HAZARD COMMUNICATION AND CHEMICAL SAFETY GUIDELINE

HAZARD COMMUNICATION AND CHEMICAL SAFETY GUIDELINE Approval: Approval signature on file 5 SEP 2013 Chair, Institution Safety Committee Date Approval signature on file 5 SEP 2013 Environmental, Health & Safety Director Date SG-01 Page 1 Rev. 4

TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE 3 1.1 Purpose 1.2 Scope 2.0 ROLES AND RESPONSIBILITIES 3 2.1 Principal Investigator (PI) / Supervisor 2.2 Personnel 2.3 Environmental Health and Safety Office (EH&S) 3.0 WRITTEN HAZARD COMMUNICATION PROGRAM 3 3.1 Location 3.2 Review 4.0 HAZARD EVALUATION 4.1 Routes of Exposure 4 5.0 CONTROL MEASURES 4 5.1 Engineering Controls 5.2 Administrative Controls 5.2.1 Work Practice Controls 5.2.2 Safety Data Sheets (SDS) 5.2.3 Container Labeling 5.3 Personal Protective Equipment (PPE) 6.0 CATEGORIES OF HAZARDOUS CHEMICALS 6 7.0 CHEMICAL PROCUREMENT AND INVENTORY CONTROLS 9 7.1 Procurement 7.2 Chemical Inventory Database 7.3 Toxic Substances Control Act 7.4 Department of Homeland Security Chemicals of Interest 8.0 EMERGENCY RESPONSE PROCEDURES 10 8.1 Incidental Spill 8.2 Hazardous Spill 9.0 INFORMATION, TRAINING, AND RECORDKEEPING 11 9.1 Information 9.2 Training 9.3 Recordkeeping 10.0 TRADE SECRETS 12 11.0 CHEMICALS IN UNLABELED PIPES 12 12.0 MULTI-EMPLOYER WORK AREAS 12 12.1 WHOI Notifications/Actions 12.2 Non-WHOI Personnel Notifications/Actions 13.0 HAZARDOUS WASTE MANAGEMENT 13 14.0 WORK AREA RENOVATION / MOVE / RELOCATION PROCEDURES 13 SG-01 Page 2 Rev. 4

1.0 PURPOSE AND SCOPE 1.1 Purpose The purpose of the Hazard Communication and Chemical Safety Guideline (guideline) is to provide guidance for WHOI personnel to understand the hazards of chemicals they work with and to provide appropriate training to assist them in working with these chemicals safely and avoiding exposures that could be injurious to their health and safety. A secondary purpose is to ensure that WHOI is in compliance with the OSHA Hazard Communication Standard (29 CFR 1910.1200). 1.2 Scope This Guideline applies to all WHOI personnel, including contractors that work with hazardous chemicals excepting those operations and personnel in research laboratories covered by the Chemical Hygiene Plan. WHOI personnel and contractors at all levels must comply with the requirements of this Guideline and participate in all applicable trainings mandated by OSHA. This Guideline does not apply to Marine Operations that are addressed by applicable United States Coast Guard regulations. 2.0 ROLES AND RESPONSIBILITIES 2.1 Principal Investigators (PIs)/Supervisors Implement and ensure compliance with the provisions of this Guideline. Ensure that a hazard evaluation is performed prior to using a new chemical. Provide personnel with training on hazards associated with specific chemicals prior to using a new chemical, when performing non-routine tasks, and when there is a significant increase of an existing hazard. Ensure that there are current SDSs on file for each chemical used and stored. Ensure that all individuals in their group affected by this standard attend scheduled training. Responsible for inspecting all chemical containers in their work area to ensure that they are properly labeled and in good condition. Develop work area-specific procedures for work involving highly hazardous materials/processes, reproductive toxins, and select carcinogens. 2.2 Personnel (Includes students, volunteers, minors, contractors, and researchers) Review and comply with this guideline and required procedures before using hazardous chemicals. Attend required training. Legibly label all chemical containers. Read and understand the SDSs of chemicals. 2.3 Environmental Health and Safety Office (EH&S Office) Provide assistance with labeling, storage, handling, exposure controls, spill response, and disposal of hazardous chemicals. Administer the on-line chemical inventory system. Conduct training and work area inspections. Periodically review this guideline and update as necessary. Conduct exposure assessments as necessary. The Safety & Health Officer, x2244, is the point of contact for this guideline. 3.0 WRITTEN HAZARD COMMUNICATION PROGRAM 3.1 Location SG-01 Page 3 Rev. 4

A copy of this Guideline must be made available to all personnel. This Guideline is located on the EH&S website (http://ehs.whoi.edu/). Each space that uses or stores hazardous chemicals should keep a paper copy of this guideline with the SDS binder. 3.2 Review The EH&S Office will periodically review and evaluate the effectiveness of the Guideline and amend as necessary. 4.0 HAZARD EVALUATION Before the proper control (s) can be selected, PIs/Supervisors and personnel should conduct a hazard evaluation of the process, activity, or material. Every hazard evaluation should first determine if the hazardous conditions can be prevented, e.g., substituting with a less hazardous material or process. A hazard evaluation may include reviewing information from a chemical container label, SDS, manufacturer, EH&S website, and other resources as needed, identifying route(s) of exposure, evaluating the process/activity to determine if an exposure evaluation is needed. If necessary, the EH&S Office is responsible for conducting and documenting exposure evaluations, i.e., evaluate exposures relative to limits. 