Chemical Hygiene Policy and Plan - NMU Policies and Requirements

TABLE OF CONTENTS

1.           Introduction
2.           Definitions
3.           Responsible Persons
4.           University Chemical Hygiene Plan Review Committee
5.           Enforcement
6.           General Safety Rules
7.           Understanding and Recognizing Chemical Hazards
8.           Lab Equipment Inspection, Testing & Maintenance
9.           Personal Protective Equipment (PPE)
10.         Specific Chemical Hazards
11.         Chemical Ordering/Storage & Disposal Procedures
12.         Laboratory Decommissioning Criteria
13.         Chemical Emergency Action
 

Appendices

            Appendix A - Informational Links: Included in this document
            Appendix B - Lab Sign Templates: Print and post as needed
            Appendix C - Hazardous Waste Label - Secondary Container Label - Print on sticker paper and use appropriately 
            Appendix D - PPE Assessment Form - Print and use as needed. Keep a copy in the department
            Appendix F - Standard Operating Procedure for specific chemical hazards
            Appendix G - Laboratory Standard Operating Procedure Form - Print and use this form for laboratory procedures. Keep a copy in the lab and department

1. INTRODUCTION

Northern Michigan University Chemical Hygiene Plan (CHP)

Northern Michigan University (NMU) is committed to protecting employees from the health and physical hazards associated with chemicals in university laboratories. The university strives to mitigate these risks to acceptable levels through appropriate engineering controls, administrative procedures, and institutional policies.

This Chemical Hygiene Plan (CHP) provides guidance for maintaining a chemical safety program at NMU. Its purpose is to ensure that adequate control measures are in place to protect laboratory workers from hazardous chemicals. This plan has been developed to comply with the U.S. Occupational Safety and Health Administration (OSHA) Laboratory Standard (29 CFR 1910.1450) and the Michigan Occupational Safety and Health Administration (MIOSHA) Hazardous Work in Laboratories Standard (Part 431). Additionally, this document provides information on practices and procedures necessary to maintain compliance with other applicable federal, state, and local regulations regarding the use and storage of hazardous chemicals.

The CHP is intended to serve as a reference for employees on safe laboratory work practices. A CHP is required in any laboratory where hazardous materials are used or stored; however, the OSHA and MIOSHA standards apply only in laboratory areas where hazardous materials are used and when all of the following criteria are met:

• Chemical operations are conducted on a laboratory scale (i.e., container sizes that can be safely handled by one person).
• Multiple chemical procedures or chemicals are used.
• The procedures are not part of a production process, nor do they simulate a production process.
• Protective laboratory practices and equipment are available and commonly used to prevent employee exposure.

Under the MIOSHA Laboratory Standard, a hazardous chemical is defined as any chemical classified as a health hazard or simple asphyxiant in accordance with the MIOSHA Hazard Communication Standard (§1910.1200). At NMU, this definition is expanded to include chemicals that pose physical hazards, as defined by the Hazard Communication Standard.

The primary focus of this plan is to protect laboratory workers from overexposure to hazardous substances through appropriate administrative procedures and/or engineering controls. However, this plan also applies to clerical, custodial, maintenance, and contract personnel who, as part of their assigned duties, may work with hazardous chemicals.

2. DEFINITIONS

Action level - A concentration designated in 29 CFR part 1910 for a specific substance, calculated as an eight (8)-hour time-weighted average, which initiates certain required activities such as exposure monitoring and medical surveillance.

Asphyxiant - Simple - A substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death.

Ceiling (C)- Environmental limit. The maximum concentration of an airborne hazardous substance that should not be exceeded.

Chemical Hygiene Officer - An employee who is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan. This definition is not intended to place limitations on the position description or job classification that the designated individual shall hold within the employer's organizational structure. 

Chemical Hygiene Plan - A written program developed and implemented by the employer which sets forth procedures, equipment, personal protective equipment and work practices that (i) are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace.

Designated area - An area that may be used for work with particularly hazardous substances. A designated area may be the entire laboratory, an area of a laboratory, or a device such as a laboratory fume hood.

Emergency - Any occurrence, including, but not limited to, equipment failure, container rupture, or failure of control equipment, that results in an uncontrolled release of a hazardous chemical into the workplace constitutes an emergency. 

Emergency Response - In all emergency situations, NMU prioritizes human safety above all other considerations. Individuals exposed to an emergency must take whatever actions are necessary to protect their personal safety. All procedures that follow are provided as guidance only and are to be followed solely when it is safe to do so.

Employee - An individual employed by NMU who may be exposed to hazardous chemicals in the course of their work assignment.

Health Hazard - A chemical that is classified as posing one of the following hazardous effects:

• Acute toxicity, any route of exposure
• Skin corrosion or irritation
• Serious eye damage or eye irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific target organ toxicity, single or repeated exposure
• Aspiration hazard

Laboratory - Any lab, studio, classroom, or shop area used for academic or research purposes, in which hazardous chemicals are used and meets the four criteria listed above. Non-academic and non-research-oriented spaces where hazardous chemicals are used will not be considered laboratories.

Laboratory scale - 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 supervisor - An individual that has authority and responsibility for the personnel and procedures conducted in an individual laboratory.

Laboratory-type hood - A device located in a laboratory, enclosure on five sides with a moveable sash or fixed partial enclosed on the remaining side; constructed and maintained to draw air from the laboratory and to prevent or minimize the escape of air contaminants into the laboratory; and allows chemical manipulations to be conducted in the enclosure without insertion of any portion of the employee's body other than hands and arms. 

