus preventing explosions, boil overs, and implosions. Cellulose nitrate tubes may explode and should not be autoclaved.
14. Before any equipment is sent for repair, it should be thoroughly cleaned and decontaminated.
15. Be alert to unsafe conditions and see that they are corrected when detected.
Use the hood for operations which might result in release of toxic chemical vapors or dust. Hoods should also be used when working with flammable or noxious materials. As a rule of thumb, use a hood or other local ventilation device when working with any appreciable volatile substance with a threshold limit value of less than 50 ppm. (This information can be found on the Material Safety Data Sheet.) Confirm adequate hood performance before
use. Keep materials stored in hoods to a minimum and do not allow them to block vents or airflow. Leave the hood "on" when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is "off". The OEHS
will inspect hoods annually to check that they are operating properly. Fume hoods should be thoroughly decontaminated after use and exhaust ventilation filters replaced as necessary for safe operation of the hood.
The aim of Tulane's hazardous waste disposal program is to assure that minimal harm to people, other organisms, and the environment will result from the disposal of waste laboratory chemicals. Indiscriminate disposal by pouring waste chemicals down the drain or into the trash is unacceptable. Also hoods should not be used as a means for disposal of volatile chemicals. Each waste container should be properly labeled as to its contents. Arrangements should be made with the Office of Environmental Health & Safety for pick up or delivery to the hazardous waste storage areas on the various campuses for all chemicals that are no longer needed or wanted (see Tulane's Policy and Procedure Manual, Section 20-05).
Much of the hazardous waste that is collected by OEHS can be treated or recycled. Waste acids and bases may be neutralized to a pH of between 5.5 and 10.0 and released into the sanitary sewer with copious amounts of water. Some laboratories have reduced their waste generation by the redistillation and reuse of solvents. Large volumes of waste are shipped offsite for disposal. The majority of Tulane's waste is destroyed by high temperature incineration, neutralization, or offsite recycling. Very little waste is landfilled due to regulatory restrictions and environmental concerns. Waste is disposed of according to EPA and the Louisiana Department of Environmental Quality (DEQ) regulations. Radioactive waste is handled by the methods allowed by Radiation Safety Regulations.
All infectious waste is to be sterilized prior to disposal or packaged properly for immediate incineration. No untreated infectious waste is to be discarded into solid waste (normal trash) containers for disposal. Again contact OEHS for information on proper disposal of infectious waste.
For any experiment or project that requires the use of high risk substances such as explosives, "select carcinogens,"
reproductive toxins, or substances having a high degree of acute toxicity, a protocol sheet describing the project and procedures that will be followed should be submitted to OEHS. OEHS will review the protocol and distribute the information for review and comment to the Safety Committee having jurisdiction over the laboratory. In this manner all safety questions and concerns should be addressed.
When working with allergens (such as diazaomethane, isocyanates, bichromates, etc.) or substances of unknown allergenic activity, wear suitable gloves to prevent hand contact with these substances. If you are a woman of childbearing age, embryotoxic substances such as organomercurials, lead compounds, formamide, etc. should be handled only in a hood whose satisfactory performance has been confirmed. The "designated" area for use of such substances should be conspicuously labeled with restricted access and warning signs stating the hazard. Protective apparel (especially gloves) to prevent skin contact should be used. The supervisor should review the use of each of these materials and any procedural change that is made. Records should be kept of the amount of material on hand, the amount and date used, and the names of the workers involved. These records should be kept for an employee's entire length of employment plus 30 years. Emergency plans should also be developed.
Allergens and embryotoxins should be stored, properly labeled, in an adequately ventilated area in an unbreakable secondary container. The supervisor should be notified of all incidents of exposure or spills. A qualified physician should be consulted when appropriate (see medical program outlined below).
When substances such as diisopropylfluorophosphate, hydrofluoric acid, hydrogen cyanide, etc. are used in significant quantities, exposure to these toxic substances by any route should be minimized using all reasonable precautions. Use and store these substances only in designated areas posting special warning signs. Store breakable containers of these substances in chemically resistant trays. Also work and mount apparatus above such trays or cover work and storage surfaces with removable, absorbent, plastic backed paper. Always use a hood (whose satisfactory performance has been confirmed) or other containment device for procedures which may result in the generation of aerosols or vapors containing the substance. Trap released vapors to prevent their discharge with the hood exhaust.
Always avoid skin contact of these substances by using gloves, long sleeves, and other protective apparel as appropriate. Always wash hands and arms immediately after working with these materials. Maintain records of the amounts of these materials on hand, amounts used, and the names of workers involved. These records should be kept for an employee's entire length of employment plus 30 years. Be prepared for accidents or spills and have an emergency plan of action. Assure that at least 2 people are present at all times if a compound in use is highly toxic or of unknown toxicity. If a major spill occurs outside the hood, evacuate the area and contact OEHS. Assure that cleanup personnel wear suitable protective apparel and equipment.
Contaminated waste should be stored in closed, suitably labeled, impervious containers. Contaminated clothing or shoes should be thoroughly decontaminated or incinerated.
All rules listed above should be observed and the following supplemental rules added for work with substances of known high chronic toxicity in quantities above a few milligrams to a few grams, depending on the substance. Examples of chemicals in this category include such things as dimethylmercury and nickel carbonyl, benzo-a-pyrene, N-nitrosodiethylamine, other human carcinogens or substances with high carcinogenic potency in animals. A plan for the use and disposal of these materials should be prepared and approved by the laboratory supervisor.
All transfers and work with substances of high chronic toxicity should be conducted in a "designated area" such as a restricted access hood, a glove box, or a portion of a laboratory designated for the use of highly toxic substances. The "designated area" should be conspicuously marked with warning and restricted access signs. All people with access to the "designated area" should be aware of the substances being used there and take the necessary precautions. Any vacuum pumps used should be protected against contamination by scrubbers or HEPA filters and vented into the hood. Vacuum pumps or other contaminated equipment, including glassware, must be decontaminated in the hood before removal from the designated area. The designated area should then be decontaminated before normal work is resumed. On leaving a designated area, protective apparel should be removed and placed in an appropriate labeled container. Then the hands, forearms, face, and neck should be washed thoroughly.
Substances with high chronic toxicity should be stored in a ventilated, limited access area in appropriately labeled unbreakable, chemically resistant, secondary containers. Accurate records should be kept of the amounts of these substances stored and used, the dates of use, and the names of the users. If using toxicologically significant quantities of such substances on a regular basis, contact OEHS to arrange a consultation with a qualified physician concerning the desirability of regular medical surveillance (see medical program below). Contingency plans, equipment, and materials to minimize exposures of people and property should be readily available in case of an accident or spill. Waste should be chemically decontaminated whenever possible. Containers of contaminated waste including washings from contaminated flasks should be transferred from the controlled area in a secondary container under the supervision of authorized personnel.
Negative pressure glove boxes should have a ventilation rate of at least two volume changes/hour and a pressure of at least 0.5 inches of water to be suitable for work with substances of high chronic toxicity. Positive pressure glove boxes should be thoroughly checked for leaks before each use. In both cases, exit gases should be trapped or filtered through a HEPA filter and then released into the hood.
