• Introduction
• Implementation and Responsibilities
• Scope of Application
• Administrative Details
• Required Components of a Chemical Hygiene Plan
• Generalized Standard Operating Procedures
• Control Measures to Reduce Employee Exposures
• Fume Hood Performance
• Employee Information and Training
• Activities Requiring Prior Approval
• Medical Consultation/Examinations
• Work with Particularly Hazardous Substances
• Appendix 1: Guidelines for Preparing Laboratory Specific Standard Operating Procedures
• Appendix 2: 29 CFR 1910.1450 Occupation Exposure to Hazardous Chemicals in Laboratories
• Appendix 3: OSHA Permissible Exposure Limits (PEL's)
• Appendix 4: Regulated Chemical Lists
• Appendix 5: Chemical Storage Information
• Appendix 6: Glove Selection
• Appendix 7: Laboratory Safety Checklist
• Appendix 8: Accident Reporting

Introduction

Florida Gulf Coast University (FGCU) is obligated and determined to ensure a safe working environment for all its employees and students engaged in laboratory activities. Both the FGCU Research Safety Committee and the Environmental Health and Safety Department exist on campus to promote and facilitate safe working environments by requiring that research projects meet federal, state and local safety regulations.

For FGCU employees engaged in the laboratory use of hazardous chemicals, the University requires compliance with the provisions of Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.1450 entitled Occupational Exposure to Hazardous Chemicals in Laboratories (OSHA Lab Standard). The principal requirement of this standard is for employers to develop and implement a written Chemical Hygiene Plan (CHP).

With the great diversity of FGCU laboratory activities, it is impossible for any one document to define standard operating procedures (SOPs) for every activity in every laboratory. However, the performance-oriented nature of the OSHA Lab Standard makes it possible to construct a general framework for use by individual laboratories in meeting the requirements of the OSHA Lab Standard.

This document is a template for an FGCU Chemical Hygiene Plan. Its purpose is to provide a framework for the creation of laboratory specific Chemical Hygiene Plans. It provides general information applicable to most laboratories, and identifies the specific information and procedures for each PI to add for her or his individual laboratory (ies). (See Appendix 1 of this Chemical Hygiene Plan.)

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Implementation and Responsibilities

Each Principle Investigator (PI) at FGCU shall implement and administer a Chemical Hygiene Plan for each laboratory activity. The PI for a laboratory activity is laboratory’s Chemical Hygiene Officer (CHO). The Chemical Hygiene Officer is responsible for developing, implementing, and reviewing the written Chemical Hygiene Plan including annual reviews and updates as needed.

Although ultimate responsibility for the development and implementation of the chemical hygiene plan for the University rests with the Chemical Hygiene Officer, it is important to realize that the responsibility for chemical hygiene itself rests at all levels of the University. Below are the chemical hygiene responsibilities under the FGCU Chemical Hygiene Plan. 

The President of the University, as the chief executive of the University, has ultimate responsibility for chemical hygiene within the institution and with other administrators, as well as providing continuing support for the Chemical Hygiene Plan.

Vice-presidents, Deans, Department Heads, and Principal Investigators are responsible for compliance with the FGCU Chemical Hygiene Plan within their areas. This includes, ensuring that all employees under their direct supervision are complying with the Chemical Hygiene Plan.

Each Chemical Hygiene Officer is responsible for developing, coordinating implementation, and updating their Chemical Hygiene Plan on behalf of the University President, or his designated representative. The Chemical Hygiene Officer must also institute appropriate audit methods to ensure compliance.

Department Chairmen and Chairwomen are responsible for ensuring Principle Investigators and Laboratory Managers develop and implement standard operating procedures and training programs specific to their laboratories.

Laboratory employees are ultimately responsible for developing and applying good chemical hygiene practices as outlined in the Chemical Hygiene Plan. They must always use the appropriate personal protective equipment provided for their use. Laboratory workers are required to report all accidents, injuries, and illnesses to their supervisor to investigate the circumstances of the incident. A report of the investigation and corrective action(s) taken shall be sent to EH&S. (See Appendix 8, Accident Reporting.)

Inform guests, including visiting scientists, of chemical hygiene practices in the Chemical Hygiene Plan, and of the appropriate personal protective equipment that is available for their use. Other information should include accident, injury, and illness reporting requirements.

Scope and Application

In order to determine to whom the FGCU Chemical Hygiene Plan applies, it is first necessary to provide some critical definitions. The definitions listed below are taken directly from the OSHA Lab Standard (29 CFR 1910.1450(b)). Appendix 2 of this Chemical Hygiene Plan is The OSHA Lab Standard, and it provides all definitions relevant to the OSHA Lab Standard (including the following).

Chemical Hygiene Plan means a written program developed and implemented by an employer which sets forth procedures, equipment, personal protective equipment and work practices that is capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace.

Emergency means any occurrence such as, but not limited to, equipment failure, rupture of containers or failure of control equipment that results in an uncontrolled release of hazardous chemicals in the workplace.

Employee means an individual employed in a laboratory workplace who may be exposed to hazardous chemicals in the course of his or her assignments.

Hazardous chemical means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemical carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes.

Laboratory means a facility or activity where the "laboratory use of hazardous chemicals" occurs. It is a workplace using relatively small quantities of hazardous chemicals on a non-production basis.