4.1 Routes of Exposure Chemical exposures can occur by four major routes of entry: absorption, inhalation, ingestion, and injection. 4.1.1 Absorption Absorption of chemicals through the skin or mucous membranes can be a common chemical exposure route in the lab. Spills and splashes can result in skin contamination. In addition, personnel may unknowingly contaminate themselves when they touch work surfaces, glassware, or equipment contaminated with chemicals. Chemicals can also enter the body when contaminated hands touch the mouth, nose, eyes, sores or cuts. A chemistry professor at Dartmouth College spilled a couple of drops of dimethyl mercury on her latex glove during an experiment and died 10 months later from mercury poisoning. 4.1.2 Inhalation Chemicals that can enter the body via inhalation include gases, vapors of volatile liquids, mists and sprays of liquids, and solid chemicals in the form of particles, fibers, and dusts. Chemicals in the form of dusts and particulates can become airborne when transferred from one container to another. Operations that may produce inhalation hazards include weighing, stirring, pouring, spraying, and removing caps and stoppers. Splashes created from spills, vigorous shaking and mixing may also produce inhalation hazards. 4.1.3 Ingestion Ingestion of chemicals can result from hand-to-mouth contact, consuming contaminated food or drink, smoking cigarettes that have come in contact with contaminated hands, placing part of the hand or a writing tool that has been in contaminated hands into the mouth, applying makeup, etc. Wash hands immediately after use of any chemical substance and before leaving the work area. 4.1.4 Injection Chemical exposure by means of injection can inadvertently occur when handling chemically contaminated items such as broken glass, needles, plastic, razor blades, or other items capable of causing punctures, cuts, or abrasions to the skin. In order to protect workers from this form of exposure, all "sharps" must be managed in rigid containers. 5.0 CONTROL MEASURES The use of prevention is important to the overall application of controls. The proper selection of a hazard or exposure control may involve the following considerations: SG-01 Page 4 Rev. 4

All hazards can be controlled to some degree and by some method; More than one control may be useful or required; and Controls may not completely eliminate the hazard. Engineering controls, administrative controls, and personal protective equipment (PPE) are traditional approaches used to control hazards and exposures. 5.1 Engineering Controls - minimize exposure by either reducing or removing the hazard at the source or isolating the worker from the hazard. Engineering controls include process change, substitution, isolation, ventilation, and source modification. Substitution Substituting for a less hazardous material, equipment, or process (e.g., use of soap and water in place of solvents, use of automated instead of manually operating equipment). Process change Changing a process to make it less hazardous (e.g., paint dipping in place of paint spraying). Isolation Separating personnel from hazardous operations, processes, equipment, or environments (e.g., use of control rooms, physically separating personnel and equipment, barriers placed between personnel and hazardous operations). Ventilation Two fundamental approaches: general exhaust (dilution of air contaminants) and local exhaust of air contaminants. Source modification Changing a hazard source to make it less hazardous (e.g., wetting dust particles or lowering the temperature of liquids to reduce off-gassing and vaporization). 5.2 Administrative Controls include work practice controls, SDS, signs, labels, safety guidelines, procedures, rules, supervision, training, and controlling personnel exposure by scheduling tasks in ways that minimize exposure levels. 5.2.1 Work Practice Controls alter the manner in which a task is performed. Some work practice controls include (1) changing existing work practices to follow proper procedures that minimize exposures; (2) inspecting and maintaining process and control equipment on a regular basis; (3) implementing good housekeeping practices; (4) providing good supervision; and (5) prohibiting food, drink, smoking, chewing tobacco or gum, and applying cosmetics in chemical use areas. 