MIOSHA Laboratory Standard Chemical Hygiene Plan
|Oversight Unit:||NMU POLICE DEPARTMENT|
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The purpose of this Chemical Hygiene Plan (CHP) is to minimize or eliminate human exposure to hazardous chemicals in the laboratory and in the field. This document serves as the written policy/procedure for University compliance to the MIOSHA Laboratory Standard, and the Chemical Hygiene Plan (CHP) requirements of the standard. All laboratory authorized personnel engaged in the laboratory use of hazardous chemicals are required to comply with this document.
Faculty, Staff and Students.
The Chemical Hygiene Plan will be reviewed annually from its effective date by the Safety Director and University Safety Committee, and revised and updated as needed. This review and approval will be conducted in accordance with the provisions of the Hazardous Materials Management Policy.
Chemical Hygiene Plan
Northern Michigan University is committed to employee safety as demonstrated by the University Safety Policy:
“Northern Michigan University believes that a "Total Safety" Program is essential in advancing the well-being of its students and employees.
It is the policy of Northern Michigan University to promote safe living and working through an effective safety program in all phases or our operation: Education, research, student service, public service and employee and community relations.
It is the responsibility of supervisors to make this safety policy effective. All supervisors are responsible for applying sound safety practices and safety education principles to students and employees within their jurisdiction. It is the role of the Public Safety Department to promote the use of safety principles, provide technical services to assist supervisors in their application and ensure compliance with the requirements of the University Safety Program.
It is the responsibility of all employees and all students to cooperate with the University Safety Program by observing all safe practices, policies and standards, and to observe all safety laws and regulations. Additionally, employees and students have the responsibility to alert their supervisors or instructors of any hazard in need of correction, and to suggest safety improvements.”
Furthermore, it is the responsibility of Northern Michigan University, as an employer, to take every reasonable precaution to provide a work environment that is free from recognizable hazards for its employees in accordance with the "general duty" clause of the Michigan Occupational, Safety and Health Act, Section 11(a).
NMU is required by the Michigan Occupational Safety and Health Administration (MIOSHA) Hazardous Work in Laboratories standard (the Laboratory Standard - §408.1024 of the Michigan Compiled Laws), NMU’s Hazardous Communications Policy and Hazardous Materials Management Policy to ensure that the necessary work practices, procedures and policies are implemented to protect all employees working in University owned and operated laboratories from hazardous chemicals in the work area.
For the purposes of this document, "Laboratory" means a facility where the "laboratory use of hazardous chemicals" occurs. It is a workplace where relatively small quantities of "hazardous chemicals" are used on a non-production basis.
Northern Michigan University and its employees have the responsibility to be well informed regarding hazardous chemicals and risks associated with using hazardous chemicals in the laboratory environment. This document is for University-wide compliance with the MIOSHA Laboratory Standard and will serve as a broad-based Chemical Hygiene Plan for all University owned and operated laboratories, industrial arts classrooms, and all other places where chemicals are used by employees, students or guests.
The provisions of this plan apply equally to employees, students, visiting scientists, or Research Associates who are authorized to work in University owned and operated laboratories. Throughout this document, the phrase “laboratory authorized personnel” or “laboratory authorized person(s)” will mean “employees, students, visiting scientists or Research Associates who are authorized to enter or work in University owned and operated laboratories. In addition, the terms laboratory or laboratories are intended to include industrial arts shops/classrooms, nursing labs, or similar settings where hazardous chemicals or potentially hazardous work practices are involved.
The purpose of this Chemical Hygiene Plan (CHP) is to minimize or eliminate human exposure to hazardous chemicals in the laboratory and in the field. This document serves as the written policy/procedure for University compliance to the MIOSHA Laboratory Standard, and the Chemical Hygiene Plan (CHP) requirements of the standard. All laboratory authorized personnel engaged in the laboratory use of hazardous chemicals are required to comply with this document.
This CHP is designed to be a “living document.” It will be reviewed annually from its effective date by the Safety Director and University Safety Committee, and revised and updated as needed. This review and approval will be conducted in accordance with the provisions of the Hazardous Materials Management Policy ( http://www.nmu.edu/policy/hazardous_materials.htm ).
The University Chemical Hygiene Plan is available to authorized persons through the University web site: http://www.nmu.edu/safety [This is a place-holder for the final address of the CHP].
1.2 HAZARDOUS CHEMICAL DEFINITION
MIOSHA recognizes that a chemical may pose a health or physical hazard. Any chemical that is a health or physical hazard is a hazardous chemical. These are defined by MIOSHA as follows:
A chemical is a health hazard if there is statistically significant evidence, based on at least 1 study that is conducted in accordance with established scientific principles, that acute or chronic health effects may occur in laboratory authorized personnel who are exposed to the chemical. These health effects include those that result from exposure to chemicals which are any of the following:
2. Toxic or highly toxic agents
3. Reproductive toxins
10. Agents that act on the hematopoietic systems
11. Agents that damage the lungs, skin, eyes or mucous membranes
A chemical is a physical hazard if there is scientifically valid evidence that it is any of the following (See appendix C for definition of terms):
1. A combustible liquid
2. A compressed gas
5. An organic peroxide
6. An explosive
7. An oxidizer
8. A pyrophoric
9. An unstable material (reactive)
10. A water reactive material
Particularly hazardous substances are defined by MIOSHA to include select carcinogens, reproductive toxins, and substances that have a high degree of acute or chronic toxicity.
