Laboratory Chemical Hygiene Plan

Bridgewater State College encourages and supports all programs, which promote safety, good health and well being of College faculty, staff, students and visitors. The College is committed to providing a safe and healthful environment for all members of the Bridgewater State College community and to reducing injuries and illness to the lowest possible level. To assist academic institutions and businesses in enhancing the safety of laboratory personnel, the Occupational Safety and Health Administration (OSHA) published standard 29 CFR 1910.1450, "Occupational Exposure to Hazardous Chemicals in Laboratories". This regulation, known as the "Lab Standard", is designed to protect laboratory personnel from potential hazards associated with the use of laboratory chemicals. The key elements of the OSHA Lab Standard include the development and implementation of the following:

• Chemical Hygiene Plan (CHP)
• Employee Training and Information
• Hazard Identification
• Material Safety Data Sheet (MSDS) Use and Management
• Container Labeling
• Exposure Monitoring
• Medical Examinations and Consultation
• Methods of Exposure Control
• Personal Protective Equipment
• Laboratory Safety Equipment
• Chemical Waste Management
• Safeguards for Particularly Hazardous Substances
• Emergency Procedures
• Recordkeeping

The standard's intent is to ensure that laboratory personnel are apprised of the hazards of the chemicals in their work area, and that appropriate work practices and procedures are in place to protect laboratory personnel from chemical health and safety hazards. This Chemical Hygiene Plan has been prepared to provide guidance in safe laboratory operations for Bridgewater State College laboratory personnel.

Goal

The policies and procedures in this Chemical Hygiene Plan are applicable to all laboratory operations and personnel. Laboratory operations are defined as handling or manipulation of hazardous chemicals in reactions, transfers, etc. in small quantities on a non-production basis. Hazardous chemicals are defined as any elements, compounds or mixture of elements and/or compounds which have physical or health hazards associated with them. Laboratory personnel include faculty, staff, research associates and assistants, technicians, teaching assistants, graduate and undergraduate students.

Purpose

This Chemical Hygiene Plan is designed to identify the safety practices that should be implemented when working with common hazardous chemicals found in the laboratory. These safeguards will protect laboratory workers from unsafe conditions in most situations. There are instances, however, when the physical and chemical properties, the proposed use, the quantity used or the toxicity of a substance will be such that these controls may need to be modified. Professional judgment is essential in the interpretation and application of these procedures, and laboratories may modify or enhance these procedures to meet their specific uses and operational needs. This document identifies the ways in which Bridgewater State College is complying with each portion of the

OSHA Lab Standard. An official copy of the Bridgewater State College Chemical Hygiene Plan is located in the offices of the Department of Environmental, Health and Safety.

The Bridgewater State College Laboratory Safety Program is based on the premise that every member of the college community shares the responsibility for safety. As part of the community, it is important for each laboratory worker to be familiar with the health and safety guidelines that apply to his or her work and to conduct that work in the safest possible manner. The Chemical Hygiene Plan is a resource to assist laboratory workers in fulfilling these responsibilities.

Plan Organization

Section I contains information regarding the general administrative components of the Chemical Hygiene Plan. This section outlines the purpose, scope and applicability of the plan. In addition, responsibilities, authority and resources are also defined. Training, medical surveillance, exposure monitoring, hazard identification, Recordkeeping, plan evaluation and review and resources are detailed in this section.

Section II contains recommended general precautions for working with laboratory chemicals. These precautions address broad classes of chemicals and include information and guidance in the following areas:

• Common hazards
• General safe work practices
• Chemical storage
• Personal protective equipment
• Other safety equipment and engineering controls
• Work practices for particularly hazardous substances
• Chemical waste management
• Emergency procedures

General Principles

To provide for the safety of the Bridgewater State College community and to protect Bridgewater State College and surrounding property from damage, the following general principles apply to all faculty, staff and students performing work in laboratories:

1. Perform Hazard Assessment: Prior to initiation of new experiments or procedures, assessment of potential hazards must be performed. Appropriate protective measures,

including personal protective equipment and engineering controls, must be identified and implemented. Laboratories should develop process- or experiment-specific guidelines and protective procedures.

2. Minimize Chemical Exposures: Since few laboratory chemicals are without

hazards, general precautions for chemical handling, storage and disposal (contained in Part II) should be implemented in all laboratories. Use of less hazardous materials, implementation of engineering controls whenever feasible, and use of personal protective equipment to avoid skin contact with or inhalation of chemicals is encouraged.