5.2.2 Safety Data Sheets (SDS) SDSs are documents created by the chemical manufacturer that describe the substance. Some information found on an SDS includes: hazardous and physical characteristics, handling requirements, storage and disposal information, and signs and symptoms of exposure. SDSs must remain on file for 30 years after employment. If you work with hazardous chemicals, you are required by OSHA to have up-to-date SDSs that are readily available for each chemical. PIs/Supervisors are responsible for obtaining SDSs for their chemicals. SDSs should be requested by the individual ordering the chemical at the time the order is made if there is no SDS on file. If a chemical arrives without an SDS or there is no current SDS for it, the chemical shall be safely stored until the SDS is obtained. Paper copies are required, as electronic copies may not always be available. For work areas with multiple chemicals, an SDS binder must be readily available to all emergency response personnel, regulatory inspectors, and everyone working with the hazardous chemicals. EH&S recommends that SDS binders be located outside the work area and wall-mounted. The EH&S Office will supply SDS binders and wall-mounted holders. 5.2.3 Container Labeling SG-01 Page 5 Rev. 4

All hazardous materials, hazardous waste, chemical containers, and chemical storage areas shall be appropriately labeled indicating the chemical identity, hazards present and any other relevant regulatory requirements. All chemical containers at WHOI must be labeled regardless of size and whether or not they are hazardous. For small chemical containers, the label can be placed on the secondary containment bin, tray, or rack. Labeling of all chemical containers assists emergency personnel and others in identifying what is and what is not hazardous should a spill occur or other emergency situation arise. Original labels on chemical containers must not be removed or defaced. Labels must be in English and they must contain the complete name of the chemical and be traceable or easily linked to the appropriate SDS (chemical formulas are not allowed). The manufacturer s label is generally sufficient to meet OSHA labeling requirements and should be replaced only if it becomes damaged or illegible. Chemical container labeling is the responsibility of the individual who fills and/or uses the chemicals. All containers into which chemicals are transferred also need to be legibly labeled in English and include the name of the chemical and appropriate hazard warnings (chemical formulas are not allowed). The National Fire Protection Association (NFPA) labeling system has been selected for use at WHOI to ensure uniform labeling. The NFPA system requires the chemical name to be listed along with health, flammability, reactivity and specific hazard ratings. The stockroom supplies these labels. Refer to the NFPA Guideline on the EH&S website for further instruction. Refrigerators or freezers containing either chemicals or food should be appropriately labeled, e.g., chemicals only, no food or drink, or food and drink only. Food/drink and chemicals cannot be stored together. 5.3 Personal Protective Equipment (PPE) Each potentially hazardous task must be evaluated to identify appropriate controls, including PPE. Feasible engineering controls are always preferable and should be implemented first, as PPE does not eliminate the hazard. PPE shall be inspected before each use to ensure that there are no defects that may lead to an exposure. Ensure that all PPE is compatible with the chemical to be used. For hazardous chemicals, review the SDS to determine the necessary PPE to limit your exposure. Refer to the Personal Protective Equipment Guideline on the EH&S website for further instruction. 6.0 CATEGORIES OF HAZARDOUS CHEMICALS A hazardous chemical is any chemical which is a physical hazard or a health hazard. A health hazard means acute or chronic health effects that may occur in exposed personnel. Chemicals that are health hazards include: carcinogens, toxics, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system and agents which damage the lungs, skin, eyes, or mucous membranes. Chemicals that are physical hazards include: combustible liquids, compressed gases, explosives, flammables, organic peroxides, oxidizers, pyrophorics, and water-reactives. The PI/Supervisor or designee shall ensure that all personnel are aware of the locations, hazards, and appropriate control measures for work involving hazardous materials. Prudent practices must be implemented by all personnel when handling hazardous materials. Appropriate engineering controls, administrative controls, personal protective equipment, procedures, and training should be in place prior to use of hazardous materials and equipment. PIs/Supervisors should develop written work area-specific procedures for safely with highly hazardous materials/processes, reproductive toxins, and select carcinogens. General prudent practices for work involving hazardous materials include: Use general or local exhaust for conducting hazardous materials/processes. If the process does not permit using general or local exhaust, contact EH&S at X3347 to review alternative exposure control measures. SG-01 Page 6 Rev. 4