For large scale studies of animal work with chemicals of high chronic toxicity, special facilities with restricted access are preferable. Whenever possible, the toxic substance should be administered by injection or gavage instead of in the diet. If administration is in the diet, use a caging system under negative pressure or under laminar air flow directed toward HEPA filters. Procedures should be devised to minimize formation and dispersal of contaminated aerosols, including those from food, urine, and feces (e.g., use HEPA filtered vacuum equipment for cleaning, moisten contaminated bedding before removal from the cage, mix diets in closed containers in a hood). When working in the animal room, wear plastic or rubber gloves, a fully buttoned laboratory coat or jumpsuit, and other apparel and equipment that may be needed such as shoe and head coverings, respirators, etc. Dispose of contaminated animal tissues and excreta by incineration if the available incinerator can convert the contaminant to non-toxic products. Otherwise package the waste appropriately for burial in an EPA-approved site. Contact OEHS for details or questions on disposal procedures. In addition, see Tulane's Policy on the Medical Surveillance Program for Animal Handlers.
Tulane is required to provide employees with an opportunity to receive a medical consultation with a licensed physician whenever an event takes place in the work area such as a spill, leak, explosion or other occurrence which could result in the likelihood of a significant exposure to a hazardous chemical, or if the employee is exhibiting signs or symptoms associated with an exposure to a hazardous chemical. Medical surveillance should also be done if monitoring reveals an exposure level routinely (e.g., 3 times/week) above the action level or PEL for an OSHA-regulated substance with requirements for exposure monitoring and medical surveillance. The medical consultation is provided for the purpose of determining the need for a medical examination. The employee shall be afforded the opportunity to receive any exams recommended by the physician. All consultations and examinations shall be performed at a reasonable time and place without cost to the employee.
Anyone whose work involves regular and frequent handling of toxicologically significant quantities of a chemical should contact OEHS. A consultation will be set up with a qualified physician to determine on an individual basis whether a regular schedule of medical surveillance is desirable.
In the event an employee suffers a work-related injury, the incident should be immediately reported the supervisor who will complete a "First Report of Injury" form. The supervisor should see that the injured employee gets medical attention or first aid if needed.
The Office of Environmental Health and Safety will keep records of any exposure monitoring or medical consultations and/or examinations in accordance with the Laboratory Standard. In addition training records, inventory records, inspections, and material safety data sheets should be kept on file both in OEHS and in the laboratory.
The laboratory supervisor is responsible for his own safety and that of his workers. Under the Laboratory Standard, the supervisor should make sure that his workers receive proper operating procedures to follow and are trained to work with the specific chemical and toxic hazards present in the laboratory. Periodic inspections and daily observations should be done to ensure that employees are using their training and protecting themselves from harm. Safe practices are important in minimizing exposures and potential risks. Safety should be an integral part of every laboratory procedure and operation.
Policy and Procedure Manual - General Occupational Health and Safety Plan
20-01-05 Inspection and Compliance Operating Procedures
In order that the efforts to provide a safe and healthful campus environment at Tulane are carried out, there is a need to inspect (audit) the safety and health conditions of the facilities and operations of the University.
In the complex university environment many items affect the students, patients, visitors, employees, and the surrounding community. It is imperative that the environment be closely monitored and controlled. One method in achieving this objective is to perform inspections. The basic operating procedure involves periodic inspections of all University physical facilities and the operations performed therein, with the results documented in permanent record form. Inspections will be made by a representative of OEHS, with opportunity through notice to its Chairman, for a member of the School or Administrative Unit Safety Committee to participate, and inspections are also to be performed by the supervisor in charge of a particular job or shop, University-wide.
20-01-05.01 Reasons for Inspections
The University is subject to various types of inspections which serve the University in many ways. Some of which:
a. To detect unsafe and unhealthy conditions and/or actions.
b. To demonstrate the Administration's sincerity in accident prevention and the health and welfare of the employees, patients, students, and visitors.
c. To help inform employees, of the Environmental Health and Safety Program, as to hazardous activities associated with facilities.
d. To enable the members of the various Safety committees, the staff of the OEHS and other individuals with safety related responsibilities, to work with departmental personnel in improving the institutional environment.
e. To meet requirements set forth by Federal, State, local, licensing, and accrediting agencies.
20-01-05.02 Inspection Techniques ;
a. Inspections will be made utilizing prepared checklists, (See Checklists Attached).
b. The persons who make inspections should prepare themselves as follows:
1. Analyze incident experience of the area(s) to be inspected.
2. Familiarize themselves with the types of hazards inherent in the area(s) to be inspected.
3. Review of previous inspection reports. ;
c. Inspection personnel should be tactful in pointing out unsafe acts to employees and should notify the supervisor immediately.
d. The person in charge of the area to be inspected should be consulted prior to the inspection, and given the opportunity to participate in the inspection process . Other faculty to staff members may participate to the extent of commenting upon and bringing possible violations to the attention of those making the inspection.
e. Inspections should cover all areas of the University, but certain emphasis may be put on those areas where excessive numbers of employee incidents (accidents) occur.
f. Pictures will be used by the OEHS to document unsafe conditions and to compare with corrected facilities.
20-01-05.03 Inspection Types
a. Periodic inspections - Scheduled to be made at regular intervals. Such inspections may be monthly, semi-annually, annually, quarterly, or at other suitable intervals.
1. As required by law, supervisors must make inspections of the areas under their jurisdiction once every three months. These inspections are to be retained on file for one year and copies are to be sent to the School and Administrative Unit Safety and Health Committees with plans for corrective action. The School and Administrative Unit Safety Committee should review and forward the report to the University Safety Committee and the OEHS.
2. The representative from the OEHS will conduct periodic inspections also, but attempt not to duplicate recent inspection efforts of Safety and Health Committee Members.
3. School and Administrative Unit Safety and Health Committees and the University Safety Committee may make periodic inspections as deemed necessary.
b. General inspections - An inspection is to be made of the entire premises. Those areas that have been recently inspected should be avoided.
c. Intermittent inspections (walk-through) - this type of inspection is made at irregular intervals and may include a specific department, piece of potentially hazardous equipment, etc. Intermittent inspections tend to keep supervisors alert to find and correct unsafe conditions.
d. Special inspections (including imminent danger actions) - Often necessary because new and/or potentially hazardous equipment procedure has been implemented. In the event any manipulation, action or condition is discovered which in the opinion of the director of OEHS or his authorized representative, is consider to constitute unsafe situation with imminent danger potential, the Director of OEHS or his representative may order the immediate cessation or modification of such manipulations, actions, or conditions as may be deemed necessary. A special inspection may also be conducted as a follow-up to an incident investigation.
e. Agency inspections - This type of inspection is made at irregular intervals by OSHA, State Department of Environmental Quality, the City of New Orleans Fire Department, Division of Fire Prevention; State Health Department; the Office of the State Fire Marshal; insurance companies; State Division of Hospitals; Joint Commission on Accreditation of Hospitals, and others that pertain to environmental health and safety.
f. Complaint based inspections - Violations and deficiencies observed by affected persons may be reported by such persons directly to the OEHS which will inspect in response to valid complaints. Notification of the results of the inspection will be given to the complainant if requested. The rights of affected personnel in reporting complaints of matters affecting occupational health shall be exercised without retaliation on the part of any other person.
