Appendix A - Chemical Hygiene Plan
CHEMICAL HYGIENE PLAN
The Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1450, "Occupational Exposure to Hazardous Chemicals in Laboratories” mandates the development of a Chemical Hygiene Plan which is capable of protecting employees from health hazards associated with hazardous chemicals in the laboratory and capable of keeping exposures below OSHA Permissible Exposure Limits.
The Cornell University Chemical Hygiene Plan is developed and coordinated by Environmental Health and Safety (EHS). This Chemical Hygiene Plan is designed to supplement department and laboratory specific safety manuals and procedures that already address chemical safety in laboratories.
As per the OSHA Laboratory Standard, the following are elements of the Chemical Hygiene Plan:
1) Standard Operating Procedures
There are over three thousand research laboratories at Cornell University and most of these use hazardous chemicals. Many departments have developed comprehensive safety and health manuals. These manuals address specific safety rules, regulations and standard operating procedures for laboratory workers in the department or college.
EHS will assist laboratories in developing general and specific standard operating procedures for chemical use in laboratories. Due to the large variety of research and the number of laboratories involved, it will be the responsibility of each laboratory, department or college to ensure that their practices and procedures are adequate to protect their workers who use hazardous chemicals.
It will be up to the Principal Investigator or department head to ensure that written safety procedures are developed for work in their labs and that controls and protective equipment are adequate to prevent overexposure. In many cases, standard operating procedures for laboratory safety have been developed and implemented for years and few changes will be necessary to comply with the OSHA Lab Standard. Existing standard operating procedures may need to be reevaluated to ensure that they address the health and safety requirements for the chemicals in use.
2) Control Measures
The exposure to hazardous chemicals in the laboratory shall be controlled through the use of engineering controls, personal protective equipment, good general laboratory practices, and standard operating procedures specific to an individual laboratory or department.
- Engineering controls: There are a variety of engineering controls that can be used in the laboratory to control exposures to hazardous chemicals. Some of the engineering controls that will be used in laboratories at Cornell may include dilution ventilation, local exhaust ventilation (fume hoods), and proper storage facilities.
- Personal protective equipment: Personal protective equipment (PPE) will be available to laboratory workers for use to reduce exposures to hazardous chemicals in the laboratory. Common PPE such as goggles, gloves, face shields, and aprons are recommended for use with hazardous chemicals. Other PPE such as respirators will be available and recommended for use if necessary. EHS will assist in the proper selection, use, and care of PPE. PPE will be readily available and most equipment is provided at no cost to the employee.
- General laboratory practices: EHS provides laboratories with information about general laboratory work practices and rules that are recognized as effective control measures to minimize exposure to hazardous chemicals in the laboratory. The information is referenced from Prudent Practices in the Laboratory, Safety in Academic Chemistry Laboratories, and other references. These general procedures include guidelines on use of chemicals, accidents and spills, personal protection, use of fume hoods and other good laboratory practice information.
- Specific laboratory practices: Individual departments or laboratories must develop additional written safety procedures whenever necessary to protect laboratory workers from specific chemical hazards that are unique to their particular area of research. Particular attention should be given to control measures for operations that involve the use of particularly hazardous substances such as select carcinogens, reproductive toxins, or acutely toxic chemicals. EHS can assist researchers in developing safety procedures for specific hazards.
- Other: Other control methods that will be used to determine and reduce employee exposures to hazardous chemicals in the laboratory may include exposure monitoring, testing eyewash and emergency shower facilities, developing emergency procedures, proper container selection, and substitution of less toxic chemicals whenever possible.
3) Fume Hoods and Other Protective Equipment
Fume hoods and emergency eyewash and showers are inspected annually by EH&S and Facilities. EHS will coordinate the inspection and repairs with the Facilities and Campus Services shops to ensure a timely and accurate repair process.
The proper functioning and maintenance of other protective equipment used in the lab is the responsibility of a variety of service groups. Maintenance Management, Facilities Engineering, EH&S, and other groups provide and service equipment such as fire extinguishers, eyewash/shower facilities, spill response equipment and mechanical ventilation. Periodic inspections and maintenance by these groups ensure proper functioning and adequate performance of the equipment.
4) Information and Training
Federal and state laws and Cornell University policy require all laboratory workers to receive Laboratory Safety and Chemical Waste Disposal training and be informed of the potential health and safety risks that may be present in their workplace. Documentation must be maintained to demonstrate that such training was provided and received. In order to assist laboratory personnel comply with this requirement, laboratory safety training must be obtained either through EH&S (classroom or web-based sessions) or documented as having been received from an alternative source. Laboratory personnel who attend EH&S training classes will have documentation entered and maintained for them in a training database. Laboratory personnel who have not attended the EH&S Laboratory Safety Training program must submit documentation of training received from alternative sources for verification by EHS.
Please note: For outlying facilities that may not have adequate internet access or for situations such as visiting faculty or staff who may not have a Cornell NetID, EH&S can easily send you a cd-rom with the Laboratory Safety and Chemical Waste Disposal training programs. If you would like to request a cd-rom with these training programs, please send an email request for the cd-rom along with your mailing address and one will be sent to you.
