Chapter 1: Purpose, Scope and Responsibilities

Revised January 2023

Purpose

The purpose of the University Chemical Hygiene Plan (CHP) is to establish policies and procedures that when implemented will minimize risks to personnel, facilities, and the environment that arise from laboratory chemical use. These policies and procedures are based on currently accepted good laboratory safety practices in place at academic, government, and industrial research laboratories. Additionally, the CHP is designed to comply with the OSHA Standard (29 CFR 1910.1450), Occupational Exposure to Hazardous Chemicals in the Laboratory, commonly referred to as the OSHA Lab Standard. Laboratories that utilize biological agents and/or radioactive material should refer to the University Biosafety Manual and Radiation Safety Manual, respectively.

Scope

The CHP applies only to laboratories; however, it is applicable to all laboratories that utilize chemicals, regardless of the area of research or laboratory activity. For example, research and teaching laboratories that utilize hazardous chemicals are examples of workplaces where the CHP is applicable. Storerooms and stockrooms that stock and supply chemicals in direct support of laboratory operations are also within the scope of this CHP. Non-laboratory workplaces that use or store hazardous chemicals fall under the scope of the University Written Hazard Communication Program, for example: crafts shops, printing shops, and photo labs.

Responsibilities

Laboratory Safety Committee

The Laboratory Safety Committee (LSC) provides guidance and administrative oversight related to broad laboratory safety issues associated with University laboratories. The LSC considers all environmental health and safety risks associated with the University laboratory activities that arise from chemical, biological, radiological, and physical hazards; however, radiation safety and biological safety issues are the primary responsibility of the Radiation Safety Committee and the Institutional Biosafety Committee, respectively.

The LSC is responsible for development of University policies and administrative oversight of laboratory activities. Specific responsibilities of the LSC include:

• Advise the Vice President for Research and Innovation (VPRI) on matters related to laboratory safety.
• Develop, recommend, and oversee policies and procedures for management and reduction of laboratory risks throughout the University.
• Oversee broad laboratory safety issues and regulatory compliance associated with laboratory research and teaching, to include review of assessments of laboratory environmental health and safety issues.
• As requested by EH&S or the VPRI, make recommendations on facility design features, laboratory ventilation, utilities, equipment, and services necessary to conduct high quality laboratory teaching and research while minimizing risks. Both “typical” laboratory operations and unique laboratory operations should be considered. Recommendations should include financial and operational responsibilities, including design, construction, purchase, installation, maintenance and repair, and testing and calibration services.
• As requested, advise and provide technical expertise on matters regarding laboratory safety to EH&S staff or other members of the University community.
• Review reported laboratory safety incidents such as personnel exposures, hazardous materials spills, and fires, and provide recommendations to responsible laboratory supervisors and administrators to prevent similar occurrences.
• Conduct investigations of serious violations of regulations or university policy, incidents, or operational problems, and make recommendations to the VPRI, Provost, and other appropriate university administrators for the resolution of continued non-compliance or serious infractions.
• As an agent of the University, the LSC can recommend to the VPRI that authorization to conduct laboratory activities be suspended or cancelled when training and/or experience, or laboratory facilities and equipment, is deemed inadequate, or in the event of continued non-compliance or serious infractions.

Environmental Health and Safety Department

The Environmental Health and Safety Department (EH&S) is an administrative unit that reports to the Vice President for Research and Innovation. EH&S has responsibility for development and implementation of the University environmental health and safety policies. A member of the EH&S staff is designated as the University Chemical Hygiene Officer (CHO). Responsibilities of the University CHO include:

• Administering and implementing the University CHP.
• Assisting laboratory supervisors in development and implementation of laboratory-specific CHPs and work practices.
• Ensuring that appropriate laboratory assessments are conducted to ensure implementation of this program.
• Reviewing the University CHP at least annually.
• Determining if exposure monitoring is necessary.
• Determining if medical surveillance is necessary.

Academic Departments and Other Administrative Units

The Chair of each academic department (or other administrative unit) has responsibility for environmental health and safety issues within the department. It is the Chair’s responsibility to ensure that department faculty understand their laboratory safety responsibilities and are committed to implementation of the CHP in research labs and teaching labs. To facilitate this process, it is recommended that each department appoint a safety representative or form a department safety committee.