Laboratory scale means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safety manipulated by one person. "Laboratory scale" excludes those workplaces whose function is to produce commercial quantities of materials.

Laboratory-type hood means a device located in a laboratory, enclosed on five sides with a movable sash or fixed partial enclosure on the remaining side; constructed and maintained to draw air from the laboratory and to prevent or minimize the escape of air contaminants into the laboratory; and allows chemical manipulations to be conducted in the enclosure without the insertion of any portion of the employee's body other than hands and arms.

Walk-in hoods with adjustable sashes meet the above definition provided that the sashes are adjusted during use so that the airflow and the exhaust of air contaminants are not compromised and employees do not work inside the enclosure during the release of airborne hazardous chemicals.

Laboratory use of hazardous chemicals means handling or use of such chemicals meeting all of the following conditions:

• Chemical manipulations are carried out on a "laboratory scale;"
• Multiple chemical procedures or chemicals are used;
• The procedures involved are not part of a production process, nor in any way simulate a production process; and
• "Protective laboratory practices and equipment" are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

Physical hazard means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, orpyrophoric, reactive (unstable), or water reactive.

Protective laboratory practices and equipment means those laboratory procedures, practices and equipment accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals.

Based on the definitions above, the FGCU Chemical Hygiene Plan will apply to all areas or laboratories engaged in the laboratory use of hazardous chemicals.

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Administrative Details

The template for the FGCU Chemical Hygiene Plan is available on the Environmental Health & Safety website. This location allows the most current information to be available for all FGCU employees. It will also provide a template for new investigators or Lab Managers when they bring new laboratories on-line and need to complete their own portions of the Chemical Hygiene Plan.

All laboratories are required to comply with the FGCU General Laboratory Health and Safety Manual.

Laboratories using radioactive materials are also required to follow the policies and procedures outlined in the FGCU Radiation Safety Manual; it can be found at http://www.fgcu.edu/orsp/Compliance/RadiationManual.doc or by contacting the EH&S Radiation Safety Officer ay (239) 590-1414.

Laboratories where work involving human/primate tissues, recombinant DNA or select agents, etio/select agents is conducted must also comply with CDC and NIH guidelines. Contact EH&S for details at (239) 590-1414 or find them at http://www.cdc.gov/od/ohs/biosfty/bmbl4/bmbl4toc.htm.

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Required Components of a Chemical Hygiene Plan

The OSHA Lab Standard specifies that eight elements be addressed in order to ensure the protection of laboratory employees. These eight elements are summarized below, and are fully detailed in 29 CFR 1910.1450(e)(3) of the regulation.

• Standard operating procedures for handling toxic chemicals.

•  Control measures to reduce worker exposures.

• Fume hood performance.

• Employee information and training (including emergency procedures).

• Requirements for prior approval of laboratory activities.

• Medical consultation and medical examinations.

• Chemical hygiene responsibilities.

• Special precautions for work with particularly hazardous substances.

Responsibilities under the Chemical Hygiene Plan (#7) are found earlier in this document, and in the General Laboratory Health and Safety Plan. The remaining elements will be addressed in the pages that follow. This portion of the Chemical Hygiene Plan is generalized, and individual Principal Investigators are responsible for lab safety in their areas. See Appendix 1 of this Chemical Hygiene Plan for more information.

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Generalized Standard Operating Procedures

At all times, in all laboratories, the use of "Good Laboratory Practices" is required (see References). Individuals are responsible for ensuring that not only themselves, but also all others around them, are working in a safe manner.

There are many excellent publications containing guidelines for the safe conduct of laboratory work, also known as "Good Laboratory Practice." Safety in Academic Chemistry Laboratories, published by the American Chemical Society, is an excellent reference for these practices.  This particular publication is concise, readable, and is oriented toward academic laboratories. It is recommended reading for all laboratory personnel. Consulting other safety information resources is encouraged, review the references or contact the Chemical Hygiene Officer.

The following general Standard Operating Procedures apply to all laboratories ¹. Each laboratory must include any specific rules pertaining to Standard Operating Procedures used in that lab.

ACCIDENTS AND SPILLS:

Eye Contact: Promptly flush eyes with water for a prolonged period (15 minutes) and seek medical attention. Hold eyelids open if possible.

Ingestion: Consult MSDS, a chemical first aid manual or call the Poison Control Information Center at 1-800-282-3171. Seek medical attention as soon as possible.

Skin Contact: Promptly flush the affected area with water (minimum of 15 minutes) and remove any contaminated clothing. If symptoms persist after washing, seek medical attention.

Accident Reporting: Should an accident occur, follow procedures outlined in Appendix 8 of this CHP. Report all accidents to your supervisor.

Clean-up: Promptly clean up all spills, using appropriate personal protective equipment and properly dispose of the resulting waste, including all labeling requirements. Consult MSDS and other safety information sources for specific clean-up recommendations. Spills are to be cleaned up by those working in the area when there is proper training and resources available.

For spills that exceed the laboratory available resources due to volume, toxicity, or other hazard, secure the facility and contact EH&S to arrange for an outside contractor to clean-up the spill.

All spills must be reported to EH&S at (239) 590-1414. After normal working hours, contact EH&S personnel by calling the FGCU Police at (239) 590-1911.