It is the responsibility of Principal Investigators and laboratory supervisors to ensure personnel working in laboratories under their supervision have been provided with proper training, have received information about the hazards in the laboratory they may encounter, and have been informed about ways the employees can protect themselves.
Cornell University will provide employees with information and training to ensure that they are apprised of the hazards of chemicals present in their work area. EH&S regularly provides a variety of training programs for laboratory workers such as Laboratory Safety, EPA – Chemical Waste Disposal, Radiation Safety, Biological Safety, Spill Response, and other training programs, including providing laboratory workers with information on how to obtain additional safety information.
Individual laboratories maintain notebooks or electronic access to Material Safety Data Sheets (SDSs) for chemicals used in the lab. Employees are encouraged to consult the SDSs before working with new chemicals, or to call or write to EH&S for additional information. EH&S also maintains a webpage with links to a variety of internal and external websites for SDS and other chemical safety related information.
EHS will provide information to laboratories, including the Chemical Hygiene Plan, the Laboratory Safety Manual, SDSs, OSHA Permissible Exposure Limits, and specific topical information from employee requests. EH&S personnel are available on a daily basis to answer questions and provide information to employees about chemical safety in laboratories.
Other sources of information and training may come from informal group or individual discussions with a supervisor, posted notices, fliers, web documents, and other written materials. Properly labeled containers, such as those using Right-To-Know labels, will give immediate warning information to workers about specific chemical hazards. Many departments have safety committees and safety manuals that provide information on laboratory safety. Employees are encouraged to contact their Department Safety Representative and EH&S at 255-8200 for more information about safety in laboratories.
5) Prior Approval for High Hazard Work
EH&S can assist in identifying circumstances when there should be prior approval before implementation of a particular laboratory operation. Due to the large variety of research being conducted in laboratories at the University, it is impossible to apply one prior approval process that can apply to all laboratories. Instead, high hazard types of activities should be identified by the Principal Investigator or person responsible for the work, and any type of approval process should be addressed in the laboratory's or department's standard operating procedures.
EH&S will assist in providing information to researchers about work with select carcinogens, reproductive toxins, and acute toxins. General guidelines and recommendations for the safe handling, use and control of high hazard materials can be provided through SDSs, and reference sources such as Prudent Practices in the Laboratory, Safety in Academic Chemistry Laboratories, and other resources.
6) Medical Consultations and Medical Examinations
Medical consultations and medical examinations will be made available to laboratory workers who work with hazardous chemicals as required. All work related medical examinations and consultations will be performed by or under the direct supervision of a licensed physician and will be provided at no cost to the employee through the Gannett Health Center.
The opportunity to receive medical attention, including any follow up examinations, will be provided to employees who work with hazardous chemicals under the following circumstances:
- Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory.
- Where airborne exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the Permissible Exposure Limit) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements. Action level means the airborne concentration of a specific chemical, identified by OSHA, and calculated as an 8-hour time weighted average (TWA).
- Whenever an event such as a spill, leak, explosion or other occurrence takes place and results in the likelihood of a hazardous exposure. Upon such an event, the affected employee shall be provided an opportunity for a medical consultation. The consultation shall be for the purpose of determining the need for a medical examination.
All records of medical consultations, examinations, tests, or written opinions shall be maintained at Gannett Health Center in accordance with 29 CFR 1910.1020 - Access to employee exposure and medical records
. The Gannett Health Center (255-5155) is located at 10 Central Avenue. Exposure monitoring records of contaminate levels in laboratories will be maintained at EH&S 395 Pine Tree Road, Suite 210. For more information, contact EH&S at 607-255-8200.
7) Personnel Responsible for the Chemical Hygiene Plan
EHS will provide technical information and program support to assist laboratories comply with the OSHA Laboratory Standard. EHS will maintain the campus Chemical Hygiene Plan (CHP) and the institutional Chemical Hygiene Officer responsibilities will reside within EH&S. However, it will be the responsibility of the Principal Investigator or individual supervisor, department or college to be in compliance with the components of the CHP.
Each college, center, department, or laboratory may adopt or modify this CHP or write their own chemical hygiene plan as long as the requirements of the OSHA Laboratory Standard are met. It is assumed if a college, center, department, or laboratory has not developed their own chemical hygiene plan, then that unit or laboratory has adopted the Cornell University Chemical Hygiene Plan.
8) Provisions for Additional Employee Protection for Work with Particularly Hazardous Substances
The Chemical Hygiene Plan includes provisions for additional employee protection for work with particularly hazardous substances. Research involving the use of particularly hazardous substances, such as select carcinogens, reproductive toxins or acute toxins may require prior review to ensure adequate controls are in place which will protect the worker. EH&S will assist with the review and make recommendations for additional employee protection.
Additional employee protection may require the use of additional provisions such as:
- Establishment of a designated area.
- Use of containment devices such as fume hoods or glove boxes.
- Procedures for safe removal of contaminated waste.
- Decontamination procedures.
The provision for additional controls may require the expertise and recommendations of various groups including EHS, Facilities Engineering, technical committees and outside consulting companies. These groups have all been previously involved with review and implementation of controls for high hazard research. All additional provisions for work with particularly hazardous substances must be incorporated into the lab’s standard operation procedures for those materials.