Medical consultation - A consultation which takes place between an employee and a licensed physician for the purpose of determining what medical examinations or procedures, if any, are appropriate in cases where a significant exposure to a hazardous chemical may have taken place. 

Mutagen - Chemicals that cause permanent changes in the amount or structure of the genetic material in a cell. Chemicals classified as mutagens in accordance with the Hazard Communication Standard (§1910.1200) shall be considered mutagens. 

Must - Designates a contractual or policy requirement.

Physical Hazard - A chemical that is classified as posing one of the following hazardous effects:

• Explosive
• flammable (gasses, aerosols, liquids, or solids)
• oxidizer (liquid, solid or gas)
• self-reactive
• pyrophoric (liquid or solid)
• self-heating
• organic peroxide
• corrosive to metal
• gas under pressure in contact with water emits flammable gas

Protective laboratory practices and equipment - Those laboratory procedures, practices and equipment accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals. 

Permissible Exposure Level (PEL) - The maximum permitted 8-hour time-weighted average concentration of an airborne contaminant.

Reproductive toxins - Chemicals that affect the reproductive capabilities including adverse effects on sexual function and fertility in adult males and females, as well as adverse effects on the development of the offspring. Chemicals classified as reproductive toxins in accordance with the Hazard Communication Standard (§1910.1200) shall be considered reproductive toxins.

Safety Data Sheet (SDS) - A document that provides information about the hazards of a product and how to safely handle it. 

Select carcinogen - Any substance which meets one of the following criteria:

• It is regulated by OSHA as a carcinogen; or
• 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
• It is listed under Group 1 ("carcinogenic to humans") by the International Agency for Research on Cancer Monographs (IARC) (latest editions); or
• 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:
• After inhalation exposure of 67 hours per day, 5 days per week, for a significant portion of a lifetime to dosages of less than 10 mg/m3;
• After repeated skin application of less than 300 (mg/kg of body weight) per week; or
• After oral dosages of less than 50 mg/kg of body weight per day.

Short Term Exposure Limit (STEL) - The maximum concentration to which a person can be exposed for a short, defined period without experiencing adverse health effects. 

Shall - Designates a regulatory mandate.

Should - Designates a recommendation contained in the regulations or a recommendation from a recognized industry.

Stockroom - Areas where chemicals are mixed, repackaged and/or distributed for laboratory use.

Storeroom - Areas where chemicals are stored with no manipulation of chemicals.

Threshold Limit Value (TLV) - The concentration of a substance in the air to which nearly all persons may be repeatedly exposed day after day without adverse effects.

Time Weighted Average - An average concentration over a longer period, typically an 8-hour workday.

3. RESPONSIBLE PERSONS

Roles and Responsibilities for the Chemical Hygiene Plan (CHP). The following outlines individuals responsible for implementing the Chemical Hygiene Plan (CHP) and their respective duties.

Chemical Hygiene Officer (Director of Safety) is responsible for the overall management of the CHP and laboratory safety programs. Duties include:

• Prepare, implement, and maintain the CHP.
• Coordinate safety and training programs for laboratory personnel.
• Conduct safety inspections and provide guidance on correcting deficiencies.
• Maintain records of all safety training and inspections.
• Promote laboratory safety throughout the university.
• Provide consultation, training, exposure monitoring, record maintenance, and inspections as needed.
• Serve as the primary contact for hazardous material emergencies.
• Act as liaison with external regulatory agencies.

Deans provide leadership and resources to support safe laboratory operations. Duties include:

• Ensure and maintain safe working conditions within their colleges.
• Assist with disciplinary actions for employees who violate safety rules.

Department Heads / Principal Investigators (PIs)  At NMU, Department Heads serve as Principal Investigators for laboratories under their control. Duties include:

• Provide leadership and resources to maintain safe working conditions in the department (e.g., working with department safety committees to implement safety programs).
• For departments with their own CHP/SOPs, assign responsibility for developing and implementing departmental plans. Ultimate compliance responsibility remains with the Principal Investigator.
• Establish laboratory policies, ensuring they meet or exceed regulatory and campus-wide requirements, with approval from the Chemical Hygiene Officer.
• Motivate and assist employees with CHP and SOP compliance.
• Communicate to department employees that attendance at all required safety training sessions is mandated by federal and state law.
• Report employees violating safety rules to the Academic Dean’s office.

Supervisors, Professors, Instructors, and Graduate Assistants, Laboratory Supervisors and Instructors ensure safe daily operations. Duties include:

• Arrange for repairs to maintain a safe laboratory environment.
• Make lab spaces safe for maintenance personnel performing work in the area.
• Clean and decontaminate lab equipment and materials prior to removal from the lab.
• Enforce all CHP requirements.
• Ensure laboratory employees receive proper training before working with chemicals.
• Provide appropriate personal protective equipment (PPE).
  Correct safety deficiencies promptly.
• Maintain accurate chemical inventories.
• Ensure Safety Data Sheets (SDS) are accessible for all chemicals in their inventory.
• Refer to the Hazardous Communications Policy and Procedure for information on the University SDS Repository.

Employees and Students: All laboratory personnel must follow established safety procedures. Responsibilities include:

• Follow the CHP, SOPs, and all safety rules.
• Use appropriate personal protective equipment (PPE).
• Report safety hazards to their supervisor immediately.
• Report signs or symptoms of exposure, known exposures, accidents, or near misses to their supervisor.
• Attend all required safety training sessions.