20-01-05.04 Inspection Personnel
a. The inspectors should have the following qualifications:
1. Knowledge of the incident experience of the area to be inspected.
2. Familiarity with the incident potential in the area to be inspected.
3. Ability to make practical recommendations for corrective action.
4. Diplomacy when interacting with personnel.
b. Inspectors should set an example by always wearing proper clothing in special areas (i.e., wear gown, cap and shoe covers in clean Central Service areas of Hospital, or protective eye wear in welding area, etc.)
c. The inspector may be:
1. Representatives of the OEHS.
2. Safety and Health Committee Members for periodic or special safety inspections.
3. Department heads/supervisors for in-house periodic(Quarterly) inspections.
4. Official Governmental Agency Inspectors or Insurance Company Inspectors for Agency inspections.
d. If possible, Safety and Health Committee inspectors should be assigned to areas in which they have knowledge but do not necessarily work.
e. Representative from the OEHS shall accompany all inspectors who perform Agency inspections and shall assist safety and health committee members with their inspection efforts.
20-01-05.05 Inspection Process
a. Inspection Process - The three general components of inspecting are: (1) solicit the assistance of the person in charge of the area, (2) walk-around to observe for unsafe conditions or actions, and (3) a closing conference with the person in charge of the area. Helpful inspection suggestions are as follows:
1. Make a note when the unsafe condition or action is discovered. All notes can be incorporated into the final report.
2. Use the check list when making the survey, if applicable.
3. Always indicate the exact location and nature of the hazard.
4. Avoid citing trivial items, as this will undermine inspection credibility but note them verbally to person in charge..
5. Conducting of a closing conference will help expedite corrective action.
6. Inspections should be done systematically and thoroughly.
b. Inspection reports
1. An Imminent Danger Report is used to report conditions requiring immediate action. This is done by submitting a work order, discontinuing an unsafe practice, etc.
2. Observed violations of safety and health standards, deficiencies, and non-compliance items observed during General, Special, Periodic and Intermittent Inspections will be recorded in written inspection reports for OEHS records. The original inspection report of all recorded violations will be sent to OEHS for disposition. The faculty or staff person responsible for the area inspected will make arrangements for and accomplishment of appropriate corrective action. The responsible person should respond to OEHS indicating corrective action taken with regard to each reported violation, or the reason for lack of abatement of violations. Such reasons should be set forth in sufficient detail to permit determination by OEHS, School/Administrative Unit Safety and Health Committee or University Safety Committee if further action is required.
20-01-05.06 Report Disposition
a. Supervisor's quarterly inspection reports should be sent to:
1. School and Administrative Unit Safety and Health Committees with plans for corrective action indicated on the form.
2. The OEHS for review by OEHS and The University Safety Committee as appropriate.
3. Appropriate person in charge of the area inspected.
b. School and Administrative Unit Safety and Health Committee inspection reports are to be sent to:
1. OEHS which will advise the University Safety Committee of such inspections.
2. The appropriate person in charge of the area inspected.
3. The University Risk Manager.
c. The OEHS inspection reports are to be sent to:
1. The appropriate person in charge of the area inspected.
2. The immediate supervisor of the person in charge of the area inspected.
3. The University Risk Manager who will advise the University Safety Committee of such inspections.
d. All agency inspection reports are to be sent to the Director of OEHS who will send the report or the applicable actions to those responsible for correcting any problems. These must be answered and OEHS will report to the inspecting agency as to corrective steps taken.
20-01-05.07 Remedial Action
a. The person responsible for the area inspected should take all corrective actions necessary for the resolution of the items noted on the inspection form..
b. The OEHS should be consulted when necessary on the type of corrective actions to be taken to ensure that such actions are adequate to correct the problem.
c. The Risk Manager may intervene, when necessary, to ensure remedial action.
20-01-05.08 Follow-up Action
a. Generally, a 15 day abatement period, longer if needed, will be allowed before initiating the "No Response Memorandum".
b. If no response is received by OEHS relative to the inspection report, the immediate supervisor and/or the appropriate School/Administrative Unit Safety and Health Committee may be contacted to assist in securing compliance.
c. Additional follow-up may be necessary if all violations have not been corrected within a reasonable time period.
20-01-05.09 Inspection Checklists
For the convenience of the School and Administrative Unit Safety Committees and the various department/section supervisors who must perform quarterly inspections of their areas, inspection checklists are included at the end of this section. Please note that these are just memory joggers and are not intended to be all inclusive or totally complete inspection forms. For that reason space has been provided at the end of the reports to include additional items noted during the inspection. Please note these inspection checklists have a column for "corrective action" and "anticipated date of correction." This has been set-up so that the person responsible for the area can respond to the inspection as to how and when the item(s) will be corrected. These inspection reports must not be ignored, but properly and legibly completed and forwarded as indicated previously under "Report Disposition."
Chemical Hygiene Plan
Policy and Procedure Manual - General Occupational Health and Safety Plan
20-03 Laboratory Safety
20-03-01 Chemical Hygiene Plan (Laboratory Standard)
a. Tulane University is firmly committed to providing each of its laboratory employees a safe and healthy work environment and protecting them from the adverse effects of toxic and hazardous chemicals. Laboratories generally differ from industry in that employees are exposed to multiple hazardous substances used intermittently on a small scale. OSHA's General Industry Standards did not adequately address this type situation, but instead dealt more with the use of a single chemical substance used constantly in large quantities. OSHA recognized the unique situation of laboratories and the need to protect laboratory workers, and thus the OSHA Laboratory Standard was developed to keep exposures below the permissible exposure limits in a laboratory setting. Tulane has developed this written Chemical Hygiene Plan in order to comply with the OSHA Laboratory Standard and to provide guidelines and procedures for a safe laboratory work environment.
b. Chemical Hygiene Plan Applicability
This written Chemical Hygiene Plan applies to all "laboratory" facilities at Tulane where relatively small quantities of multiple hazardous chemicals are used on a non-production basis. It does not apply to particular chemical use in a laboratory when that particular chemical comes under an OSHA substance specific standard that preempts the Laboratory Standard. (An example of this is formaldehyde use in histology, pathology, and anatomy laboratories; this is governed by the Formaldehyde Standard rather than the Laboratory Standard.) It also does not apply if exposure limits for a particular OSHA regulated chemical are routinely being exceeded. In the above cases more stringent rules will be needed in order to comply with OSHA's General Industry Standards. This Plan also does not apply to laboratory uses of hazardous chemicals which provide no potential for employee exposure such as procedures using chemically-impregnated test media (Dip-and-Read color strip tests), or commercially prepared kits where all reagents needed to conduct the test are contained in the kit (pregnancy test kits). Most laboratories at Tulane however meet OSHA's definition and criteria for a laboratory facility and will fall under this written Chemical Hygiene Plan.
c. Written Program Description
This Chemical Hygiene Plan contains general operating procedures to be followed when hazardous chemicals are used, criteria to determine and implement control measures to reduce employee exposure to hazardous chemicals, and specific measures that ensure protection from hazardous and toxic exposures such as adequate performance of fume hoods and other protective equipment. It also addresses provisions for employee information and training, circumstances requiring prior approval from Tulane's administration, provisions for medical consultation and examinations, designation of a chemical hygiene officer, and provisions for worker protection for work with particularly hazardous substances (select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity).