AVOIDANCE OF "ROUTINE" EXPOSURE:

Develop and encourage safe work practices. Avoid unnecessary exposure to chemicals by any route; encourage proper personal hygiene (i.e. wash hands prior to leaving laboratory area). Do not smell or taste chemicals. Vent apparatus that may discharge toxic chemicals (vacuum pumps, distillation columns, etc.) into local exhaust devices. Inspect gloves and test glove boxes before use. Do not allow release of toxic substances in cold rooms and warm rooms, since these contain recirculated atmospheres.

CHOICE OF CHEMICALS:

Strive to substitute less hazardous chemicals whenever practical. Limit inventory on hand to chemicals and quantities necessary for laboratory activities. Inspect chemical inventories periodically and dispose of out-dated chemicals in accordance with chemical disposal controls.

EATING, SMOKING, ETC:

Do not eat, drink, use tobacco products (smoke, chew, dip), chew gum, or apply cosmetics in areas where laboratory chemicals are present; wash hands before conducting these activities.

Do not store food or beverages in refrigerators or glassware that have been used for laboratory operations.

EQUIPMENT AND GLASSWARE:

Handle and store laboratory glassware with care to avoid damage; do not use damaged glassware. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Use equipment only for its designed purpose. Dispose of damaged/unwanted glassware in accordance with associated hazards; sharps and chemical.

EXITING:

Wash areas of exposed skin well before leaving the laboratory.

HORSEPLAY:

Avoid practical jokes or other behavior, which might confuse, startle or distract another worker.

MOUTH SUCTION:

Do not use mouth suction for pipetting or starting a siphon.

PERSONAL APPAREL:

Confine long hair and loose clothing. Wear close-toed shoes and long pants at all times in the laboratory. Do not wear sandals, perforated shoes, or cloth sneakers.

PERSONAL HOUSEKEEPING:

Keep the work area clean and uncluttered, with chemicals and equipment being properly labeled and stored; clean up the work area on completion of an operation or at the end of each day.

PERSONAL PROTECTION:

Assure that all persons, including visitors, where chemicals are stored or handled, wear appropriate eye protection. Minimum eye protection is safety glasses with side shields, other forms may include goggles, face shields, etc., used as necessary based on potential hazard. Wear appropriate gloves when the potential for contact with toxic materials exists; inspect the gloves before each use, wash them before removal, and replace them periodically. (See Appendix 6 of the Chemical Hygiene Plan for more information on proper glove selection.) Wear laboratory coats when working in the laboratory.

Use appropriate respiratory equipment when engineering controls do not sufficiently control air contaminant concentrations. Inspect the respirator before and after use. You must contact FGCU EH&S before using any respirator in order to receive mandatory training.

Use any other protective and emergency apparel and equipment as appropriate. Avoid use of contact lenses in the laboratory unless necessary. Remove laboratory coats immediately upon significant contamination and decontaminate or dispose of properly.

PLANNING:

Seek information and advice about hazards. Review all applicable MSDSs before handling chemicals. Plan appropriate protective procedures. positioning of equipment, and emergency procedures before beginning any new operation. Locate emergency supplies near exits. Ensure that aisles are clear and kept clear during laboratory operations.

UNATTENDED OPERATIONS:

Leave lights on, place an appropriate sign on the door, and provide for containment of toxic substances in the event of failure of a utility service (such as cooling water) to an unattended operation. Provide all unattended operations with automatic shutdown controls to prevent accidents, fires, or explosions.

USE OF HOOD:

Use the hood for operations that may result in release of toxic chemical vapors or dust. As a rule of thumb, use a hood or other local ventilation device when working with any appreciably volatile substance with a Threshold Limit Value (TLV) of less than 50 ppm. Confirm adequate hood performance before use; keep hood closed at all times except when adjustments within the hood are being made; keep materials stored in hoods to a minimum and do not allow them to block vents or air flow. Leave the hood "on" when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is "off". Always have a contingency plan in the event of hood failure. Do not store chemicals or wastes in a fume hood. (See also section on Fume Hood Performance)

AWARENESS:

Be alert to unsafe conditions and see that they are corrected when detected. Supervise all visitors to the laboratory, and ask unescorted visitors to leave the area.

WORKING ALONE:

Avoid working alone in a building. Prior approval from the Principal Investigator is required before working alone in a laboratory. Working alone in a laboratory is prohibited when working with a compound of high or unknown toxicity.

WASTE DISPOSAL:

Standard Operating Procedures (See Appendix 1) for each laboratory must include procedures for waste disposal. Each laboratory generating hazardous waste must ensure that all waste generators within his/her lab receive annual Hazardous Waste Training.

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Control Measures to Reduce Employee Exposures

Safe work with hazardous chemicals can only be accomplished through the use of proper control measures. Proper control measures include the use of engineering controls, personal protective equipment, proper storage and handling of chemicals, and proper use and maintenance of safety equipment. Use of proper control measures reduces the risk of employee exposure to hazardous chemicals.

Engineering Controls:

Ventilation is the most common and most important form of engineering control used to reduce exposures to hazardous chemicals. There are two types of ventilation: general ventilation and local exhaust.