4. UNIVERSITY CHEMICAL HYGIENE PLAN REVIEW COMMITTEE

The NMU Safety Department will hold an annual review of this CHP. There will be two review committees, one representing academics and one representing facilities. These committees will be charged with overseeing the direction of the CHP and recommend updates. There will be a representative from each of the following departments:

Academic Chemical Hygiene Plan Review Committee

• Chemistry
• Biology
• Art & Design
• Psychology
• Technology and Occupational Sciences
• Clinical Sciences
• Center for Forensic Science
• Brain Tumor Center
• Physics
• Seaborg Center
• Sociology/Anthropology
• Nursing
• EEGS            

Facilities Chemical Hygiene Plan Committee 

• Auxiliary Services
• Dining Services
• Plant Operations
• Grounds
• Building Services
• Trades
• Preventative Maintenance
• Ripley Heating Plant

5. ENFORCEMENT 

Persons who disregard the contents of this plan, the following steps will be taken to correct the situation: 

• Step 1 - The individual will be notified of the problem by their Department Head and/or Supervisor and given the opportunity to comply in a timely manner. 
• Step 2 - If there is still a problem following step 1, then the Dean of the College will be notified of the problem. The Department Head and/or Supervisor will meet with the individual and reinforce the need to correct the problem. The individual will be given the opportunity to comply in a timely manner. 
• Step 3 - If there is still a problem following step 2, then the Director of Safety and Dean of the College will meet with both the individual and Department Head and/or Supervisor to again reinforce the need to correct the problem. The individual will be given the opportunity to comply in a timely manner. 
• Step 4 - If there is still a problem following step 3, then the Dean of the College and Director of Safety must take the problem to Human Resources and/or Academic Affairs to consider further action. 

6. GENERAL SAFETY RULES

General Safety Practices: 

• Avoid working alone. Never work alone in areas where hazardous chemicals are stored or used. If working alone is unavoidable, the laboratory supervisor must:
  • Assess hazards thoroughly.
  • Develop contingencies for emergencies.
  • Approve the work only if the risk of injury is minimal.
  • Maintain regular contact with the employee working alone.
• Wear appropriate personal protective equipment (PPE) at all times when hazardous chemicals are present or hazardous operations are underway.
• Food and beverages are prohibited in laboratories where hazardous chemicals are used or stored; Food or beverages used for research must be clearly labeled as “NOT for human consumption.”
• Never smell, taste, or mouth-pipette chemicals.
• Wear proper clothing / secure dangling or loose items:
  • Long pants and shirts that cover the torso (long or short sleeves).
  • Closed-toe and closed-heel shoes with socks.
  • Tie back long hair and secure loose clothing. Remove dangling jewelry.

Chemical Handling and Storage: 

• Store flammable and corrosive chemicals in approved cabinets.
• Maintain an up-to-date chemical inventory and indicate the location of Safety Data Sheets (SDS).
• When handling chemicals, be aware of:
  • Hazards as identified in the SDS or other verified references.
  • Required PPE and safeguards.
  • Emergency equipment location and proper use.
  • Proper storage and disposal methods.
  • Safe transport procedures within the facility.
  • Emergency procedures, including evacuation routes and spill cleanup protocols.
• Return all chemicals to their assigned storage locations at the end of each day.
• Keep fume hoods operational with doors/sashes in place before working inside them.

Flammable and Ignitable Materials: 

• Ensure no ignition sources are near flammable chemicals.
• Return flammable materials to designated flammable storage cabinets.

Emergency Response to Accidents, injuries, or Chemical Releases: Any occurrence, including, but not limited to, equipment failure, container rupture, or failure of control equipment, that results in an uncontrolled release of a hazardous chemical into the workplace constitutes an emergency. In all emergency situations, NMU prioritizes human safety above all other considerations. Individuals exposed to an emergency must take whatever actions are necessary to protect their personal safety. All procedures that follow are provided as guidance only and are to be followed solely when it is safe to do so:

• In emergencies, dial 911 and 
• Notify your supervisor immediately.
• Supervisors should take appropriate action.
• Injuries must be reported through the NMU Incident Reporting System (accessible via MyNMU).
• Accidents and chemical releases must also be reported to NMU Dispatch.

Laboratory Conduct

• Avoid horseplay, practical jokes, or distractions in areas with hazardous materials or potentially dangerous operations.
• Be alert for unsafe conditions; either remediate hazards or notify a supervisor.
• Do not block access to:
  • Emergency equipment
  • Safety showers and eyewashes
  • Fire extinguishers
  • Electrical panels
  • Gas shutoff valves
  • Exits
• Keep work areas, hoods, aisles, hallways, and stairways free of clutter and obstructions.
  

Equipment and Waste Management

• Inspect all equipment and PPE for damage before use.
• Clean work surfaces and floors regularly; maintain a slip- and trip-free environment.
• Return materials requiring long-term storage to appropriate storage areas.
• Ensure all chemical containers are closed when not in use.
• Dispose of glass, sharps, and chemical waste according to departmental SOPs.
• Label and store waste containers properly.
• Secure compressed gas cylinders at all times, keeping cylinder caps in place when not in use.

Visitors and Maintenance Personnel

Ensure service/maintenance workers and visitors are not exposed to hazardous materials in the laboratory.

Hygiene

Wash hands thoroughly after handling chemicals, even if gloves were worn.