Wear appropriate gloves, protective clothing and eye protection. A designated area should be identified and appropriate warning labels should be posted when working with highly hazardous materials. SDSs must be available for all hazardous materials in the work area. Personnel must review and understand the SDSs prior to working with chemicals. Review all emergency procedures to ensure appropriate response to unexpected spills and accidents. Some specific hazards that may be present in various work areas are listed below. Combustible Dust Is any finely divided solid material that presents a fire or explosion hazard when dispersed and ignited in the air. Any area or location with more than a 1/8 inch build-up of combustible dust is considered hazardous. Refer to the Combustible Dust Safety Procedure on the EH&S website for further instruction. Compressed Gases A variety of hazards may be present when working with compressed gas cylinders, including high pressure and rapid release of contents. Refer to the Compressed Gas Cylinder Safety Guideline on the EH&S website for further instruction. Controlled Substances A controlled substance is a drug or other substance, or immediate precursor, regulated by the Drug Enforcement Agency (DEA) under schedules I-V. It is the responsibility of the PI/Supervisor to obtain and maintain a permit/registration for all controlled substances used at WHOI and to comply with all applicable requirements. The possession and use of controlled substances requires a permit/registration from both DEA and Massachusetts Department of Public Health Drug Control Program. Refer to the Controlled Substances Guideline on the EH&S website for further instruction. Corrosive Chemicals A liquid or solid that causes visible destruction or irreversible alteration of living tissue at the site of contact or a liquid that has a significant corrosion rate on steel. Isolate corrosive chemicals from incompatible chemicals. Acids and bases can cause severe tissue damage depending on the corrosivity of the chemical. Exercise extreme caution when handling these types of chemicals. If an acid or base comes in contact with your skin or clothing, thoroughly wash the affected areas utilizing the safety showers or eyewash units. Cryogenic Liquids - Cryogenic liquids are liquefied gases that are kept in their liquid state at very low temperatures and are associated with various hazards including: extreme cold, asphyxiation, and toxicity. Personnel must be properly trained to handle and use cryogenics. Appropriate personal protective equipment must be worn. Refer to the Cryogenics Liquid Safety Guideline on the EH&S website for further instruction. Ethidium Bromide (EtBr) - EtBr is a potent mutagen and moderately toxic after an acute exposure. It can be absorbed through skin, so it is important to avoid any direct contact with the chemical. EtBr is an irritant to the skin, eyes, mouth, and upper respiratory tract. Consider using a less toxic chemical (e.g., SYBR Safe DNA gel stain) to reduce potential hazardous exposures and amounts of hazardous waste generated. EtBr work areas must be posted: Ethidium Bromide Caution: Mutagen and Carcinogen. Refer to the Ethidium Bromide Safety Procedures on the EH&S website for further instruction. Flammable/Combustible Liquid - is any substance that is easily ignited, burns intensely, or has a rapid rate of flame spread. For regulatory convenience, flammable and combustible liquids are defined together as any liquid with a flash point below 140 F. The quantity of flammable liquids stored in a work area should be kept to a minimum. Isolate flammable liquids from ignition sources and incompatible chemicals, e.g. oxidizers. Refer to the Flammable and Combustible Liquid Storage Guideline on the EH&S website for further instruction. SG-01 Page 7 Rev. 4

Hydrofluoric Acid (HF) is an extremely corrosive acid used for many purposes including mineral digestion, surface cleaning, etching and biological staining. HF is very aggressive physiologically because of the fluoride ion. When exposed to air, concentrated solutions and anhydrous hydrofluoric acid produce pungent fumes which are especially dangerous. Burns with concentrated HF can be very serious, with the potential for significant complications due to fluoride toxicity. Every effort must be made to prevent exposure to HF. Refer to the Hydrofluoric Acid Safety Guideline on the EH&S website for further instruction. Lead - is a neurotoxin, reproductive toxin, hematologic (blood) toxin, may cause cancer based on animal data, and can pose other significant health hazards if the material is not safely handled. Personal protective equipment such as gloves should be worn when handling lead weights or lead-contaminated items. Thoroughly wash hands, arms, and face after handling lead. Do not eat, drink, or smoke in or around areas where lead is handled or stored. Transport and store lead in secondary containers to minimize the spreading of lead dust. Refer to the Lead Weight Handling and Storage Safety Guideline on the EH&S website for further instruction. Oxidizers can initiate or promote combustion in other materials. Examples include potassium permanganate, silver nitrate, and nitric acid. Keep these chemicals in a tightly