This written program is to be supplemented with laboratory-specific operating procedures written by the laboratory supervisors and based on the materials present in a particular lab. (For a list of hazardous chemicals used at Tulane and the means used to inform employees of the hazardous properties associated with these chemicals, see Section 400 Hazard Communication Plan of Tulane University's EHS Policy and Procedure Manual.)
d. Review and Update
The Chemical Hygiene Plan will be reviewed and its effectiveness evaluated by OEHS annually. It will be updated as necessary.
e. Access to the Written Program
This written Chemical Hygiene Plan is available to employees, their designated representatives and other parties having a need to view this document.
The success of this Chemical Hygiene Plan depends to a great extent upon the cooperation of every laboratory supervisor and employee. Employees should be alert to the potential hazards of the material in their work area, and should follow the appropriate work practices that have been established by their supervisors and the administration to protect their health and safety. Employees should plan and conduct each operation in accordance with Tulane's chemical hygiene procedures and develop good personal chemical hygiene habits.
Supervisors have a responsibility to compose and implement chemical hygiene rules specific for their laboratory and ensure that their employees follow these rules. They are responsible for determining the required levels of protective apparel and equipment (OEHS may be contacted for assistance in this area), and for making sure that this protective equipment is available and in working order. They must also see that appropriate laboratory safety training is provided. In addition, supervisors have a responsibility to routinely (at least every quarter) inspect their labs and equipment and to report unsafe conditions and practices to the appropriate safety committee for review so that these may be corrected. They should know the current legal requirements concerning regulated substances and ensure that facilities and training for use of any material being ordered are adequate.
g. The Chemical Hygiene Officer
An employee of the Office of Environmental Health & Safety who is qualified by training or experience to provide technical guidance in the development and implementation of Tulane's Chemical Hygiene Plan shall be designated as the Chemical Hygiene Officer for Tulane. This person shall work with administrators and other employees to develop and implement appropriate chemical hygiene policies and practices, giving guidance in the procurement, use, and disposal of chemicals used in the laboratory. Other duties include training the supervisors regarding the Laboratory Standard and Tulane's Chemical Hygiene Plan, performing periodic lab inspections and audits, annual certification of chemical and radiation fume hoods, helping project directors to develop precautions and adequate facilities, advising on the current legal requirements concerning regulated substances, and promoting the chemical hygiene program and laboratory safety throughout Tulane's facilities. The Chemical Hygiene Officer will work with the Safety Committee System set up in Section 1-03 of Tulane University's EHS Policy and Procedure Manual in order to advise and correct unsafe laboratory conditions and to establish necessary policies on laboratory safety and health.
20-03-01.02 Standard Operating Procedures - General Laboratory Safety Guidelines
See Section 20-03-02 Laboratory Safety Guide, Section 20-02-02 Procedures for the Storage and Use of Flammable and Combustible Liquids, Section 20-04 Radiation Protection, Section 20-03-04 Compressed Gases and Cylinders, and Section 20-05 Hazardous Materials Handling and Disposal of Tulane University's EHS Policy and Procedure Manual.
a. The recommendations and procedures discussed in this chemical hygiene plan and relevant sections of Tulane University's EHS Policy and Procedure Manual should be instituted in each laboratory at Tulane. Following these procedures should be a regular continuing effort and not a standby or short-term activity. The recommendations should be followed in academic teaching laboratories as well as by full-time laboratory workers.
b. Important Terms
The term "hazardous chemical" in respect to the Laboratory Standard means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees.
The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes.
A "physical hazard" means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive.
The term "select carcinogen" means any substance which meets one of the following criteria:
(i) It is regulated by OSHA as a carcinogen; or
(ii) 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
(iii) It is listed under Group 1 (carcinogenic to humans") by the International Agency for Research on Cancer Monographs (IARC) (latest editions); or
(iv) 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:
(A) 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;
(B) After repeated skin application of less than 300 (mg/kg of body weight) per week; or
(C) After oral dosages of less than 50 mg/kg of body weight per day.
The term "reproductive toxin" means any chemical which affects the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis).
A "designated area" is an area that must be established for work with "select carcinogens", reproductive toxins, or substances with a high degree of acute toxicity. This may be the entire laboratory, an area of the laboratory, or a device such as a laboratory hood.
The "toxicity" of a material is due to its ability to damage or interfere with the metabolism of living tissue. An "acutely toxic" substance can cause damage as the result of a single or short-duration exposure. A "chronically toxic" substance causes damage after repeated or long-duration exposure or that becomes evident only after a long latency period.
c. Purchasing, Receiving, & Distributing Chemicals
When purchasing a hazardous chemical, order in minimum quantities. Try to anticipate and order only what is needed. Before a chemical is received, information on the hazardous properties as well as proper handling, storage, and disposal techniques should be known to those who will be involved. The supervisor should make sure that the facilities are adequate for the chemical that will be used, and that proper personal protective equipment is available and in good condition. No container should be accepted without an adequate identifying label. MSDS's should be obtained for new and existing chemicals and should be readily accessible to laboratory employees. When transporting chemicals from receiving or a storage area, a freight-only elevator should be used if possible and secondary containment such as an outside container or bucket may be desirable.
d. Avoidance of "Routine" Exposure
1. Every effort should be made to minimize chemical exposures. Because few chemicals are without hazards, general precautions for handling all laboratory chemicals should be adopted. Skin contact with chemicals should be avoided as a cardinal rule, but one should also refrain from unnecessary exposure to chemicals by any route. Safe laboratory habits must be developed and encouraged.
2. Avoid underestimation of risk. Even for substances of no known hazard, exposure should be minimized. For work with substances which present special hazards, special precautions should be taken. See rules for "select carcinogens," embryotoxins, and substances with a high degree of acute toxicity discussed later in this document. One should assume that any mixture will be more toxic than its most toxic component, and that all substances of unknown toxicity are toxic.
3. Provide for adequate ventilation when using hazardous and toxic chemicals. Use only those chemicals for which the quality of the ventilation system is appropriate. Vent apparatus which may discharge toxic chemicals (vacuum pumps, distillation columns, etc.) into local exhaust devices. The best way to prevent exposure to airborne substances is to prevent their escape into the working atmosphere through the use of hoods and other ventilation devices. Confirm adequate hood performance before use.
4. Do not smell or taste chemicals. Inspect gloves and test glove boxes before use. Do not allow release of toxic substances in cold rooms and warm rooms, since these have contained recirculated atmospheres.
5. Observe the permissible exposure limits (PELs) and time weighted averages (TLVs) put out by OSHA and the American Conference of Governmental Industrial Hygienists and do not exceed these.
6. Amounts of chemicals kept in a laboratory should be as small as practical. Periodic inventories should be conducted with unneeded or deteriorating items being discarded.
Laboratories should be inspected quarterly by the laboratory supervisor. See Section 20-01-05 Inspection and Compliance Operating Procedures of Tulane University's EHS Policy and Procedure Manual for details, an inspection form, and reporting requirements.
