Chemical Hygiene Plan

Chemical Hygiene Plan

Introduction 1 Responsibilities Information and Training 2 Information Resources Standard Operating Procedures (SOPs) 3 Procurement Distribution Disposal Storage Potentially High Risk Procedures Particularly Hazardous Substances Approval of High Risk Protocols Controlling Exposures 5 Hazard Potential Control Measures: Engineering Controls Personal Protective Equipment Administrative Controls Detecting Chemical Exposures Medical Consultations and Examinations 7 Exposure Related Examinations Medical Consultation Reproductive Health Policy Accident/Spill Response 7 Spills and Releases: Minor Major Emergency Procedures Laboratory Generated Chemicals 8 Intra-Laboratory Use of Chemicals of Known Composition Intra-Laboratory Use of Chemicals of Unknown Composition Chemicals Produced for Inter-Laboratory Use Safety Resources Particularly Hazardous Substances Waste Disposal Policy Chemical Compatibility Chart Hazard Communication Program Reproductive Health Policy Laboratory Specific Procedures

INTRODUCTION: The Chemical Hygiene Plan (CHP) defines a formal program for minimizing personnel and environmental exposures to hazardous chemicals used in the laboratory. The principal purpose of the CHP is to assist the laboratory investigator in the selection and use of safeguards that will serve to ensure a safe and healthful environment. The plan is based on the provisions described in the OSHA regulation entitled "Occupational Exposure to Hazardous Chemicals in Laboratories". While the plan defines specific procedures and control measures for handling chemicals in the laboratory, the cornerstone of this chemical safety program is the communication of information. It is imperative that all laboratorians become aware of the hazards associated with the chemicals they use, as well as the appropriate measures for controlling exposures. Responsibilities. The responsibility for implementing the CHP will be shared between administration, the Environmental Safety Office, principal investigators/lab supervisors, and the laboratory personnel. The Environmental Safety Office has been given the administrative authority to coordinate this effort and has specific responsibility for: 1) developing the CHP; 2) compiling the related information resources; 3) providing information and training on the CHP; 4) providing technical guidance in selecting laboratory practices and engineering controls; 5) auditing laboratories; and 6) investigating possible over-exposures and accidents. The principal investigator/laboratory supervisor has the responsibility for : 1) understanding and implementing the CHP in their laboratory; 2) acquiring the knowledge and information needed to recognize and control chemical hazards; 3) informing his/her employees of potential hazards associated with the chemical being used; 4) selecting and employing laboratory practices and engineering control that reduce potential exposures; 5) obtaining approval from the Environmental Safety Office before undertaking the high risk procedures defined in Section 3 of the CHP; and 6) arranging for immediate medical attention and reporting of all chemical injuries and over-exposures. Each employee is responsible for: 1) knowing the provisions of the CHP and complying with all safety procedures defined by the principal investigator; 2) reporting unsafe conditions; 3) reporting all injuries, accidents and over-exposures. Duke University Chemical Hygiene Plan Page 1

INFORMATION & TRAINING: An informed and trained staff is of singular importance in ensuring the safe use of chemicals within the laboratory. Our employees must have a clear understanding of the hazards associated with the chemicals being used, as well as, the methods for detecting and controlling their exposures to those chemicals. There are numerous methods available for obtaining the necessary information and all employees should become familiar with the following resources: 1. The Chemical Hygiene Plan (CHP) is a primary resource and provides information on standard operating procedures for handling chemicals, specific methods for detecting and controlling exposures, and a description of acceptable exposure levels. Each laboratory should have a copy of the CHP which is available through the Environmental Safety Office. 2. A Chemical Hygiene Poster describing safe handling practices and access to information is available through the OESO. All laboratories are encouraged to display the poster in a prominent location. 3. Material Safety Data Sheets (MSDS's) provide detailed information on individual chemicals. The MSDS includes the chemical identity and physical characteristics, health effects information, primary routes of entry, exposure limits, handling practices, control measures, fire and explosion hazards, and spill response procedures. All MSDS's that are received in the laboratory must be retained for employee review. In addition, employees can obtain access to other MSDS's in the Medical Center Library, Perkins Library, Chemistry Library and the OESO which has compiled the MSDS's for all chemicals used at Duke. 4. Container labels are the most accessible source of health and safety information for a specific chemical. Labels will typically describe the physical and chemical hazards, storage requirements, and appropriate protective equipment. Never remove or destroy existing labels and always consult the label prior to using a chemical. The laboratory director, principal investigator or supervisor is responsible for assuring that all employees receive appropriate training and are familiar with the provisions of the CHP. The Environmental Safety Office (ESO) will assist this effort by providing specific training sessions for any laboratory upon request. STANDARD OP ERATING PROCEDURES ( S O P S ) : The development and implementation of detailed work practices is one method of protecting laboratory personnel from chemical hazards. These Standard Operating Procedures (SOPs) provide guidance to protect employees from health and physical hazards associated with handling chemicals in the workplace. General guidelines for common activities associated with chemical handling are presented below. These activities include procurement, distribution, storage, disposal, and potentially high risk procedures Duke University Chemical Hygiene Plan Page 2