closed container and store in a cool, dry, ventilated area. Isolate from incompatible chemicals (e.g., organic solvents) and ignition sources. Avoid storage on wood floors and separate from incompatibles, combustibles, organic or other readily oxidizable materials. Perchloric Acid - is extremely dangerous because it is a very strong oxidizer. When perchloric acid reacts with organic material, an explosive reaction product may be formed. It is essential that such materials not accumulate in the hood ductwork. Refer to the Laboratory Hoods Guideline on the EH&S website for further instruction. Pyrophoric Chemicals For pyrophoric materials, oxidation of the compound by oxygen or moisture in air proceeds so rapidly that ignition occurs. Many finely divided metals can be pyrophoric. Many reducing agents, such as metal hydrides, alloys of reactive metals, low-valent metal salts, and iron sulfides are also pyrophoric. A UCLA researcher used a plastic syringe to extract from a sealed container a small quantity of t-butyl-lithium, a chemical compound that ignites instantly when exposed to air. As she withdrew the liquid, the syringe came apart in her hands, spewing flaming chemicals. She had not been properly trained and was not wearing protective clothing when the experiment exploded, spreading second- and third-degree burns over 43% of her body. She died 18 days later. Select carcinogen means any substance which meets one of the following criteria: It is regulated by OSHA as a carcinogen such as formaldehyde; or It is listed under the category, "known to be carcinogens," such as benzene, 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," such as cadmium, 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" such as lead and chloroform, 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 SG-01 Page 8 Rev. 4

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 Toxins May affect the reproductive health of women, men, and the unborn child. These hazards may cause problems such as infertility, miscarriage, and birth defects. Reproductive toxins may affect the parent, developing child (even after birth), or both. OSHA defines reproductive toxins as chemicals which affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis). Examples include mercury and lead compounds. The use of reproductive toxins in work areas must be identified and exposure control measures must be implemented. Personnel may consult with EH&S before the start of any activity involving reproductive toxins. Time Sensitive Chemicals - develop additional hazards upon prolonged storage. Examples include peroxidizables, polynitrated aromatics, chloroform and anhydrous HF. All time-sensitive chemicals shall be immediately dated when they are received from the manufacturer and dated when opened in the work area for use. Purchase the smallest quantity that is practical for all time-sensitive chemicals. Substitution for a less hazardous chemical is preferable. For peroxidizables, periodically test for peroxides using peroxide indicator strips. Never, under any circumstances, touch or attempt to open a container of a peroxide-forming liquid if there are crystals around the cap and/or in the bottle. The friction of unscrewing the cap could detonate the bottle. Refer to the Time Sensitive Guideline on the EH&S website for further instruction. Toxic Chemicals Toxic effects are classified as acute or chronic. Acute effects are observed shortly after exposure. Chronic effects result from long term exposures. Access to work areas which have toxic chemicals should be controlled by the PI/Supervisor. The work area door should be kept closed while experiments with toxic chemicals are in progress. Personnel are advised to wash their hands immediately after completion of any procedure involving toxic chemicals and when they leave the work area. Work surfaces and equipment which become contaminated during experimental procedures are to be decontaminated. Exhaust hoods can be used to control airborne contaminants and reduce or eliminate exposures. Toxic chemicals must be stored in tightly sealed containers. Chemicals of unknown toxicity, including synthesis of new chemicals, must be treated as toxic/hazardous until fully characterized. Water-Reactive Chemicals - Water reactive materials are those that react violently with water. Alkali metals (e.g., lithium, sodium, and potassium), many organometallic compounds, and some hydrides react with water to produce heat and flammable hydrogen gas, which can ignite or combine explosively with atmospheric oxygen. Follow manufacturer handling and storage requirements. 