Since 1990, the Occupational Safety and Health Administration (OSHA) has required facilities engaged in the use of chemicals in a laboratory to develop and implement a written chemical hygiene plan (CHP). OSHA requires these facilities to set forth procedures, equipment, PPE, work practices, training, and policies to help protect employees from the health hazards presented by hazardous chemicals used in their workplace.
The CHP must be easily accessible and designed to protect employees from health hazards associated with hazardous chemicals in their specific laboratories. The plan can be maintained and available electronically as long as employees know how to access it.
The CHP Has Eight Elements, Including:
- Describe standard operating procedures.
- Define criteria for implementation of control measures, which means deciding how the employer is going to protect employees. There is a general priority of protecting employees. The three-tier system: engineering controls, administrative controls, and PPE.
- Define (and document) procedures to maintain proper functioning of chemical fume hoods and protective equipment. This includes procedures such as checking the flow rate of hoods and verifying that equipment is working properly.
- Provide employee information and training.
- Provide criteria for prior approval. Where you have processes or procedures where employees have to get prior approval (e.g., working alone) criteria allow employers to make arrangements for protection.
- Provide criteria for medical consultation and examination.
- Designate persons responsible for implementation of the CHP. Employers must designate responsibilities to a variety of people both in and out of lab, including the chemical hygiene officer (CHO) and others. The highest ranking person should sign the plan, saying that he/she has authorized the plan.
- Provide employee protection from particularly hazardous substances. Inventory chemicals and decide what in this category—for example, carcinogens and extremely reactive materials.
Employer Responsibilities Under the CHP
- Develop and implement a written CHP
- Inventory all hazardous chemicals and ensure each has a safety data sheet (SDS)
- Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced
- Maintain any SDSs that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible to laboratory employees
- Train employees on physical and health hazards and protective measures
- Provide medical monitoring for employees (under certain circumstances)
Employee Responsibilities Under the CHP
- Follow all procedures and policies relating to chemicals and follow appropriate laboratory procedures and rules as outlined in the CHP
- Refrain from operations without proper instruction and/or authorization
- Seek out and request information
- Wear appropriate PPE
- Report accidents and near-misses immediately, even minor injuries or exposures
OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories Standard (29 CFR 1910.1450) applies to all laboratories that use hazardous chemicals on a laboratory scale.
- A laboratory is defined as a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.
- “Laboratory scale” is defined by OSHA as: “Work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. Laboratory scale excludes those workplaces whose function is to produce commercial quantities of materials.”
Laboratory use of hazardous chemicals means handling or use of such chemicals in which all of the following conditions are met:
- Chemical manipulations are carried out on a laboratory scale. Multiple chemical procedures or chemicals are used.
- The procedures involved are not part of a production process, nor in any way simulate a production process.
- Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
The uses of chemicals in the laboratory that do not meet the requirements above fall under the Hazard Communication Standard (HazCom).
For more information or assistance with your environmental and health & safety (EHS) regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at 908-442-8599 or rcarito@TotalEnviron.com