Responsibilities

President, Provost and Senior Vice Provost for Research

• Promoting the importance of laboratory safety for all VCU laboratories.
• Promoting the attitude and culture of safety among university students and employees.
• Supporting safety programs that protect employees from chemical exposure.
• Ensuring that the deans, directors and department heads are provided adequate resources for ensuring safety in all laboratory activities.

Environmental Health and Safety: Laboratory Safety Office

• Partnering with and assisting the research community in enacting the components found in the CHP.
• Developing training modules that are delivered through SciShield.
• Providing technical guidance and assisting laboratory staff with risk assessments and risk mitigation strategies.
• Conducting official and unofficial lab safety assessments annually for each laboratory at the university.

Department

• Promoting a culture of safety for all laboratories within the department.
• Ensuring appropriate resources are delegated and available to all research laboratories.
• Ensuring that all laboratory safety assessment escalations brought to the attention of the department chair are addressed.
• Owning overall responsibility for laboratory safety within the department.

Laboratory Principal Investigator (PI)

• Overseeing the safety of all laboratory staff and to promoting a positive safety culture by example and leadership. 
• Designating a Chemical Hygiene Officer (CHO) (qualified by training, knowledge or experience) to coordinate the requirements of the CHP. The CHO designation may be in addition to other employee titles held such as PI, lab manager, supervisor, etc.
• Making sure that all employees and students have access to pertinent safety information through their supervisory staff and via SciShield.
• Certifying the laboratory hazards through SciShield annually.
• Taking all required safety training annually. 

Building Managers/Departmental Administrators

• Acting as a liaison between the employing unit and SRM.
• Knowing the rules to assist the researchers in complying with safety requirements.
• Assisting the investigators in developing a safety plan for their laboratories.
• Developing building Emergency Action Plans (EAPs).

Chemical Hygiene Officer

• Promoting a culture of safety and accountability in the laboratory.
• Implementing CHP requirements.
• Compiling, updating and certifying the following in SciShield:
• Lab member list
• Chemical inventory along with required yearly reconciliation of the inventory
• Laboratory safety equipment (biosafety cabinets, fume hoods, etc.)
• Developing safety signage, labeling and standard operating procedures for all laboratory chemical hazards.
• Making sure that students and employees who work with hazardous materials are knowledgeable of the contents of the CHP and have reviewed both the VCU CHP and lab specific SOPs. 
• Reviewing safety data of all chemicals being used by personnel and determining how to store, use and dispose of each chemical in accordance with the CHP.
• Maintaining a current safety data sheet (SDS) for each chemical in use in the laboratory. SDSs can be stored electronically in Scishield.
• Confirming all required training is completed and that employees and students are proficient in safety practices and procedures.
• Reviewing SOPs annually and updating as needed.
• Documenting an annual laboratory review of the university CHP, lab specific SOPs and lab safety procedures.
• Partnering with EHS-SRM to assure proper CHP implementation and ongoing maintenance.

Laboratory Staff and Students

• Acting responsibly when using, handling or storing hazardous chemicals.
• Wearing appropriate personal protective equipment (PPE).
• Using prescribed engineering controls.
• Following administrative control practices as described in the CHP.
• Sharing and reporting safety concerns with the PI or CHO.
• Holding themselves and all lab staff accountable for safety in the laboratory.
• Take all required safety training.

VCU Laboratory Safety Committee

The  Laboratory Safety Committee (LSC) meets as needed to provide oversight and review highly hazardous work in laboratories (see the High Hazard Chemical Work in Laboratories section for more information).  All work that fits within the definition of high hazard, must be reviewed and approved by the LSC before purchasing, synthesizing, working with or storing chemicals that fall within the definition of high hazard work. This committee constitutes EHS-SRM members, and ad hoc consultants or faculty with knowledge of the hazards being reviewed.

Laboratory Safety Meetings

Regular safety meetings foster a culture of safety and community in the laboratory. Meetings should be scheduled as often as necessary to maintain safety awareness and safe work practices. Below is some guidelines for effective safety meetings:

• Maintain a routine with the meetings. Each laboratory is different. Schedule the meetings often so laboratory employees are kept up-to-date. Some labs may need to meet daily or weekly; others may only need to schedule monthly or quarterly meetings. 
• Start and end on time. Respect everyone’s time by setting aside a regular allotment of time on the same day of the week for the meetings.
• Have an agenda so the meeting runs smoothly. Keep attendees focused on the agenda topics but include “other concerns” as a standard agenda item.
• Keep minutes. The CHO or a designee should record the minutes for every meeting and share them with attendees. 
• End the meeting with a summary. This is a good way to cover regular lab business.
• Get feedback on whether the format is working. Ask lab personnel if the meetings have been productive for them. Listen and act upon suggestions to make all procedures and meetings better.
• Make sure that meetings allow for open discussion with employee feedback.
• Ask for help. Contact EHS-SRM for assistance and guidance for safer lab practices or to facilitate training.
• EHS-SRM staff may present a safety topic as requested during the meetings. 

