1.0 STATEMENT
OF RESPONSIBILITY
It is the responsibility of the University to take every
reasonable precaution to provide a work environment that
is free from recognizable hazards to its employees. The
University is required by the Occupational Safety and
Health Administration’s (OSHA) standard on Occupational
Exposure to Hazardous Chemicals in Laboratories Standard
(29 CFR 1910.1450) to ensure that the necessary work
practices, procedures and policies are implemented to
protect employees working in University owned and/or
operated laboratories from hazardous chemicals. It is
the responsibility of the University and its employees
to be well-informed regarding hazardous chemicals and
the risks associated with using them in the laboratory.
1.1 THE
OSHA LABORATORY SAFETY STANDARD
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. The Laboratory Standard
applies to all laboratories that handle or use hazardous
chemicals in which all of the following criteria are
met:
- Chemical manipulations are carried out on a laboratory
scale. Laboratory scale means 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.
- Multiple chemical procedures or chemicals are used.
- The procedures involved are not part of a production
process, nor in any way simulate a production process.
- "Protective laboratory practices and equipment" are
available and in common use to minimize the potential
for employee exposure to hazardous chemicals.
Generally, where this standard applies, it supersedes
for laboratories the requirements of all other Occupational
Safety and Health Administration (OSHA) health standards
in 29 CFR part 1910, subpart Z, except for the obligation
to maintain employee exposures at or below the permissible
exposure limits (PEL) (subpart Z of 29 CFR 1910.1000),
prohibition of skin and eye contact where specified by
any OSHA standard and in other instances where the scope
of hazards are not adequately addressed by this standard.
OSHA’s definition of "hazardous chemical" refers
to a chemical for which there is statistically significant
evidence, based on at least one study conducted in accordance
with established scientific principles, that acute or
chronic health effects may occur in exposed employees.
The term "health hazard" includes chemicals
which are carcinogens, toxic or highly toxic agents,
reproductive toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, agents which
act on the hematopoietic systems and agents which damage
the lungs, skin, eyes, or mucous membranes. Chemicals
with physical hazards such as flammability and reactivity
are also considered hazardous.
1.2 SCOPE AND APPLICATION
This policy outlines how the University shall comply with
the OSHA Laboratory Safety Standard. All schools at the
University engaged in the laboratory handling or use
of hazardous chemicals are required to comply with this
policy.
This policy does not apply to:
-
Work
involving chemicals that do not meet
the conditions of the definition of laboratory
use of hazardous chemicals. In such cases,
the University shall comply with all relevant
specific substance standards even if such
use occurs in a laboratory type setting.
-
Work
involving the laboratory use of hazardous
chemicals that does not have the potential
for employee exposure.
1.3 RESPONSIBILITY
The
Office of Environmental Health & Safety (EHS). EHS
shall be responsible for assisting the schools
with the implementation this policy. As part
of this responsibility, EHS shall develop a generic Chemical
Hygiene Plan (CHP) for the University. The
primary objective of this document is to provide
a general guide for handling hazardous chemicals
in laboratories. The CHP will
establish the basic safety principles for laboratory
procedures, equipment and work practices that
are capable of protecting employees from the
hazards associated with the use of chemicals
in the laboratory. The CHP is
intended only to highlight those safety measures
necessary for achieving a safe and healthy work
environment. Where the scope of hazards are not
adequately addressed by the CHP,
specific Standard Operating Procedures (SOPs)
must be developed by the Principal Investigator
(PI). In addition, EHS shall provide consultation
services such as laboratory safety training,
environmental sampling, accident investigation,
and laboratory fumehood testing. A representative
from EHS shall serve as the campus Chemical Hygiene
Officer (CHO). The CHO shall have overall responsibility
for implementing the CHP.
Schools at the
University. The Deans and Department
Chairs of the schools at the University are responsible
for promoting and ensuring a safe working environment.
They are also responsible for ensuring that the
provisions of this policy are implemented. Each
Department within the schools shall appoint a
Safety and Health Representative (SHR). The SHR
shall work with the CHO to implement this policy.
Principle
Investigators/Laboratory Supervisor. The
ultimate responsibility for the safety and health
of personnel working in the laboratory lies with
the PI and/or Laboratory Supervisor. They are
responsible for:
- Ensuring that all employees under their supervision
have received general laboratory safety training
from EHS.