Select carcinogens are defined by MIOSHA to be identical with the definition adopted by OSHA which is:
Select carcinogen means any substance which meets one of the following criteria:
(i) It is regulated by OSHA as a carcinogen; or
(ii) 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
(iii) It is listed under Group 1 ("carcinogenic to humans") by the International Agency for research on Cancer Monographs (IARC)(latest editions); or
(iv) 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:
(A) After inhalation exposure of 6-7 hours per day, 5 days per week, for a significant portion of a lifetime to dosages of less than 10 mg/m(3);
(B) After repeated skin application of less than 300 (mg/kg of body weight) per week; or
(C) After oral dosages of less than 50 mg/kg of body weight per day.
Reproductive toxicants are defined by MIOSHA as any chemicals that affect the reproductive capabilities, including chromosomal damage (mutations) and effects on fetuses (teratogenesis). Information on reproductive effects will be listed on the MSDS.
Chemicals with a high degree of acute and chronic toxicity are not defined in the Laboratory Standard. Therefore, the MIOSHA Hazard Communication definition of a highly toxic chemical will be used. Chemicals with a high degree of acute toxicity are chemicals that have a median lethal dose (LD50) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each. The LD50 is that dose at which a lethal response is observed in 50% of the test animals.
The following sources have established lists of hazardous chemicals based on substantiated tests:
1. OSHA, 29 CFR 1910.1200 Subpart Z, Toxic and Hazardous Substances and Appendices A and B of OSHA 29 CFR 1910.1200 which are referenced in MIOSHA R325.70101(2)
2. American Conference of Governmental Industrial Hygienists (ACGIH), “Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment,” (latest edition) The hazard(s) of a chemical may also be listed on its container label. Additionally, if the hazard of a chemical is not evident from the container label, the Material Safety Data Sheet (MSDS) will list the specific hazards. Use the MSDS to address chronic toxicity.
In addition to the foregoing, Northern Michigan University will regard as hazardous chemicals
1. any chemical that bears a Hazardous Material Information System (HMIS) rating of 2, 3 or 4
2. any chemical that bears a National Fire Protection Association (NFPA) rating of 2, 3 or 4.
3. any chemical that has a bio-safety level of 2, 3 or 4
4. any chemical that is described in its MSDS as toxic or with additional modifiers such as “highly toxic.”
If you are not sure a chemical you are using is hazardous, review the Material Safety Data Sheet for the substance or contact your supervisor.
1.3 DEFINITION OF RESPONSIBILITIES
Chemical Hygiene Responsibilities
Responsibility for chemical hygiene rests at all levels including the:
1. President of the University, who has ultimate responsibility for chemical hygiene within the University and must, with other administrators, provide continuing support for institutional chemical hygiene.
2. The University Safety Director who is responsible for the implementation of the University Safety Program
3. The Dean of the college who is responsible for ensuring that all aspects of the University Safety Program are implemented within the college.
4. Department Head, who is responsible for chemical hygiene within the department and serves as the Chemical Hygiene Officer and who must:
(a) Work with administrators and other employees to develop and implement appropriate chemical hygiene policies and practices;
(b) Monitor procurement, use, and disposal of chemicals used in the lab;
(c) See that appropriate audits are maintained;
(d) Help project directors develop precautions and adequate facilities;
(e) Know the current regulatory requirements; and
(f) Seek ways to improve the chemical hygiene program.
5. Laboratory supervisor1, who has overall responsibility for chemical hygiene in the laboratory including responsibility to:
(a) Ensure that workers know and follow the chemical hygiene rules, that protective equipment is available and in working order, and that appropriate training has been provided;
(b) Provide regular, formal chemical hygiene and housekeeping inspections including routine inspections of emergency equipment;
(c) Know the current legal requirements concerning regulated substances;
(d) Determine the required levels of protective apparel and equipment; and
(e) Ensure that facilities and training for use of any material being ordered are adequate.
6. Project director or director of other specific operation, who has primary responsibility for chemical hygiene procedures for that operation.
1Laboratory Supervisor means any person who has been designated by the Chemical Hygiene Officer as having responsibility for the personal use of a laboratory or to supervise others who use a laboratory. A Laboratory Supervisor must be a department head, a faculty member, adjunct faculty member, post doctoral faculty member, or a graduate teaching assistant. A Laboratory Supervisor must be qualified to assure compliance with this Chemical Hygiene Plan.
The Department Head has the responsibility for implementing the chemical hygiene plan in the department, and providing continuing support for chemical hygiene and the proper handling of all hazardous materials including radioactive material and biological materials.
There shall be a Department Safety Committee of three or more members to review and recommend policies that provide for safe conduct involving hazardous chemicals and to develop guidelines for reviewing and approving the use of high risk substance in the laboratories. The Departmental Safety Committee is recommended by the Department Head and notification of the committee’s membership provided to the College Dean and University Safety Director.
There shall be departmental representation in the University Safety Committee oversight structure as determined by University Safety Director.
Scientific research projects or investigations must be reviewed and approved by the department’s Chemical Hygiene Officer and Safety Committee prior to the commencement of the project. The proposal for a research project must contain
1. The name of the Principal Investigator who will be in charge of the project.
2. A statement of known hazardous risks associated with the project.
3. A statement of known security risks associated with the project.
4. A safety/security plan for the project that addresses
a. Chain of custody for substances of known risk
b. Safety training
c. Record keeping
Records of research projects must be retained by the department for seven years.
The Department Chemical Hygiene Officer sits on the Department Safety Committee, has the responsibility for developing and implementing the laboratory safety and chemical hygiene plan, and thus ensures compliance with the regulatory requirements and maintains a safe work environment. Chemical Hygiene Officer shall:
1. Provide general chemical hygiene training.
2. Work with principal investigators to define the location of work areas where toxic substances and/or potential carcinogens will be used, and ensure that the inventory of these substance is properly maintained.