Safety meetings topics may include, but are not limited to:

• Recent incidents including near misses
• New experiments or chemicals and associated safety practices and PPE
• Staff concerns
• SOPs
• New compliance requirements
• Training

Laboratory Specific Hazard Assessment 

VCU laboratories are essential for learning and conducting research. However, the dynamic environment of laboratories also presents a variety of health and safety hazards. The Laboratory Hazard Assessment Form was designed to provide an effective method for analyzing laboratory hazards and defining and documenting appropriate control methods. Using this methodology assures risks are identified; proper protections are implemented to reduce or eliminate identified hazards; and aids the CHO  in the development of lab-specific SOPs. The completed form facilitates compliance with all required health and safety regulations and grant requirements including, but not limited to, Virginia Occupational Safety and Health, National Fire Protection Association (NFPA), the Virginia Department of Transportation, and the EPA.

Hazard Assessment Procedure

• Hazard assessments must be completed regularly and prior to commencement of any new research protocol in the laboratory. To facilitate the process for PIs and/or designees, the assessment should be conducted using the Laboratory Hazard Assessment Form. Whenever conducting a laboratory hazard assessment, review necessary resources needed to accomplish the laboratory’s goals (e.g., PPE and engineering control requirements). Please contact EHS-SRM at srm@vcu.edu if you require assistance in completing the Laboratory Hazard Assessment Form.
• Once hazards are identified and the controls are chosen, complete the Laboratory Hazard Assessment Form to develop the SOPs for each protocol, including the safety components.
• Hazards can be categorized into the following:
• Prioritize and decide how administrative and engineering controls as well as PPE will be implemented to mitigate these hazards. Some examples include:

Hierarchy of Hazard Controls

When considering how to mitigate hazards, use the following hierarchy of controls. This hierarchy of controls delineates the most effective to the least effective mode of hazard mitigation and each level may be used in conjunction with other levels. 

Elimination

The best way to control a hazard is to eliminate it and remove the danger. This can be done by changing a work process in a way that will get rid of a hazard, such as purchasing equipment with updated safety devices that remove the hazard without compromising any laboratory work.

Substitution

The second best way to control a hazard is to exchange a more hazardous chemical for a less- or non-hazardous material. For example, use GelSafeTM as a replacement for ethidium bromide for nucleic acid staining.

Engineering Controls

If a hazard cannot be eliminated or a safer substitute cannot be found, use engineering controls to keep the hazard from reaching the worker. This could include methods such as using local exhaust ventilation that captures and carries away the contaminants before they enter the breathing zone of workers (i.e., use of fume hoods and biosafety cabinets). Please note that ductless fume hoods are not approved to be used as a replacement for ducted fume hoods and must be approved by EHS-SRM prior to use. For more information see the Ductless Fume Hoods section below.

Administrative Controls

In addition to engineering controls, or if engineering controls cannot be implemented correctly, administrative controls must be considered. Administrative controls involve provisions relating to organization and management, procedures, record keeping, assessment and reporting necessary to ensure safe operation of a facility. Administrative controls in a laboratory include: 

• Ensuring that all personnel have received mandatory training to conduct their work safely;
• Implementing and enforcing SOPs that include safe work practices;
• Reducing time that personnel might be exposed to a specific hazard;
• Restricting access to certain areas and chemicals with high hazards, except for personnel with appropriate training; and
• Enforcing good housekeeping at all times.

Personal Protective Equipment (PPE)

PPE can control hazards by placing protective equipment directly on workers' bodies. Employees must be trained how to wear each type of PPE properly. When conducting a hazard assessment, PPE must be carefully chosen to ensure that all potential routes of exposure are protected. A PPE assessment must be part of the comprehensive hazard assessment and the right PPE must be chosen for each specific task. For example, if gloves are required for work with certain chemicals, the right type of gloves must be used. PPE must be used while other more effective controls are implemented, or if there are no other more effective ways to control the hazard.

PPE is used to control hazards that cannot be eliminated through engineering and administrative controls. PPE includes all clothing and accessories designed to protect against safety and health hazards. Before selecting PPE for your lab be sure to complete a risk assessment to determine the PPE required for work with a particular hazardous material.