Stairwells and hallways should not be used as storage areas. Access to exits, emergency equipment, and utility controls should never be blocked. Chemical storage in hoods should be kept to a minimum and should not block vents or airflow. Chemical exposure to heat or direct sunlight should also be avoided. Chemicals should be segregated as to their hazard class with incompatible or reactive chemicals stored away from substances that could cause a reaction. Toxic substances should be stored in unbreakable secondary containers.
g. Signs and Labels
Prominent signs and labels should be posted in a laboratory listing emergency phone numbers; locations of safety showers, eyewash stations, and other safety and first aid equipment; and warnings at areas or equipment where special or unusual hazards exist. In addition, identity labels showing contents of containers and associated hazards should be provided in accordance with Tulane University's Hazard Communication Policy (see Section 400 of Tulane University's EHS Policy and Procedure Manual).
For chemical spill control procedures see Section 20-05-03 of Tulane University's EHS Policy and Procedure Manual.
i. Waste Disposal
For chemical waste disposal procedures see Section 20-05 of Tulane University's EHS Policy and Procedure Manual.
j. Chemical Synthesis/Right-to-know
When a chemical substance is developed in a laboratory and the composition of the substance which is produced exclusively for the laboratory's use is known, the laboratory supervisor shall determine if the substance is a hazardous chemical. If so, he shall provide training as required in this document. If the chemical produced is a by-product whose composition is not known, the supervisor shall assume that the substance is hazardous and shall follow the provisions of this Chemical Hygiene Plan. If the chemical substance is produced for another user outside of the laboratory, the supervisor shall comply with the Hazard Communication Standard including the requirements for preparation of Material Safety Data Sheets and labeling.
20-03-01.03 Exposure Monitoring Policy
a. Regular instrumental monitoring is not usually justified or practical in laboratories but may be appropriate when testing or redesigning hoods or other ventilation devices or when a highly toxic substance is stored or used regularly. Contact OEHS for advice in these type situations.
b. For laboratory uses of OSHA regulated substances, employee exposures must not exceed the permissible exposure limits specified in 29 CFR part 1910, subpart Z. OEHS will measure an employee's exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels for that substance routinely (e.g., 3 times/week) exceed the action level (or in the absence of an action level, the PEL).
c. If the initial monitoring prescribed above discloses employee exposure over the action level (or in the absence of an action level, the PEL), OEHS will immediately comply with the exposure monitoring provisions of the relevant standard. OEHS will work with Maintenance or Physical Plant as well as with the laboratory worker to institute control measures (engineering controls, the use of personal protective equipment and hygiene practices, etc.) to reduce exposures, including a total shut-down of the operation if deemed appropriate.
d. Monitoring may be terminated in accordance with the relevant standard.
e. OEHS will notify the employee in writing of any monitoring results within 15 days after the receipt of the results. This may be done either individually or by posting the results in an appropriate location that is accessible to employees.
f. OEHS shall establish and maintain for each employee an accurate record of any measurements taken to monitor exposures. These records shall be kept, transferred, and made available in accordance with 29 CFR 1910.20.
20-03-01.04 Ventilation, Fume Hoods & Engineering Control Measures
a. All laboratories at Tulane should be designed with an appropriate general ventilation system with air intakes and exhausts located so as to avoid intake of contaminated air. This system should provide a source of air for breathing and for input to local ventilation devices; it should not be relied upon for protection from toxic substances released into the laboratory. Maintenance and physical plant personnel should ensure that laboratory air is continually replaced with at least 4-12 room air changes/hour to prevent an increase of air concentrations of toxic substances during the working day, and that the general airflow is relatively uniform throughout the laboratory with no high velocity or static areas. Air should flow into the laboratory from non-laboratory areas and out to the exterior of the building.
b. Laboratories should be equipped with laboratory hoods and sinks as dictated by the specific chemicals or hazards that will be used in that laboratory. Laboratory fume hoods with 2.5 linear feet of hood space per person should be provided for every 2 workers if they spend most of their time working with chemicals.
c. Other safety equipment such as eyewash fountains and safety showers should be readily available where hazardous chemicals are used. Eyewash fountains should be inspected at least every three months by laboratory personnel, and safety showers should be tested routinely (at least annually) by Maintenance or Physical Plant. Dated inspection records should be kept on these items.
d. Fume hoods should have a continuous monitoring device to allow convenient confirmation of adequate hood performance before use. If this is not possible, work with toxic substances or substances of unknown toxicity should be avoided, or other types of local ventilation devices should be provided. Maintenance or Physical Plant should check the performance of the continuous monitoring devices at least annually to assure that these are operating properly.
e. Airflow into and within the hood should not be excessively turbulent. Hood face velocity should be adequate (typically 80-120 lfm for chemical fume hoods, 125 lfm for radiation fume hoods at full sash). The OEHS will provide annual certification of all chemical and radiation fume hoods as well as biological safety cabinets and should be contacted if there is a problem with a particular hood. If a hood's airflow is deemed inadequate, the hood, in addition to the continuous monitoring device discussed above, will be appropriately labeled with a warning sign until such time as modifications and repairs have been made and its efficiency determined. Work with toxic substances or substances of unknown toxicity should be avoided, or other types of local ventilation used until the hood is repaired.
f. Cold rooms and warm rooms should have provisions for rapid escape in the event of electrical failure.
g. Any alteration of the ventilation system should be made only if thorough testing indicates that worker protection from airborne toxic substances will continue to be adequate. Laboratory workers should be warned by Maintenance or Physical Plant personnel whenever work is being performed on the ventilation system and proper shutdown notices should be posted.
h. The quality and quantity of ventilation should be evaluated by maintenance or physical plant personnel on installation, regularly monitored, and reevaluated whenever a change in local ventilation devices is made.
i. The laboratory supervisor should make sure that the work conducted in the laboratory is appropriate to the physical facilities available and to the quality of the ventilation.
20-03-01.05 Personal Protective Equipment Policy
See Section 20-01-06 Provisions for Personal Protective Equipment and Clothing of Tulane University's Policy and Procedure Manual. Also see Section 20-01-07 Respiratory Protection Policy.
a. Personal protective equipment for each laboratory should include apparel compatible with the required degree of protection for the substances being handled, an easily accessible drench-type safety shower, an eyewash fountain, a fire extinguisher, respiratory protection, a fire alarm, a telephone for emergency use, and other items designated by the laboratory supervisor.
b. Under no circumstances should an unprotected person be knowingly subjected to a hazardous environmental condition above the PELs established by OSHA.
c. Where the use of respirators is necessary to maintain exposure below permissible exposure limits, proper respiratory equipment shall be provided at no cost to the employee. Respirators shall be selected and used in accordance with the requirements of 29 CFR 1910.134 and Tulane's Respiratory Protection Policy. They should be inspected before use and checked periodically by the laboratory supervisor.
d. It shall be the supervisor's responsibility to see that all protective apparel is appropriate for the tasks to be performed and that the equipment is in good condition. No gloves should be used if they are peeling, cracked, or discolored, or if they have punctures, tears, or other evidence of deterioration. All personal protective equipment should be inspected regularly by the laboratory supervisor (every 3-6 months). The supervisor should develop procedures to prevent the use of out-of-service equipment.