3. Monitor the procurement, use and disposal of chemicals used in laboratories.
4. Know the current legal requirements concerning regulated substances.
5. Maintain an up-to-date list of hazardous materials used or stored, and review it annually.
6. Develop and oversee implementation of the Chemical Hygiene Plan.
Principle Investigator(s) or project directors shall:
1. Ensure that all personnel including visiting scientists and students under his/her supervision have access to copies of this CHP and receive general chemical training from the chemical hygiene officer.
2. Ensure that all personnel under his/her supervision have been trained in safety procedures specific to their work assignment before beginning laboratory work.
3. Maintain an up-to date chemical inventory in his/her teaching and research labs.
4. Report accidents or incidents resulting from the project in accordance with University Policy.(http://www.nmu.edu/OccupationalSafety.htm )
5. Investigate the cause of accidents or incidents resulting from the project and report these to the department’s Chemical Hygiene Officer.
6. Review and update MSDS documents and postings.
7. Ensure that all materials associated with the project are properly labeled.
8. Ensure that cabinets, storage lockers and rooms are properly labeled to reflect the materials associated with the project.
Instructor/Teaching Assistant: will provide student training at the beginning of each lab in which hazardous chemicals are used. Specific safety instructions will be provided at the beginning of each class period. Students will be made aware of chemical health and safety hazards in classroom situations and will be provided with information and equipment to protect themselves from those hazards. In addition, Instructors/Teaching Assistants will report accidents or incidents resulting from lab activity to the Chemical Hygiene Officer and otherwise in accordance with University Policy.
Students are responsible for:
1. Attending required training sessions and following all standard operating procedures of working in the laboratory.
2. Wearing personal protective equipment as directed by the principal investigator or instructor.
3. Reporting to the teaching assistant, faculty member, or department chemical hygiene officer/laboratory supervisor any accidents that in the exposure to toxic chemical, and/or any action or condition that may exist that could result in an accident
1.4 LABORATORY AUTHORIZED PERSONNEL INFORMATION AND TRAINING
Laboratory authorized personnel must have access to information and training to ensure that they are apprised of the hazards of chemicals present in the work area. Such information must be provided at the time of a laboratory authorized person’s initial assignment to a work area where hazardous chemicals are present and prior to assignment involving new exposure situations. Laboratory authorized personnel shall receive periodic refresher information and training to ensure that they are aware of the risks of exposure to hazardous chemicals.
Each Department’s Chemical Hygiene Officer shall provide the refresher information and training for laboratory supervisors at intervals not to exceed one year or immediately whenever new potential hazards are present. Records of this training, including the names of the participants and the subjects covered, must be maintained by the department for a period of seven years. All such records must be sent to Public Safety as well. The department’s Chemical Hygiene Officer is responsible for ensuring that copies MSDS documents are sent to Public Safety as they become available in the department.
Information provided by department/Supervisors to laboratory authorized personnel must include:
1. The contents of the MIOSHA Hazardous Work in Laboratories standard.
2. The location and availability of the NMU CHP.
3. Signs and symptoms associated with exposures to hazardous chemicals used in the laboratory (available on Material Safety Data Sheets).
4. The location and availability of known reference materials 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 the supplier.
Method of Training. General training will be provided by the Chemical Hygiene Officer and may take the form of individual instruction, group seminars, audiovisual presentations, handout material, or any combination of the above. Site-specific training will be provided by supervisors or an appropriate designee.
General chemical hygiene training provided by the Chemical Hygiene Officer to laboratory authorized personnel will include:
1. General physical and health hazards of chemicals in the work area.
2. The measures laboratory authorized personnel can take to protect themselves from these hazards, including specific procedures the department has implemented to protect laboratory authorized personnel from exposure to hazardous chemicals, such as
a. appropriate work practices,
b. emergency procedures, and
c. personal protective equipment (PPE) including MIOSHA standards for use, inventory and cleaning
3. The applicable details of this CHP.
Site-specific training provided by Supervisors to laboratory authorized personnel will include:
1. Site-specific standard operating procedures including personal protective equipment (PPE)
2. Specific physical and health hazards of chemicals in the work area (available on Material Safety Data Sheets).
Supervisors are responsible for training laboratory authorized personnel and students under their supervision in all safety procedures specific to the laboratory authorized person’s work assignment before such work is initiated.
1.5 RECORD KEEPING
The department’s Chemical Hygiene Officer will retain the records on safety training of laboratory authorized personnel who attend the general chemical safety seminar provided by the Chemical Hygiene Officer. Copies of laboratory authorized person’s training records must be sent to Public Safety. It is required that records of specific laboratory training for individual laboratories be retained by the department for a period of seven years.
Accident records for laboratory authorized personnel shall be written and retained within the department for seven years. University Accident/Incident Report must be used and distributed according to policy.
2.0 STANDARD OPERATING PROCEDURES
The University has developed general standard operating procedures relevant to safety and health considerations when laboratory work involves the use of hazardous chemicals. Standard operating procedures must be provided to all affected laboratory authorized personnel.
2.1 GENERAL SAFETY PRINCIPLES
The following general guidelines have been established to minimize hazards and to maintain basic safety in the laboratory.
1. Examine the known hazards associated with the materials being used. Never assume all hazards have been identified. Carefully read the label before using an unfamiliar chemical. When appropriate, review the Material Safety Data Sheet (MSDS) for special handling information. Determine the potential hazards and use appropriate safety precautions before beginning any new operation.
2. Be familiar with the location of emergency equipment - fire alarms, fire extinguishers, emergency eyewash and shower stations and know the appropriate emergency response procedures.
3. Ensure fire extinguishers and pull stations are unobstructed and that eye wash and shower stations are tested and records kept.
4. Avoid distracting or startling other workers when they are handling hazardous chemicals.
5. Use equipment and hazardous chemicals only for their intended purposes.
6. Always be alert to unsafe conditions and actions and call attention to them so that corrective action can be taken as quickly as possible.
