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Laboratory Inspection Explanation Key

General:

Self-inspection – It is good practice for staff in laboratories and research areas to use the self-inspection checklist to go through their laboratories and research areas and conduct their own laboratory/research area inspections identifying the same topics covered during the Laboratory and Research Area Inspection conducted by the Department of Environmental Health and Safety.

Injury and illness reporting – All accidents and exposures to harmful chemicals, no matter how minor, need to be reported to the supervisor and the injury/illness/exposure report needs to be filled out online.


Research Laboratory:
Chemical Hygiene Plan – A Chemical Hygiene Plan (CHP) for laboratories is required by OSHA. It must be accessible in all labs either electronically or as a hard copy.

SDS – OHSA regulations require that employees have access to Safety Data Sheets (SDS), electronically or a hardcopy or both within five (5) minutes. In addition, emergency responders may need a hard copy of an SDS.

HASP/Door signage – The Hazard Assessment Signage Program (HASP) requires that each room have a hazard identification sign on the door indicating the primary hazards present in the room. HASP signs need to be updated annually.


Research Hazard Communication Areas:

Policy – Each non-laboratory space is required to have access to the Hazard Communication Program.

Training – OSHA also requires training on the Hazard Communication Program. Non-laboratory personnel should take ”Hazard Communication” training provided by EHS. The “Laboratory Safety” course also meets these requirements.

Chemical Inventory - An inventory of all hazardous chemicals should be maintained.

Labeling – All containers that are not empty must be labeled with their contents and must be marked with the right-to-know information for any hazardous chemicals present. The original manufacturer’s label is fine, but if the chemical is transferred to a non-original container, it must have a secondary label that must include the chemical name, a harmonized signal word, GHS pictogram, hazard statement for each hazard class/category, a precautionary statement, and supplier identification.  

 

Chemical Safety:

Labeling – For safety reasons as well as EPA and OSHA regulations, every container that appears to have a chemical in it must be labeled and easily identified by every user within the lab. Some common labeling methods are original manufacturer labels, secondary labels that must include the chemical name, a harmonized signal word, GHS pictogram, hazard statement for each hazard class/category, a precautionary statement, and supplier identification. If abbreviations are more practical, use a list or key to the abbreviations.

Container Integrity – Containers in bad condition run the risk of being cited by EPA as “inherently waste-like”. Containers should be in good condition, with no leaks or spills, no broken caps, and no rusty cans.

Abbreviation Key - The “key” must contain the abbreviation and the name of the chemical. Including the hazards of the chemical on the “key” is also useful information. A sample fill-in-the-blank key can be found on the EHS website. The abbreviation key must be readily available upon request by visitors, emergency responders, state and federal regulatory agencies such as EPA, OSHA, or NYS OFPC inspectors.

SOPs – Standard Operating Procedures (SOP) - Each lab is required to develop safe handling instructions for their highly hazardous, highly toxic, and carcinogenic chemicals. If a format is needed, see the SOP Examples.

Segregation – Chemicals must be segregated, by the hazards they present, to avoid incompatible materials being stored together. Storing chemicals by hazard class in different cabinets or in different secondary containment is recommended.

Secondary Containment - Use trays or bins, to conduct your experiment in and for storage of particularly hazardous substances and hazardous waste containers.

Flammables in Flammable-rated Cabinet – Larger volumes of flammable liquids must be stored in a flammable rated cabinet. As a general guide, we recommend that rooms with more than 10 gallons of flammable liquids use a flammable rated storage cabinet.

Flammables in Flammable-rated Refrigerator – Flammable liquids (flashpoint below 100°F) should not be stored in regular refrigerators because of the risk of explosion (this includes walk-in units). Flammable liquids may be stored in flammable or explosion rated refrigerators. Using an ice bath to cool chemicals before an experiment might be an option for some laboratories.

Overhead or Floor Storage – Hazardous chemicals should be not stored above eye level or on the floor. Heavy equipment and heavy boxes should not be stored overhead.

Surplus Chemicals – Some surplus chemicals may be able to be used by others in your department. Contact your Department Safety Representative to send out the list. If the chemicals cannot be used, they should be disposed of properly.

 

Specific Chemicals:

Perchloric Acid – Heating perchloric acid requires a specific fume hood with a wash down system. When working with Perchloric acid, be sure to remove all organic materials, such as solvents, from the immediate work area.

Ethidium Bromide (EtBr) – The areas where EtBr is used should be labeled and require special deactivation process.

Hydrofluoric Acid (HF) – The areas where HF is used needs to be clearly labeled. Calcium gluconate is required to be available for first aid treatment in case of accidental exposure. HF Training is required for all that use HF.

Cryogenic Liquids – Cryogenics are extremely cold and their vapors pose an asphyxiation hazard. Dispensing and storage areas need to be well ventilated.