PI or designee are responsible for:

• Enforcing PPE requirements in their laboratories.
• Completing a risk assessment to determine the appropriate PPE for their lab.
• Updating laboratory safety signage to indicate required PPE.
• Providing disposable PPE for visitors and VCU Facilities Management staff when necessary.
• Making sure that employees are properly fitted and trained to use their assigned PPE.
• Confirming employees know how to use, maintain and store their PPE in safe, sanitary conditions.
• Communicating and providing documented training on these topics to each employee required to use PPE. Training should include:
• The type of PPE selected
• When an employee must use PPE
• How to inspect, put on, adjust, wear and remove PPE according to manufacturer instructions
• Limitations of the PPE
• Proper care, maintenance, useful life and disposal of their PPE
• How to discard contaminated PPE

Employees are responsible for:

• Asking if PPE is needed to perform their assigned tasks.
• Demonstrating a full understanding of the use and limitations of PPE.
• Wearing only the PPE assigned for a specific job assignment or task.
• Telling their supervisor if the hazards of the task change.
• Inspecting the condition and fit of their PPE before each use.
• Avoiding altering or compromising the effectiveness of your PPE.
• Cleaning, maintaining and storing their assigned PPE in a ready-to-use and sanitary condition at all times.

Body Protection PPE

• Use protective clothing as a safeguard against hazardous material spills, splashes, intense heat, impact, cuts, infectious materials and radiation exposures. Protective clothing includes lab coats, smocks, scrub suits, gowns, rubber or coated aprons, coveralls, uniforms, and pierce-resistant jackets and vests.
• Minimum required PPE that must be worn at all times in a laboratory or technical area is full-length pants (or equivalent).
• Lab coats (or equivalent protective garments) must be worn by all employees working with hazardous materials as determined by a hazard assessment.
• Flame resistant lab coats are required when handling pyrophoric, air/water reactive materials, open flames, and highly flammable liquids.

Eye, Face and Neck Protection PPE

• Safety glasses should be worn for eye protection from flying particles, acids or caustic liquids, welding, light that could injure eyes (lasers, ultraviolet, infrared and radiation), and infectious body fluids. Adequate eye protection requires the use of hardened glass or plastic safety spectacles with side shields. Safety glasses used in the laboratory must comply with the Standard for Occupational and Educational Eye and Face Protection (Z87.1) established by the American National Standards Institute (ANSI). Use safety glasses for minor splash hazards, goggles for moderate hazards, and goggles combined with a face shield for severe hazards such as working with pressurized systems, large volumes of hazardous chemicals or any procedure that may cause splashing. .
• Side shields on safety glasses offer some protection from objects approaching from the side but do not provide adequate splash protection. Wear chemical splash goggles or full-face shields when significant liquid splash hazards exist.
• Goggles provide a tighter face seal than safety glasses and are not for general laboratory use. Wear them when there is a hazard from splashing chemicals or flying particles. For example, wear goggles when using glassware under reduced or elevated pressure or when using a glass apparatus in combustion or other high-temperature operations. Impact-protection goggles have perforated sides to provide ventilation and reduce lens fogging but do not offer full protection against chemical splashes. Use chemical goggles with splash-proof sides for protection from harmful chemical splash. There are also specific goggles and masks for glassblowing and intense light sources such as welding or lasers.
• Goggles or safety glasses alone do not meet ANSI standards for face and neck protection. For greater protection from flying particles and harmful liquids, wear a face shield to protect the face and throat — critical if your work puts you at risk of hazardous material splashes or flying debris from possible explosions. For full protection, wear a pair of safety glasses or goggles (depending on the hazard) in combination with a face shield. Consider using a face shield or mask when operating a vacuum system that may implode or conducting a reaction with explosive potential. Always use a UV-blocking face shield when working with transilluminators or other devices that produce ultraviolet radiation.

Laboratory Foot Protection PPE

Closed toe/heel shoes to protect feet from chemical spills and sharp objects must be worn at all times in a laboratory or technical area.

Hand Protection PPE

• Wear proper protective gloves for potential contact with corrosive or toxic materials, materials of unknown toxicity, sharp-edged objects, and very hot or cold materials.
• Select gloves based on the material handled, the particular hazard involved, and their suitability for the operation conducted. Not every glove is good for every application.
• Perform a risk assessment before making your selection. 
• Common glove materials include neoprene, polyvinyl chloride, nitrile, butyl and natural rubbers (latex). These materials differ in their resistance to various substances.
• Chemicals eventually permeate all glove materials. However, gloves are safe for limited periods if one knows the specific use and glove characteristics, such as thickness and permeation rate and time. 
• Use disposable surgical-type gloves for incidental contact. 
• Consider double gloving (wearing two gloves on each hand) when handling highly toxic or carcinogenic materials. 
• Use heavy-duty gloves for non-incidental contact and gross contamination. 
• Wear sturdier gloves such as leather for handling broken glassware, inserting glass tubes into rubber stoppers, and similar operations where you do not need protection from chemicals. 
• Use insulated gloves when working at temperature extremes. 
• Do not wear woven gloves while working with cryogens as the liquid may work its way through the glove to your hand. 
• Use gloves specifically designed for work with cryogens. 
• Gloves worn for working with elevated temperatures may not be appropriate for working with extremely low-temperature liquids. 
• For work with liquid pyrophoric chemicals outside of a glove box, appropriate hand protection must include chemically resistant outer gloves (Ansell 25-201 NeoTouch® neoprene gloves) on top of an approved flame resistant (FR) inner glove or glove liner (Ansell 70-200 Kevlar Liner gloves).
• If flame-resistant gloves compromise dexterity due to the nature of the work, contact the Lab Safety Office (804) 828-1392 for guidance. 
• Never reuse disposable gloves.