7. Wear eye and face protection when appropriate.
8. Always inspect equipment for leaks, tears and other damage before handling a hazardous chemical. This includes fume hoods, gloves, goggles, etc.
9. Follow MIOSHA Personal Protective Equipment and Lockout/Tag out Procedures/standards and corresponding University policies. http://www.nmu.edu/OccupationalSafety.htm
10. Do not taste or smell hazardous chemicals.
2.2 HEALTH AND HYGIENE
The following practices have been established to protect laboratory authorized personnel from health risks associated with the use of hazardous chemicals:
1. Avoid direct contact with any hazardous chemical. Know the types of protective equipment available and use the proper type for each job.
2. Confine long hair and loose clothing and always wear footwear which fully covers the feet.
3. Do not use your mouth to withdraw substances via a pipette.
4. Use appropriate safety equipment whenever exposure to gases, vapors or aerosols is suspected and ensure exhaust facilities are working properly.
5. Wash thoroughly with soap and water after handling chemicals, before leaving the laboratory and before eating or drinking.
6. Laboratory authorized personnel will be permitted to wear contact lenses when handling hazardous chemicals provided that the safety guidelines listed here are followed and that contact lenses are not banned by regulation or contraindicated by medical or industrial hygiene recommendations. If these guidelines cannot be adhered to, then contact lenses will be prohibited while handling hazardous chemicals. It is important to remember, in any event, that contact lenses are not eye protective devices, and wearing them does not reduce the requirement for eye and face protection. The following guidelines for contact lens use in a chemical environment must be observed:
1. Conduct an eye injury hazard evaluation in the workplace that includes an assessment of the following:
o Chemical exposures (as required by MIOSHA Standard Part 33)
o Contact lens wear
o Appropriate eye and face protection for contact lens wearers
The eye injury hazard evaluation should be conducted by a competent, qualified person such as a certified industrial hygienist, a certified safety professional, or a toxicologist.
Information from the hazard evaluation should be provided to the examining occupational health nurse or occupational medicine physician.
The chemical exposure assessment for all workers should include, at a minimum, an evaluation of the properties of the chemicals in use—including concentration, permissible exposure limits, known eye irritant/injury properties, form of chemical (powder, liquid, or vapor), and possible routes of exposure. The assessment for contact lens wearers should include a review of the available information about lens absorption and adsorption for the class of chemicals in use and an account of the injury experience for the employer or industry, if known.
2. Provide suitable eye and face protection for all workers exposed to eye injury hazards, regardless of contact lens wear. Wearing contact lenses does not appear to require enhanced eye and face protection. For chemical vapor, liquid, or caustic dust hazards, the minimum protection consists of well-fitting non-vented or indirectly vented goggles or full-face piece respirators. Close-fitting safety glasses with side protection provide limited chemical protection but do not prevent chemicals from bypassing the protection. Workers should wear face shields over other eye protection when needed for additional face protection; but they should not wear face shields instead of goggles or safety glasses—regardless of contact lens wear.
3. Establish a written policy documenting general safety requirements for wearing contact lenses, including the eye and face protection required and any contact lens wear restrictions by work location or task. In addition to providing the general training required by the OSHA personal protective equipment standard [29 CFR 1910.132], provide training in employer policies on contact lens use, chemical exposures that may affect contact lens wearers, and first aid for contact lens wearers with a chemical exposure.
4. Comply with current MIOSHA regulations and University policy on contact lens wear and eye and face protection.
5. Notify workers and visitors about any defined areas where contact lenses are restricted.
6. Identify to supervisors all contact lens wearers working in chemical environments to ensure that the proper hazard assessment is completed and the proper eye protection and first aid equipment are available.
7. Train medical and first aid personnel in the removal of contact lenses and have the appropriate equipment available.
8. In the event of a chemical exposure, begin eye irrigation immediately and remove contact lenses as soon as practical. Do not delay irrigation while waiting for contact lens removal.
9. Instruct workers who wear contact lenses to remove the lenses at the first signs of eye redness or irritation. Contact lenses should be removed only in a clean environment after the workers have thoroughly washed their hands. Evaluate continued lens wear with the worker and the prescribing ophthalmologist or optometrist. Encourage workers to routinely inspect their contact lenses for damage and/or replace them regularly.
10. Evaluate restrictions on contact lens wear on a case-by-case basis. Take into account the visual requirements of individual workers wearing contact lenses as recommended by a qualified ophthalmologist or optometrist.
These recommendations are for work with chemical hazards. They do not address hazards from heat, radiation, or high-dust or high-particulate environments.
7. Replace personal protective equipment as appropriate.
8. Laboratory authorized personnel shall be familiar with the symptoms of exposure for the chemicals with which they work and the precautions necessary to prevent exposure.
2.3 FOOD AND DRINK IN THE LABORATORY
The following statement is the accepted practice on food and drinks in laboratories and shall be followed at all times:
"There shall be no food, drink, smoking or applying cosmetics in laboratories which have radioactive materials, bio-hazardous materials or hazardous chemicals present. There shall be no storage, use or disposal of these 'consumable' items in laboratories (including refrigerators within laboratories). Rooms which are adjacent, but separated by floor to ceiling walls, and do not have any chemical, radioactive or bio-hazardous agents, present, may be used for food consumption, preparation, or applying cosmetics at the discretion of the project director responsible for the areas."
Safety follows from good housekeeping practices. Use the following guidelines to maintain an orderly laboratory:
A. Keep work areas clean and uncluttered with chemicals and equipment. Clean up work areas upon completion of an operation or at the end of each work day, including floors.
B. Dispose of waste in accordance with the Northern Michigan University Hazardous Materials Management Plan.
C. A separate waste receptacle must be designated for non-contaminated glass.
D. Clean spills immediately and thoroughly, as per the guidelines established in section 4.0 of this document. Ensure a chemical spill kit is available and that laboratory authorized personnel know how to use it.