Silver – Groups that develop film or use silver nitrate in staining solutions should know where a silver filtering unit is, and how to use it. For information please contact EHS at 607-255-8200.

Peroxide Formers - Peroxide forming chemical containers should be dated on the container when they are received and opened. They also need to be checked regularly with peroxide test strips with the results noted on the container. The regularity at which chemicals need to be tested for peroxides can be found in the Chemical Hygiene Plan. If peroxides begin to form, the material must be treated to remove peroxides, or disposed of properly.

Security for Highly Hazardous Materials – Laboratories need to take specific actions in order to provide security against theft of highly hazardous materials. Examples include using locked cabinets, locked drawers, and lock boxes, in addition to keeping laboratory doors locked when the room is unoccupied.


Compressed Gases:

Secured - Cylinders must be secured to a sturdy object to prevent toppling. A chain (preferred) or strap should be tight enough and strong enough to secure the cylinder. Placement of the strap should be in the upper 1/2 of the cylinder but not around the cap or valve. A cylinder chained on a cylinder cart is acceptable but not as safe as if it were chained to an immobile object.

Cap/Regulator – Cylinders that are ‘in use’ must have a regulator attached. Cylinders that are not hooked up to equipment or considered ‘in use’ must be capped with a valve protection cap. Cylinders must be capped during transport.

Hang Tags – Cylinders should be tagged with: ‘Full’, ‘In-use’, or ‘Empty’ tags. Gas vendors are usually willing to provide tags at no charge to customers.

Segregation/Storage – Flammable gases and oxidizing gases must be separated by an acceptable fire barrier. This separation could be a fire-rated wall or a minimum of 20 feet space between the types of cylinders. Flammable gases or oxygen should not be stored near a source of ignition such as electrical panels or open flames.


EPA Compliance:

Labeling – Hazardous waste is required to be labeled with the words “Hazardous Waste” and the contents and hazards. Use the EHS hazardous waste label. (Tip Sheet)

Closed – Hazardous waste containers must be kept closed with a tight sealing lid. For containers hooked up to equipment, bottles still need to be closed when not in process. Special caps can be procured where the bottle remains closed while tubing is connected to equipment.

Point of Generation – Hazardous Waste must be stored in the area where it was generated. We have interpreted this to mean ‘in the same room’.

Secondary Containment – As stated in CFR 267.195, the following are the requirements for a secondary containment system used to prevent the release of hazardous waste. A secondary containment system must be constructed with or lined with materials that are compatible with the wastes placed in the tank and must have sufficient strength to prevent failure. This system must be placed on a foundation/base capable of supporting it. The secondary containment system must also have a leak detection system such that the failure of the primary or secondary containment structure or the presence of the release of hazardous waste can be detected within 24 hours. The system must also be sloped or designed or operated to drain and remove liquids from leaks within 24 hours.

Accumulation of Excess Waste – Large quantities of stored hazardous waste should be removed to prevent accidental spills.

Old, inherently Waste-like Containers – Degraded containers can release hazardous vapors that are detrimental to the health of laboratory personnel and allow chemicals to become contaminated, which can have an adverse effect on experiments.

Oil – Containers of used oil should be labeled “Used Oil”, kept closed and be placed in secondary containment. Check with the building manager for the location of the used oil drum in your building. If you suspect that oil has become contaminated with a hazardous chemical such as Freon or PCBs (maybe from a transformer or old refrigerator), please call EHS at 607-255-8200 before discarding or mixing with other oil.

Universal wastes - Universal wastes include batteries and fluorescent light bulbs. Universal Wastes require the labeling: “Universal Waste - Bulbs” or “Universal Waste - Batteries”. Universal Waste must be labeled with an accumulation start date and must be disposed of within the year of the start date. We recommend that universal wastes be disposed of every 9 months to give the solid waste group time to process it.


Fume Hoods:

Tested – Fume hoods are tested annually by Cornell’s HVAC shop in a program that is overseen by EHS.

Items in Hood Blocking Flow - Keep all materials from blocking vents or baffles in the back of the hood by elevating materials at least one inch off the work surface.

Bench Cabinet – The cabinet where chemicals are stored should be good condition. If the interior is degraded, the cabinet should be replaced.


PPE: 

PPE Assessment - Personal Protective Equipment (PPE) is the equipment necessary for you to protect yourself while performing your job. The assessment determines the type of PPE that is needed, when it is appropriate, and the limitations of the PPE. The PPE includes the following (but is not limited to): respirators, eye protection, gloves, clothing, hearing protection, and foot protection.

Use of Respirator - The use of all types of respiratory protection at Cornell is governed by the OSHA standards and the Cornell EHS Respiratory Protection Program. A laboratory worker at Cornell may not purchase a respirator and bring it to their lab for personal use without prior consultation with EHS.