                                General Ventilation:

General ventilation for laboratory operations should be designed such that the laboratory is under a slightly negative pressure relative to other parts of the building. This prevents odors and vapors from leaving the lab. Lab ventilation should be 6 to 8 room air changes per hour, verified by professional engineering analysis at the time of installation. It should be noted that this rate will not necessarily prevent the accumulation of chemical vapors in "dead spots" or "eddies," which should be minimized during the design of the laboratory.

Local Exhaust:

Local exhaust ventilation, like that provided by a chemical fume hood, is the recommended method for reducing employee exposures to hazardous dusts, fumes and vapors. Also, with the hood sash closed or lowered to an appropriate working level, the hood can provide some protection from chemical splashes and fires. The maximum working level of the hood sash is identified by the EH&S sticker that contains the maximum working height, hood face velocity, date of inspection and the inspectors' initials. The fume hoods are certified annually. If there are problems with the hood EH&S should be notified. A hood is not designed to withstand explosions. When using a fume hood, always keep your work at least 6 inches inside the hood face. This simple step can reduce vapor concentrations at the face of the hood by as much as 90 percent. See standard operating procedures in the section titled "Fume Hood Performance" for more information on hood usage.

Other Ventilation:

Other means of ventilation include the use of biological safety cabinets, glove boxes, and isolation rooms. These are usually very specialized pieces of equipment, and must be certified for use annually by individuals with proper training and credentials to perform the inspection, i.e. the manufacturer or the distributor. The exhaust from these types of equipment passes through special filters or scrubbers before being exhausted to the atmosphere or recirculated to the area.

Personal Protective Equipment:

Standard laboratory attire must be worn when working with hazardous chemicals. Standard laboratory attire includes; lab coat, safety glasses/goggles, gloves, long pants, and closed-toed shoes, preferably leather shoes. Additional protective equipment such as face shields, blast shields, or respirators may be appropriate in some cases. Respirators may only be worn when engineering controls cannot keep exposure to chemicals below permissible exposure levels (PELs) set by OSHA. (See Appendix 3 of this CHP.) Employees may not wear a respirator until they have been cleared by a physician, attended FGCU Respiratory Protection Training, and been fit tested for the respirator they will be using.

Proper Storage and Handling of Chemicals:

Proper storage of chemicals is important to prevent chemical reactions that may result in fires, explosions or other safety/health hazards. Chemicals must not be stored in simple alphabetical order. Storage in this manner is unsafe as no regard for chemical incompatibility is considered. Chemicals must be stored according to chemical compatibility, that is, store chemicals of similar hazards and reactives together. Suggested chemical storage patterns and lists of chemical incompatibilities are included in Appendix 5 of this plan. Additionally, many chemical companies provide storage codes for their products in order to provide for safe storage. Some general rules for safe chemical storage follow:

• Store chemicals only in a secure area.
• Do not store chemicals in fume hoods.
• Shelving must be stable.
• Do not store chemicals on the floor.
• Do not store chemicals on top of shelving units.
• Keep an accurate inventory, update frequently.
• Keep inventory to a minimum.
• Dispose of outdated chemicals.
• Always keep chemicals properly labeled.
• Store large quantities of flammable chemicals in an approved flammable storage cabinet. The cabinet should be vented and exhausted properly to avoid the accumulation of potentially flammable vapors.

When handling chemicals always wear proper personal protective equipment as specified above and in the section titled "Personal Protective Equipment" of this plan. When transporting chemicals from one location to another, always use secondary containment to prevent spills.

Flammable Chemical Storage:

When the volume of flammable liquids stored in a laboratory exceeds 10 gallons of flammable or combustible liquids, those liquids must be stored in an approved flammable storage cabinet. Volumes below 10 gallons should be stored based on other compatibility considerations.

Ideally, flammable storage cabinets will be grounded to a true earth ground and ventilated from the bottom at about 20 cubic feet per minute (cfm). The cabinet should be vented directly to the building exterior.

As with other types of storage, store only compatible materials in the same cabinet. Do not overload the cabinet.

Not more than 60 gallons of flammable liquids, nor more than 120 gallons of combustible liquids may be stored in a flammable storage cabinet.

If flammable chemicals are to be stored in a refrigerator, the refrigerator must be approved for flammable storage, i.e. no lights, switches, thermostats inside and marked/labeled appropriately.

Corrosive Liquid Storage:

Corrosive liquid storage should be designed based on the compatibility of both construction materials and other chemicals. Containers should be unbreakable or double contained packaging. Cabinets should be designed to hold the contents in case of container breakage.

Toxic Chemical Storage:

Toxic chemicals should be stored in accordance with general chemical compatibility guidelines. In the case of some poisons, they should be stored in a dedicated locked cabinet.

Storage of Chemicals in Refrigerators:

All refrigerators located in laboratory areas must be clearly marked as to their contents. An inventory list should be posted on the outside of the refrigerator.

Refrigerators used for chemical storage must be marked "Chemical Storage Only! No Food!"

Refrigerators located in breakrooms or lunchrooms and which are located in the vicinity of laboratories should be marked "Food Storage Only! No Chemicals!"

Safety Equipment:

At a minimum, the following safety items must be readily available in all laboratories:

• Fire Extinguishers
• Eyewash/Safety Showers
• Spill Kits/Absorbents
• First Aid Kits
• Telephone with emergency numbers posted

Fire Extinguishers and eyewash/safety showers are inspected annually by EH&S personnel. However, all safety equipment should be checked at least once a month by personnel in the laboratory, operation and accessibility should be verified.

