Laboratory Chemical Safety Compliance Guidelines

INTRODUCTION AND SCOPE

On January 31, 1990, the Occupational Safety and Health Administration (OSHA) published the final rule for occupational exposures to hazardous chemicals in laboratories (29 CFR §1910.1450). The rule, commonly referred to as the laboratory standard, is tailored to clinical, industrial, academic, and research laboratories engaged in the laboratory use of hazardous chemicals and establishes standards to ensure a safe work environment. The standard requires the employer to determine employee exposure to hazardous chemicals, develop a written chemical hygiene plan, ensure adequate hazard identification and recordkeeping procedures, and provide employee training and information. In addition, respirator use and medical consultation and examination programs may be necessary. The primary objective of the standard is to ensure that laboratory employees' exposures to hazardous chemicals do not exceed the established OSHA permissible exposure limits.

The intent of this guideline is to offer employees assistance in understanding OSHA's laboratory standard requirements. The standard applies to all employers engaged in the laboratory use of hazardous chemicals.

REQUIREMENTS

Chemical Hygiene Plan

The cornerstone of the standard is the employer plan to control employee exposures to chemicals in the workplace. The plan is a written document called the Chemical Hygiene Plan (CHP). Arizona State University has developed and implemented a CHP, which addresses the following:

• Standard operating procedures for working with hazardous chemicals
• Criteria for the use of personal protective equipment and other engineering controls when working with extremely hazardous substances
• A program to ensure proper functioning of fume hoods
• A program to ensure employee training and access to information
• Procedures for waste disposal
• Criteria and procedures for reviewing laboratory process hazards
• Chemical inventory lists and material safety data sheets
• Provisions for medical consultations and examinations
• Personnel responsibilities and designation of a Chemical Hygiene Officer, a safety coordinator and safety committees
• Extra provisions for the safe use of select carcinogens and substances with high acute toxicity
• Procedures for annual review, evaluation, and updating
• Procedures for emergencies, evacuations, and first aid
• Methods used to document and preserve records required by the standard

The standard is performance-based and, as a result, there are few specific requirements detailed by the regulation. The emphasis is on administrative controls to protect employees from overexposure to hazardous chemicals. Administrative controls including procedure review, preplanning, risk management, and training provide proactive management of hazards in the laboratories.

Periodic review of the plan allows changes in administrative controls to be implemented before accidents demand changes.

An Environmental Health & Safety (EH&S) representative is designated as the university's Chemical Hygiene Officer and is required to work with university administration and employees to develop and implement appropriate chemical hygiene policies and procedures. EH&S is available to provide assistance as needed by individual departments.

Laboratory safety registration is the process the university uses to maintain laboratory emergency contacts and information, develop laboratory hazardous chemical inventories, and establish laboratory safety inspections for ensuring compliance with the ASU Chemical Hygiene Plan.  The laboratory registration process requires the person responsible for the laboratory (i.e., principal investigator, laboratory supervisor, or manager) to annually submit a complete and current hazardous chemical inventory and Responsible Party Information (RPI) sheet to EH&S.  Contact EH&S at 965-1823 for further information and assistance in developing individual programs.

UNIVERSITY UNITS WITH LABORATORY CHEMICAL SAFETY RESPONSIBILITIES

EH&S is responsible for ensuring regulatory compliance with the OSHA Laboratory Standard for ASU.

Deans, directors, and chairs are responsible for establishing and implementing department information and training programs for their respective areas, as outlined in the Employee Information and Training section of this plan. Delegation of this responsibility to the Principle Investigator (PI), laboratory supervisor or manager or Compliance Officer and/or safety committee is acceptable.

The EH&S Operations Committee provides oversight for the all EH&S programs at ASU.

Where individual departments establish safety committees, the primary function should be to provide peer review of all internal safety audits, training reviews, accident investigations, and other safety related actions as deemed necessary by the department and in accordance with regulatory and EH&S mandates.

APPLICABLE REGULATIONS

U.S. Department of Labor, 29 CFR § 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories

UNIVERSITY DOCUMENTS AND MANUALS

Arizona State University Pollution Prevention Plan
Arizona State University Chemical Hygiene Plan
Environmental Health & Safety Policies and Procedures Manual

TECHNICAL CONTACTS

Robert Ott, Occupational Health and Safety, Asst. Director
Environmental Health & Safety 480.965.6219

Michael Ochs, Occupational Health and Safety, Manager
Environmental Health & Safety 480.965.3580