Chemical Hygiene Plan & Laboratory Safety Manual
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Chemical Hygiene Plan & Laboratory Safety Manual https://wp.stolaf.edu/chemical-hygiene/ All laboratory workers* must read and understand this Manual before working with or near chemicals on campus. “Where hazardous chemicals as defined by this standard are used in the workplace, the employer shall develop and carry out the provisions of a written Chemical Hygiene Plan which is: (i) Capable of protecting employees from health hazards associated with hazardous chemicals in that laboratory and (ii) Capable of keeping exposures below the limits specified [in 29 CFR part 1910, subpart Z].” 29 CFR 1910.1450(e)(1) “The Chemical Hygiene Plan shall be readily available to employees, employee representatives and, upon request, to the [OSHA] Assistant Secretary.” 29 CFR 1910.1450(e)(2) * This manual is intended for use by FNSM employees who work in Regents Hall of Natural Sciences. Academic-related employees who work in the Dittmann Center or Speech Theater follow the “Art Safety Manual.” Facilities personnel follow the policies and guidelines outlined in the “Employee Right-To-Know Written Program.” Implemented: January 1991 Last Updated: August 2021 Updated by: Dr. Patrick A. Ceas Chemical Hygiene Officer St. Olaf College (signee for the St. Olaf College) TABLE OF CONTENTS Chapter 1 Introduction: Why Must I Read, Understand, and Follow this Safety Manual? Chapter 2 Responsibilities Chapter 3 Laboratory Facilities Chapter 4 How Am I Exposed to Chemicals, and How Can I Avoid/Minimize Exposure? Chapter 5 How Do I Know if a Chemical is Hazardous, and How Do I Learn About Its Hazardous Characteristics? Chapter 6 Engineering Controls: When & How to Use Fume Hoods and other Protective Equipment Chapter 7 Basic Rules & Procedures for Working with Hazardous Chemicals Chapter 8 Hazardous Chemicals: Categories, Examples, & Standard Operating Procedures for their Proper Use Chapter 9 Biological Safety Chapter 10 Radiation Safety Chapter 11 Animal Care and Use Chapter 12 Controlled Substances Chapter 13 Waste Disposal Program Chapter 14 Employee Information & Training Chapter 15 Handling Accidents, Spills, and Emergencies Chapter 16 Medical Consultation & Examination Chapter 17 Record Keeping CHAPTER 1 “Introduction: Why Must I Read, Understand, and Follow this Safety Manual?” 1.1 Why Do We Have this Manual? 1.2 The OSHA “Laboratory Standard” – Why Was it Written? 1.3 The “Laboratory Standard” – A Brief Overview 1.4 The Chemical Hygiene Plan – What is Required? 1.5 Overview of Additional Regulatory Information 1.6 Chemical Safety in Other St. Olaf Buildings 1.1 WHY DO WE HAVE THIS MANUAL? (adapted and modified from the Univ. Minnesota “Laboratory Safety Plan” http://www.dehs.umn.edu/safety/lsp/intro.html) 1.1.a To Provide Safety Guidelines & Policies. The St. Olaf College Chemical Hygiene & Safety Manual is intended to provide guidelines and policies that, when properly followed, are capable of protecting employees, students, visitors, and the surrounding community from harmful exposure to, and health hazards associated with, hazardous chemicals. 1.1.b To Comply with and Meet Regulatory Requirements. This Manual is intended to meet the requirements of: (1) the Occupational Health and Safety Administration (OSHA) “Laboratory Standard” (29 CFR 1910.1450), formally known as "Occupational Exposure to Hazardous Chemicals in Laboratories; Final Rule” (reproduced in Appendix B), (2) the Minnesota Employee Right To Know Act (MERTKA), and (3) other relevant standards summarized in Section 1.5. 1.1.c To Evaluate the Workplaces for Hazards. MERTKA requires employers to evaluate their workplaces for the presence of hazardous substances, harmful physical agents, and infectious agents and to provide training to employees concerning those substances or agents to which employees may be exposed. Written information on agents must be readily accessible to employees or their representatives. Employees have a conditional right to refuse to work if assigned to work in an unsafe or unhealthful manner with a hazardous substance, harmful physical agent or infectious agent. Labeling requirements for containers of hazardous substances and equipment or work areas that generate harmful physical agents are also included in MERTKA. 1.1.d To Eliminate Hazards or Reduce Risks. The guidelines and policies found in this Manual are designed to eliminate hazards or at least (if followed properly) reduce risks to ensure a safe and healthy work environment for all laboratory workers, students, visitors, and the surrounding community: (1) Administrative Controls. (2) Engineering Controls. (3) Personal Protective Equipment. (4) Standard Operating Procedures. 