involving chemicals. Due to the variation in chemicals and procedures used in the laboratory you should use these general provisions to create SOPs specific to the procedures and substances used in your laboratory. Procurement: Consideration should be given to the following factors prior to purchasing or accepting chemicals into the laboratory: 1. Consider the potential hazards of the substance and select the least hazardous chemical for the procedure. 2. Ensure that all chemical containers are labeled with the physical and health hazards of the substance. 3. Use central stockrooms, when possible, rather than maintaining large inventories within the lab. 4. Order quantities appropriate to your chemical needs. Distribution: When chemicals are distributed or being transported, the opportunity for spills and accidental release increases. To decrease the probability of exposures, the following controls should be practiced when transporting chemicals: 1. Use transport vessels or secondary containers. 2. Use a stable cart or transport vehicle on low occupancy routes to reduce the chance of exposure to other Duke employees or visitors. 3. Wear personal protective equipment as needed for safe transport. Storage: The quantity of chemicals stored in the laboratory should be the least amount practical. Periodic review of label quality, container integrity, and chemical quantity can help control the accumulation of undesirable or unknown substances. Routine storage practices should include: 1. Follow the storage recommendations on the container label. 2. Segregate chemicals according to their hazard class to avoid the mixing of incompatible materials. 3. Avoid storing chemicals in open areas; such as, under bench tops or walkways. 4. Avoid the storage of chemicals or waste materials in the hood by providing adequate space in other areas of the laboratory. 5. Avoid exposing chemicals to heat sources or direct sunlight. Disposal: Duke University manages chemical waste in accordance with applicable local, state, and federal regulations. All generators of hazardous waste have the responsibility to follow our established waste disposal policy which defines the regulated hazardous wastes and explains the procedures for having these materials removed from the work area. To prevent inappropriate disposal of chemical wastes, the following procedures are to be incorporated into all chemical lab operations: 1. Do not pour hazardous waste into the sanitary sewer system. 2. Develop procedures to reduce the generation of hazardous materials. 3. Prepare unwanted or used chemicals for removal according to Duke University's waste disposal policy. Duke University Chemical Hygiene Plan Page 3

4. Segregate unwanted or waste chemicals for removal. 5. Consult the ESO for information on specific guidelines and regulations concerning waste removal. Potentially High Risk Procedures: Potentially high risk procedures are those activities that could result in chemical overexposure due to excessive or unexpected releases. Extra consideration must be given to the safe handling of all chemicals when performing potentially high risk procedures such as: 1. Weighing or preparing stocks. 2. Handling concentrated acids and bases. 3. Pressurization activities (including gases). 4. Rinsing with solvents. 5. Heating or cooling chemicals. 6. Using reactive substances. Handling Particularly Hazardous Substances. 7. Laboratory personnel must give special consideration to selecting the appropriate protective equipment to prevent exposure during these procedures. Particularly Hazardous Substances (PHS's). Certain chemicals present a unique or extreme risk potential to laboratorians and may require additional control measures to assure safe handling. Such chemicals are categorized as PHS's and include chemicals that are carcinogenic (known or probable), reproductive toxins, or highly toxic. Carcinogen: A causal relationship between the substance or agent and human cancer has been demonstrated. Reproductive Toxin: Substances which affect the reproductive capabilities and/or cause adverse effects on the fetus. Mutagens, Teratogens and Embryotoxins are examples of Reproductive Toxins. Highly/Acutely Toxic: A substance of high toxicity has the potential to damage the metabolism of living tissue. Acutely toxic substances require only a brief exposure to cause damage. A listing of these substances has been developed by the Environmental Safety Office. The chemical list has been sorted by the Chemical Abstract Service (CAS) Registry Number, which is typically listed on the chemical label. The list also includes the common name and synonyms for each substance; however, please note that because of the variability in chemical nomenclature it is advisable to use the CAS number as the primary reference. Maintain this list as a reference for your chemical inventory of PHS's. If you do not have an inventory list in your work area, please contact the Environmental Safety Office. Due to the hazard potential presented by PHS's, the following additional controls must be considered prior to use: 1. Establish designated work areas to segregate the use of PHS's from other laboratory procedures. 2. Use containment devices, such as PPE's and fume hoods to strengthen the barrier between the substance and laboratory personnel. 3. Establish decontamination procedures for leaving the designated work area to prevent exposure to other laboratory personnel. Duke University Chemical Hygiene Plan Page 4