E. Do not block exits, emergency equipment or controls or use hallways and stairways as storage areas.
F. Assure hazardous chemicals are properly segregated into compatible categories.
G. “Sharps” require a proper storage container and a proper container for their disposal
2.5 TRANSPORTING OF CHEMICALS
When transporting chemicals outside the laboratory, precautions should be taken to avoid dropping or spilling chemicals.
1. Carry glass containers in specially designed bottle carriers or a leak resistant, unbreakable secondary container.
2. When transporting chemicals on a cart, use a cart that is suitable for the load and one that has high edges to contain leaks or spills. Cart and containers must be labeled
3. Avoid exposing passengers to risk on elevators.
2.6 UNATTENDED EXPERIMENTS AND WORKING ALONE
No one, (including Faculty/Staff) may work alone if the work involves the use or manipulation of hazardous materials, or if hazardous conditions may exist (e.g. high pressure, high voltage or vacuum systems). “Working Alone” means working out of sight or sound communications with another person for more than 5 minutes at a time. Overnight procedures involving high pressure, high voltage, or vacuum systems are only to be done when there is no other way of accomplishing this procedure and exposure to potential hazards are minimized. Overnight operations require the approval of the Chemical Hygiene Officer and Safety Director.
Student researchers (both graduate and undergraduate) may never work alone if working with hazardous chemicals or in a hazardous environment.
Laboratory operations involving hazardous substances are sometimes carried out continuously or overnight with no one present. It is the responsibility of the researcher to design these experiments so as to prevent the release of hazardous substances in the event of interruptions in utility services such as electricity, cooling water, and inert gas. Laboratory lights should be left on, and signs should be posted identifying the nature of the experiment and the hazardous substances in use. If appropriate, arrangements should be made for other workers to periodically inspect the operation. Information should be posted indicating how to contact the responsible individual in the event of an emergency.
This section of the policy applies to laboratory and field based work.
All containers of hazardous chemicals must be labeled with the name of the chemical and the hazard(s), if not provided by the manufacturer. If a chemical has more than one hazard, it must be labeled with both hazards. For example, acetaldehyde is both a flammable and a carcinogen, and must be labeled appropriately. Additionally, the subsequent guidelines shall be followed:
2.7.1 Labeling Basics
a. For containers labeled by the manufacturer:
• Inspect the labeling on incoming containers.
• Replace damaged or semi-attached labels.
b. For transferred products or solutions labeled by the user:
• Label each chemical container with the chemical name and
• Refer to the Material Safety Data Sheet (MSDS) for hazard warning.
2.7.2 Alternate Method for Labeling Multiple Small Containers
a. Legend Method:
•Label containers with abbreviated chemical name and a hazard warning.
•Provide a key in a visible location in the lab with the complete chemical name.
•Document that laboratory authorized personnel are trained on the labeling system.
b. Box or Tray Method:
•Put containers in a box or a tray.
•Label the tray with chemical name and hazard warning.
•If containers are removed from the box/tray they must be properly labeled or returned to the box or tray within the work-shift.
•Document that laboratory authorized personnel are trained on the labeling system.
2.7.3 Labeling Peroxide Forming Chemicals
Peroxidizable materials, when in the presence of oxygen and stored for long periods of time, or when exposed to sunlight, form unstable peroxides. These peroxides are friction and heat sensitive. They may explode if conditions allowed. Do not open containers with suspicious crystal liked solids found around the bottle cap.
Peroxidizable chemicals are listed in Appendix E and must be labeled with:
• Date Received
• Date Opened
• Date Tested (e.g., Iodide Test, Ferrous Thiocyanate Test, Peroxide Test Strips)
• Test Results
2.7.4 Consumer Products
Anything available over the counter to the general public is exempt from labeling requirements if it has already been labeled by the manufacturer. This includes consumer products such as cans of spray paint or turpentine. Container labels for over the counter materials must be maintained, and the container must be re-labeled if the original is missing or un-readable. MSDS documents for over the counter materials must be obtained and maintained according to the Hazardous Material Management policy.
2.7.5 Stationary Containers
Stationary process containers such as tanks may be identified with signs, placards, process sheets, batch tickets or other written materials instead of actually affixing labels to process containers. The sign or placard must convey the same information that a label would and be visible to authorized laboratory personnel throughout the work shift.
2.7.6 Portable Containers
Portable containers into which hazardous chemicals are transferred from labeled containers and which are intended to be under the use and control of the person who transferred it, within the work shift in which it was transferred, must have a temporary label identifying the chemical and its primary hazard affixed to the container.
2.8 PROCUREMENT, STORAGE, AND DISTRIBUTION OF CHEMICALS
Each research scientist is responsible for the proper procurement, storage, and distribution of hazardous chemicals used in his/her research activities. Hazardous chemicals required for research shall be obtained, stored, and dispensed in accordance with the Hazardous Materials Management plan and the guidelines outlined below.
2.8.1 Procurement of Hazardous Chemicals
Before a substance is ordered, information on proper handling, storage, and disposal must be known to those who will be involved. In particular, no substance may be ordered without having first obtained an MSDS for that material. No container will be accepted without an adequate identifying label.
Instructions for locating MSDS materials on line can be found here:
All departmentally based chemicals shall be ordered through a single point of control which may be
1. the stockroom manager or
2. the department’s Chemical Hygiene Officer.
All substances must be received in a central stockroom which shall be designated by the department’s Chemical Hygiene Officer.