1.1.e To Avoid Exposure Limits or Action Levels. This Manual is intended to provide policies and procedures that, when followed properly, will safely limit laboratory workers' exposure to OSHA-regulated substances. (1) Laboratory workers must not be exposed to substances in excess of the Permissible Exposure Limits (PELs) specified in OSHA Rule 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances. (2) Certain substances have “Action Levels” - air concentrations below the PEL - that nevertheless require that certain actions such as medical surveillance and workplace monitoring take place. 1.1.f To Ensure the Medical Surveillance of Employees. An employee's workplace exposure to any regulated substance must be monitored if there is reason to believe that the exposure will exceed an Action Level or a PEL. If exposures to any regulated substance routinely exceed an action level or permissible exposure level there must also be employee medical exposure surveillance. 1.2 THE OSHA “LABORATORY STANDARD” – WHY WAS IT WRITTEN? Numerous regulations affect laboratory employees who work with or may be exposed to hazardous chemicals. The Occupational Safety and Health Administration (OSHA) administers a variety of federal regulations related to occupational safety and health issues. These regulations, found in Part 1910 of Title 29 of the Code of Federal Regulations (cited as “29 CFR 1910”), are divided into Subparts A through Z. Subpart Z addresses specifically the use of toxic and hazardous substances, and includes regulations designed to protect all employees from harmful exposure to, and associated health hazards associated with, hazardous chemicals. On November 25, 1983, OSHA published the Hazard Communication Standard (cited as “29 CFR 1910.1200”), which applied to certain manufacturers and in part to certain laboratories. This Standard requires that employers develop, implement, and maintain a written Hazard Communication Program that provides information to their employees about the hazardous chemicals to which they are exposed, and is designed to ensure the safety of employees from exposure to hazardous chemicals by including information on: • labels and other forms of warning, • material safety data sheets, • information and training, • how the employer will implement the Program, • a list of the hazardous chemicals known to be present, • the methods the employer will use to inform employees of the hazards of non-routine tasks, and • the methods the employer will use to inform employees of chemicals contained in unlabeled pipes in their workstation. OSHA received many comments regarding whether the procedures of the Hazard Communication Standard should apply to laboratories where the staff is usually “highly educated.” OSHA decided although “31.9% of all laboratory workers have bachelors degrees, 20.6% have masters degrees, and 20.9% have doctorates, … there is some question as to whether laboratory workers actually make themselves as knowledgeable as they should be and some laboratory employees are not professionally trained.” Other unique differences for laboratories were noted, including: the small amounts of chemicals used; the vast numbers of different chemicals involved; and that nearly half of the laboratories in one survey could not accurately predict their chemical needs even one month in advance. OSHA decided that "Despite the existence of the unique characteristics of laboratory work places, in actual practice incidents of acute adverse health effects resulting from exposures to toxic substances in laboratories do occur. Furthermore, some studies … have shown increased risks of certain types of diseases for laboratory workers. In addition, although laboratory workers are, in general, a well educated work force, there is evidence that many laboratories do not have health and safety programs… ". Therefore, on January 31, 1990, OSHA published in the Federal Register an amendment to 29 CFR 1910, Subpart Z, identified as Section 1910.1450. The title of this amendment is “Occupational Exposures to Hazardous Chemicals in Laboratories; Final Rule” but it is better known as the “Laboratory Standard.” 1.3 THE LABORATORY STANDARD – A BRIEF OVERVIEW (The entire document is reproduced in Appendix B, and can be viewed online at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10106&p_table=STANDARDS) 1.3.a Effective Dates. The effective date of the Laboratory Standard was May 1, 1990. A primary requirement of the standard is a written Chemical Hygiene Plan, to be developed and implemented by January 31, 1991. St. Olaf College met this deadline. 1.3.b Scope and Application. The Laboratory Standard applies to employers and employees who are involved with the laboratory use of hazardous chemicals (as explained in Sections 1.3.c-1.3.g below). It supersedes the requirements of all other OSHA health standards in 29 CFR 1910