20-03-01.06 Employee Information and Training Program Policy
a. All employees working with or potentially exposed to hazardous chemicals will be appropriately informed and trained concerning the potential hazards of the chemicals to which they may be exposed (see Section 400 Hazard Communication Plan of Tulane University's EHS Policy and Procedure Manual) as well as the proper procedures and precautions to follow when using or during exposure to these chemicals. (See Employee Training Record 30-05 of Tulane University's EHS Policy and Procedure Manual.)
Employee Information includes:
1. The contents of the Laboratory Standard and its appendices.
2. The location and availability of Tulane's written Chemical Hygiene Plan.
3. Permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard.
4. Signs and symptoms associated with exposures to hazardous chemicals used in the lab.
5. The location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier.
b. Employee Training includes:
1. Methods and observations that may be used to detect the presence or release of hazardous chemicals in the work area (such as monitoring by OEHS, continuous monitoring devices, visual appearance or odor of hazardous chemicals, etc.).
2. The physical and health hazards of the chemicals in the work area.
3. The measures employees can take to protect themselves from these hazards, including specific procedures Tulane has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used. Every laboratory worker should know the location and proper use of available personal protective apparel and equipment.
4. The applicable details of Tulane's Chemical Hygiene Plan.
OEHS is responsible for implementing the employee information and training program.
c. OEHS will train all laboratory supervisors, directors, and department heads in the subjects required by OSHA. These supervisors, directors, and department heads will then be responsible for training their employees in the use of potentially hazardous and toxic materials. The training curriculum will consist of on-the-job instruction designed to be work-area specific. The aim of training is to assure that all individuals at risk are adequately informed about the work in the laboratory, its risks, and what to do if an accident occurs.
d. OEHS has prepared a Laboratory Standard training curriculum outline for use by supervisory personnel. The training curriculum outline will be issued at the supervisor training sessions.
e. All laboratory employees are required to go through the Laboratory Standard training curriculum that has been designed as part of the employee information and training program for the use of hazardous and toxic materials.
f. An introductory training period explaining this program will be given to all new employees during orientation. More detailed information and training will be provided at the time of an employee's initial assignment to work with hazardous or toxic chemicals, or whenever a new hazardous chemical or exposure situation is introduced into the work area. The initial training will be completed as expeditiously as possible. Periodic updates and reinforcement will be conducted through verbal communications from informed supervisors and through topics at safety meetings, as appropriate.
g. Before any non-routine task is performed that could involve exposure to hazardous or toxic chemicals, the employee's supervisor will carefully review all potential hazards of the task with the employee and will prescribe appropriate work practice procedures. OEHS will assist if contacted.
20-03-01.07 Prior Approval Policy
For any experiment, research proposal, or sponsored project that requires the use of high risk substances such as explosives, "select carcinogens," reproductive toxins, or substances having a high degree of acute toxicity, a protocol sheet describing the project and the operating procedures that will be followed should be submitted to OEHS. OEHS will review the protocol sheet and distribute the information for review and comment to members of the Safety Committee having jurisdiction over the laboratory. OEHS will correspond with the researcher and the Safety Committee presiding so that all safety questions and concerns can be addressed.
20-03-01.08 Medical Consultations and Examinations Policy
a. Whenever an employee develops signs or symptoms associated with a hazardous chemical to which he or she may have been exposed in the laboratory, the employee shall be provided with an opportunity to receive an appropriate medical examination. This would be considered an occupational injury/illness, and the policies and procedures established in section 20-01-03 of the Tulane University Policy and Procedure Manual dealing with Occupational Injury/Illness Reporting and Recordkeeping should be followed.
b. Where exposure monitoring reveals an exposure level routinely (e.g., 3 times/week) above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance shall be established for the affected employee as prescribed by the particular standard. The medical surveillance records, along with personal or area monitoring results will be maintained by OEHS for the minimum of time required by law or regulations.
c. 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, the affected employee shall be provided an opportunity for a medical consultation. Such consultation shall be for the purpose of determining the need for a medical examination. Again policies established in Section 20-01-03 of Tulane University's Policy and Procedure Manual dealing with Occupational Injury/Illness Reporting and Recordkeeping Should be followed.
d. All medical examinations and consultations required by law in the above instances shall be performed by or under the direct supervision of a licensed physician and shall be provided without cost to the employee, without loss of pay, and at a reasonable time and place in accordance with Section 20-01-03 of Tulane University's EHS Policy and Procedure Manual. First aid procedures are covered in Section 20-01-02 of Tulane University's EHS Policy and Procedure Manual.
e. For all medical consultations and examinations required by law in the instances listed above, the physician shall be provided with information on the identity of the hazardous chemical(s) to which the employee may have been exposed, a description of the conditions under which the exposure occurred (including quantitative exposure data, if available), and a description of the signs and symptoms of exposure that the employee is experiencing, if any. Material Safety Data Sheets on the chemical(s) should be obtained and given to the physician if requested. See Section 400 of Tulane University's EHS Policy and Procedure Manual (Tulane's Hazard Communication Policy) for more information on Material Safety Data Sheets.
f. For all examinations or consultations performed in accordance with this policy, a written opinion from the examining physician shall be obtained and forwarded to the Office of Risk Management with a copy to OEHS. This written opinion shall include any recommendation for further medical follow-up, the results of the medical examination and any associated tests, any medical condition revealed in the course of the examination that may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace, and a statement that the employee has been informed by the physician of the results of the examination or consultation and any medical condition that may require further examination and treatment. These medical records shall be retained, transferred, and made available in accordance with the requirements of 29 CFR 1910.20 and other state and federal regulations.
g. The written opinion shall not reveal specific findings of diagnoses unrelated to occupational exposure.
20-03-01.09 Work with "Select Carcinogens," Reproductive Toxins, and Substances with a High Degree of Acute Toxicity
a. Inventory and usage records of high-risk substances such as these should be kept. These records should state the amount of material on hand, the amount and date used, and the names of the workers involved. It is the supervisor's responsibility to see that these records are kept up to date and accurate.
b. In addition to inventory and usage records, the supervisor should prepare standard operating procedures as well as an emergency plan to follow when using these high-risk chemicals. These procedures should be added to this written Chemical Hygiene Plan as an addendum with a copy being sent to OEHS, and should be reviewed and updated annually. In the event of an emergency such as a spill or leak outside of a hood, OEHS must be contacted immediately. The area should be evacuated until cleanup and decontamination by trained personnel wearing appropriate protective equipment is complete.
c. A "designated area" must be established for work with "select carcinogens", reproductive toxins, or substances with a high degree of acute toxicity. This may be the entire laboratory, an area of the laboratory, or a device such as a laboratory hood. The designated area should be conspicuously marked with restricted access and special warning signs stating the hazard. All people with access to the area should be aware of the substances being used and the necessary precautions.
d. Use of containment devices such as fume hoods or glove boxes is highly recommended when using "select carcinogens", reproductive toxins, and substances with a high degree of acute toxicity. Confirm adequate performance before use. Released vapors and aerosols should be trapped to prevent their discharge with the hood exhaust.
e. Always wash hands and arms immediately after working with any of these materials. Avoid skin contact by use of gloves and long sleeves, and other protective apparel as appropriate. Be sure to remove protective apparel on exiting the designated area.
