Laboratory Safety: Chemical Hygiene Plans

by New Pig Technical Team

Employees who work in non-production laboratories may experience different types of hazards than employees who work in production areas. Because of this, the standard operating procedures that are followed in production areas may not be applicable or sufficient to provide them with adequate protection against chemical, biological, radiological and physical hazards.

The Occupational Safety and Health Administration (OSHA) recognizes the specialized needs of employees who perform laboratory tests and experiments. To help prevent their injury or illness, OSHA requires employers with laboratories to evaluate and identify specific risks that the chemicals used in laboratories present and establish a written Chemical Hygiene Plan (CHP) that minimizes occupational exposure to hazardous chemicals in laboratories.

This laboratory standard also requires an employer’s CHP to outline the policies, responsibilities, procedures and protocols that will be used to minimize exposure. Teaching employees to recognize hazardous chemicals and how to use engineering and administrative controls, as well as personal protective equipment (PPE) are additional tools that will help them avoid exposure and prevent injuries and illnesses.

To be effective, CHPs must be specific to the facility’s laboratory operations. They must also be reviewed at least annually and updated when chemicals, procedures or other elements of the program change.

Chemical Hygiene Plans must be readily available to employees. They must also have access to a copy of OSHA’s Laboratory Standard [29 CFR 1910.1450]. Read on to learn the required and recommended elements of a comprehensive CHP.

Standard Operating Procedures [29 CFR 1910.1450(e)(3)(i)]

Safety Data Sheets (SDS), chemical labels, instruction manuals and other vendor-supplied information helps employers evaluate the risks and hazards of chemicals that are used in laboratories. This information, combined with in-house process knowledge is used to create Standard Operating Procedures (SOPs).

The SOPs that are established provide a detailed outline for employees to follow that allows them to use engineering controls and Personal Protective Equipment (PPE) properly. When the SOPs are followed, the risk of injury or illness can be prevented.

Housekeeping procedures, the use of ventilation systems and waste disposal protocols are all examples of SOPs that may be established as safe work practices in laboratories. Some general SOPs that apply to most laboratory operations include:

Following assigned work schedules and never working alone
Maintaining situational awareness
Only performing authorized experiments
Establishing and reviewing safety procedures before beginning any laboratory operation
Reading SDS and labels before using a chemical
Wearing appropriate PPE at all times
Wearing long-sleeved shirts, long pants and closed-toed shoes to protect skin from splashes; removing jewelry and tying back loose hair
Pipetting must never be done by mouth
Washing hands with soap and water after working with chemicals, even if gloves were worn
No eating, drinking, smoking, gum chewing, applying cosmetics or taking medicine in laboratories; food, cups, plates and eating utensils may not be stored in the laboratory
Properly disposing of all wastes
Reporting injuries and near misses

Providing access to SOPs or including written copies with each experiment can help to reinforce their use.

In addition to SOPs, laboratory employees should also know what to do when there is an emergency, such as a fire or spill. Posting information on evacuation procedures, evacuation routes and how to handle suspicious packages can help employees to be prepared.

Stocking first aid kits, spill kits and other response supplies also helps employees to respond quickly. When these items are available, the proper use of each tool should be covered during training so that employees will know how and when to use them.

Exposure Control Measures [29 CFR 1910.1450(e)(3)(ii)]

Engineering controls, such as fume hoods and glove boxes are two means of controlling exposure to hazardous chemicals. Some operations also benefit from continuous air monitoring devices that sound an alarm if chemical concentrations exceed a pre-determined level.

Properly labeling containers and identifying the byproducts of experiments are also control methods, and are required under the standard [29 CFR 1910.1450(h).] The use of PPE — including respirators, gloves, goggles, face shields and gloves — is another common exposure control method.

If an engineering control or PPE fails, eyewash stations, drench showers, fire extinguishers, first aid supplies and other safety equipment are additional types of control measures that can provide protection and help control the extent of exposure.

The CHP must document what types of exposure control measures will be used to minimize hazards. It must also list the criteria used to select each product, especially when working with extremely hazardous chemicals.

Adequacy and Proper Functioning of Fume Hoods and Other Protective Equipment [29 CFR 1910.1450(e)(3)(iii)]

Faulty air monitoring equipment and unmaintained fume hoods may not provide adequate protection for laboratory employees. Because these and other controls are essential to the health and safety of employees, CHPs must include documentation that describes how each control device will be maintained.

Specific measures may include following the vendor’s recommended maintenance schedule, performing daily or weekly inspections, or establishing changeout schedules for filters and sensing devices. Documentation should include how these measures ensure that equipment works properly and how it provides adequate protection.