Report discharged, overcharged, or missing fire extinguishers immediately to the Physical Plant for replacement.

Report malfunctioning eyewash/safety showers and fume hoods are to the Physical Plant. If the unit is not repaired quickly, please call EH&S at (239) 590-1414. Restrict laboratory operations until safety equipment is repaired, no chemical work is to be performed in a malfunctioning fume hood.

Spill Kits and First Aid Kits are to be maintained by individual laboratories or departments. Spill Kits must be available for the specific hazards of the chemicals in use in the laboratory. For example; clay absorbent or activated carbon for flammable solvents, bicarbonate of soda for acids, and citric acid for bases. Amorphous silica spill absorbents may be used for all types of spills, except hydrofluoric acid spills. Neutralize hydrofluoric acid with sodium bicarbonate, or absorb it with clay absorbent. Solid materials may be placed directly into the appropriate container (based on volume of spill and chemical nature).

All materials collected during spill cleanup must be placed in an appropriate container and properly labeled. If the material is identified as waste it must be disposed of properly by calling EH&S.

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Fume Hood Performance

Yearly Certifications.

• Environmental Health & Safety certifies chemical fume hoods annually to ensure that they are functioning properly. Each hood will be marked with maximum sash height that provides adequate face velocity across the hood opening.
• Biological Safety Cabinets, gloveboxes, and other specialty ventilation devices must be certified by appropriately trained and competent external vendors. Consult the manufacturer or distributor for more information.

Inspections by Users

• Users must ensure that fume hoods are working before using them.
• All fume hoods should be equipped with either a low airflow alarm or a magnehelic gauge to detect hood malfunctions.
• Do not use a hood if the inspection label is missing or out-of-date (more than 1 year since last inspection). Contact EH&S at (239) 590-1414.

Contingency Plan for Hood Failures

• For a variety of reasons: electrical problems, service, mechanical problems, or maintenance; fume hoods may malfunction. To avoid interruptions in laboratory use, users must have a contingency plan for hood failure.
• If a fume hood malfunctions close the sash and report it to the FGCU Physical Plant. If a hazardous condition exists in a malfunctioning fume hood it must be contained and removed before calling the Physical Plant. Place a warning sign on the hood to prevent others from using it until it is repaired and re-certified by EH&S to ensure the unit is working properly.
• In the event of scheduled maintenance or service, where the power is to be disrupted, the Physical Plant shall notify the affected laboratories. Notification should include the work schedule and how long the hood will be inoperative.

Employee Information and Training

An essential component of the FGCU Chemical Hygiene Plan is providing information and training to all laboratory workers. This information and training will ensure that laboratory workers are aware of the hazards posed by chemicals in their work areas and how to protect themselves from these hazards.

Provision of information and training will occur at the time of initial assignment and prior to work involving new exposure situations. Refresher training will occur annually.

Employee Information

Laboratory workers will be informed of, and provided access to the following:

• Contents and appendices of the "Lab Standard" itself, OSHA 29 CFR 1910.1450.
• Contents and appendices of the FGCU CHP.
• Mandatory and recommended exposure limits for hazardous chemicals.
• The signs and symptoms associated with exposures to hazardous chemicals.
• The location and availability of safety reference materials, including MSDS's, for hazardous chemicals.

Employee Training

At a minimum, employee training will include:

• Methods used to detect the presence or release of hazardous chemicals.
• Physical and health hazards of chemicals in the work area.
• Protective measures used to reduce hazards or exposures.
• Applicable details of the FGCU CHP.

Information and Training Responsibilities

To satisfy the information and training requirements outlined above, laboratory workers must receive a combination of the following training:

• Hazard Communication/Right-to-Know training. ²
• General laboratory safety training.
• On the job training specific to the work area.

Note: Other training such as Hazardous Waste training may be required of certain laboratory personnel

Responsibilities of FGCU EH&S

• Provide Hazard Communication training.
• Provide general lab safety training.
• Review documentation and training records.
• Provide consultation on safety and environmental issues as requested.

Responsibilities of FGCU Departments

• Identify laboratory workers who require training.
• Ensure workers attend scheduled training sessions, including refresher training.
• Provide a location for the training sessions.
• Provide on-the-job, specific training (Principal Investigators, Lab Managers).

Activities Requiring Prior Approval

In order to protect the health and safety of laboratory employees, building occupants, and the community at large, certain laboratory activities will require prior approval from the designated approval point. See the General Laboratory Health and Safety Manual for details.

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Medical Consultation/Examinations

Whenever an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory, the employee shall be provided an opportunity to receive an appropriate medical examination.

Where monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance shall be established for the affected employee as prescribed by the particular standard.

Whenever an event takes place in the work area such as a spill, leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure, the affected employee shall be provided an opportunity for a medical consultation. Such consultation shall be for the purpose of determining the need for a medical examination.

All consultations/examinations will be conducted or supervised by a licensed physician. These consultations and/or examinations will be provided by the employer to the employee at no cost. The consultation or examination must be at a University approved medical facility.