3. Avoid Underestimation of Risk: Even for substances with no known significant

hazard, exposure should be minimized. For work with particularly hazardous substances, special precautions must be taken (contained in Part II). It should always be assumed that the toxicity of a mixture would be more toxic than its most toxic component. All substances of unknown toxicity should be considered toxic.

4. Provide Adequate Ventilation: The best way to prevent exposure to airborne

substances is to prevent their escape into the working atmosphere by using chemical fume hoods or other ventilation devices.

5. Observe Established Standards: The permissible exposure limits and threshold limit

values established by OSHA and other organizations should be observed. Where a regulatory standard does not exist, other recognized exposure limits should be followed.

6. Follow the Chemical Hygiene Plan: Procedures described in this Chemical Hygiene
   
7. Plan is designed to minimize or prevent exposure to hazardous chemicals.
   
8. Implementation of the CHP should be a regular, continuing effort.

Roles and Responsibilities

The Environmental Health and Safety Officer is responsible for promoting and maintaining a safe, healthful and environmentally responsible workplace. Specific responsibilities include:

• Ensuring the regulatory compliance programs is in accordance with Bridgewater State College standards and requirements.
• Identifying personnel affected by specific compliance requirements.
• Communicating compliance program requirements to administration and faculty.
• Securing faculty and administration input for the development and implementation of compliance management programs. Communicating, periodically, compliance programs status to the Bridgewater State College community, including program results, effectiveness and agendas.

Departments

Each department is responsible for supporting and promoting good safe and compliant work practices in the laboratory. Department faculty and administration are responsible for facilitating the implementation of the Chemical Hygiene Plan within each department.

Department Chairs

They have overall responsibility for ensuring that all work performed within their departments complies with applicable health, safety and environmental requirements. The department chairs may implement this responsibility through delegation to Environmental Health and Safety Officers, other faculty, department administration or other departmental staff deemed appropriate.

Faculty

Collaborating with the administration, Environmental Health and Safety and others to identify effective means to implement the Chemical Hygiene Plan in the laboratory. Providing feedback to administration regarding compliance status. Ensuring that personnel receive required training, to implement the Chemical Hygiene Plan effectively. Coordinating and facilitating exchange of information regarding chemical hygiene issues with the research and teaching community.

Department Staff Assistant

Facilitating compliance with the Chemical Hygiene Plan requirements. Ensuring that compliance responsibilities are assigned and implemented for all areas and operations in the Department. Each Staff Assistant plays a critical role in the implementation of the Chemical Hygiene Plan. The Staff Assistant has primary responsibility for chemical hygiene and EH&S compliance in his or her laboratory. These responsibilities include ensuring that:

• Laboratory personnel have adequate knowledge and information to recognize and control chemical hazards in the laboratory.
• Hazardous operations are defined and safe practices and protective equipment are designated and provided.
• Safe work practices, personal protective equipment and engineering controls are used to reduce the potential for exposure to hazardous chemicals.
• Laboratory personnel are informed of the potential hazards of the chemicals they use and are trained in safe laboratory practices, controls and emergency procedures.
• Chemical waste is managed properly.
• Action is taken to correct work practices and conditions that may result in the release of hazardous chemicals.
• Approval, where required, is obtained prior to using particularly hazardous substances.
• Laboratory operations are supervised to ensure that the Chemical Hygiene Plan is being followed.
• Compliance with the CHP is maintained and documented.

The Staff Assistant is critical to the effective implementation of the Chemical Hygiene Plan. The Staff Assistant, working with the Environmental Health and Safety Officer is responsible for the adaptation and implementation of the Chemical Hygiene Plan in his or her laboratory, thus maintaining a safe work environment and ensuring compliance with regulatory requirements. The duties of the laboratory supervisor include ensuring that:

• Appropriate training is provided to new and current workers and is properly documented. Workers know and follow established safe work procedures and emergency procedures.
• Safety equipment and engineering controls are utilized.
• Appropriate personal protective equipment is utilized.
• Laboratory practices and safety and control equipment inspections are routinely
  conducted and properly documented.
• Copies of the up-to-date Chemical Hygiene Plan and MSDSs are available to

laboratory workers.