Information and Training [29 CFR 1910.1450(e)(3)(iv)] and [29 CFR 1910.1450(f)]

Before employees are permitted to work in laboratories, or when new chemicals or procedures are introduced, they must receive training that informs them of the hazards that are present in this work area. Copies of the facility’s CHP, the full text of the laboratory standard (29 CFR 1910.1450) SDS for chemicals that will be used in the lab and other reference materials must be made available to each laboratory employee.

Training must include details of the facility’s CHP, including the safe practices that will be used to control exposure. Chemical exposure signs and symptoms must be covered as well as methods or observations that may be used to detect exposure.

When PPE is used, employees must be taught how to use, store, and clean it properly as well how and when to replace worn or spent equipment. Employees should also be aware of engineering controls and monitoring devices and how to determine if they are functioning properly to provide protection.

Requirement of Prior Approval of Laboratory Procedures [29 CFR 1910.1450(e)(3)(v)]

Some labs perform the same types of experiments or tests daily, and the SOPs for conducting those operations are well established. However, in some laboratories, there may be circumstances where a procedure or test requires the employer’s approval before work can begin.

Examples could include the use of new chemicals or procedures that are unfamiliar to the employee, or processes involving highly toxic chemicals. The use of new laboratory equipment may also necessitate training and approval before work begins.

Medical Consultations and Examinations [29 CFR 1910.1450(e)(3)(vi)] and [29 CFR 1910.1450(g)]

Hazardous chemicals used in laboratories can cause acute or chronic health problems. The facility’s CHP must include provisions for medical consultations and exams.

Laboratory employees must be given the opportunity to receive medical attention and follow-up care from a licensed physician whenever they:

Develop a sign or symptom associated with a hazardous chemical exposure
Are exposed to a chemical
Have an increased likelihood of exposure due to a spill, leak, explosion or other similar occurrence
Routinely work in atmospheres that exceed permissible exposure limit (PEL) or action level

Consultations and exams must be provided at no cost to the employee, without loss of pay, and at a reasonable time and place.

Employers must provide physicians with information about the chemicals that the employee has been exposed to. They must also obtain a copy of the physician’s opinion and results of examinations or tests that were performed in relation to any occupational exposure to chemicals.

Accurate records of exposure monitoring measurements, medical consultations, exams, tests and written physician opinions must be maintained as required under OSHA’s recordkeeping standard [29 CFR 1910.1450(j) and 29 CFR 1910.1200(d)(1)(i)]

Designation of a Chemical Hygiene Officer and Other Responsible Personnel [29 CFR 1910.1450(e)(3)(vii)]

Employers must designate a chemical hygiene officer to develop and implement the CHP. This person must also monitor the procurement, use and disposal of chemicals that are used in laboratories.

Chemical hygiene officers may also be involved with audits, inspections and other procedures to ensure that the CHP is adequate, maintained and updated as necessary. In some facilities, it may also be appropriate to form a chemical hygiene committee to assist the officer with these duties.

Special Precautions for Particularly Hazardous Substances [29 CFR 1910.1450(e)(3)(viii)]

Particularly hazardous substances, such as carcinogens, reproductive toxins and chemicals with highly acute toxicity characteristics, may necessitate additional forms of protection. Employers must evaluate these types of hazards and consider methods to prevent contact and exposure.

Some methods may include establishing designated, secure areas when working with particularly hazardous substances or the use of glove boxes and fume hoods. Establishing safe disposal procedures and decontamination protocols can also increase safety with these substances.

Some facilities view a CHP as an extension of the facility’s hazard communication plan. However, where a hazard communication plan may generally address workplace hazards, establishing a CHP that is specific to the chemicals used in laboratories and outlines the procedures that will be used to address those hazards adds an additional layer of safety for employees involved in laboratory operations.

TAGS: Safety

Standard Operating Procedures [29 CFR 1910.1450(e)(3)(i)]

Exposure Control Measures [29 CFR 1910.1450(e)(3)(ii)]

Adequacy and Proper Functioning of Fume Hoods and Other Protective Equipment [29 CFR 1910.1450(e)(3)(iii)]

Information and Training [29 CFR 1910.1450(e)(3)(iv)] and [29 CFR 1910.1450(f)]

Requirement of Prior Approval of Laboratory Procedures [29 CFR 1910.1450(e)(3)(v)]

Medical Consultations and Examinations [29 CFR 1910.1450(e)(3)(vi)] and [29 CFR 1910.1450(g)]

Designation of a Chemical Hygiene Officer and Other Responsible Personnel [29 CFR 1910.1450(e)(3)(vii)]

Special Precautions for Particularly Hazardous Substances [29 CFR 1910.1450(e)(3)(viii)]

New Pig Technical Team

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