In cases where laboratory employees seek medical attention for possible overexposure to hazardous chemicals, the Principal Investigator, supervisor, or Lab Manager must provide the following information to the attending physician:

• The identity of the hazardous chemical(s) to which the employee may have been exposed;
• A description of the conditions under which the exposure occurred including quantitative exposure data, if available; and
• A description of the signs and symptoms of exposure that the employee is experiencing, if any.

If at all possible, a copy of the Material Safety Data Sheet(s) for the chemical(s) involved should also be given to the physician.

Principal Investigators, supervisors, Lab Managers, or other responsible parties must notify FGCU EH&S of all cases of possible overexposure to hazardous chemicals. EH&S will then conduct an exposure assessment and collect all relevant information regarding the situation. All incidents of overexposure must be fully documented. See Appendix 8, Accident Reporting.

For any consultation/examination provided under this program, the person responsible for the employee must ensure that the attending physician provides a written opinion regarding the case to FGCU EH&S. The written opinion must include the following:

• Any recommendation for further medical follow-up;
• The results of the medical examination and any associated tests;
• Any medical condition which may be revealed in the course of the examination which may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace; and
• A statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination or treatment.

The written opinion must not reveal specific findings or diagnoses that are unrelated to the occupational exposure.

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Work with Particularly Hazardous Substances

Additional protective measures must be implemented in areas where OSHA "select carcinogens," reproductive toxins, and substances with a high degree of acute toxicity are used. Measures to be taken include: (See also, Appendix 4 of this CHP.)

• Establishing designated work areas
• Using containment devices such as fume hoods and glove boxes
• Following good industrial/chemical hygiene practices (i.e., no eating drinking or tobacco products, wash hands, use of proper PPE, etc.)
• Properly handling and storing waste
• Decontamination procedures

The following guidelines, taken from Appendix A of 29 CFR 1910.1450 (Appendix 2 of this CHP), should be adhered to when working with hazardous chemicals of a specific nature:

Working with Allergens and Embryotoxins

Allergens (examples: diazomethane, isocyanates, bichromates): Wear suitable PPE (gloves, lab coats, safety glasses, respirators, etc.) to prevent hand contact with allergens or substances of unknown allergenic activity.

Embryotoxins (examples: organomercurials, lead compounds, formamide): If you are a woman of childbearing age, handle these substances only in a glove box or hood with satisfactory performance. Use appropriate protective apparel (gloves, lab coats, etc.) to prevent skin contact.

Review the use of these materials with the research supervisor. Review procedures annually or whenever making a procedural change.

Store these substances in an unbreakable secondary container, properly labeled, and in a secure area (capable of being locked) and adequately ventilated area.

Notify supervisors of all incidents of exposure or spills. Consult a qualified physician when appropriate.

Work with Chemicals of Moderate Chronic or High Acute Toxicity

EXAMPLES: diisopropylflurophosphate, hydrofluoric acid, hydrogen cyanide.

Supplemental rules to be followed in addition to those mentioned above:

• Aim: To minimize exposure to these toxic substances by any route using all reasonable precautions.
• Applicability: These precautions are appropriate for substances with moderate chronic or high acute toxicity.
• Location: Use and store these substances only in areas of restricted access with special warning signs.
• Always use a hood (previously evaluated to confirm adequate performance) or other containment device for procedures that may result in the generation of aerosols or vapors. Trap released vapors to prevent their discharge with the hood exhaust.
• Personal protection: Avoid skin contact by use of gloves and long sleeves (and other protective apparel as identified in the MSDS or other safety document). Always wash hands and arms immediately after working with these materials.
• Records: Maintain records of the amounts of these materials on hand, amounts used, and the names of the workers involved.
• Prevention of spills and accidents: Be prepared for accidents and spills.
• Assure that at least 2 people are present at all time if a compound in use is highly toxic or of unknown toxicity.
• Store breakable containers of these substances in chemical resistant trays. Work (including instrumentation areas) and storage areas should be covered with removable, absorbent, plastic backed paper.
• If a major spill occurs outside the hood, evacuate the area. Cleanup personnel must wear suitable protective apparel and equipment. Contact EH&S at the earliest convenient time to report the spill, or to request outside clean-up assistance if necessary.
• Waste: Thoroughly decontaminate/dispose of containers, labware, and contaminated clothing or shoes in accordance with directions in the CHP.

Store contaminated waste in closed, properly labeled, impervious containers. Ensure that absorbent material is used to prevent breaking of containers and to absorb any leakage. All materials used must be compatible with the chemicals in the container.

Work with Chemicals of High Chronic Toxicity

Examples: dimethylmercury and nickel carbonyl, benzo-a-pyrene, N-nitrosodiethylamine, other human carcinogens or substances with high carcinogenic potency in animals.

Further supplemental rules to be followed, in addition to all those mentioned above, for work with substances of known high chronic toxicity (in quantities above a few milligrams to a few grams, depending on the substance as identified in a MSDS or other safety document).