f. High risk substances should be properly labeled and stored in an adequately ventilated area in an unbreakable secondary container such as a chemically resistant tray capable of containing the contents of the primary container should it break. Work and storage surfaces should be covered with removable, absorbent, plastic backed paper for ease in decontamination and cleanup.
g. A wide variety of substances known as allergens can produce skin and lung hypersensitivity. Examples include diazomethane, chromium, nickel, isocyanates, bichromates and certain phenols. Because of the variety and the varying response of individuals, suitable gloves should be used whenever hand contact with allergens or substances of unknown allergenic activity is probable. Wash hands and exposed areas of skin thoroughly after use.
h. Women of childbearing age should handle embryotoxins (examples: organomercurials, lead compounds, formamide) only in a hood whose satisfactory performance has been confirmed, using appropriate protective apparel (especially gloves) to prevent skin contact. Review each use of these materials with the research supervisor and review continuing uses annually or whenever a procedural change is made. OEHS should be notified of all incidents of exposure or spills requiring special control.
i. When working with chemicals of moderate chronic or high acute toxicity (examples: hydrogen cyanide, hydrogen sulfide, nitrogen dioxide, vinyl chloride, diisopropylflurophosphate, hydrofluoric acid), exposure by any route should be minimized by taking all reasonable precautions. At least two people should be present at all times when working with these materials. A hood or other containment device should always be used especially for procedures involving volatile toxic substances or aerosol generation, and suitable protective apparel including gloves and long sleeves should be worn. Wash hands and arms immediately after use. If a major spill occurs outside the hood, the area should be evacuated and OEHS contacted immediately for cleanup procedures. Volatile toxic substances should never be disposed of by evaporation in the hood, but should be chemically decontaminated, if possible, by chemical conversion. If this is not feasible, waste materials should be stored in closed, impervious, properly labeled containers so that personnel handling the containers will not be exposed to their contents. Contact OEHS for waste disposal collection procedures.
j. When working with chemicals of high chronic toxicity (examples: dimethylmercury and nickel carbonyl, benzo-a-pyrene, N-nitrosodiethylamine, 3-methylcholanthrene, dimethylcarbamoyl chloride, hexamethylphosphoramide, bis(chloromethyl)ether, or other "select carcinogens"), all of the procedures and precautions described above should be followed. In addition, the laboratory supervisor should review each worker's plans for experimental work to ensure that the toxic material is effectively contained during the experiment and that wastes are disposed in a safe manner. Storage areas for substances in this category should have limited access and should be maintained under negative pressure with respect to surrounding areas. When a negative pressure glove box is used, the ventilation rate must be at least 2 volume changes/hour, the pressure at least 0.5 inches of water lower than the external environment, and exit gases should be passed through a trap or HEPA filter. For a positive pressure glove box, thoroughly check for leaks before use and again pass exit gases through a trap or HEPA filter. Vacuum pumps should be protected against contamination by scrubbers or HEPA filters. All equipment including glassware should be decontaminated before removing from the "designated" area, and the "designated" area should be thoroughly decontaminated before normal work is resumed there.
k. When doing animal work with chemicals of high chronic toxicity, administer the substance by injection or gavage instead of in the diet whenever possible. If administration is in the diet, use a caging system under negative pressure or under laminar air flow directed toward HEPA filters. Minimize formation and dispersal of aerosols including those from food, urine and feces by using HEPA filtered vacuum equipment when cleaning, moistening contaminated bedding before removal from the cage, and mixing diets in closed containers in a hood. Wear suitable protective clothing and dispose of wastes properly.
INCOMPATIBLE CHEMICAL LIST
PRUDENT PRACTICES FOR HANDLING CHEMICALS IN LABORATORIES
Examples of Incompatible Chemicals
|CHEMICAL||IS INCOMPATIBLE WITH|
|Acetic Acid||Chromic acid, nitric acid, hydroxyl compounds, ethylene glycol, perchloric acid, peroxides, permanganates|
|Acetylene||Chlorine, bromine, copper, fluorine, silver, mercury|
|Acetone||Concentrated nitric and sulfuric acid mixtures|
|Alkali and alkaline earth metals (such as powdered aluminum or magnesium, calcium, lithium, sodium, potassium)||Water, carbon tetrachloride or other chlorinated hydrocarbons, carbon dioxide, halogens|
|Ammonia (anhydrous)||Mercury (in manometers, for example), chlorine, calcium hypochlorite, iodine, bromine, hydrofluoric acid (anhydrous)|
|Ammonium nitrate||Acids, powdered metals, flammable liquids, chlorates, nitrites, sulfur, finely divided organic or combustible materials|
|Aniline||Nitric acid, hydrogen peroxide|
|Arsenical materials||Any reducing agent|
|Carbon (activated)||Calcium hypochlorite, all oxidizing agents|
|Chlorates||Ammonium salts, acids, powdered metals, sulfur, finely divided organic or combustible materials|
|Chromic acid and chromium trioxide||Acetic acid, naphthalene, camphor, glycerol, alcohol, flammable liquids in general|
|Chlorine||Ammonia, acetylene, butadiene, butane, methane, propane (or other petroleum gases), hydrogen, sodium carbide, benzene, finely divided metals, turpentine|
|Chlorine dioxide||Ammonia, methane, phosphine, hydrogen sulfide|
|Copper||Acetylene, hydrogen peroxide|
|Cumene hydroperoxide||Acids (organic and inorganic)|
|Flammable liquids||Ammonium nitrate, chromic acid, hydrogen peroxide, nitric acid, sodium peroxide, halogens|
|Hydrocarbons (such as butane, propane, benzene)||Fluorine, chlorine, bromine, chromic acid, sodium peroxide|
|Hydrocyanic acid||Nitric acid, alkali|
|Hydrofluoric acid (anhydrous)||Ammonia (aqueous or anhydrohydrous)|
|CHEMICAL||IS INCOMPATIBLE WITH|
|Hydrogen peroxide||Copper, chromium, iron, most metals or their salts, alcohols, acetone, organic materials, aniline, nitromethane, combustible materials|
|Hydrogen sulfide||Fuming nitric acid, oxidizing gases|
|Hypochlorites||Acids, activated carbon|
|Iodine||Acetylene, ammonia (aqueous or anhydrous), hydrogen|
|Mercury||Acetylene, fulminic acid, ammonia|
|Nitric acid (concentrated)||Acetic acid, aniline, chromic acid, hydrocyanic acid, hydrogen sulfide, flammable liquids, flammable gases, copper, brass, any heavy metals|
|Nitroparaffins||Inorganic bases, amines|
|Oxalic Acid||Silver, mercury|
|Oxygen||Oils, grease, hydrogen, flammable liquids, solids, or gases|
|Perchloric acid||Acetic anhydride, bismuth and its alloys, alcohol, paper, wood, grease, oils|
|Peroxides, organic||Acids (organic or mineral), avoid friction, store cold|
|Phosphorus (white)||Air, oxygen, alkalis, reducing agents|
|Potassium||Carbon tetrachloride, carbon dioxide, water|
|Potassium chlorate||Sulfuric and other acids|
|Potassium perchlorate (see also chlorates)||Sulfuric and other acids|
|Potassium permanganate||Glycerol, ethylene glycol, benzaldehyde, sulfuric acid|
|Silver||Acetylene, oxalic acid, tartartic acid, ammonium compounds, fulminic acid|
