The Chemical Hygiene Plan

H. Safety considerations. The Occupational Safety and Health Administration (OSHA), US Department of Labor, standard entitled Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) makes it necessary to address safety issues in the SOP. The standard requires laboratories that use hazardous chemicals to maintain employee exposures at or below the permissible exposure limits specified for these chemicals in 29 CFR Part 1910, Subpart Z. Hazards associated with any specific chemicals used in a method must be addressed so that the user has the information needed to follow the Chemical Hygiene Plan for their laboratory. The method developer should limit the use of hazardous chemicals where feasible. The use of toxic and/or carcinogenic reagents should be avoided or eliminated as much as possible. Additionally, the cost of disposal is increasing and could impact the practicality of a method. Material Safety Data Sheets for the analyte(s) and any unusual or hazardous reagents should be provided for the user. 

Students and workers should be taught about the concept of the chemical hygiene plan. 

All laboratories must have a written plan—the Chemical Hygiene Plan (CHP)— which describes the provisions that have been made for safety by the laboratory managers. This requirement is regulated by OSHA under standard 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories. The CHP sets out the specific procedures, work practices, safety equipment and personal protective equipment that have been selected to provide employee protection for the hazards found in each laboratory. An individual university or college laboratory will follow the CHP of the institution, which applies to all laboratories on campus the laboratory may also have a CHP that is specific to its individual conditions. College students should follow the provisions of the applicable CHP to ensure their safety. The CHP must include ... 

CFR1910.1450 - Occupational Exposure to Hazardous Chemicals in Laboratories The chemical hygiene plan should address shock-sensitive hazards. 

The Chemical Hygiene Plan, HAZ COM Plan, and Carcinogen Management Attachments to the Chemical Management LIR outline LANL s planning requirements for safe chemical management. 

A key component of the OSHA standard is the Chemical Hygiene Plan (CHP). This is an e5q)licit requirement for laboratory activities that conform to the definitions given in the preceding section. The facihty must develop and carry out a written CHP which satisfies several criteria. The first three are generalizations but are nevertheless essential, ft is not required in these three sections to define how one is to accompUsh them. 

The remaining elements of the plan are much more explicit in their requirements. The standard states The Chemical Hygiene Plan shall include each of the following elements and shall indicate specific measures that the employer will take to ensure laboratory employee protection. ... 

The centerpiece of the Laboratory Standard is the Chemical Hygiene Plan. This is a written plan developed by the employer (e.g., university or research organization) and has the following major elements ... 

The OSHA-mandated special provisions for work with carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity include consideration of "designated areas," use of containment devices, special handling of contaminated waste, and decontamination procedures. The OSHA requirement is for evaluation, assessment, and implementation of these special controls, when appropriate. These special provisions are to be included in the Chemical Hygiene Plan. 

The Chemical Hygiene Plan shall be readily available to enployees, employee representatives and, upon request, to the Assistant Secretary. 

The enploya- shall review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary. 

Components of the Chemical Hygiene Plan Basic Rules and Procedures Chemical Procurement, Distribution, and Storage Environmental Monitoring Housekeeping, Maintenance and Inspections Medical Program... 

The Chemical Hygiene Plan should require that laboratory workers know and follow its rules and procedures. In addition to the procedures of the sub programs mentioned above, these should include the rules listed below. 

Waste disposal Assure that the plan for each laboratory operation includes plans and training for waste disposal (230). Deposit chemical waste in appropriately labeled receptacles and follow all other waste disposal procedures of the Chemical Hygiene Plan (22, 24). Do not discharge to the sewer concentrated acids or bases (231) highly toxic, malodorous, or lachrymatory substances (231) 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 (242). 

The preparation and use of Laboratory Chemical Safety Summaries as described here are consistent with the Chemical Hygiene Plans required for every laboratory under the OSHA Laboratory Standard. Thus, the identification of substances that meet the OSHA criteria for "particularly hazardous substances" or "select carcinogens" should be facilitated by the use of these summaries. 

Supervisors must ensure that employees know, understand, and follow the chemical hygiene plan and related SOPs. Supervisor must ensure availability of proper PPE and employees know its proper use. Perform quarterly chanical hygiene and housekeeping inspections. Perform semiannual chemical inventories of all laboratories and storage areas. Determine PPE for the procedures and chemicals in use in their area. Supervisor must conduct self-inspections to assure that healthful working conditions regulatory compliance. 

Legally, what group of people is not bound by the Chemical Hygiene Plan ... 

Schools can also use the chemical hygiene plan as guidance for a lab safety plan of their own. The chemical hygiene plan has two goals to protect employees from health hazards associated with work procedures and hazardous chemicals in the lab and to keep personal exposure to below the established limits. The plan should be... 

The laboratory worker has the responsibility of following all rules and procedures established in the chemical hygiene plan and reporting all deficiencies (29 CFR 1910.1450 Appendix A). 

The housekeeping and inspection section of the chemical hygiene plan should establish cleaning procedures and acceptable methods and cleaning chemicals. It should identify basic inspection criteria for all lab participants prior to and during lab use. It should also include a training portion on these matters for school custodians. 

The training section ideally should be a formal training needs assessment and storage of records. It could also be used as a central location for the listing of training topics and specific objectives for each section of the chemical hygiene plan. 

Lab personnel must plan and conduct each laboratory operation in accordance with the chemical hygiene plan. Employees must also keep lab work areas in good order. Employers must educate personnel on how to correctly select and use required PPE. Provide employees with a system to report exposures, injuries, or problems to supervisors or the chemical hygiene officer. 

CFR 1910.1450(0(1990) Training must include methods that can be used to detect the release of a chemical, the hazards associated with the chemical and the information available to employees in the Chemical Hygiene Plan. 

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