 

Electrical Safety: 

Electrical panels – The area in front (minimum of 3 feet) is required to be free of material, to allow access. The circuit breakers need to be labeled appropriately to what each circuit breaker controls and the breaker panel needs to be intact; all openings must be covered with appropriate material.

Extension Cord/Power strip – Equipment should be grounded or double insulated and be tested by a third party such as Underwriters Laboratories (UL approved). You must not use equipment that has a worn or frayed cord. Extension cords are allowed only for temporary use on portable power equipment. A power strip cannot be plugged into another power strip or have extension cords plugged into it. Inspect the cord prior to use for any deficiencies if any are found, the cord needs to be replaced.

GFCI – When working with electrical equipment around wet and/or damp environments, a Ground Fault Circuit Interrupter is required to be used. Temporary GFCI plug adapters can also be used, but are not a substitute for GFCI outlets or circuit breakers.


Lab Equipment Safety:

Equipment Labeled for use – Refrigerators, freezers, microwaves, and dishwashers need to be labeled: Chemical/sample storage Only’, ‘Research Use Only’, ‘Food Only – No Chemicals’, or other appropriate labels.

Refrigerant/Ozone Depleting – All equipment that uses refrigerant or Ozone depleting substances should have an EHS Environmental Compliance inventory sticker.

Rotovaporators – Due to vacuum pressure upon the glass there is increased risk of implosion hazard. The glass should be wrapped in a protective coating, for example with a plastic mesh sleeve or with clear packing tape if they do not contain a protective coating.

Mercury-containing Equipment – Equipment that contains mercury is recommended to be changed out with like equipment that does not contain mercury. If not applicable, then the equipment should be labeled with a sticker ‘Contains Mercury’ and an appropriate mercury spill clean-up kit should be available.

Sonicators – Hearing protection is recommended to be available and worn when using this equipment, to protect against hearing loss.

Battery Recharging Station – Requirements for lead/acid battery charging stations:
plumbed eyewash station, PPE (gloves, apron, goggles and face shield), fire extinguisher, good ventilation, and no sources of ignition.

Equipment in Working Order – Equipment that is used, needs to be functioning according to the manufactures' specifications. If the equipment is not functioning properly it should be tagged and taken out of service until repaired.

Machine Guarding - All moving parts on equipment must be properly guarded.

Ladder Safety – Ladders need to be functioning properly and sized appropriately for the application.


Emergency Preparedness:
Emergency Action Guide – This is a guide covering various emergencies that may occur and how to respond if they were to occur.

Spill Kit - A well-prepared spill kit will help manage small spills quickly and safely. Check the EHS Webpage for recommended materials for spill kits. The rule of thumb for safety on spill cleanup is: If you don’t feel comfortable doing it, or you don’t have the necessary materials, evacuate the area and use the facility emergency phone or 911 for help.

 

Housekeeping:
Aisle Space - Fire code requires a minimum 36” aisle space. Spaces between workbenches should not be cluttered with storage of materials and/or equipment.

Eat/Drinking - It is possible for the food or drink to absorb chemical vapors and thus lead to a chemical exposure when the food or drink is consumed. Eating or drinking in areas exposed to toxic materials is prohibited by the

OSHA Sanitation standard, 29 CFR 1910.141(g)(2).

Work Space/Fume Hood – Cluttered and messy workspaces can lead to safety issues and can attract attention when regulators inspect the area. Workspaces should be kept orderly and all chemical spills must be cleaned up.

Chemical Spills Cleaned Up - Ensure all spills have been cleaned up and all potentially contaminated surfaces have been thoroughly cleaned with water and detergent.

Lighting – Work areas should always have adequate lighting to work safely.

Slips/trips/fall Hazards – Floors should be kept clean and free from debris and electrical cords. Chemicals and hazardous materials should not be stored in floor spaces.


Biosafety:
Hypodermic Needles – A certificate of need from the Department of Health is required to possess hypodermic needles and syringes. This is obtained either by the department or PI. Stocks of hypodermic needles must be kept in locked storage with an inventory system (log of use) that is kept for three years.

Work with Biohazards, Infectious Material, Recombinant DNA – The Cornell University Institutional Biosafety Committee issues a Memorandum of Understanding to investigators to assure appropriate health and safety measures are in place and to comply with existing government regulations and applicable University policies.

Regulated Medical Waste – Waste generated at Biosafety Levels 2 and 3 is defined as that generated in the diagnosis, treatment or immunization of human beings or animals, in research pertaining thereto, or in production and testing of biologicals. Additionally, regulated medical waste cannot contain any hazardous chemical or radioactive waste components. The biological component must first be decontaminated, and then treated as chemical or radioactive waste.