7.0 CHEMICAL PROCUREMENT AND INVENTORY CONTROLS 7.1 Procurement The decision to procure a chemical is a commitment to handle and use the chemical properly from initial receipt to ultimate disposal. Chemical purchases should be evaluated for regulatory, safety and environmental considerations before the orders are placed. Implement just-in-time chemical inventory process, where possible. Order the least hazardous chemical and the smallest quantity needed to complete the task. Chemicals must be ordered using a purchase requisition form, or be purchased through the authorized Speedy Order Systems (SOS) program currently in place. SOS program participants include Corp Brothers, Fisher, and Sigma-Aldrich. The Procurement Department will assist you with the placement of chemical orders. Contact the Procurement Department for further instruction. No new chemical should be used until required emergency equipment, personal protective equipment, and/or exposure controls have been obtained and are available for use. 7.2 Chemical Inventory Database PIs/Supervisors or their designees are responsible for entering their chemical inventory electronically into the WHOI Chemical Inventory Database located on the EH&S website. New chemicals must be added to the SG-01 Page 9 Rev. 4

chemical inventory database upon receipt. The inventory should be printed from the database and kept with the SDS binder to ensure that it is readily available to personnel. The inventory shall be kept up-to-date. If you need assistance with the Chemical Inventory Database, contact the Safety and Health Officer at X2244 who also functions as the administrator of the Chemical Inventory Database. 7.3 Toxic Substances Control Act Chemical substances that are imported or exported may be subject to U.S. EPA Toxic Substances Control Act (TSCA) requirements. In addition, significant adverse health affects may need to be reported. A summary of the importation and exportation requirements is provided below. Refer to the TSCA Guideline on the EH&S website for detailed instructions or contact the SHO. Import of Chemicals: A TSCA Import Certification Form (refer to the TSCA Guideline on the EH&S website) must be completed for any chemical substances that are brought into the U.S. by any means, including: through U.S. Customs, shipped by mail service, hand carried, or other importation mode. An importer must declare whether a chemical substance is regulated under TSCA with a POSITIVE CERTIFICATION or not regulated with a NEGATIVE CERTIFICATION on the TSCA Import Certification Form. If a chemical supply vendor or distributor, such as Fisher Scientific, imports chemicals for WHOI s use, that vendor is the importer of record and must comply with TSCA s importation requirements and they may use their own importation certification form. Export of Chemicals: TSCA requires the completion of the TSCA Export Notification Form (refer to the TSCA Guideline on the EH&S website) prior to the exportation of chemical substances that are contained on EPA s Current List of Chemical Substances Subject to TSCA Section 12(B) Export Notification Requirements. A link to this list is located on the EH&S website. 7.4 Department of Homeland Security Chemicals of Interest Department of Homeland Security (DHS) promulgated the Chemical Facility Anti-Terrorism Standards (CFATS) Interim Final Rule. Appendix A of the CFATS regulation lists the DHS chemicals of interest (COI) and their corresponding Screening Threshold Quantities (STQ). If WHOI possesses or later comes into possession of a COI at or above the specified STQ or if DHS determines that WHOI presents a high level of security risk, WHOI will have to comply with the substantive requirements of CFATS e.g., preparing a Security Vulnerability Assessment, developing and implementing a Site Security Plan, etc. The potential penalties for non-compliance with these chemical safety/security regulations are civil and criminal penalties, including cessation of operations by the DHS. To maintain compliance with DHS requirements: PIs/Supervisors and personnel are responsible for reviewing the COI list prior to purchasing a chemical. EH&S discourages the use of low threshold COIs and will encourage substitution or disposal. The COI list is available on the EH&S website. If you plan to procure a COI with a low STQ of cumulative 100g (CUM 100), A Placarded Amount (APA), or 2.2 pounds, you must notify the SHO at X2244 prior to purchasing the chemical for review/approval. Consider substituting with a chemical not listed as a COI. If your research absolutely requires a COI with a low STQ, limit your quantities to the least amount possible. The SHO will periodically review the Chemical Inventory Database to screen for COIs. 8.0 EMERGENCY RESPONSE PROCEDURES The time to prepare for an emergency is before it happens. Accidents and spills involving chemicals and exposure are required to be reported to the PI/Supervisor and the EH&S Office. For hazardous materials release and spill procedures, personnel must follow the procedures detailed in the Comprehensive Emergency Management Plan (CEMP) located on the EH&S website. The best spill procedure is prevention, which includes: Read the SDS for all new chemicals and follow recommended storage, use and disposal practices; SG-01 Page 10 Rev. 4