|Sodium||Carbon tetrachloride, carbon dioxide, water|
|Sodium nitrite||Ammonium nitrate and other ammonium salts|
|Sodium peroxide||Ethyl or methyl alcohol, glacial acetic acid, acetic anhydride, benzaldehyde, carbon disulfide, glycerin, ethylene glycol, ethyl acetate, methyl acetate, furfural|
|Sulfuric acid||Potassium chlorate, potassium perchlorate, potassium permanganate (similar compounds of light metals such as sodium, lithium)|
LABORATORY STANDARD TRAINING GUIDELINES
A. OSHA Laboratory Standard - May 1, 1990
B. Tulane's Chemical Hygiene Plan - January 31, 1991 - OEHS Policies and Procedures Manual
C. Standard Operating Procedures - written by Laboratory Supervisor
D. Tulane's Chemical Hygiene Officer - Pam Fatland, Office of Environmental Health & Safety, 988-5486
II. Sources of Chemical Information
A. Container Labels
B. Material Safety Data Sheets
C. Chemical Dictionary, Merck Index
D. Other reference material
1. Flammables, Combustibles
3. Organic Peroxides
4. Water Reactives
5. Explosives, Unstable Reactives
7. Compressed Gases
8. Radioactive Materials
5. Select Carcinogens
6. Reproductive Toxins
IV. Detecting Hazardous Chemicals
A. OSHA Permissible Exposure Limits
1. Time Weighted Average - average exposure over an 8 hour day
2. Short Term Exposure Limit - a concentration at which workers can be exposed to for a short period of time
3. Ceiling Limit Value - A concentration that workers should not be exposed to at any time
4. Action Levels - concentrations that initiate required activities such as exposure monitoring or medical surveillance
B. Other Exposure Limits
1. Threshold Limit Values - safe exposure levels developed by the American Conference of Governmental Industrial Hygienists
2. IDLH Levels - concentrations that are immediately dangerous to life or health
1. When to Monitor
2. Types of Monitors
D. Symptoms of Exposure
V. Personal Protective Equipment
C. Eye Protection
VI. Safe Work Practices
A. Obtaining Chemicals
B. Transporting Chemicals
C. Storing Chemicals
D. Hood Use
E. Minimize Exposure
F. Don't Underestimate the Risk
VII. Emergency Procedures
B. Emergency Shower and Eyewash
C. Medical Procedures
D. Fire Procedures
The Standard Operating Procedures Guidelines form was developed to assist you in composing standard operating procedures (SOPs) for safety in your laboratory. While it is not mandatory that you follow the form, it is mandatory that written standard operating procedures be developed for your laboratory. The Guidelines form simply gives you an idea of some of the information that should be included.
Once complete, your SOPS should be submitted to the Office of Environmental Health & Safety. If you have already submitted your SOPs to OEHS, they need to be reviewed annually and updated as necessary. Please submit updates or a statement saying that no changes are needed by May 15th of each year, our annual review date.
For questions or assistance please contact Pam Fatland at 988-5486.
STANDARD OPERATING PROCEDURES GUIDELINES
1. In this laboratory we use the following hazardous chemicals or types of hazardous chemicals (give examples):
2. The following chemicals used in the lab are considered "select" carcinogens, embryotoxins, or substances having a high degree of acute toxicity:
(Information can be obtained from your MSDS, a chemical dictionary, or other reference materials.)
3. For the chemicals in item #2, the following designated area has been established for use (example: hood, section of room, entire room) and is conspicuously marked (example: with a carcinogen sign on door) warning of the hazards. Only authorized personnel trained in the hazards and proper precautions to take are allowed in the designated area.
4. For the chemicals in item #2, the following containment devices are used: (hood, glove box, respirator, etc.).
5. When contamination occurs from chemicals, especially those listed in item #2, the following procedures are used to decontaminate: (spill clean-up procedures, equipment cleanup procedures particular for the lab).
6. The following are our procedures for safe removal of contaminated waste, particularly for waste contaminated with chemicals listed in item #2: (Example: Hazardous waste disposed of through OEHS by calling 988-5486 and making arrangements.)
7. Other special procedures, equipment, or work practices employed for added protection when using chemicals in item #2 consist of: (Example: respirators, limited hours of use, special ventilation, etc.)
8. Types and location of personal protective equipment available and frequency of inspection: (Example: Rubber gloves kept in bottom drawer inspected once a month for tears and holes.)
9. Location of nearest emergency eyewash & shower:
10. Location of nearest fire extinguisher:
11. Location of posted emergency numbers and procedures:
12. Type of ventilation available: (chemical fume hood, local exhaust, etc.)
13. Chemical storage procedures: (Example: Flammables stored in flammable cabinet or safety cans. Incompatible chemicals are segregated. Secondary containers are used when storing toxic chemicals.)
14. Sign and labeling procedures: (Example: Containers are labeled in accordance with right-to-know requirements and warning signs stating flammable, corrosive are posted on the entrance door.)
15. Location of MSDSs:
16. Recordkeeping procedures: (Example: Training records are located in Departmental office. Inventory and usage records for carcinogens are kept in notebook near door. Inspection records are kept in third file drawer. Medical records are kept in employee file. Etc.)
17. Laboratory inspections are conducted quarterly by ___________ and reports are sent to _________________ (the appropriate safety committee).
18. If an employee develops signs or symptoms of exposure, in the event of a spill or leak, or if permissible exposure limits are routinely exceeded, the following steps are taken to see that medical attention is obtained:
19. If an employee feels that monitoring may be needed, the following procedures should be followed: (Example: OEHS will be notified.)
20. Other procedures: (Example: Large surpluses of chemicals will not be ordered and less hazardous substances will be substituted when possible. Include special procedures for handling cryogenics, infectious materials, etc.)
Compliance Evaluation Form
EVALUATION OF COMPLIANCE WITH LABORATORY STANDARD
A. STANDARD OPERATING PROCEDURES
Written and dated
Available to employees
Copy sent to OEHS
B. PERSONAL PROTECTIVE EQUIPMENT
C. TRAINING and INFORMATION
Initial training done
Initial training documented
New Exposure training done
New Exposure training documented
Inventory of chemicals done
Other reference materials available
D. LAB INSPECTIONS
Copies sent to Safety Committee
E. HOODS, BIOLOGICAL SAFETY CABINETS
Tested before use
F. TOXICS, HIGH RISK CHEMICALS
Name of chemical(s)_____________________________________________________
Designated area identified______________________________________________
Records kept of amount, use, etc._______________________________________
Prior approval needed/received__________________________________________
G. EXPOSURE MONITORING
Monitoring records kept
Monitoring records available to employee
Reason - signs or symptoms of exposure_________________________________
Reason - exposure above PEL____________________________________________
Reason - Spill, leak, other____________________________________________
Records available to employee
I. ADDITIONAL COMMENTS
OEHS, 1430 Tulane Ave., TW-16, New Orleans, LA 70112 | 504-988-5486 | firstname.lastname@example.org