7. UNDERSTANDING AND RECOGNIZING CHEMICAL HAZARDS

To ensure that employees of Northern Michigan University (NMU) are not exposed above regulatory standards to chemicals, each employee must be knowledgeable of the chemical hazards in his/her work environment. Each employee must be able to identify chemical hazards and understand what measures can be taken to eliminate chemical hazards. This section addresses how to understand and recognize chemical hazards. 

Each hazardous chemical container label includes the product identifier used on the SDS. Additionally, the label contains a signal word, hazard statement(s), OSHA standard pictograms(s) and precautionary statements(s) for each hazard class. Pictograms have been standardized with the Global Harmonization Standard. 

These pictograms are the standards used at NMU. For a digitally accessible version, and downloadable pictograms that can be resized, see the pictograms on the OSHA website at https://www.osha.gov/hazcom/pictograms

Employee Training: All Employees of Northern Michigan University are required to take Hazardous Communication; Right to Understand training. 

Northern Michigan University is using Vector LMS, Higher Education Edition to offer online training courses for your convenience. Through your MyNMU, under the Safety Department tile, you will find the link to the Employee Training System. Or go directly to Safe Colleges  Employee Online Training. Log in using your NMU credentials and begin your training session. 

Supervisors shall provide a safety orientation specific to their lab and operation to new lab workers. The lab specific safety training shall be completed before the worker is granted unescorted access to or assigned work activities in the lab. This training must be documented and the supervisor shall keep a copy of this record for each active employee.

Lab Safety Training at a minimum will include the following:

• The content and requirements of the Laboratory Standard
• The content, location, and availability of the chemical hygiene plan.
• The location and availability of SDS and other reference materials.
• The methods and observations that may be used to detect the presence or release of a hazardous chemical.
• Signs and symptoms associated with exposures to the hazardous chemicals used in the laboratory.
• The measures employees can use to protect themselves from these hazards, including specific procedures such as appropriate work practices, personal protective equipment to be used, and emergency procedures. 
• The proper disposal of hazardous waste
• Individual Departments may assign additional training.

If there are any questions about training contact the Department Head, principal investigator, the supervisor, or the University Chemical Hygiene Officer.

Identification of Hazardous Chemicals: Before starting any procedure that requires the use of a chemical, you must identify the hazards associated with the chemical. Reading and understanding the warning or hazard labels on the chemical containers and the Safety Data Sheet (SDS) for each of the chemicals used can help achieve this. All Safety Data Sheets can be found in the NMU Safe Colleges SDS Repository

Signage: At a minimum, you should post the following signs in each laboratory: 

• Lab Door Sign, which includes telephone numbers for NMU Police (2151), the Department Office and supervisory personnel, should be posted on the outside of the lab door. 
• Location signs for safety equipment, such as safety showers, eyewash stations, fire extinguishers, emergency cut-off switches, gas shut off valves and first aid equipment. 
• MIOSHA Right to Understand signs designating the location of SDS information.
• Warning signs where dangerous equipment is in use or where potentially dangerous operations are taking place.
• Unattended Lab Operations signs should be posted next to lab operations running unattended.

Chemical Labeling: See the NMU Hazard Communication Policy for more information about the Michigan Hazard Communication Standard and Michigan's Right To Know Law, as they pertain to; Hazardous Material Inventory, Purchasing, Labeling, Portable Containers, Waste, Safety Data Sheets, Employee Training, Firefighters Right To Know and Contractor Responsibilities. At minimum, each new chemical container from a manufacturer must be labeled with the following:

• Name of chemical (no abbreviations). 
• Hazard warnings. 
• Name and address of supplier. 
• Chemical concentration. 
• At a minimum, you must label each transfer chemical container(secondary container) with the following: 
• Name of chemical (no abbreviations). 
• Hazard warnings. 
• Chemical concentration. 

For small chemical containers that are too small for a legible complete label, such as sample vials, it is appropriate to label them with a letter or numbering system and place them in a secondary container that is labeled with the chemical name, hazard warning, and chemical concentration. You must also properly label containers of non-hazardous materials. (Example: distilled water). Dispose of unlabeled containers as unknown hazardous waste.

Safety Data Sheet (SDS): Departments shall ensure access to Safety Data Sheets (SDS) for each hazardous chemical used in their department. SDS must be readily available to employees and students in their work area. When a new chemical arrives, you must fill out the SDS Additions Form ADDITIONS

The NMU Safety Department maintains a searchable SDS database for all chemicals on campus. To view this repository scan the QR Code or use the following link: NMU Safe Colleges SDS Repository

Chemical Inventory: 

• All Departments are responsible for their own chemical inventory. It is REQUIRED that departments update the inventory of every lab/studio/chemical storage room on an annual basis. 
• Each laboratory shall maintain a hazardous chemical inventory. If a new chemical is introduced the SDS must be immediately uploaded to the Repository by filling out the additions form.
• The inventory of each Laboratory must match the inventory of SDSs for each Laboratory.
• To add chemicals to the inventory use the ADDITIONS
• To remove chemicals use the DELETIONS this will archive the SDS.
• Store all chemicals safely and properly. Store by chemical classification and hazard, and separate incompatible materials. 

Inspections: Principal Investigators/Supervisors are responsible for conducting periodic inspections of laboratories. Quarterly inspections are strongly recommended. These inspections should include but not limited to: 

• Personal protective equipment (PPE)
• Safety equipment 
• Electrical cords
• Laboratory equipment
• Clearance to emergency eyewash and drench stations
• Clearance to first aid and fire blanket
• General laboratory conditions during the inspection.