• Procedures developed for new or particularly hazardous chemicals or operations are
  Cordinated with input from the Environmental Health and Safety Department.
• Accidents and other potential exposure conditions are reported to the Environmental Health and Safety Office for further investigation, exposure monitoring or input regarding appropriate corrective action. Recommended actions are taken to correct any unsafe condition.
• Participating in laboratory safety training sessions.
• Being aware of the hazards of the chemicals they are working around or with, and safe storage, handling and disposal procedures.
• Planning and conducting each operation or experiment in accordance with established
  chemical hygiene procedures.
• Using appropriate safe work practices, personal protective equipment and engineering
  controls at all times.
• Reporting unsafe conditions to their supervisor or Environmental Health and Safety Officer.
• The laboratory workers and Environmental Health and Safety Officers share responsibility for chemical safety in their laboratory, as well as informing visitors entering their laboratory of the potential hazards and safety precautions to be taken.

Environmental, Health and Safety Department

The primary responsibility of the Environmental, Health and Safety Department is to provide technical support and guidance to laboratory personnel for the development and management of environmental, health and safety programs. EH&S is responsible for reviewing and updating the common (non-lab specific) portions of this Chemical Hygiene Plan on an annual basis and distributing any required changes to appropriate College personnel. The EH&S Department offers the following services relating to chemical hygiene:

• Development and evaluation of safety procedures.
• Laboratory inspection and audits.
• Training and information dissemination.
• Hazardous waste disposal.
• Exposure assessment.
• Accident investigation.
• Emergency assistance.

Information and Training

Bridgewater State College will provide laboratory personnel with information and training to ensure that they are apprised of the hazards of the chemicals present in their work area. The purpose of information and training is to ensure that all individuals at risk are adequately informed about the work being performed in the laboratory, associated hazards and actions to be taken to protect themselves during normal operations, as well as emergencies.

General Requirements

Information that must be provided or made available to laboratory personnel includes:

• A copy of the OSHA Lab Standard and its appendices.
• The location and availability of the Chemical Hygiene Plan. This information is
  provided in Laboratory Summary at the front of this Chemical Hygiene Plan.
• The Permissible Exposure Limits (PELs) for OSHA-regulated substances and the AGCIH Threshold Limit Values (TLVs) for hazardous substances not given OSHA PELs. These lists are provided in Part II of this document.
• Signs and symptoms associated with exposure to hazardous substances used in the laboratory.
• The location and availability of known reference materials on hazards, safe handling storage and disposal of hazardous chemicals found in the laboratory.

Training must include coverage of the following topics, at a minimum:

• Methods and observations that may be used to detect the presence or release of a
  hazradous chemical.
  Physical and health hazards of chemicals in the work area.
• Measures workers can take to protect themselves from these hazards.
• Specific procedures to provide protection, including engineering controls, work practices and personal protective equipment.
• Emergency procedures.
• Explanation of Material Safety Data Sheets and container labeling.
• How to obtain and use chemical hazard information.
• Review of the components and implementation of the Chemical Hygiene Plan.

The Bridgewater State College safety training program for laboratory personnel consists of two parts:

• General Laboratory Safety Training regarding general laboratory safety practices,
  provided by EH&S. 
• Site-specific Laboratory Safety Training regarding specific chemicals, experiments or procedures provided by the Environmental Health and Safety Officer and/or the laboratory supervisor.
• Safety information and training must be provided to personnel initially, upon assignment to a laboratory where hazardous chemicals are present, and also prior to assignments involving new hazardous chemicals and/or new laboratory work procedures.

Records of training must be maintained for all workers. These records must include the following information, at a minimum:

• A copy of the materials used in the training (i.e. handouts, agenda etc.)
  An attendance record identifying the training provided, the date of training and the names and signatures of the attendees

Chemical Safety Information Sources

There are numerous sources of chemical safety information. These sources include:

• Chemical Container Labels
• Material Safety Data Sheets (MSDSs)
• Laboratory Signs
• Health and Safety Reference Literature

In addition, your supervisor is available to provide safety information. Each of these sources is now discussed in greater detail.

Chemical Container Labeling

Chemical container labels are a good resource for information on chemical hazards. All containers of chemicals must have labels attached. Labels on purchased chemicals must include:

• The common name of the chemical
• An appropriate hazard warning. The warning may be a single word (i.e. Danger, Caution, Warning) or may identify the primary hazard both physical (i.e. water reactive, flammable, or explosive) and health (i.e. carcinogen, corrosive or irritant).

