Chemical Safety

NOTE: This is a major revision of the content and organization of this document. Please take some time to review the changes and additions.

Chapter 1: Introduction

1.1 Purpose

The purpose of this document is to educate research investigators about consensus standards of good laboratory practice, and to promote conformance with the OSHA Laboratory Standard (29 CFR 1910.1450).

The Chemical Safety Guide is intended to be part of a laboratory?s safety references, which would sensibly include such classic publications as the National Research Council?s Prudent Practices in the Laboratory and the American Chemical Society?s Safety in Academic Chemistry Laboratories. These and other resources together form the backbone for a laboratory?s local Chemical Hygiene Plan (CHP).

This document is to be used and supplemented, as needed, by each Principal Investigator (PI) or lab-related research at the University of Illinois, Urbana-Champaign. It is the responsibility of the PI to review the Chemical Safety Guide and to use it in the development of a complete CHP specific to their laboratories. Each PI is responsible for the implementation and documentation of his or her own Chemical Hygiene Plan and for providing safety information and training to their employees.

Colleges, department, other units, and individual laboratories are free to establish the guidelines found within this document as required policies for their units or laboratories.

1.2 Laboratory Safety Manual

Each Principal Investigator (PI) shall develop and maintain a Laboratory Safety Manual for their laboratory. A lab safety manual (1) contains safety information relevant to the laboratory's specific hazards and research materials, (2) serves as a training tool for lab personnel and should include documentation of such training, and (3) must be readily available to all research personnel in the lab.

A lab safety manual shall include:

• Lab safety policies and Standard Operating Procedures (SOPs)
• Lab safety program key personnel
• Lab contact information
• Lab security procedures
• Hazard assessment information and Personal Protective Equipment (PPE) selection
• Lab emergency procedures
  • Spill response
  • Medical response
  • Lab- and building-specific evacuation information
• Descriptions of lab incidents, injuries, and corrective actions
• Safety training records for lab personnel
• Safety program correspondence

The lab safety manual shall also include a Biosafety Manual for biological materials, a Chemical Hygiene Plan (CHP) for chemicals, a Radiation Permit for radioactive materials, and a Laser Safety Plan for Class 3b and 4 lasers. For more information please contact the Division of Research Safety (333-2755 or via e-mail) or visit our website: .

1.3 Chemical Hygiene Plans

Each Principal Investigator (PI) is responsible to develop and maintain the Chemical Hygiene Plan (CHP) for his or her laboratory. In broad terms, a CHP is a detailed strategy for controlling hazards in a given location. A laboratory?s CHP shall (1) identify all the hazards present at that location, and (2) describe specific measures for effectively controlling those hazards. Furthermore, a laboratory?s CHP shall be considered as a combination of two broad sections:

• General Safety Information
  The Chemical Safety Guide is intended as general-level information, a starting point in assembling a laboratory-specific CHP.
• Laboratory-Specific Safety Information
  This includes written documents or records such as Standard Operating

Procedures (SOPs), laboratory safety policies, or completed inventory reports. Details concerning the Unit, Personnel, Facility, Equipment, Procedures and Chemicals shall be included in such information. For assistance in compiling lab-specific safety information, CHP Forms are available at http://www.drs.illinois.edu/css/.

It is the responsibility of the PI to review the Chemical Safety Guide and to use it in the development of a complete plan specific to each laboratory.

1.3.1 Regulatory Introduction

In January 1991, the Occupational Safety and Health Administration (OSHA) promulgated a final rule for occupational exposure to hazardous chemicals in laboratories (29 CFR 1910.1450, also known as the OSHA Lab Standard, available at http://www.osha.gov/). Included in the standard is the requirement that all employees covered by the standard must carry out the provisions of a Chemical Hygiene Plan (CHP).

1.3.1.1 Requirements for CHPs

As defined in the OSHA Lab Standard, a CHP is a written program which must:

• Be capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular laboratory
• Be capable of keeping exposures below Permissible Exposure Limits (PELs)
• Indicate specific measures that the employer will take to ensure laboratory employee protection
• Include the following elements:
  1. Designation of personnel responsible for implementation of the CHP.
  2. Standard Operating Procedures (SOP) relevant to safety and health to be followed whenever laboratory work includes the use of hazardous chemicals and other agents.
  3. Provisions for employee information and training to be provided before the assignments to work areas where hazardous chemicals are present and prior to assignments involving new exposure situations. Information to be provided includes:
     • Contents of Standard 29 CFR 1910.1450
     • Location of Principal Investigator's (PI's) CHP
     • Inventory of laboratory chemicals
     • Methods and means to evaluate potential hazards, including discussion of permissible exposure limits
  4. Employee training including, as a minimum:
     • Physical and health hazards associated with the hazardous chemicals in the work area
     • Measures employees can take to protect themselves from these hazards
     • Methods and observations to help detect the presence or release of hazardous chemicals
     • Signs and symptoms associated with overexposures to hazardous materials used in the laboratory
     The frequency for refresher training for employees trained under the OSHA Laboratory Standard is left to the discretion of the employer. At the University the frequency of refresher training is determined by principal investigators. DRS recommends that refresher training be performed annually.
  5. Determination and implementation of control measures to reduce employee exposures to hazardous chemicals by using:
     • Engineering controls
     • Personal protective equipment (PPE)
     • Safe work practices and personal hygiene
  6. Requirements that fume hoods and other protective equipment are functioning properly and for maintaining adequate performance of such equipment.
  7. Availability of Material Safety Data Sheets (MSDS) and other sources of information, to describe potential hazards and safety precautions for specific chemicals.
  8. Provisions, as may be needed, for additional employee protection for work involving particularly hazardous substances and conditions, including situations which may require special approval from the PI prior to implementation.