If you discover any defective equipment during the safety inspection, tag it, take it out of service, and have it repaired. If the equipment is not going to be repaired, then it is to be recycled/removed from the lab. You may use the Mail and Warehouse Services Work Request System form to have unwanted items removed. 

Each department will maintain a file of inspection checklists and logs. 

8. LAB EQUIPMENT TESTING, INSPECTION AND MAINTENANCE

Maintenance and regular inspection of laboratory equipment are essential parts of the laboratory safety program.

Fume Hoods: Annually during the spring months NMU Engineering and Planning coordinates a third-party contractor to perform certification testing. If deficiencies are found, they are corrected in a timely manner.

Vacuum Pumps: Vacuum pumps tested and maintained according to manufacturer instructions.

Emergency Eyewash and Drench Stations: The NMU Safety Department is responsible for inspecting/flushing safety showers and eyewash stations on a weekly basis. All NMU Safety Department inspections are recorded electronically. These records can be requested by contacting Safety@nmu.edu

Fire Extinguishers: The NMU Safety Department is responsible for inspecting fire extinguishers monthly and annually. All NMU Safety Department inspections are recorded electronically. These records can be requested by contacting Safety@nmu.edu

First Aid Kits: The NMU Safety Department maintains an ANSI Class A first aid kit for all academic labs, studios, and shops. Follow the instructions provided on the kit to request refills of items.

Fire Blankets: All academic laboratories and studios have a fire blanket.

9. PERSONAL PROTECTIVE EQUIPMENT (PPE)

Supervisors and Principal Investigators are responsible for the Personal Protective Equipment (PPE) program in their laboratories. This includes enforcement of the program and maintenance of the equipment. Appropriate disciplinary action must be taken for repeated violation of this program. Each Department must provide the necessary PPE for their employees and instructions of the requirements to their students.

Workplace Assessments: Perform a workplace assessment in each laboratory to determine if hazards requiring the use of PPE are present. This form can be found in Appendix D. If potential hazards are present in the laboratory, do the following:

• Identify each hazard and the source. 
• Determine which body parts are affected.
• Select appropriate PPE against the hazard. 
• Train each employee on the hazards present and when PPE should be worn. 
• Train employees on the proper use, maintenance and limitations of each PPE device used.
• Maintain training records within the department. 

Also, complete and maintain a workplace assessment form for each task or process performed in the laboratory that requires PPE. Do not rely upon PPE alone to completely protect against hazards. Rather, use it in conjunction with effective engineering controls and workplace practices to minimize hazards in the workplace. 

Eye Protection: All safety eyewear and face protection must meet the ANSI Z87.1 standard for minimum allowable protection. All eye and face protection supplied by Northern Michigan University Departments must meet this standard, to provide impact protection. Side shields are required, under Michigan law, on all safety glasses. It is recommended that each individual be issued their own eye protection. MIOSHA regulations state that shared eyewear must be cleaned and disinfected between uses by different wearers. 

Safety glasses do not give adequate protection from chemical splashes. If the potential for liquids to be splashed or sprayed is present, wear safety goggles. When liquids are under extreme, high pressure, wear a face shield. Never wear a face shield without wearing eye protection underneath. 

Contact lenses do not provide eye protection: wearing contact lenses is discouraged when working with materials or procedures that give off gases, vapors, welding fumes, smoke or dust. When choosing to wear contacts, be aware of the hazards of wearing contacts in a lab.

Eye Protection Requirements: Eye protection is absolutely required: 

• When working with or in the vicinity of solvents or corrosive chemicals, or with any chemical that could produce an eye injury. 
• When working near equipment or apparatus under high pressure or vacuum, or when around equipment that could produce projectiles. 
• When near laboratory benches where chemical reactions are being run or when around a radiation hazard. 
• When transporting flammable, corrosive or toxic chemicals. 
• During routine or maintenance activities involving chemicals, hand/power or machine tools, welding, cutting, grinding, or abrasive blasting. 
• When working behind hood doors or blast shields.

Gloves: Gloves provide protection against chemical, radiological and biological agents. Flame-resistant gloves shall be worn whenever possible where pyrophoric reagents are used outside the inert atmosphere of a glovebox. Selection of proper gloves for the work task is critical in maintaining protection against hazardous agents. Note the following for safe glove usage:

• When working with corrosive liquids, solvents, or other potentially hazardous materials, wear proper gloves. One type of glove will not protect against all chemicals. Therefore proper glove selection is critical. Consult with the glove manufacturer(s) as the primary source for glove selection and compatibility with intended procedures. 
• Remove gloves prior to answering phones, using computers, opening doors, or any other situation that might cause the spread of hazardous materials. 
• Remove gloves prior to leaving the laboratory area. 
• Wash hands anytime gloves are removed. 
• Be careful not to touch other parts of your body or apparel while wearing gloves (i.e. pushing up your glasses, etc.). 
• Dispose of gloves as instructed by your supervisor.

Respiratory Protection: Respirators are designed to keep the wearer from inhaling toxic chemicals or other contaminants in the air during accidents, emergencies or when engineering controls are not sufficient to maintain exposures below the Permissible Exposure Limit (PEL). 

Departments shall make every effort to use engineering and workplace controls to minimize exposures. Respirators shall only be used when engineering controls and workplace practices fail to reduce the exposures below the PEL. Departments are responsible for ensuring compliance with the NMU Respiratory Protection Program.

Respirators have inherent hazards and should be considered the last line of defense, and should not be used during routine laboratory operation. If it becomes necessary to use a respirator you must do the following:

• Perform a workplace assessment.
• Contact your Department Head.
• Contact the NMU Safety Department.

