Chemical Hygiene Plan (CHP)

Laboratory Supervisor  ___________________________________________________________________

Building(s)  ___________________  Room(s)  ____________________  Dept  _______________________ 

Dept CHO  ___________________________                Date  ____________________________________

Introduction

The University of Alabama is committed to full compliance with federal, state, and local laws and regulations regarding hazardous materials.  In recognition that individuals who work in laboratories are potentially exposed to a wide variety of hazardous materials, the University of Alabama has created the 'University of Alabama Chemical Hygiene Plan and Laboratory Guide'.  Along with state and local regulations, the UA CHP embraces the OSHA Lab Standard (29 CFR 1910.1450) and OSHA's Hazard Communication Standard (29 CFR 1910.1200).  Accordingly, each laboratory that uses or stores chemicals must submit a Chemical Hygiene Plan to Environmental Health and Safety, to be reviewed and verified annually.  The laboratory CHP is intended to:

·         inform laboratory workers of the potential hazards present in their workplace.

·         inform laboratory workers of the precautions and preventive measures established to protect their health and well-being.

·         inform laboratory personnel of the required training programs established by The University of Alabama Chemical Hygiene Plan and Laboratory Guide.

·         provide information that allows risk evaluation of hazardous lab procedures.

·         provide information needed to determine any required regulatory response.

The UA CHP states that the 'supervisor of the department or other administrative unit is responsible for the chemical hygiene in their area and the laboratory supervisor has responsibility for the chemical hygiene in their laboratory area.'

I.  Standard Operating Procedures

The standard operating procedures (SOPs) are to be followed in all laboratories. The UA Chemical Hygiene Plan contains some general SOPs for laboratory operations.  The development of any lab-specific SOPs is the responsibility of the Laboratory Chemical Hygiene Officer.  This person is also responsible for the portion of the training that covers these SOPs.  Copies of any lab-specific SOPs should be forwarded to EHS to be maintained on file.

Safety procedures or programs that are included in this laboratory are (check all that apply):

II.  Inventory Control

Federal law mandates that anyone using chemicals in their work must maintain a current inventory of what is in their work space, along with MSDS for all these chemicals.  This inventory must be updated with EHS annually.  In addition, please indicate below the classes of chemicals that you use/store in your lab areas:

III. Control Measures to Reduce Potential Exposure

Employers must take measures to protect employees from exposure to harmful chemicals and their effects.  These measures are specific for each lab, depending on the operations being performed in the area.  Please indicate below any procedures specific to your lab area that require:

A.  use of a fume hood:

B.  use of a biological safety cabinet:

C.  use of a glove box

D.  Respirators are to be used in accordance with the respiratory protection program in practice at The University of Alabama and with the OSHA respirator standard (29 CFR 1910.134).  This policy and associated documentation is available for review at the Office of Environmental Health and Safety or the departmental office.

E.  Appropriate protective apparel (gloves, gowns, etc) compatible with the required degree of protection for substances handled shall be use.  _________________________________________________ (Lab CHO) will advise employees on the proper use of these items.  Glove permeability charts are available for review at the Office of Environmental Health and Safety or the departmental office.

F.  Laboratory workers will be instructed on the location and use of eyewash stations and safety showers.  The Lab CHO is responsible for this instruction.   _________________________________________________ (Lab CHO) will advise employees on the proper use of these items.  Documentation of this training should be maintained and should be easily accessible for review and verification.

G.  Laboratory workers should be trained at appointment on the use of fire extinguishers and other fire protection systems available in their areas.  If you need assistance with this training, please contact EHS at 348-5905 for the schedule of our training sessions.  If there is a need for a refresher training session, contact EHS at 348-5905 to schedule training.

In addition, some programs require additional control measures to minimize exposure.  These include such things as medical testing (e.g., for respirator use), interlocks (e.g., for lasers), etc.  EHS will notify Lab CHOs of these additional requirements based on their specific lab hazards.

The following controls are required for this laboratory area:

IV.  Maintenance of Fume Hoods/Protective Equipment

A.  Fume Hoods will be inspected at least once every twelve (12) months by Environmental Health and Safety.  Satisfactory performance will also be verified after any work is performed on a fume hood.  Certification stickers will be attached to hoods at inspection.  Any hoods that do not pass inspection will be reported for repair and certified once work is complete.  Reports of hood inspections are available for review at the Office of Environmental Health and Safety.

The standard of acceptability for the UA campus is a minimum of 100 linear FPM.

B.  Biological Safety Cabinets and filters will be inspected checked every twelve (12) months by a certified inspector.  Reports of hood inspections are available for review at the Office of Environmental Health and Safety.

C.  All other protective equipment (eye washes,  cabinets, interlocks, etc) shall be inspected in labs monthly by _____________________________________________________________ (Lab CHO).  EHS does safety shower verifications annually and eyewash flushes semi-annually.  More frequent inspections, as required by safety standards, are the responsibility of the Lab CHO.

V.  Information and Training

All laboratory workers covered by the Chemical Hygiene Plan will be provided with initial training on the contents of the OSHA Lab Standard and on the UA CHP.  The Lab CHO is responsible for providing specific training to ensure they are aware of the chemical hazards present in their work area.  This training will be given at the time of initial assignment and prior to new assignments involving different exposure situations.  Refresher training should be given annually.  Each laboratory worker will be required to sign the training completion form documenting that he/she has received training.

Laboratory workers shall be informed of:

A.  The contents of the UA Chemical Hygiene Plan and the applicable OSHA standard.  These shall be available to lab workers for review at the departmental office and the Office of Environmental Health and Safety.