4. Establish special waste removal procedures for PHS's The ESO will provide consultation to assist in the development of specific SOPs for handling PHS's. Material Safety Data Sheets for PHS's will be housed at the Medical Center Library, Perkins Library, Gross Chemistry Library, and the Environmental Safety Office. Approval of High Risk Protocols. As part of Duke's effort to reduce accidental exposures to laboratory personnel, prior review of experimental protocols by the ESO will be required for certain high risk operations involving hazardous materials. It is the responsibility of the principal investigator or project manager to ensure that approval is given prior to implementation of the experiment under the following circumstances: 1. When any extremely and severely toxic inhalation hazards (listed under Particularly Hazardous Substances) are prepared outside of containment devices. 2. When using highly reactive or unstable compounds in potentially high risk laboratory procedures. CONTROLLING EXPOSURES: Hazards associated with chemical use can be reduced by being aware of the hazards and using proper controls to prevent exposure. All laboratorians should be familiar with methods of detecting exposures as well as the proper use of control devices such as fume hoods and personal protective equipment. Hazard Potential: Hazards associated with chemical use can be reduced by becoming aware of the hazard potential of chemicals and using proper control measures to prevent exposures. The hazard potential of a particular chemical is a function of the probability for exposure, the route of exposure, and its toxicity. The selection of control measures is based on our understanding of these elements of hazard potential. The probability for exposure is a function of the physical and chemical properties of the material. Highly volatile compounds and fine powders are difficult to contain and represent a significant inhalation hazard upon release. Solvents of low volatility may present less of an inhalation hazard, but pose a higher potential for skin absorption following contact. In order for a chemical to cause injury, there must be some method of personnel exposure. The most common routes of exposure to chemicals are through the inhalation of dusts, mists or vapors, ingestion and contact absorption through the skin or mucous membranes. Exposures may also occur through injection by a needle or other sharp objects. Toxicity is a measure of a chemicals ability to damage living tissue. Highly toxic chemicals cause severe injury at low doses and may require a higher level of control than a low toxicity chemical. Control Measures: Control of chemical exposures is accomplished by using good work practices, proper engineering controls, and appropriate personal protective equipment. Selection of these control measures is based on the hazard potential of the chemicals being used. General considerations are as follows: Duke University Chemical Hygiene Plan Page 5

Engineering Controls. Engineering controls are the methods of choice to reduce personnel exposures. These controls are usually in the form of local ventilation systems which remove the contaminant at the source of generation. The chemical fume hood, the most prevalent engineering control in the laboratory, is very effective in reducing the likelihood of exposure to vapors or powders when used properly. To ensure proper use and maintenance of the fume hood, the following should be considered: 1. Know how to use and interpret the performance indicator and controls if they are installed on your hood. Call maintenance when the hood is outside of normal operating parameters. 2. Ensure that hood performance is tested at least annually by the Environmental Safety Office. 3. Keep all equipment at least 6 inches from the face of the hood to prevent disruptive air flow patterns. 4. Do not store chemicals or equipment in the hood. When items must be placed in the hood, slots in the rear baffle must be kept free of obstructions. 5. Keep the sash closed as much as possible. This improves the exhaust effectiveness and provides additional splash protection. 6. Minimize traffic past the face of the hood. Engineering controls also include devices which provide a barrier between the worker and the contamination source. Glove boxes are a good example of this type of control. Personal Protective Equipment (PPE). Personal Protective Equipment includes such devices as protective eyewear, gloves, aprons, lab coats, an respirators, which are intended to provide a barrier against direct or indirect contact with chemicals. Such equipment is used when other control measure are not feasible or not sufficient to protect the worker. In order to be effective, PPEs must e appropriate for the operation. Consult the Chemical Hygiene poster or contact the Environmental Safety Office for assistance in the selection of PPEs. Respirators must e used only with ESO approval; refer to the Respiratory Protection Policy for program requirements. Administrative Controls. Administrative controls may prove effective in some situations. These methods include work shift modifications which control exposures by reducing the duration of an employee s contact with the chemical. Because administrative controls are less effective than engineering controls and are commonly misused, any application of these methods must be approved by the Environmental Safety Office and Employee Occupational Health Service. Detecting Chemical Exposures: All laboratorians must become aware of methods for detecting chemical exposures. Indicators of exposure include symptoms, such as irritation, intoxication, and rashes; physics signs like odors or visual appearance; or environmental monitoring. Regardless of the indicator, any recognized or presumed detection of a chemical exposure may indicate a failure of selected control measures and should be reported to the Environmental Safety Office for assessment. Environmental monitoring is conducted by the Environmental Safety Office as part of a formal program intended to assure that exposures are maintained below the following guideline levels: Duke University Chemical Hygiene Plan Page 6