Environmental Monitoring: The recommended exposure limits or OSHA-mandated limits for toxic chemicals can be found in the SDS for most of the chemicals used in the laboratory. These limits may be expressed as threshold limit values (TLV), permissible exposure limits (PEL), short-term exposure limits (STEL), ceilings (C), and action levels. These limits help to serve as guidelines for determining the appropriate safety precautions to be taken when handling specific chemicals. In laboratories, instrumental monitoring for airborne contaminants is usually not practical or required.

Contact the NMU Safety Department if you have any monitoring concerns. Safety@nmu.edu            

Hearing Protection: If in the laboratory or studio or other work setting, if a process is being conducted with a high noise output, contact NMU Safety Department to conduct a noise survey. From this survey, the following items can be addressed:

• Sources of noise output. 
• Whether the action levels are exceeded.
• Types of hearing protection devices needed and when they should be worn.
• Who is affected by the noise.

Generally speaking, if you have to raise your voice to have a conversation with the person standing next to you, then the noise may be at a level that requires a noise survey and assessment. 

10. SPECIFIC CHEMICAL HAZARDS

Particularly Hazardous Substance (PHS): Particularly hazardous substances, by MIOSHA definition, are select carcinogens, reproductive toxins and chemicals with a high degree of acute and chronic toxicity. MIOSHA Part 431. Hazardous Work in Laboratories mandates the establishment of specific provisions to protect employees who work with particularly hazardous substances. Therefore, a written standard operating procedure (SOP) is REQUIRED to be completed and kept on file in the lab.

An SOP form can be found in appendix F. This form is to be filled out for each of the Particularly Hazardous Substances in your chemical inventory. In some cases, you may have several substances that are nearly identical in their composition, function, and hazards. In this case only one form is required however you must list each substance on the form. Forms are to be submitted to the NMU Safety Department and are to be kept in the laboratory where the chemical is stored/used.

Examples of substances that could be considered particularly hazardous under MIOSHA:

• Carcinogens: Benzene, asbestos, formaldehyde
• Reproductive toxins: Lead, bisphenol A
• Highly toxic chemicals: Cyanide, mercury, arsenic
• Corrosive Chemicals: Hydrochloric acid, Sodium Hydroxide
• Solvents: Methylene chloride (or dichloromethane)
• Pyrophoric/Water Reactive Chemicals: Metal Hydrides, Lithium metals
• Explosives: Ammonium Nitrate, Benzoyl Peroxide, Sodium Azide
• Organic Peroxides or Peroxide-Forming Chemicals
• Label all peroxide-forming chemicals with the date the container was received from the supplier. Use or dispose of any peroxide-forming chemical prior to the expiration date. 
• For additional guidance for Hazard Determination see the MIOSHA Guidance Site

11. CHEMICAL ORDERING/STORAGE/DISPOSAL PROCEDURES

Ordering Chemicals: 

• Check your department chemical inventory to verify that the chemical is not already available.
• Obtain information concerning proper handling, storage and disposal of the chemical. 
• Determine the minimum amount of chemicals needed to complete the work. Do NOT order extra amounts of chemicals that will not be used in a timely manner.
• Chemicals MUST arrive with the proper hazard communications labeling and SDS. 
• Do not accept a chemical container without the proper hazard communications labeling.

Chemical Stockrooms and Storerooms: Stockrooms are defined as areas where chemicals are mixed, repackaged and/or distributed for laboratory use. Storerooms are defined as the areas where chemicals are stored with no manipulation of chemicals.

• Store hazardous materials, when not in immediate use, in an environmentally controlled, stockroom, storeroom, or storage cabinet.
• Do not use storerooms as preparation or repackaging areas.
• Do not transport chemicals from the stockroom unless they are in a secondary container.
• Wear proper PPE when moving chemicals.

Chemical Storage: Follow these general procedures for storage of chemicals:

• Conduct routine inspections to check containers for deterioration and integrity.
• Store the smallest amounts of hazardous materials as practical in the laboratory.
• Do not use fume hoods as storage areas for chemicals.
• Store chemicals in cabinets or on shelves, not on the floor.
• Store chemicals according to hazard class, not alphabetically.
• Do not store incompatible materials together.
• Secure bottle caps to prevent accidental spills and minimize odors.
• Provide spill trays in liquid storage areas.
• Store large quantities and heavy chemicals on lower shelves. Store only lightweight or small quantities above eye level.
• Do not store corrosive materials of any quantity above eye level.
• Wear appropriate PPE, including eye protection, when handling chemicals stored above eye level.
• Keep an appropriate step stool available for reaching overhead storage.
• Store chemicals away from heat and direct sunlight.
• Avoid containers derived from disposable food products in labs where hazardous chemicals are used.

Flammable Materials Storage: Store all flammable materials in a proper flammable cabinet.

Corrosive Materials Storage:

• Store mineral acids, such as sulfuric and hydrochloric acids, in acid storage cabinets.
• Store bases and solutions of bases separately from acids.
• Store oxidizing acids, such as nitric and perchloric acids, with oxidizing materials and away
• from organics.
• Store organic acids, such as acetic and formic acids, with flammable materials.

Oxidizer Storage: Store oxidizers, such as hydrogen peroxide and chlorine bleach, away from all organic materials and reducing agents. Do not store near any combustible materials.