B.  The availability and location of the written chemical hygiene plan for the lab area in which they work.

C.  The permissible exposure limits (PELs) or threshold limit values (TLVs) for regulated substances or recommended exposure limits for other hazardous chemicals.

D.  Signs and symptoms associated with exposure to hazardous chemicals used in the laboratory.

E.  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 chemical suppliers.

Laboratory workers shall be trained on:

A.  Methods and observations that may be used to detect the presence or release of a hazardous chemical.  These may include monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor, etc.

B.  The physical and health hazards of the chemicals in the work area.

C.  The measures lab workers can take to protect themselves from these hazards.  These measure should include specific procedures the employer has implemented to protect lab workers from exposure to hazardous chemicals.  This would include such things as: standard operating procedures, work practices, emergency procedures, and personal protective equipment.  Training on these measures will be conducted by _____________________________________ (Lab CHO).  The training sessions may consist of videotapes, slides, lectures, computer review, etc.  An outline of the training program is included in the UA Chemical Hygiene Plan.

VI.  Prior Approval for Specific Laboratory Operations

Certain laboratory procedures require prior approval.  These include the use of lasers, biohazards, radiation, and other hazardous procedures.  Please contact EHS if you have any questions about your procedure.  Information and required documentation can be found at www.bama.ua.edu/~ehs.

VII.  Medical Consultation and Examination

The Capstone Medical Center shall provide medical consultation to all laboratory workers in the event of accident, injury, or exposure.  For potential exposure situations, medical attention, including any follow-up examinations that the examining physician deems necessary, will be provided under the following circumstances:

A.  Whenever a lab worker develops signs or symptoms associated with a chemical to which they have been exposed, they shall be provided an opportunity to receive appropriate medical examination.  The worker shall contact the lab chemical hygiene officer to initiate the medical program.

B.  Where exposure monitoring reveals an exposure level routinely above the PEL or the TLV for regulated substances for which medical monitoring and medical surveillance requirements exist, medical surveillance shall be established for that individual.

C.  Whenever an event takes place in the work area (i.e., spill, leak, explosion, etc.) resulting in the likelihood of a hazardous exposure, the affected employee shall be provided an opportunity for a medical consultation.  This consultation is for the purpose of determining the need for a medical examination.

D.  All medical examinations and consultations will be performed by the staff physician at Capstone Medical Center.  All aspects of these exams and consultations are to be performed by a licensed physician or by someone under the direct supervision of a licensed physician.  These examinations are provided without cost to the laboratory worker, without any loss of pay, at a reasonable time and place.

E.  Environmental Health and Safety and/or the Departmental Chemical Hygiene Officer will provide the following information to the physician:

1.  Identity of the hazardous chemical to which the individual may have been exposed.

2.  A description of the conditions of the exposure, including exposure date if available.

3.  A description of the signs and symptoms of exposure that the worker is experiencing, if any.

F.  The physician's written opinion for an examination or consultation shall include:

1.  Recommendation for future medical followup.

2.  Results of examinations and associated tests.

3.  Any medical condition, revealed in the course of the examination, which may place the worker at an increased risk at the result of exposure to hazardous chemicals in the workplace.

4.  A statement that the physician has informed the employee about the results of the consultation or medical examination and any medical conditions that may require additional examination or treatment.

G.  The medical results returned to The University of Alabama by the physician shall not include specific findings and diagnoses that are unrelated to occupational exposure.

VIII.  Responsibilities under the Chemical Hygiene Plan

The Director of Environmental Health and Safety is designated as the Chemical Hygiene Officer for The University of Alabama.  The Chemical Hygiene Officer for each lab has specific duties as outlined in this manual.

The Laboratory Safety and Environmental Compliance Committee, comprised of representative from various campus departments, serves to advise the Office of Environmental Health and Safety.  The membership list and minutes of the meetings are available for review at the Office of Environmental Health and Safety.

IX.  Additional Protection - Select Carcinogens, Reproductive Toxins, Chemicals with High Acute Toxicity

When any of these chemicals are used, the following provisions shall be employed where appropriate:

A.  Establishment of a designated area.

B.  Use of containment devices such as fume hoods, glove boxes, etc.

C.  Procedures for safe removal of contaminated waste.

D.  Decontamination procedures.

The UA CHP outlines these chemicals and the standard operating procedures that should be followed when working with these chemicals.

X.  Emergency Response

Emergency plans, fire prevention plans, emergency response plans, and hazardous waste management programs are addressed in the UA CHP and The University of Alabama Safety Manual which is available in each departmental office and the Office of Environmental Health and Safety.  Current plans are maintained on the EHS website, www.bama.ua.edu/~ehs

XI.  Shipping

Additional concerns arise when shipping chemical, biological or radiological material off campus, including IATA and DOT compliance.  49 DOT requires safety training, hazard awareness training, and function specific training for individuals shipping and receiving Dangerous Goods.  EHS can provide this training for anyone who needs it.   The EHS website has additional shipping training information at www.bama.ua.edu/~ehs.   Contact the Office of Environmental Health and Safety for assistance with shipping. 

If any material is imported to campus, TSCA notification may apply.  Contact the Office of Environmental Health and Safety for assistance.

If any new chemical, biological or radiological material is produced, additional paperwork must be completed prior to shipping off campus (notifications, MSDS, etc).  Contact the Office of Environmental Health and Safety for assistance.

XII.  Emissions

Notify the Office of Environmental Health and Safety if there are any emissions to air, soil, or water other than through exhaust or the sewer system.