Use secondary containers when storing chemicals, chemical waste, and when transporting bottles of liquid chemicals; and Keep work areas free of clutter and separate/isolate incompatible chemicals. 8.1 Incidental Spill is a chemical spill that an individual can clean up without assistance. Examples include a small spill or a low hazard spill. May be cleaned by personnel if they feel confident in their knowledge of the material and have the ability and equipment to safely and easily accomplish this Consult the SDS to ensure that proper PPE is used and that cleanup procedures are followed Spill kits are mounted on the walls in the hallways. See the CEMP for locations. 8.2 Hazardous Spill is a chemical spill requiring the assistance of the emergency response team or outside responders. Examples include an unknown chemical spill, a highly hazardous spill, or a large spill. Report the emergency by dialing x2911 Warn others in the area Evacuate to a safe area Attend to any person who has been exposed to the chemical if safe to do so 9.0 INFORMATION, TRAINING, AND RECORDKEEPING The PIs/Supervisors is responsible for ensuring their personnel are provided with information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard that personnel have not previously been trained about is introduced into their work area. All personnel must complete required training, including work area-specific training, training from the EH&S Office, read and understand this Guideline, review SDSs, and other applicable procedures. 9.1 Information All personnel covered by this Guideline will be informed of the following: The location and provisions of the Hazard Communication & Chemical Safety Guideline The location of the work area Chemical Inventory List The location of the SDS binder, how to review/interpret the information on SDSs and container labels Operations in their work area where hazardous chemicals are present Procedures to protect against chemical hazards (e.g., required PPE, proper work practices, safe handling and use of chemicals, and procedures for emergency response) Methods used to detect the presence of a hazardous chemical release Additional information can be obtained at the EH&S Office or on the EH&S website. 9.2 Training The EH&S Office provides several OSHA and EPA mandated trainings, including: hazard communication, hazardous waste generator training, and general safety awareness. Hazard communication training covers all aspects of this guideline. These trainings are required every two years for all personnel within the scope of this guideline. The training schedule and course descriptions are located on the EH&S website under the training link. PIs/Supervisors are responsible for providing work area-specific training prior to the start of work, when a new chemical hazard is identified, when performing non-routine tasks, when the hazard level changes, or when there is evidence that training was not understood. Work area-specific training includes: physical and health hazards of chemicals in the work area, utilizing engineering controls, how to select and wear appropriate PPE, hazardous protocols and/or equipment and emergency procedures. SG-01 Page 11 Rev. 4

9.3 Recordkeeping The EH&S Office maintains the training records and any occupational exposure assessment records. The PI/Supervisor is responsible for maintaining any work area-specific training records. 10.0 TRADE SECRECTS Trade Secret is any confidential formula, pattern, process, device, information or compilation of information that can be used by WHOI. WHOI may withhold the specific chemical identity, including the chemical name and other specific identification of a hazardous chemical, from the SDS provided that: The claim that the information withheld is a trade secret can be supported; Information contained in the SDS concerning the properties and effects of the hazardous chemical is disclosed; The SDS indicates that the specific chemical identity is being withheld as a trade secret; and, The specific chemical identity is made available to health professionals, personnel, and designated representatives when it is determined that a medical emergency exists and the specific chemical identity of a hazardous chemical is necessary for emergency or first-aid treatment. WHOI shall immediately disclose the specific chemical identity of a trade secret if a medical emergency exists to the treating physician or nurse, regardless of the existence of a written statement of need or a confidentiality agreement. 11.0 CHEMICALS IN UNLABELED PIPES The PI/Supervisor will inform personnel of the hazards associated with chemicals contained in unlabeled pipes in their work areas. Prior to starting work in these areas, personnel should contact the PI/Supervisor or the Facilities Department for information regarding the chemicals in the pipes, potential hazards, and safety precautions to be taken. 12.0 MULTI-EMPLOYER WORK AREAS Non-WHOI personnel (including contractors, collaborators, customers, etc) that use hazardous chemicals in our work areas must follow this guideline or an equivalent hazard communication and chemical safety procedure. The cognizant PI/supervisor will ensure that non-whoi personnel are aware of and comply with the requirements of this guideline. 