Each Department is responsible for:

• Implementing this CHP in department laboratories, including development of Standard Operating Procedures (SOPs) and specific laboratory safety training.
• Participating with EH&S in developing an emergency response plan for the Department that is compatible with the University model.
• Participating (with EH&S) in health and safety assessments of department laboratories (and other facilities).
• Reporting laboratory and environmental incidents (e.g., injuries, illnesses, fires, explosions, and release of chemicals to the environment) to EH&S in a timely manner. Incidents requiring immediate response should be reported as soon as possible, including during non-business hours, via the EH&S 24-hour contact number (327-5040). Incidents not requiring immediate response and deemed to be minor should be reported the next business day. Departments are responsible for investigating the cause of each incident and providing a report of the investigation findings to the CHO.
• Informing the Facilities Services Department and/or EH&S of any unsafe conditions, including deficiencies in safety equipment. Anytime significant safety issues are submitted to, or resolved by, Facilities Services, EH&S should be notified.
• Promoting good environmental health and safety practice in the department.

Laboratory Supervisors

Laboratory Supervisors are responsible for the health and safety of all personnel working in their laboratory (research labs and teaching labs). The University CHP serves as a vehicle for improving laboratory safety. Laboratory supervisors are responsible for implementing the University CHP in their lab(s); however, specific duties required to meet this obligation can be delegated. Specific responsibilities include:

• Ensuring that all laboratory personnel receive documented training on the specific health and safety hazards to which they are exposed, and that personnel are competent to perform their assigned work. An outline of a training documentation form is available as an appendix to this page; however, other formats may be used. This training must communicate laboratory hazards, methods, procedures, and equipment required to work safely in the laboratory, proper emergency response actions, and when and how to obtain treatment for workplace illness or injury.
• Developing written standard operating procedures (SOPs) that address health and safety concerns associated with laboratory operations that involve hazardous chemicals (see Chapter 3).
• Ensuring that Safety Data Sheets (SDSs) and other sources of chemical hazard information are available to laboratory workers, and that workers know how to access this information.
• Upon request from authorized personnel, communicate information regarding hazards and necessary safe work practices to authorized laboratory visitors, including: other laboratory personnel, maintenance workers, custodians, and vendors.
• Provide supervision of laboratory personnel at a level commensurate with the education, experience, and competence level of the personnel. In the event of an extended absence, the Laboratory Supervisor should arrange for a qualified alternate to provide supervision of laboratory operations (generally this will be another qualified faculty member or an experienced member of the research group).
• Ensure that personal protective equipment and any project-specific safety equipment are available, in proper working order, and appropriate for the laboratory and the work being conducted.
• Implement and enforce preventative measures to control hazards and minimize risks to personnel. This includes complying with regulations, University and Departmental laboratory safety policies, and prudent laboratory safety practices.
• Promote environmental health by maintaining compliance with environmental regulations, including minimization and proper management of hazardous wastes, reduction of laboratory water and air effluent, and prudent management of hazardous materials inventories.
• Take active steps to identify laboratory safety deficiencies and ensure remediation. Such deficiencies include those identified during laboratory safety inspections, as described in the University Laboratory Safety Assessment Program Policy. This policy also requires that Laboratory Supervisors organize and conduct internal, documented, self-inspections at least annually each year. A sample checklist for laboratory inspections is included in the Appendices. It is recommended that laboratory supervisors tailor checklists for specific activities and hazards.
• Ensure that any deficiencies in facility-associated safety equipment, including laboratory fume hoods, safety showers/eyewashes, fire extinguishers, and emergency egress lighting are reported to the Facilities Services Department for remediation.
• Ensure that laboratory-related injuries and illnesses are reported to the Worker’s Compensation Office, EH&S, and the responsible Department Chair, and necessary forms are filed according to current policy. Similarly, incidents such as fires, explosions, and release of chemicals to the environment are to be reported to EH&S and the responsible Department Chair.
• Implement procedures to avoid hazards resulting from the departure of laboratory personnel. Ensure that departing personnel properly label and store, or dispose of, all chemical solvents, chemical waste, research samples, etc.

Laboratory Workers

All laboratory workers (employees and students) are directly responsible for their own safety. Unsafe acts performed by one individual can affect (directly or indirectly) the safety and work productivity of others. Personnel who have health or safety concerns should contact their supervisor and/or EH&S, and should not perform the work until they are confident their concerns have been adequately addressed. Specific responsibilities include:

• Knowing how to access the Chemical Hygiene Plan (this document) and being knowledgeable of requirements and procedures contained in the Plan.
• Conducting all laboratory activities in accordance with the University CHP and laboratory-specific standard operating procedures.
• Participating in required training.
• Utilizing engineering controls, safety equipment, and personal protective equipment in an appropriate manner.
• Informing the laboratory supervisor of any safety, health, or environmental incidents and unsafe conditions, including deficiencies in safety equipment.

Chapter 2: General Laboratory Safety