2.8.2 Storage of Hazardous Chemicals
Hazardous chemicals shall be stored according to the manufacturer’s instructions as detailed on the product label and/or in the MSDS. Chemical storage containers and facilities shall be commensurate with the quantities and hazards of the chemicals involved (e.g., flammability, temperature sensitivity, and water reactivity). Stored chemicals shall be examined periodically at the direction of the Chemical Hygiene Officer to assure container and label integrity and to check for signs of deterioration. This examination shall take place at intervals not less than annually, and a report confirming the examination must be maintained in the department office and a copy sent to Public Safety.
Toxic substances shall be segregated in a vented location with adequate hazard markings. Quantities of solvents and other hazardous chemicals shall be kept to the minimum reasonably anticipated to be needed for the work being done.
2.8.3 Distribution of Hazardous Chemicals
Chemicals shall be transported in approved carts or in a secondary container. When chemicals are hand carried, the container shall be placed in an outside container or bucket. Transportation of hazardous chemicals in the passenger elevators should be kept to a minimum, and may not be attempted if the elevator is occupied by other passengers. All containers must be properly labeled.
2.8.4 Laboratory Storage
Amounts of hazardous chemicals permitted should be as small as practical. Storage on bench tops and in hoods is inadvisable. Exposure to heat or direct sunlight should be avoided. Periodic inventories should be conducted, with unneeded items discarded or returned to the storeroom/stockroom. This examination shall take place at intervals not less than annually, and a report confirming the examination must be maintained in the department office and a copy sent to Public Safety.
2.9 INVENTORY CONTROL
Federal and State 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 department Chemical Hygiene Officer annually. In addition, the classes of chemicals that are stored in lab areas should be indicated as Flammable Chemicals, Corrosives, Carcinogens, Reactive Chemicals, Biological Agents, Radioactive Material or other. The inventory of these materials must be provided to Public Safety annually and within two weeks of the beginning of a new University fiscal year.`
2.10 STORAGE AND DISPOSAL OF HAZARDOUS CHEMICAL WASTE
Hazardous wastes generated as a result of research and teaching laboratory activities must be disposed of in accordance with all Federal, State, and local regulations.
The following general principles will be observed:
1. Unlabeled containers of chemicals and solutions must undergo prompt disposal; if partially used, they should not be opened
2. Before a worker's employment in the laboratory ends, chemicals for which that person was responsible should be discarded or returned to storage.
3. Waste should be removed from laboratories to a central waste storage area at least once per week and from the central waste storage area at regular intervals.
4. Incineration in an environmentally acceptable manner is the most practical disposal method for combustible laboratory waste.
5. Indiscriminate disposal by pouring waste chemicals down the drain or adding them to mixed refuse for landfill burial is unacceptable.
6. Hoods may not be used as a means of disposal for volatile chemicals.
7. Disposal by recycling or chemical decontamination should be used when possible.
Each laboratory in which hazardous chemical waste is generated must have a designated satellite accumulation area (SAA). This area must be at or near the point where the waste is generated, and must be under the control of the generator at all times. Wastes may be brought to the stock room when the waste container is full. The stockroom manager will contact Public Safety to arrange for proper disposal of the waste.
The following management standards must be observed for all SAAs:
1. containers must be in good condition.
2. containers must be compatible with the waste
3. containers must be labeled with “Universal Waste” labels which identify the date of accumulation as well as the contents. “Universal Waste” labels can be obtained from Public Safety. It is good practice to label containers with both the contents and the “Hazardous Waste” designation to prevent the introduction of incompatible wastes into the same container.
4. containers are to remain securely closed at all times, except when adding or removing waste.
5. each SAA must be inspected regularly and not less frequently that annually, and the inspection results documented and retained in the department for seven years.
2.11 CHEMICALS DEVELOPED IN THE LABORATORY
The following requirements apply to chemical substances developed in the laboratory:
1. If the composition of the chemical substance which is produced exclusively for the laboratory's use is known, the Laboratory Director must determine if it is a hazardous chemical. This can be done by a literature search for similar substances. If the chemical is determined to be hazardous, the Laboratory Director must provide appropriate training to protect laboratory authorized personnel.
2. If the chemical produced is a product or a by-product whose composition is not known, the Laboratory Director must assume that the substance is hazardous and must comply with the requirements of the CHP.
3. If the chemical is produced for sale or use outside of the laboratory, the Laboratory Director must prepare an appropriate MSDS in accordance to the Michigan Right-to-Know Law.
3.0 SPECIFIC SAFETY PROCEDURES
3.1 THAT APPLY TO ALL CHEMICALS
(a) Accidents and spills:
Check MSDS for the appropriate emergency treatment. Unless otherwise indicated, follow these procedures:
Eye Contact: Promptly flush eyes with water for a prolonged period (15 minutes) and seek medical attention.
Ingestion: Encourage the victim to drink large amounts of water.
Skin Contact: Promptly flush the affected area with water and remove any contaminated clothing. If symptoms persist after washing, seek medical attention.
Clean-up. Promptly clean up spills, using appropriate protective apparel and equipment and proper disposal.
(b) Avoidance of "routine" exposure:
Develop and encourage safe habits; avoid unnecessary exposure to chemicals by any route.
Do not smell or taste chemicals. Vent apparatus which may discharge toxic chemicals (vacuum pumps, distillation columns, etc.) into local exhaust devices.
Inspect gloves and test glove boxes before use.
Do not allow release of toxic substances in cold rooms and warm rooms, since these have contained re-circulated atmospheres.
(c) Choice of chemicals: Use only those chemicals for which the quality of the available ventilation system is appropriate.
(d) Eating, smoking, etc.: Eating, drinking, smoking, gum chewing, or application of cosmetics in areas where laboratory chemicals are present is prohibited; wash hands before conducting these activities. Storage, handling or consumption of food or beverages in storage areas, refrigerators, glassware or utensils which are also used for laboratory operations is prohibited.