• Access: Conduct all transfers and work with these substances in a "controlled area". A controlled area is a restricted access hood, glove box, or portion of a lab, designated for use of highly toxic substances. Make sure all people with access are aware of the substances being used and of the necessary precautions.
• Non-contamination/Decontamination: Protect vacuum pumps against contamination by scrubbers or HEPA filters and vent them into the hood. Decontaminate vacuum pumps or other contaminated equipment, including glassware, in the hood before removing them from the controlled area.
• Decontaminate the controlled area before normal work is resumed there based on guidance from a MSDS, EH&S, or other source of information.
• Exiting: On leaving a controlled area, remove any protective apparel (placing it in an appropriate, labeled container) and thoroughly wash hands, forearms, face, and neck.
• Housekeeping: Use a wet mop or a vacuum cleaner equipped with a HEPA filter. Avoid dry sweeping of powder if the substance was toxic.
• Medical surveillance: If using toxicologically significant quantities (as identified by MSDS or other source of safety information) of such a substance on a regular basis (e.g., 3 times per week), consult with FGCU EH&S at (239) 590-1414.
• Records: Keep accurate records of the amounts of these substances stored and used, the dates of use, names of users, and disposal records.
• Signs and labels: Assure that the controlled area is conspicuously marked with warning and restricted access signs. Keep all containers of these substances appropriately labeled with identity and warning labels.
• Spills: Assure that contingency plans, equipment, and materials to minimize exposures of people and property in case of accident are available.
• Storage: Store containers of these chemicals only in a ventilated, limited access area in appropriately labeled, unbreakable, chemically resistant, secondary containers.
• Glove boxes: For a negative pressure glove box, ventilation rate must be at least 2 volume changes/hour and pressure at least 0.5 inches of water. For a positive pressure glove box, thoroughly check for leaks before each use. In either case, trap the exit gases or filter them through a HEPA filter and then release them into the hood exhaust. HEPA filters must be evaluated by competent laboratory staff and renamed and disposed of in accordance with hazardous waste regulations. Contact EH&S for further information.
• Waste: Use chemical decontamination whenever possible; ensure that containers of contaminated waste (including washings from contaminated flasks) are transferred from the controlled area in a secondary container under the supervision of authorized personnel.

Appendix 1: Guidelines for Preparing Laboratory Specific Standard Operation Procedures

Laboratories must provide standard operating procedures (SOPs) for work involving the laboratory use of hazardous chemicals. See the definition of "Hazardous chemical" in the CHP section entitled, "Scope of Application." In most cases, more than one SOP will be required. An SOP must cover each hazardous chemical used in the laboratory.

There are three methods that can be used to write SOPs. They are:

• By process: (distillation, synthesis, chromatography, etc.).
• By individual hazardous chemical: (arsenic, benzene, hydrochloric acid, etc.).
• By hazardous chemical class: (flammable, corrosive, oxidizer, etc.).

These methods may be used alone or in combination. A sample form is provided in this appendix to assist in the preparation of SOPs. The form consists of nine sections and should contain the information listed below.

Section 1. Process, Hazardous Chemical, or Hazard Class - circle one.

• Process - Describe the process that involves hazardous chemicals. List all chemicals used in the process.
• Hazardous Chemical - Name the hazardous chemical for which the SOP is being developed. Include IUPAC (International Union of Pure and Applied Chemistry), common name, and any abbreviation(s) used for the chemical.
• Hazard Class - Describe the hazard associated with a particular group of similar chemicals and list the chemicals used in the laboratory.

Section 2. Describe Process, Hazardous Chemical, or Hazard Class.

Section 3. Potential Hazards - Describe the potential hazards for each process, hazardous chemical or hazard class. Include physical and health hazards.

Section 4. Personal Protective Equipment - Identify the required level of personal protective equipment and hygiene practices needed for each process, hazardous chemical or hazard class.

Personnel protective equipment includes: gloves, aprons, lab coats, safety glasses, goggles, face-shields, and respirators. (Note: Before using respirators, all employees must be entered into the University's Respiratory Protection Program. Call EH&S at 590-1414 for more information.)

Section 5. Engineering Controls - Describe engineering controls that will be used to prevent or reduce employee exposure to hazardous chemicals for the process, hazardous chemical or hazard class. This includes ventilation devices such as fume hoods, gloveboxes, etc.

Section 6. Special Handling & Storage Requirements - List storage requirements for the hazardous chemicals involved with the SOP, including specific storage areas, and policies regarding access to chemicals. Special procedures such as dating peroxide formers and testing them before distillation are appropriate here.

Section 7. Spill and Accident Procedures - Indicate how spills or accidental releases will be handled and by whom. List the location of appropriate emergency equipment (spill kits, showers, eye washes, and fire equipment). Any special requirements for personnel exposure should also be identified in this section. Identify the location of emergency response phone numbers.

Section 8. Decontamination Procedures - Specify decontamination procedures to be used for equipment, glassware, and clothing: include equipment such as glove boxes, hoods, lab benches, and controlled areas within the laboratory.

Section 9. Waste Disposal Procedures - Indicate how wastes will be disposed. Include the name of Hazardous Waste Accumulation Point Manager for the laboratory. See also, Handling and Storage of Hazardous Materials in, Appendix 2.

Section 10. Material Safety Data Sheet Location - Indicate the location of MSDSs for each hazardous chemical used. Also, indicate the location of other pertinent safety information, i.e. equipment manuals, chemical references, etc.

STANDARD OPERATING PROCEDURE

Date: _______________

Location: _______________ Principal Investigator: _____________________

Section 1: Process, Hazardous Chemical, or Hazard Class - circle one.