1.3.1.2 Responsibility to Develop and Maintain a CHP

The Principal Investigator (PI) is responsible to develop and maintain the Chemical Hygiene Plan (CHP) for his or her laboratory. According to the OSHA Lab Standard (29 CFR 1910.1450), a Chemical Hygiene Plan (CHP) applies to all employers engaged in the laboratory use of hazardous chemicals.

• The University of Illinois is the employer of all laboratory personnel at the University of Illinois at Urbana-Champaign. On this campus, Principal Investigators are University personnel with local authority and responsibility to comply with applicable regulatory requirements and promote health and safety in their areas of influence. Thus "employer" is understood by University of Illinois at Urbana-Champaign to denote a Principal Investigator (PI) in a University of Illinois at Urbana-Champaign research laboratory.
• A "laboratory" is defined as a facility where the laboratory use of hazardous chemicals occurs.
• A "hazardous chemical" is defined as a chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. Such chemicals include carcinogens, toxic agents, irritants, and agents which damage the lungs, skin, eyes or mucous membranes.
• "Laboratory use of hazardous chemicals" is defined as handling or use of such chemicals in which all of the following conditions are met:
  1. Chemical manipulations are carried out on a "laboratory scale", or work with substances in which the containers used are designed to be easily and safely manipulated by one person;
  2. Multiple chemical procedures or chemicals are used;
  3. The procedures involved are not part of a production process, nor in any way simulate a production process;
  4. "Protective laboratory practices and equipment" is available and in common use to minimize the potential for employee exposure to hazardous chemicals.

1.3.2 Reasons to Have and Use a CHP

• Quality Assurance
  A Chemical Hygiene Plan is essentially a quality assurance document and represents consensus standards from the "research" industry. The lab standard is based on good lab practices which have been established by funding agencies.
• Comprehensive Curriculum
  Practicing and teaching safety is a vital part of any laboratory curriculum. In a school of diverse backgrounds, it cannot be assumed that safe practices will always be known or automatically be followed.
• Legal Requirement
  A Chemical Hygiene Plan is required by Federal law (29 CFR 1910.1450) and by State law (IDOL) in any laboratory where employees use hazardous chemicals.
• Potential Grant Requirement
  It is anticipated that in the future, governmental agencies, such as the NIH, may require proof of compliance with Federal statutes before making grants.
• Continuing Grant Funding
  Being officially cited as not in compliance with Federal or State statutes may also make it more difficult to obtain funding for research.
• Improved Safety
  Development and implementation of a CHP will result in greater safety in our laboratories.

1.3.3 Five Steps to a Lab-Specific CHP

Getting started can be difficult, but it does not need to be. Do the following, and you will be well on your way to an effective CHP for your laboratory.

1. Review the Chemical Safety Guide.
2. Complete the contact information and emergency procedures (Sections 1 through 3) in the CHP Forms.
3. Inventory all chemicals (see Section 4 of the CHP Forms) in the rooms indicated. Approximate quantity should be adequate for most chemicals. Exceptions include DEA Controlled Substances (see also http://www.drs.illinois.edu/css/guidesplans/dea), highly toxic chemicals, and extraordinarily expensive or valuable materials.
4. Evaluate the chemical inventory (see Section 5 of the CHP Forms). Consider particularly hazardous chemicals (carcinogens, reproductive toxins, acute toxins). Consider the hazards present as a result of the chemicals present in their respective quantities. What controls should be in place to appropriately address all hazards? Which hazards are your top priority?
5. Compose safety information to supplement the Chemical Safety Guide in order to sufficiently communicate how you address the hazards present in your laboratory space. These written materials may be as simple as posted reminders or tip sheets for a process, or as complicated as formal SOPs or step-wise work instructions with safety instructions included. See Section 6 of the CHP Forms for more guidance.

1.4 Safety Responsibilities

Everyone working at the University of Illinois has the right to a safe work environment and has the responsibility to help assure safety for themselves and others. Everyone has an important role in safety. The following illustrates areas of responsibility for safety at the University of Illinois. These responsibilities are also found in the Campus Administrative Manual (available on the web at http://www.fs.illinois.edu/cam).