(e) Equipment and glassware: Handle and store laboratory glassware with care to avoid damage; do not use damaged glassware. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Use equipment only for its designed purpose.
(f) Exiting: Wash areas of exposed skin well before leaving the laboratory.
(g) Horseplay: Avoid practical jokes or other behavior which might confuse, startle or distract another worker.
(h) Mouth suction: Do not use mouth suction for pipeting or starting a siphon.
(i) Personal apparel: Confine long hair and loose clothing. Wear shoes at all times in the laboratory but do not wear sandals, perforated or open toed shoes.
(j) Personal housekeeping: Keep the work area clean and uncluttered, with chemicals and equipment being properly labeled and stored; clean up the work area on completion of an operation or at the end of each day.
(k) Personal protection: Personal Protective Equipment required will be determined by examination of the MSDS for the product/s being used. Assure that appropriate eye protection is worn by all persons, including visitors, where chemicals are stored or handled.
Wear appropriate gloves when the potential for contact with toxic materials exists; inspect the gloves before each use, wash them before removal, and replace them periodically.
Use appropriate respiratory equipment when air contaminant concentrations are not sufficiently restricted by engineering controls, inspecting the respirator before use. Those employees using respirators must follow the University policy of use of respirators.http://www.nmu.edu/OccupationalSafety.htm
Use any other protective and emergency apparel and equipment as appropriate.
Avoid use of contact lenses in the laboratory unless necessary; if they are used, inform supervisor so special precautions can be taken.
Remove laboratory coats immediately on significant contamination.
(l) Planning: Seek information and advice about hazards, plan appropriate protective procedures, and plan positioning of equipment before beginning any new operation. Ensure that all participants are aware of the requirements before beginning.
(m) Unattended operations: Leave lights on, place an appropriate sign on the door, and provide for containment of toxic substances in the event of failure of a utility service (such as cooling water) to an unattended operation.
(n) Use of hood: Use the hood for operations that might result in release of toxic chemical vapors or dust.
Use a hood or other local ventilation device when working with any appreciably volatile substance with a Threshold Limit Value (TLV) of less than 50 ppm.
Confirm adequate hood performance before use; keep hood closed at all times except when adjustments within the hood are being made; keep materials stored in hoods to a minimum and do not allow them to block vents or air flow.
Leave the hood "on" when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is "off".
(o) Vigilance: Be alert to unsafe conditions and see that they are corrected when detected.
(p) Waste disposal: Assure that the plan for each laboratory operation includes plans and training for waste disposal.
Deposit chemical waste in appropriately labeled receptacles and follow all other waste disposal procedures of the Chemical Hygiene Plan and Hazardous Material Management Policy.
Do not discharge to the sewer concentrated acids or bases; highly toxic, malodorous, or lachrymatory substances; or any substances which might interfere with the biological activity of waste water treatment plants, create fire or explosion hazards, cause structural damage or obstruct flow.
3.2 ALLERGENS AND EMBRYOTOXINS
(a) Allergens (examples: diazomethane, isocyanates, bichromates): Wear suitable gloves to prevent hand contact with allergens or substances of unknown allergenic activity.
(b) Embryotoxins (examples: organomercurials, lead compounds, formamide): If you are a woman of childbearing age, handle these substances only in a hood whose satisfactory performance has been confirmed, using appropriate protective apparel (especially gloves) to prevent skin contact.
Review each use of these materials with the research supervisor and review continuing uses annually or whenever a procedural change is made.
Store these substances, properly labeled, in an adequately ventilated area in an unbreakable secondary container. Notify supervisors of all incidents of exposure or spills; consult a qualified physician when appropriate after an exposure or a spill.
3.3 CHEMICALS OF MODERATE CHRONIC OR HIGH ACUTE TOXICITY
(a) Location: Use and store these substances only in areas of restricted access with special warning signs.
Always use a hood (previously evaluated to confirm adequate performance with a face velocity of at least 60 linear feet per minute) or other containment device for procedures which may result in the generation of aerosols or vapors containing the substance; trap released vapors to re-vent their discharge with the hood exhaust.
(b) Personal protection: Always avoid skin contact by use of gloves and long sleeves (and other protective apparel as appropriate). Always wash hands and arms immediately after working with these materials.
(c) Records: Maintain records of the amounts of these materials on hand, amounts used, and the names of the laboratory authorized personnel involved.
(d) Prevention of spills and accidents: Be prepared for accidents and spills.
Assure that at least 2 people are present at all times if a compound in use is highly toxic or of unknown toxicity.
Store breakable containers of these substances in chemically resistant trays; also work and mount apparatus above such trays or cover work and storage surfaces with removable, absorbent, plastic backed paper.
If a major spill occurs outside the hood, evacuate the area; assure that cleanup personnel wear suitable protective apparel and equipment.
(e) Waste: Thoroughly decontaminate or incinerate contaminated clothing or shoes. If possible, chemically decontaminate by chemical conversion.
Store contaminated waste in closed, suitably labeled, containers (for liquids, in glass or plastic bottles half-filled with vermiculite).
3.4 CHEMICALS OF HIGH CHRONIC TOXICITY
(Examples: dimethylmercury and nickel carbonyl, benzo-a-pyrene, N-nitrosodiethylamine, other human carcinogens or substances with high carcinogenic potency in animals.)
Further supplemental rules to be followed, in addition to those mentioned above, for work with substances of known high chronic toxicity (in quantities above a few milligrams to a few grams, depending on the substance).
(a) Access: Conduct all transfers and work with these substances in a "controlled area": a restricted access hood, glove box, or portion of a lab, designated for use of highly toxic substances, for which all people with access are aware of the substances being used and necessary precautions.