Compressed Gas Storage:

• Chain or secure all gas cylinders to a permanent fixture and store with the caps on when not in use.
• Store oxygen cylinders away from fuels and other combustible materials.
• Mark empty cylinders as “Empty” and store away from other cylinders.
• Cylinders not in active use should be removed from laboratory work areas to a designated storage area for the building. Cylinders should not be stored for more than 3 years.
• Cylinders of hydrogen fluoride and hydrogen bromide should be returned to the supplier within 2 years of the delivery date.
• Toxic, corrosive, or unstable gases:
  • These gas cylinders must be dated when they arrive. Order only the smallest quantity needed for the work.
  • These gases must be stored and used in a ventilated gas cabinet, exhausted enclosure, or a ventilated separate gas storage room.
  • Gases that are not being used should be turned in to the hazardous waste manager or returned to the supplier within one year from the delivery date. Gases that are kept for more than one year can degrade, or the cylinder and connections can degrade in such a way as to become very unstable and dangerous.
  • Emergency procedures should be made clear to all involved, including personnel from adjacent labs.
  • Fume hoods and other ventilation need to be tested before use and checked frequently during the project involving toxic gas.

Toxic Chemicals and High Risk Chemicals:

• Store toxic materials separately from other chemicals.
• Store in a vented cabinet.
• Store materials that are highly acute toxins and other high-risk chemicals with the parent container inside an unbreakable secondary container.
• Post specific warning signs on the storage area.
• Maintain records of use and disposal.

Reactive Chemicals: 

• Store reactive chemicals away from other chemicals.
• Store water reactive chemicals in cabinets protected from the fire sprinkler system or other water sources.
• Store specified reactive materials under either inert atmosphere and/or refrigeration.
• Inventory materials that may form organic peroxides and dispose of them at the time of expiration.
• Store explosive materials as specified by the manufacturer. Only knowledgeable and trained individuals may handle these materials.

Hazardous Waste Chemical Satellite Accumulation Area: A satellite accumulation area is temporary storage of hazardous waste at the point where it is generated. For example, within a lab or work area before being transported to the Hazardous Waste Storage Room. A satellite accumulation area is limited to one of the following:

• 4 liters of non acute hazardous waste. 
• .95 liter of liquid acute hazardous waste or severely toxic hazardous waste.
• One kg of solid acute hazardous waste or severely toxic waste.

Once the limit is reached, the container must be labeled with the date and be taken to the hazardous waste storage room. Containers must be labeled with the words “HAZARDOUS WASTE” and a description of the hazardous waste. Please use labels in Appendix C. You can print on sticker back paper or contact Safety@nmu.edu for stickers. DO NOT date the satellite container until it is moved to the Hazardous Waste Storage Room. Containers must be properly capped at all times except when adding to or pouring off waste material or if temporary venting is necessary. Liquid waste must be stored inside secondary containment.

Hazardous Waste Disposal: Hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. The goal of the NMU hazardous waste disposal program is to reduce the potential harm to people and the environment.  Minimize the amount of waste generated. For example: 

• When possible use non-hazardous alternatives.
• Recycle or reclaim materials when possible.
• Know the disposal requirements before ordering a material/chemical.

Containers must be labeled with the words “HAZARDOUS WASTE” and a description of the hazardous waste. Please use labels in Appendix C. You can print on sticker back paper or contact Safety@nmu.edu for stickers.

Mixture Rule: A listed hazardous waste plus a non-hazardous waste is always a hazardous waste. To dispose of hazardous materials fill out this form Hazardous Waste Disposal Form. If you are in Chemistry or Biology contact your Lab Supervisor for Hazardous Waste Disposal. 

Laboratory glass waste: Glass should NOT go into the regular trash cans. Lab glass should be disposed of in a labeled glass waste container. Dispose of: 

• Clean glass only.
• No liquids
• No highly toxic residues.
• No needles or razor blades.

Sharps waste: Sharps are needles (and attached syringes), lancets, scalpel and razor blades (even if not contaminated) or any item sharp enough to penetrate the skin that may or may not be contaminated with potentially infectious material. Sharps are disposed of by incineration through a contracted, licensed, regulated medical waste hauler. Sharps are to be collected in an FDA approved sharps container that is leak proof, puncture-resistant, closable and bears the biohazard symbol. A sharps container must be permanently closed when the contents reach the full line indicated on the container.

The container must be disposed of within 18 months of the date the first sharp was placed in it. Label sharps containers with the date the first sharp is placed in it as well as the disposal date. Take this time frame into consideration when ordering containers. When your container is ready for disposal contact the NMU Safety Department at Safety@nmu.edu with the building and room number where the container is located.

Disposal of Empty Chemical/Solvent Bottles:

• Deface or remove the label on all empty containers.
• Solvent bottles must be rinsed and air dried in a chemical fume hood until they are free of liquid and odor. All rinsate should be disposed of as hazardous waste.
• Corrosive liquid bottles should be triple rinsed with water and free of hazards and odor. Collect rinsate as hazardous waste.
• Clean plastic containers go to Waste Management Recycle.
• Clean glass containers go to glassware waste.
• Clean metal containers go to Waste Management Recycle.