Section 2: Describe Process, Hazardous Chemical, or Hazard Class.

Section 3: Potential Hazards

Section 4: Personal Protective Equipment

Section 5: Engineering Controls

Section 6: Special Handling and Storage Requirements

Section 7: Spill and Accident Procedures

Section 8: Decontamination Procedures

Section 9: Waste Disposal Procedures

Section 10: Material Safety Data Sheet Locations

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Appendix 2: 29 CFR 1910.1450 Occupational Exposure to Hazardous Chemicals in Laboratories

Appendix 3: OSHA Permissible Exposure Limits (PEL's)

Appendix 4: Report on Carcinogens

Appendix 5: Chemical Storage Information

1. Segregate all incompatible chemicals for proper storage of chemicals for hazard class codes. In other words, store like chemicals together and away from other groups of chemicals that might cause reactions if mixed. Do not simply store chemicals in alphabetical order (see #3 below).
2. Flammable materials should be stored in an approved, dedicated, flammable materials storage cabinet or room if the volume exceeds ten (10) gallons.
3. Chemicals shall be stored separately from non-compatible hazard classes. A suggested storage pattern is included on this page.
4. Liquids should be stored in unbreakable or double-contained packaging, or the storage cabinet should have the capacity to hold the contents if the container breaks.
5. Avoid floor chemical storage (even temporary).
6. Chemicals should be stored no higher than eye level and never on the top shelf of a storage unit.
7. Shelf assemblies should be firmly secured to the walls. Avoid island shelves.
8. Each shelf should have an anti-roll lip.
9. Store acids in a dedicated acid cabinet. Nitric acid may be stored there also, if it is kept isolated from the others.
10. Store severe poisons in a dedicated poison cabinet.
11. All chemicals should be labeled and dated.
12. Look for unusual conditions in chemical storage areas, such as:

•  
  • improper storage of chemicals
  • leaking or deteriorating containers -spilled chemicals
  • temperature extremes (too hot or cold in storage area)
  • lack of or low lighting levels
  • blocked exits or aisles
  • doors blocked open, lack of security
  • trash accumulation
  • smoking or open lights or matches
  • fire equipment blocked, broken or missing
  • lack of information or warning signs ("No Smoking", "Flammable Liquids", "Acids", "Corrosives", "Poisons", Chemical Storage")

Any of these conditions should be corrected immediately. Inspections of chemical storage areas on a routine basis will help to correct deficiencies and prevent accidents

Suggested Chemical Storage Pattern

Suggested Storage Time Limits for Common Peroxidizable Compounds

Safety Hints

1. Do not purchase these compounds in quantities greater than can be used in the specified storage time period.
2. Ethers should be stored in the dark and under nitrogen if possible.
3. Always check for the presence of peroxides before distilling any peroxide former.
4. Consult safety references before working with peroxidizable compounds.

Short List of Incompatible Materials

Do Not Contact

NOTE: This list is not a complete list of incompatible materials. It contains some of the more common incompatible materials. Always research the materials you work with in order to be safe.

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Appendix 6: Glove Selection

The following Internet links are manufacturers that may supply gloves to laboratories on the FGCU campus. These links contain chemical compatibility charts for the gloves supplied by each specific manufacturer. It is recommended that users select the glove that will offer the best protection for the specific chemical that is being handled. Please note that similar gloves supplied by different companies may not offer the same level of protection, therefore it is important that the compatibility chart for the manufacturer of the glove being used be referenced.

Regardless of glove selection, it is imperative that the user be aware that many factors affect the breakthrough times of glove materials including, but not limited to:

• Thickness of glove material
• Concentration of the chemical worked with
• Amount of chemical the glove comes in contact with
• Length of time which the glove is exposed to the chemical
• Temperature at which the work is done
• Possibility of abrasion or puncture

Appendix 7: Laboratory Safety Checklist

Please see the Self-Assessment form. This checklist may be used to determine if your laboratory meets basic safety practices as outlined in the FGCU General Laboratory Health and Safety Manual.

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Appendix 8: Accident Reporting

Employees who identify a hazard in the workplace should inform their supervisor. Their supervisor then has the primary responsibility for investigating the hazard with input from his or her Dean, Director, Chair, and other staff. All employee injuries require the completion of a hazard investigation in addition to the report to Workers' Compensation. Damaged equipment or other workplace property may warrant a hazard investigation at the supervisor's discretion. Call Environmental Health & Safety at (239) 590-1414 if you have any questions about workplace hazard investigation.Procedures for reporting incidents and forms are at http://www.fgcu.edu/EHS/Files/Workplace_Hazard_Investigation_Report_Form.pdf.

Footnotes

¹ Adapted from the National Research Council's, "Prudent Practices in the Laboratory handling and disposal of chemicals", National Academy Press, Washington, DC, 1995.

² Hazard Communication/Right-to-Know training requires annual refresher training.

³ Research grant proposals will be used to receive notice of these activities. Review will take place when grant is awarded.

⁴ Animal Care and Use Committee reviews work when investigator applies. Laboratory Animal Resources reviews grant applications administratively prior to submission.

⁵ Prohibited activity: A laboratory worker may not work alone in a laboratory while working with substances of unknown or high toxicity.

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