(b) Approvals: Prepare a plan for use and disposal of these materials and obtain the approval of the Chemical Hygiene Officer.
(c) Non-contamination/Decontamination: Protect vacuum pumps against contamination by scrubbers or HEPA filters and vent them into the hood. Decontaminate vacuum pumps or other contaminated equipment, including glassware, in the hood before removing them from the controlled area.
Decontaminate the controlled area before normal work is resumed there.
(d) Exiting: On leaving a controlled area, remove any protective apparel (placing it in an appropriate, labeled container) and thoroughly wash hands, forearms, face, and neck.
(e) Housekeeping: Use a wet mop or a vacuum cleaner equipped with a HEPA filter instead of dry sweeping if the toxic substance was a dry powder.
(f) Medical surveillance: If using toxicologically significant quantities of such a substance on a regular basis (e.g., 3 times per week), consult a qualified physician concerning desirability of regular medical surveillance.
(g) Records: Keep accurate records of the amounts of these substances stored and used, the dates of use, and names of users.
(h) Signs and labels: Assure that the controlled area is conspicuously marked with warning and restricted access signs and that all containers of these substances are appropriately labeled with identity and warning labels.
(i) Spills: Assure that contingency plans, equipment, and materials to minimize exposures of people and property in case of accident are available.
(j) Storage: Store containers of these chemicals only in a ventilated, limited access area in appropriately labeled, unbreakable, chemically resistant, secondary containers.
(k) Glove boxes: For a negative pressure glove box, ventilation rate must be at least two volume changes/hour and pressure at least 0.5 inches of water. For a positive pressure glove box, thoroughly check for leaks before each use. In either case, trap the exit gases or filter them through a HEPA filter and then release them into the hood.
(l) Waste: Use chemical decontamination whenever possible; ensure that containers of contaminated waste (including washings from contaminated flasks) are transferred from the controlled area in a secondary container under the supervision of authorized personnel.
3.5 ANIMAL WORK WITH CHEMICALS OF HIGH CHRONIC TOXICITY
(a) Access: For large scale studies, special facilities with restricted access are preferable.
(b) Administration of the toxic substance: When possible, administer the substance by injection or gavage instead of in the diet. If administration is in the diet, use a caging system under negative pressure or under laminar air flow directed toward HEPA filters.
(c) Aerosol suppression: Devise procedures which minimize formation and dispersal of contaminated aerosols, including those from food, urine, and feces (e.g., use HEPA filtered vacuum equipment for cleaning, moisten contaminated bedding before removal from the cage, mix diets in closed containers in a hood).
(d) Personal protection: When working in the animal room, wear plastic or rubber gloves, fully buttoned laboratory coat or jumpsuit and, if needed because of incomplete suppression of aerosols, other apparel and equipment (shoe and head coverings, respirator).
(e) Waste disposal: Dispose of contaminated animal tissues and excreta by incineration if the available incinerator can convert the contaminant to non-toxic products; otherwise, package the waste appropriately for burial in an EPA-approved site.
Supervisors must ensure that all laboratory procedures contain a written description of specific safety practices incorporating the applicable precautions described in this section. Laboratory authorized personnel should read and understand these practices before commencing a procedure.
See also the policy: Institutional Animal Care and Use:http://www.nmu.edu/graduate_studies/forms/iacuc_policy.pdf
3.6 PROCEDURES FOR PARTICULARLY HAZARDOUS SUBSTANCE
The MSDSs for many of the chemicals used in the laboratory will state recommended limits or OSHA-mandated limits, or both, as guidelines for exposure. Typical limits are permissible exposure limits (PELs), threshold limit values (TLVs), and action levels. When such limits are stated, they will be used to assist the researcher and the Chemical Hygiene Officer in determining the safety precautions, control measures, and safety apparel that apply when working with a particular chemical.
Special Considerations. The MIOSHA Laboratory Standard requires that special precautions for additional laboratory authorized person protection be followed for the laboratory use of select carcinogens, reproductive toxicants and chemicals with a high degree of acute and chronic toxicity (defined in section 1.3). Following general hygiene standards should be observed when using select carcinogens, reproductive toxicants and chemicals with high degree of acute and chronic toxicity.
A. When a PEL or TLV is less that 50 ppm or 100 mg/m3, the user of the chemical must use it in a properly-functioning chemical exhaust hood. If none are available, no work should be performed using that chemical.
B. If a PEL, TLV, or comparable value is not available for a substance, the animal or human median inhalation lethal concentration (LC50) information will be assessed. If that value is less than 200 ppm or 2,000 mg/m3 (when administered continuously for one hour or less), then the chemical must be used within the confines of the properly functioning chemical exhaust hood.
C. Establish a Designated Area – Use and store materials only in designated areas: a restricted access hood, glove box, or portion of a lab, designated for use of highly toxic substances. Assure that all personnel with access are aware of necessary safety precautions.
D. Only those persons trained to work with inimical chemicals will work with those chemicals in a designated area or transport them to or from the approved storage areas. All such personnel will:
a. Use the smallest amount of chemical that is consistent with the requirements of the work to be done.
b. Appropriately decontaminate a designated area when work is completed.
Inimical chemicals are members of one or more of these four categories:
§ select carcinogens,
§ teratogens or other reproductive toxins,
§ acutely toxic chemicals, and
§ chemicals whose toxic properties are unknown.
Select carcinogens are materials defined as such in 29CFR1910.1450 or described as such on the applicable MSDS.
Teratogens and/or reproductive toxins are chemicals described as such on the applicable MSDS.
Acute toxic chemicals are materials for which the LD50 data lead to a description in the applicable MSDS as “highly” or “acutely” toxic.
Chemicals of unknown toxicity are ones for which there is no known statistically significant study to establish toxicity.
E. Store all inimical chemicals in locked and enclosed spaces.