Most labels provide additional safety information to help workers protect themselves from the substance. This information may include protective measures and/or protective clothing to be used, first aid instructions, storage information and emergency procedures.

• Inspecting incoming containers to be sure that they are labeled with the information
  outlined above.
• Reading the container label each time a newly purchased chemical is used. It is possible that the manufacturer may have added new hazard information or reformulated the product since the last purchase. Ensuring that chemical container labels are not removed or defaced, except when containers are empty.
• Labeling any secondary containers used in the laboratory, to prevent unknown

chemicals or inadvertent reaction. Verifying that chemical waste containers have complete and accurate chemical waste labels.

Material Safety Data Sheets

Material Safety Data Sheets (MSDSs) are documents, prepared by chemical manufacturers, that describe the physical and chemical characteristics of hazardous chemicals; provide information about the chemical's physical and chemical hazards; and 3) list the means for controlling those hazards. MSDSs also provide information about first aid, emergency procedures, waste disposal and recommended exposure limits.

The formats of Material Safety Data Sheets may vary, but there is specific information that must be included in each sheet. It is useful for laboratory personnel to review this information to increase their ability to use an MSDS effectively.

Chemical manufacturers cannot anticipate all of the circumstances under which each hazardous chemical will be used; therefore MSDS information must be used in the context of actual chemical use conditions and all applicable local policies and regulations.

Laboratory Signs

Signs of the following types are commonly used in laboratory facilities:

• Biohazard Symbol (to indicate that infectious agents are in use).
• Radiation Symbol (to indicate an "Authorized Radioisotope Use Area").
• National Fire Protection Association (NFPA) 704 Hazard Classification Diamond (to indicate the type and degree of chemical hazard).
• Signs identifying the locations of safety shower, eyewash stations, other safety and first aid equipment and exits.
• Warnings at areas or equipment where special or unusual hazards exist.
• Emergency contacts and telephone numbers.

While not all of these signs are necessarily present in each lab or laboratory facility, and since local requirements may differ, it is important to become familiar with this signage and understand the proper precautions to take in areas where warning signs are posted. It is crucial to become familiar with the signs for safety equipment and exits, so that proper procedures can be implemented in emergency situations.

Health And Safety Reference Literature

The Environmental Health and Safety Office maintains a library of reference materials addressing environmental, health and safety issues. These references include applicable exposure standards and recommended exposure levels, as well as copies of the OSHA Lab Standard and its Appendices. These materials, as well as additional health and safety references, may be reviewed by visiting our EH&S Office located at Boyden Hall.

Signs and Symptoms Of Chemical Exposure

The hazards of laboratory chemicals can be ascertained by referring to label and MSDS information, as well as additional health and safety reference materials noted above. In addition, the ability to recognize the signs and symptoms of chemical exposure is important. Then, if adverse effects do arise despite all precautions taken to avoid exposure, those effects can be recognized early and appropriate action taken. Actions to take if chemical exposure has occurred include:

• Seeking prompt medical attention at College Health Services.
• Contacting the Environmental Health and Safety Officer.

Some signs and symptoms of chemical exposure include:

• Skin that has become dried, whitened, reddened, swelled, blistered, and itchy or
  exhibits a rash.
• A chemical odor. Many chemicals can be smelled at concentrations well below harmful levels. On the other hand, a chemical may be present without a detectable odor.
• A chemical taste. Some chemicals have characteristic tastes.
• Tearing or burning of the eyes.
• Burning sensations of the skin, nose or throat.
• Cough.
• Headache or dizziness.

These general symptoms may also be associated with conditions other than chemical exposure. The signs and symptoms of exposure to specific chemicals are contained in the "Health Hazard Information" section of the MSDS. Laboratory personnel should be aware of the signs and symptoms of exposure to the chemicals they use.

Medical Examination and Consultation

Bridgewater State College is required to provide laboratory personnel who have an exposure to hazardous chemicals an opportunity to receive medical attention, including physician-determined follow-up examinations, when any of the following conditions are met:

• The worker develops signs or symptoms associated with a hazardous chemical used in the laboratory.
• Exposure monitoring reveals consistent worker exposure greater than the action level (or in the absence of an action level, the applicable OSHA exposure limit) for a chemical.
• Whenever a leak, spill, explosion or other occurrence results in the likelihood of hazardous exposure to the worker.
• When respiratory protective equipment is required.
• When medical surveillance requirements for OSHA regulated-substances must be met.