Sharps Disposal - Hypodermic needles must always be discarded in a red sharps container. Hypodermic Needles should never be removed from a syringe; instead, the entire unit should be put into a sharps container. Other sharps such as razor blades can be collected in sturdy puncture-resistant container, taped shut and disposed of directly into the dumpster.

Exposure Control Plan – OSHA requires that an employer implement the plan when employees are working with bloodborne pathogens. Research groups may need to add additional information relevant to their particular site in order to have an effective and comprehensive plan.

Biosafety Cabinet - Biosafety Cabinets (BSC) need to be inspected and certified for use annually. BSCs should only be used for the work for which they were designed. Most Biosafety Cabinets (BSC) are not designed for chemical use. Alcohol for disinfection should have only limited use in BSCs.


Radiation:
All radioactive materials must be acquired, possessed, and used at Cornell University facilities following the procedures described in this manual. This includes exempt quantities of radioactivity. All radioactive materials must be in compliance with the requirements of the U.S. Nuclear Regulatory Commission, the New York State Department of Health, and the New York State Department of Environmental Conservation. If you are working with radiation sources in your laboratory, make sure you contact Environmental Health & Safety to ensure legal compliance.


Pesticides:
Federal law requires personnel to have Worker Protection Standard training prior to or within 5 days of working with pesticide-treated plants. Contact: Eric Harrington; CALS OEH 5-0485

Federal and state law, as well as the University Health & Safety Policy 2.4, require lab personnel to be certified commercial pesticide applicators, technicians, or apprentices if working with amounts greater than very small lab scale. Contact: Eric Harrington; CALS OEH 5-0485


Shipping Hazardous Materials:
If the group ships hazardous materials, they should have a plan on how to do this correctly, using trained and qualified people. EHS provides training for compliance with the Department of Transportation’s regulations governing the shipping of hazardous materials.

 

Training:
Every person who handles Hazardous Waste must know what their role is in making sure that the waste is handled properly. EHS provides a “Chemical Waste Disposal” class that covers these requirements.

 

Animal Areas:
Facility Manager – The facility manager’s information is required to be posted such that it is easily accessible to those entering these animal areas.

AUHSP Paperwork Posted at Entrance – The required postings are the animal health and safety brochure and allergy prevention fact sheet. These can be picked up at the CARE front office if needed.

Waste Anesthetic Gas (WAG) – Procedure rooms or areas that use WAGs need to be reviewed by EHS and if procedures have changed since the last review, a new review should be conducted. Training is required when working with WAGs.

Record of Machine Maintenance - CARE requires that all anesthetic gas machines are certified annually. The certification date should be located on the equipment and CARE will keep a record of this as well.

Control Measures for Allergens – People who work with and around animals need to review and understand the information found in the Animal Users Health and Safety Brochure entitled "Allergy Prevention".

SOP for Cage Transport – CARE requires a standard operating procedure (SOP) be written for animal cage transporting.

Escape Bars in Wash Areas – Walk-in cage washing units need interior escape bars for personnel to effectively exit the cage washer unit.

Hearing Protection – Hearing protection devices should be provided before entering areas of loud noise areas.

 

Eyewash/Safety Shower:
Corrosive Chemical Use – An efficient functioning eyewash station is required to be readily accessible, free of obstructions and within 10 seconds from the hazard. The ANSI standard also outlines specific requirements related to flow requirements, use of tempered water, inspection and testing frequencies, and training of laboratory personnel in the proper use of this important piece of emergency equipment.

Weekly/Annual Testing – Laboratory personnel should flush the eyewash on a weekly basis, and post atest sheet for logging who and when the flushing occurred.  EHS tests the eyewashes annually and tags them appropriately.

Eyewash/Safety shower labeled – A sign(s) denoting the location of the eyewash/safety shower should be posted.

 

Fire Safety:
Fire Extinguisher – All workers must have immediate access to a fire extinguisher (within 75 feet). The extinguisher needs to have a current inspection and needs to be appropriate for the fire risks present. Personnel should frequently check the pressure gauge to make sure that their extinguisher is still properly charged. The fire extinguisher should be secured to a wall.

Combustible Storage – Combustibles (materials that burn easily) must not be stored within 2 feet of the ceiling in a non-sprinklered room or, if the room is sprinklered, both combustibles and non-combustibles must be kept 18 inches below the level of the sprinkler head. Combustible materials should not be stored near sources of ignition including electrical panels, sparking equipment, and open flames.

Excess Combustible Storage – Large amounts of combustible material (paper, plastic, cardboard, etc) that is being stored within an area should be removed or recycled, due to the fire hazard the material presents.

Potential Fire Hazards – Special consideration about surrounding material needs to be taken when using equipment that produces an open flame, high heat, or electrical spark.