OSHA Permissible Exposure Limits (PEL s) ACGIH Threshold Limit Values (TLV s) These exposure guidelines are set at levels which, when averaged over the specified time period (normally 8 hours), should prevent any adverse health effects. The FEL s and TLV s list most chemicals which are likely to be used in industry. Because of the large number of chemicals which may be used in the laboratory setting, exposure guidelines may not be available for some compounds. Control of these chemicals will be based on their toxicities and exposure potentials as described under Particularly Hazardous Substances. Results of all environmental monitoring will be reported directly to the affected employees by the Environmental Safety Office. MEDICAL CONSULTATIONS AND EXAMINATIONS: Exposure Related Examination: All laboratory personnel exposed to hazardous chemical are given the opportunity to receive medical attention under certain circumstances. Such circumstances include: 1. Whenever an employee believes they have developed signs or symptoms associated with exposure to a hazardous chemical. 2. Whenever an employee is involved in a spill, leak, explosion, or accidental release during which hazardous exposures may have occurred. 3. Whenever occupational exposure monitoring indicates exposures above regulated levels. To obtain a medical consultation, complete form A016, Supervisors s Report of Occupational Injury/ Illness, and make an appointment with Employee Occupational Health Service (EOHS), 684-3225. Bring a copy of t5he A016 form to the appointment. If a medical emergency exists, the affected employee should be given appropriate first aid and transported to the Emergency Room. Dial 911 and a Public Safety Officer will provide the assistance. Medical Consultations. Any employee may obtain free medical consultation regarding concerns about chemical or other occupational exposures by contacting EOHS at 684-3225. Reproductive Health Policy. Duke University has developed a Reproductive Health Policy to protect our employee s reproductive capacity and employee pregnancies from possible adverse effects of work and the work place. A copy of this policy is available for review by all employees. ACCIDENT/SPILL RESPONSE: Spills and Releases. The range and quantity of hazardous substances used in laboratories require preplanning to respond safely to chemical spills. The cleanup of a chemical spill should only be done by knowledgeable and experienced personnel. Spill kits with instructions, absorbents, reactants, and protective equipment may be available for the clean up of minor spills. A minor chemical spill is one that the laboratory staff is capable of handling safely without the assistance of safety and emergency personnel. All other chemical Duke University Chemical Hygiene Plan Page 7

spills are considered major. Minor Chemical Spill Alert people in immediate area of the spill. Wear protective equipment, including safety goggles, gloves, and long sleeve lab coats. Avoid breathing vapors from the spill. Confine the spill to a small area. Use appropriate kit to neutralize and absorb inorganic acids and bases. Collect residue, place in container, and dispose of as chemical waste. For other chemicals, use appropriate kit or absorb spill with vermiculite, dry sand, or diatomaceous earth. Collect residue, place in container wand dispose of as chemical waste. Clean spill area with water. Major Chemical Spill Attend to injured or contaminate persons and remove them from exposure. Alert people in the laboratory to evacuate. If spilled material is flammable, turn of ignition and heat sources. Call Chemical Spill Emergency Response number *(911). Close doors to affected areas. Have person knowledgeable of incident and laboratory assist emergency personnel. If you have questions regarding chemical spill response or chemical safety, call the Environmental Safety Office at 684-2794 or 684-5843. Emergency Procedures. * All emergency response calls to 911 are handled by Duke University dispatchers (not City of Durham) who will contact the Safety Office and support groups. This dispatch system is operated 24 hours per day. CHEMICALS PRODUCED IN THE LABORATORY: Special requirement have been established for determining and communicating the hazards related to chemical produced in the laboratory. Specific provisions vary based on intended use. Intra-Laboratory Use of Chemicals of Known Composition: When a chemical of known composition is produced and is determined to be hazardous, the principal investigator must ensure that the personnel who use this chemical are provided appropriate training and controls. This implies investigator responsibility for the determination of specific hazards. Intra-Laboratory Use of Chemicals of Unknown Composition: Chemicals produced in the laboratory, when their compositions are unknown, must e considered as Particularly Hazardous Substances. Each investigator has the responsibility to identify and characterize these unknowns as soon as possible so that it may be determined whether or not they are hazardous chemicals. In the interim, these chemicals must be handled according to the guidelines presented under Particularly Hazardous Substances. Duke University Chemical Hygiene Plan Page 8

Chemicals Produced for Inter-Laboratory Use: If chemical substances are produced for other laboratories, then all requirements of 29 CFR 1910.1200, Hazard Communication must be met. The provisions of this standard are presented in Duke s Hazard Communication Program and include: 1. Hazard Determination 2. Development of Labels 3. Preparation of Material Safety Data Sheets (MSDS s) An investigator who is responsible for preparation of the above materials may contact the Environmental Safety Office for assistance. Duke University Chemical Hygiene Plan Page 9