Periodically inspectors from regulatory agencies (such as the IEPA and IDOL) visit campus for regulatory compliance inspections. When this happens, it is possible that they may visit your work place and speak with you. If this occurs, please call DRS immediately at 333-2755. DRS will provide assistance in addressing the concerns of the inspector.

1.4.1 Deans, Directors and Heads of Academic and Administrative Units

Deans, Directors and Heads of Academic and Administrative Units have a primary responsibility in providing for the health and safety of their faculty, staff, students, and visitors, and ensuring that work activities do not violate environmental standards. Unit head responsibilities include:

• Establishing environmental, safety, and regulatory compliance as a unit priority. (In some instances departmental or college safety committees may be helpful. Experience has indicated that such committees can provide an effective means of implementing safety programs.)
• Striving to provide adequate resources to meet safety and regulatory needs.
• Implementing programs to assure compliance with applicable environmental, health, and safety rules, regulations and standards.
• Ensuring that General Laboratory Safety training is completed by all incoming faculty, staff and students who will work in laboratory space, belonging to the unit, where biological, chemical or radiological materials are used. (This training is available online at http://www.drs.illinois.edu/training/.)

1.4.2 Principal Investigators (PIs)

Principal Investigators (PIs) have specific responsibilities toward providing a work environment free from environmental, health and safety hazards for those supervised. PI responsibilities include:

• Providing information about relevant environmental, health, and safety rules, regulations, standards, or practices.
• Assuring that required safety-related equipment and personal protective devices are provided, maintained, and used.
• Taking prompt action when unsafe acts or hazardous conditions are reported or noted.
• Providing or arranging for environmental, health, and safety training and education as needed.
• Promptly investigating and reporting all on-the-job accidents and/or job-related health problems and requesting medical treatment, if needed.
• Promptly reporting any spills or releases to the environment or any observed illicit environmental actions.
• Taking prompt action to prevent and clean up spills to the environment. Encouraging and training employees to use recommended best management practices to prevent and reduce pollution on campus.
• Requesting the assistance of the next higher level of supervision regarding budget requests for environmental, health, and safety improvements.

1.4.3 Laboratory Personnel

Laboratory Personnel as employees or students, are responsible for complying with existing environmental, health and safety rules, regulations and standards. Employee responsibilities include:

• Following all applicable environmental, health, and safety regulations, standards, campus plans, or policies.
• Wearing or using required safety-related equipment and personal protective devices.
• Refraining from operating any mechanical equipment that has the potential to harm personnel or the environment without proper instruction, training or authorization to safely use the equipment.
• Reporting unsafe acts or hazardous conditions to the supervisor.
• Attending prescribed environmental, health, and safety training and education.
• Reporting all on-the-job accidents and/or job-related health problems to the supervisor and requesting medical treatment, if needed.
• Reporting any spills or releases to the environment or any observed illicit environmental actions.
• Using recommended best management practices to prevent and reduce pollution to the environment.

1.4.4 The Division of Research Safety (DRS)

1.4.4 The Division of Research Safety (DRS) is committed to assisting campus units to identify and manage biological, chemical and radiological hazards. DRS responsibilities include:

• Providing advice and technical assistance in using these materials safely.
• Facilitating the campus community?s understanding of and compliance with required regulations.
• Developing, implementing, and overseeing comprehensive safety programs and policies, in partnership with campus safety oversight committees. Unit heads and supervisors remain responsible for promoting safety and ensuring regulatory compliance in their research area. Such programs are designed to:
  • Ensure the health and safety of faculty, staff, students, and visitors.
  • Protect the environment.
  • Facilitate compliance with regulatory requirements.

1.4.4.1 Overview of the DRS Chemical Safety Section

As part of DRS, the mission of the Chemical Safety Section (CSS) is to work with the campus community to develop and implement an efficient, convenient, comprehensive, and forward-looking chemical safety program. Priorities are as follows:

• Develop chemical safety programs that protect the health and well being of students, faculty, staff, and visitors at the University of Illinois.
• Develop programs to minimize chemical hazards and chemical wastes.
• Provide guidance for the safe handling, storage, and disposal of chemicals used on campus.
• Dispose of chemical wastes in an environmentally sound and cost-effective manner.
• Assist the campus community in complying with federal, state, and local regulations.

1.4.4.2 Chemical Hygiene Officer

The Director of DRS or a Division staff person designated by the Director is designated as the Chemical Hygiene Officer for the University of Illinois at Urbana-Champaign.

The Chemical Safety Committee will be advisory on matters relating to the safe handling, transport, use, and disposal of chemicals on the Urbana-Champaign campus. The committee will report to the Vice Chancellor for Research through DRS.

Academic units that have chemistry laboratories are encouraged to have their own chemical safety officers to help implement their chemical hygiene plans. Likewise, individual research groups or users of significant amounts of chemicals in non-laboratory settings are encouraged to designate chemical safety liaisons to facilitate the flow of safety information throughout the campus community.