12. LABORATORY DECOMMISSIONING CRITERIA

If you are faculty or staff leaving the University, make an appointment with your department head and lab supervisor (if applicable) to check out your laboratory, shop, or studio space. Likewise, if you are leaving for sabbatical or other leave for a period of time you must decommission your workspace appropriately. At a minimum, removal of hazardous waste, store and secure chemicals, materials and equipment. All chemicals, hazardous waste, student projects and any other potentially hazardous materials must be properly dealt with before you leave. Additionally, if applicable, cleaning and decontamination of the space must be completed prior to your departure:

• Hazardous chemical waste and unwanted chemicals should be disposed of. 
• Before leaving the laboratory, all chemical storage areas should be completely clean.
• Wipe down all surfaces, and empty shelves, cabinets, and drawers. This includes; chemical storage equipment (corrosive cabinets, flammable liquid storage cabinets, laboratory refrigerators and freezers) must be decontaminated prior to moving.
• Clean out all fume hoods. All research apparatus must be decontaminated.
• All unnecessary compressed gas cylinders should be removed prior to leaving the laboratory. Compressed gas cylinders must be properly secured and capped when they are transported. Compressed gas cylinders must be transported in an approved cylinder cart.
• Practice good general housekeeping. All papers, rags, empty bottles, boxes etc. should be properly disposed of prior to vacating the laboratory.

13. CHEMICAL EMERGENCY ACTION

Spill Procedures: It is the responsibility of the department to have spill response materials available. Spill response materials must be available and readily accessible for any satellite waste accumulation site. For labs, studios, shops satellite waste accumulation sites include all spaces with hazardous waste containers.

Hazardous Spills: In the event of a hazardous chemical spill, do the following:

• Eliminate all sources of ignition and evacuate the immediate area.
• Close all doors leading into the spill area.
• If applicable, assist contaminated persons to a safety shower or eyewash station.
• Notify NMU Police Department by calling 906-227-2151 OR 911 if an emergency.
• Report the spill immediately to your supervisor.
• Report whether the spill has entered the air, ground, sanitary or storm sewers, or any surface water.

Incidental Spills: In the event of an incidental spill, do the following:

• Assess the hazard.
• Wear appropriate PPE. At a minimum, this requires gloves, lab coat, and safety glasses/goggles.
• Isolate/barricade the affected area.
• Notify a coworker that you are cleaning up the spill.
• Neutralize strong acids and bases.
• Dispose of all chemical spill cleanup material as hazardous waste.
• Write a brief report describing how the spill occurred and the cleanup procedures used. Send a copy to your supervisor and the NMU Safety Department Safety@nmu.edu         

Personal Chemical Exposure: Chemical exposure can lead to irritation or burns of the skin, eyes, throat, and lungs, dizziness, headaches, disorientation or unconsciousness, or damage to internal organs. 

• **CONTACT 911** AND PERFORM THE FOLLOWING AS APPROPRIATE
• If your eyes are splashed with a chemical:
  • Immediately flush them in the nearest eyewash fountain for 15 minutes.
  • Keep your eyes open while washing them.
  • Seek medical attention.
• If your skin comes in contact with a chemical:
  • Flush the area with water for 15 minutes and remove contaminated clothes
  • If large areas are exposed, go to the emergency chemical shower and begin flushing with water at once while removing clothes in the shower. Continue flushing with water for 15 minutes.
  • Seek medical attention.
• If you inhale a chemical:
  • Immediately move to fresh air. 
  • Seek medical attention.
• If you ingest a chemical:
  • You may or may not induce vomiting depending on the chemical. 
  • Refer to the SDS for recommended first aid. Never induce vomiting when corrosives are ingested.
  • Seek medical attention.

Fire: In the event of a fire, prioritize your personal safety above all else and do whatever is necessary to remain safe. If it is safe to do so, take the following actions:

• Activate the fire alarm pull station.
• Instruct all personnel you see to evacuate the facility immediately.
• Leave the area, closing doors as you leave to help confine the fire.
• Stay at a safe location near the building to advise emergency personnel on the nature of the fire.

Utility Failure: The interruption of any utility services either scheduled or from natural causes, is considered an emergency event. 

• If the ventilation system shuts down, cease and safely shut down any operations in the ventilated areas. 
• Close and secure all chemical containers.
• A building evacuation may be required.
• Shut down ovens and kilns.

Reporting Injuries: If anyone is in need of emergency medical attention call 911 and report your specific location on the NMU Campus. To report injuries on the NMU campus follow these instructions at NMU Incident Reporting Policy 

Appendix A - Informational Links

NMU Police Department 906-227-2151

NMU Campus Safety Campus Safety webpage and Safety@nmu.edu

OSHA Laboratory Standard 29 CFR 1910.1450

Michigan OSHA Hazardous Work in Laboratories Standard Part 431

§1910.1200 MIOSHA Hazard Communication Standard 

NMU Hazard Communications Policy & Procedure

NMU Employee Online Training

NMU Safe Colleges SDS Repository

Form to have an SDS uploaded to the NMU Repository ADDITIONS

Form to have an SDS archived in the NMU Repository DELETIONS

NMU Hazardous Waste Disposal Form

To have unwanted equipment removed Work Request System

NMU Respiratory Protection Program

MIOSHA Guidance for Chemical hazard determination MIOSHA Guidance Site

Chemical Database of Hazardous Materials CAMEO Chemicals

NMU Incident Reporting Policy NMU Incident Reporting Policy 

Appendix B - Lab Sign Templates: Print and post as needed

Appendix C - Hazardous Waste Label - Secondary Container Label 

Print on sticker paper and use appropriately 

Appendix D - PPE Assessment Form - Print and use as needed. Keep a copy in the department

Appendix F - Standard Operating Procedure for specific chemical hazards

Appendix G - Laboratory Standard Operating Procedure Form
Print and use this form for laboratory pro

Acknowledgment: Portions of this Chemical Hygiene Plan are derived from authorized materials provided by Central Michigan University. We gratefully acknowledge their contribution.