- Providing all employees under their supervision with
site-specific training and appropriate safety equipment.
- Follow appropriate guidelines prescribed in the CHP.
- Developing SOPs for the use of hazardous chemicals
not covered by the CHP.
Employee. Individual laboratory
employees are responsible for their own safety. All individuals
performing work with hazardous substances must accept
a shared responsibility for operating in a safe manner.
They also have the responsibility to inform their supervisors
of accidents and of any work practices or working conditions
they believe to be hazardous.
Student. While students
are not covered under the provisions of the OSHA Laboratory
Safety Standard, students must be aware of the safety
and health hazards associated with laboratory work. Students
must also use the appropriate protective equipment while
working in the laboratory and must follow all appropriate
safety procedures.
1.4 EMPLOYEE RIGHTS
It is the employee's right to receive information about
the known physical and health hazards of the chemicals
in their work areas and to receive adequate training
and equipment to work safely with these substances. Employees
have the right to work in a safe environment and inform
the PI or laboratory supervisor about potential risks
in the laboratory.
1.5 AVAILABILITY
This policy and the CHP must
be readily available to employees and employee representatives.
They are available on the Office of Environmental Health & Safety
web site (printed copies are available from EHS upon
request). Each department and laboratory supervisor should
maintain a copy in their work area.
1.6 ANNUAL REVIEW
The CHP will be reviewed annually
by the University’s SHRs and CHO.
1.7 EMPLOYEE
INFORMATION AND TRAINING
Employees must have access to information and training
to ensure that they are aware of chemical hazards in
their work area. Such information must be provided at
the time of an employee's initial assignment to a work
area where hazardous chemicals are present and prior
to any assignment involving new exposure situations.
Employees should receive periodic refresher information
and training to ensure that they are aware of the risks
of exposure to hazardous chemicals.
Information provided to employees shall include:
- The contents of the OSHA Occupational Exposure to
Hazardous Chemicals in Laboratories Standard.
- The location and availability of the University CHP.
- The Permissible Exposure Limits (PEL) for OSHA regulated
substances or published exposure limits for other
hazardous chemicals where there is no applicable
OSHA standard.
- Signs and symptoms associated with exposures to hazardous
chemicals used in the laboratory (available on MSDSs).
- 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, MSDSs
received from the supplier.
All of the above information is available from EHS.
General training will be provided by EHS 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
PIs or an appropriate designee.
General awareness training provided by EHS to employees
will include:
- Methods and observations that may be used to detect
the presence or release of a hazardous chemical (such
as monitoring conducted by continuous monitoring
devices, visual appearance or odor of hazardous chemicals,
etc.).
- General physical and health hazards of chemicals
in the work area. This must include an awareness
that many factors influence whether a given chemical
might constitute a hazard (e.g. dose, exposure time,
genetic background, developmental state, mixtures
of interactions of chemicals, etc.).
- The measures employees can take to protect themselves
from these hazards. This includes specific procedures
the University or department has implemented to protect
employees from exposure to hazardous chemicals, such
as appropriate work practices, emergency procedures,
and personal protective equipment to be used.
- The applicable details of the University CHP.
Site-specific training provided by PIs/Supervisors to
employees will include:
- Site-specific SOPs.
- Specific physical and health hazards of chemicals
in the work area.
1.8 RECORDKEEPING
General awareness training required by the CHP will
be documented by EHS. When such training is conducted
by schools or departments, training records must be provided
to EHS by the person(s) responsible for the training
program. EHS will retain records of all employees who
attend the general awareness training. All employee medical
records shall be kept by Student and Employee Health
(SEH) and are strictly confidential.
1.9 CHILDREN UNDER 18.
It is the responsibility of the laboratory supervisor
to ensure the safety and health of anyone under the age
of 18 working in or visiting a University laboratory.
Prior to allowing anyone under the age of 18 from entering
the laboratory, the laboratory supervisor shall have
a parent or guardian complete a written consent statement.
The department chairman shall also sign off on the consent
statement. At no time shall children under the age of
18 be left unattended in the laboratory. A consent
statement form can be printed from the EHS web site
(or obtained from EHS by calling 410.706.3490).
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