12.1 WHOI Notifications/Actions To ensure compliance with this guideline, the cognizant PI/Supervisor will inform the non-whoi personnel of the following: The location of this guideline The location of SDSs for WHOI-supplied hazardous chemicals in their work areas The list/inventory of the hazardous chemicals in their work areas Any precautionary measures that need to be taken to protect personnel The NFPA labeling system 12.2 Non-WHOI Personnel Notifications/Actions Non-WHOI personnel that bring hazardous chemicals on-site must comply with the following: Supply a list/inventory of the hazardous chemicals and SDSs and any other precautions to WHOI s cognizant PI/Supervisor Ensure all chemical containers are properly labeled Remove all unused chemicals after the project is complete SG-01 Page 12 Rev. 4

Arrange for proper disposal of all hazardous and non-hazardous wastes (contact EH&S Office for assistance, x3347) 13.0 HAZARDOUS WASTE MANAGEMENT Hazardous Waste is any solid, liquid, sludge, or containerized gas that is discarded, has served its intended use, is a by-product, and exhibits any of the following characteristics: flammable, corrosive, reactive, or toxic. All personnel that generate hazardous waste are responsible for the proper identification, labeling, storage, management, and waste minimization. Refer to the Hazardous Waste Generator Guideline on the EH&S website for further instruction. P-Listed Waste is acutely hazardous by reactivity and/or toxicity and are highly regulated by the U.S. Environmental Protection Agency. WHOI cannot generate more than 2.2 pounds per month of these substances as a waste. Limit your inventory and minimize the generation of all acutely hazardous waste. Refer to the Hardous Waste Generator Guideline on the EH&S website for the listing of P-Listed waste. Sharps are devices or objects capable of cutting or piercing. This includes items such as hypodermic syringes, scalpels, razor blades, and broken glass items such as Pasteur pipettes, capillary tubes, and microscope slides. This definition excludes most broken glassware and bottles which are generally collected in yellow, puncture-resistance, plastic drums. Use an approved sharps container for safe handling and storage of sharps waste. A sharps container must be a rigid, plastic, leak proof, puncture-resistant, and break- resistant container. Do not overfill these containers. Refer to the Sharps Handling and Disposal Guideline on the EH&S website for further instruction. Universal Waste in Massachusetts is classified as fluorescent lamps, hazardous batteries, thermostats, mercury containing lamps, pesticides, and mercury containing devices that cannot be disposed in the general trash. Hazardous batteries include hazardous materials, such as lithium (primary, non-rechargeable), nickel cadmium, lead acid, and nickel metal hydride. Refer to the Universal Waste Management Guideline on the EH&S website for further instruction. 14.0 WORK AREA RENOVATION / MOVE / RELOCATION PROCEDURES All hazardous materials impacted by renovation/move/relocation activities must be properly managed. This will protect WHOI personnel and outside contractors from exposure to hazards. This section applies to personnel engaged in the following: leaving WHOI and closing his/her work area, retiring and closing his/her work area, relocating his/her work area to a different location on campus, renovating his/her work area, or leaving WHOI but transferring responsibility of his/her work area to another PI/Supervisor. It is the responsibility of the PI/Supervisor or their designee to: Notify EH&S of work area renovation/move/relocation activities as soon as possible. Contact EH&S for assistance with hazardous material moves. The transportation of hazardous materials must be in compliance with the Department of Transportation regulations. Unknown or unlabeled chemical containers cannot be transported. Ensure all hazardous materials are properly moved, disposed, or transferred to another PI/Supervisor. Check with your Department to see if unwanted chemicals can be recycled. Chemicals must not be abandoned. SG-01 Page 13 Rev. 4

Unneeded gas cylinders must be returned to vendor or transferred to another PI/Supervisor. Tag all hazardous waste and complete a waste pickup request on-line at wastepickup@whoi.edu. Ensure all chemical containers are properly labeled with the full name and hazard (s). Do not leave any unknowns. Clean surfaces and equipment that have come in contact with chemicals using a warm solution of soap and water or other sufficient cleaning method to ensure surfaces are free of visible chemical residue. This may include exhaust hoods, bench tops, floors, equipment, refrigerators and sinks. Update the chemical inventory on the WHOI chemical inventory database. Request a walk-through of your work area from EH&S at X2244 or X3347 after these procedures have been completed to ensure there are no exposure hazards. SG-01 Page 14 Rev. 4