Exposure Information

A licensed physician providing care to a potentially exposed worker must be provided the following information:

• The identity of and MSDS(s) for the hazardous substance(s) to which the worker may
  have been exposed.
• The conditions that surrounded the exposure.
• The signs and symptoms of exposure that the worker is experiencing, if any.

Examination Criteria and Frequency

The licensed physician performing the exam will determine medical exam criteria. Where medical exam guidance exists, such as for OSHA-regulated substances, these criteria will be included in the physician's exam.

Frequency of medical examinations is at the discretion of the physician, if the examination resulted from a potential overexposure to hazardous substances. If the examination resulted from an exposure to an OSHA-regulated substance, examinations will be at least as frequent as the period set in the OSHA standard for each particular substance. Medical examinations provided for required respirator use must be performed, annually, unless specified more frequently by the physician.

Physician's Written Opinion

The physician is required to submit a written opinion to the Environmental Health and Safety Officer. This opinion must not reveal any specific findings or diagnoses unrelated to the chemical exposure. The written opinion must include the following information:

• Results of the medical examination, including any test results
• Any medical condition, revealed during examination, which may place the worker at increased risk as a result of the chemical exposure or use of personal protective equipment.
• Recommendations for further medical follow-up.
• A statement that the worker was informed of the medical examination results.

Cost and Scheduling

All required medical examinations and consultations must be provided to laboratory personnel at no cost, without loss of pay, and at a reasonable time and place.

Exposure Monitoring

Regular environmental or worker exposure monitoring of airborne contaminants is not usually warranted or practical in laboratories, since chemicals are typically used for a relatively short period of time and in small quantities. However, air monitoring will be conducted if:

• There is reason to believe that exposure levels for a substance routinely exceed either the action level (AL) or permissible exposure level (PEL) set by OSHA.
• Workers report that they have been overexposed to a chemical in the laboratory.
• A particularly hazardous chemical is used on a regular basis (several times per week) for an extended period of time (3-4 hours at a time) or in large quantities. Use of particularly hazardous substances in this manner should be reviewed with the Environmental Health and Safety Officer.

Monitoring will be conducted in accordance with established sample collection and analytical methodology for the chemical exposure being evaluated. If initial monitoring indicates that worker exposure is above the AL or PEL, the periodic monitoring provisions of the relevant OSHA standard will be met.

Upon receipt, results of personal monitoring will be made available to workers, in writing within 15 days, either individually or by posting in an appropriate location accessible to the affected workers.

Recordkeeping

Bridgewater State College will maintain accurate and complete records concerning the following:

• Medical examination and consultation
• Exposure monitoring;
• Training
• Fume hood evaluations
• Laboratory inspections.

Retention and Storage

Medical examination and consultation records, including test results and physician's written opinions, must be maintained in the Human Resources. These records must be kept, transferred and made available for at least the duration of the worker's employment plus thirty years. These records must be maintained in accordance with 29 CFR 1910.20 "Access to Employee Exposure and Medical Records".

Training records, including handout materials, agendas and signed training attendance records, must be maintained in the Human Resources files along with the Environmental Health and Safety Office files. These records must be maintained for a period of 3 years.

Fume hood evaluation records must be maintained in the EH&S department files and updated annually. These records must be maintained until the next evaluation is performed. Records of fume hood evaluations performed by EH&S will be maintained in the EH&S central files.

Laboratory inspection records must be maintained in the laboratory's department files. These records must be maintained until the next inspection is performed. Records of inspections conducted will be maintained in the EH&S central files.

Plan Evaluation, Review and Update

In order to evaluate the implementation status and effectiveness of the Chemical Hygiene Plan, periodic inspections will be performed to review laboratory safety practices and check safety equipment.

Internal Inspections

Laboratory workers should inspect their work area(s) routinely for compliance with the Chemical Hygiene Plan. Laboratory Supervisors should inspect their laboratories on a semester basis. Environmental Health and Safety will perform laboratory safety inspections on an annual basis. Fume hood evaluations will done on an annual basis. These evaluations will assess the adequacy of air flow in the hood by determining average face velocity, air flow pattern and direction and extent of turbulence (if any).

Plan Review and Update

The Environmental Health and Safety will review and update this Chemical Hygiene Plan annually and more frequently on an ad hoc basis as necessary. Changes to the plan will be based on regulatory changes, changes in safety practices, feedback from laboratory personnel and results of internal inspections.