Hearing Protection PPE

• A variety of hearing protectors, including earplugs and earmuffs, are available for employees whose workplace reaches critical noise levels. 
• Situations, where employees are routinely exposed to elevated noise levels, must be evaluated by VCU Industrial Hygiene.

Other Criteria for Selecting Laboratory Clothing PPE

• Wear liquid-resistant fabric or coatings when spills or splashes are anticipated.
• Non-disposable garments must be capable of withstanding sterilization in case they become contaminated.
• Consider closure types and location for ease of use.
• Consider antistatic properties.

Respiratory Protection PPE

• All respirator use, including powered air purifying respirators and filtering face-piece respirators (i.e., dusk masks or disposables such as N95s) require approval by SRM before use by faculty, staff and students. 
• Respiratory protection should only be used when effective engineering controls such as a fume hood or a bio-safety cabinet are not available to minimize inhalation exposure to chemical gasses, vapors or particulates. 
• Anyone who may be at risk of exposure can contact the VCU Respiratory Protection Program Administrator to be evaluated and included in the program.

Prevent the Spread of Contaminants 

• Remove all PPE before leaving the workplace.
• Never wear lab coats, gloves, coveralls or other potentially contaminated PPE to public locations such as cafeterias, restrooms, elevators, offices or other off-site areas.
• Clean and store PPE as described in training and according to manufacturer's instructions.
• Always wash your hands after removing PPE and before leaving the work area.
• Do not reuse disposable gloves.
• Have lab coats and coveralls laundered regularly by a designated vendor.
• Do not take contaminated clothing home or to any other undesignated site for laundering.

Personal Protective Equipment (PPE)

PPE can control hazards by placing protective equipment directly on workers' bodies. Employees must be trained how to wear each type of PPE properly. When conducting a hazard assessment, PPE must be carefully chosen to ensure that all potential routes of exposure are protected. A PPE assessment must be part of the comprehensive hazard assessment and the right PPE must be chosen for each specific task. For example, if gloves are required for work with certain chemicals, the right type of gloves must be used. PPE must be used while other more effective controls are implemented, or if there are no other more effective ways to control the hazard.

PPE is used to control hazards that cannot be eliminated through engineering and administrative controls. PPE includes all clothing and accessories designed to protect against safety and health hazards. Before selecting PPE for your lab be sure to complete a risk assessment to determine the PPE required for work with a particular hazardous material.

PI or designee are responsible for:

• Enforcing PPE requirements in their laboratories.
• Completing a risk assessment to determine the appropriate PPE for their lab.
• Updating laboratory safety signage to indicate required PPE.
• Providing disposable PPE for visitors and VCU Facilities Management staff when necessary.
• Making sure that employees are properly fitted and trained to use their assigned PPE.
• Confirming employees know how to use, maintain and store their PPE in safe, sanitary conditions.
• Communicating and providing documented training on these topics to each employee required to use PPE. Training should include:
• The type of PPE selected
• When an employee must use PPE
• How to inspect, put on, adjust, wear and remove PPE according to manufacturer instructions
• Limitations of the PPE
• Proper care, maintenance, useful life and disposal of their PPE
• How to discard contaminated PPE

Employees are responsible for:

• Asking if PPE is needed to perform their assigned tasks.
• Demonstrating a full understanding of the use and limitations of PPE.
• Wearing only the PPE assigned for a specific job assignment or task.
• Telling their supervisor if the hazards of the task change.
• Inspecting the condition and fit of their PPE before each use.
• Avoiding altering or compromising the effectiveness of your PPE.
• Cleaning, maintaining and storing their assigned PPE in a ready-to-use and sanitary condition at all times.

PPE Selection and Body Protection

• Use protective clothing as a safeguard against hazardous material spills, splashes, intense heat, impact, cuts, infectious materials and radiation exposures. Protective clothing includes lab coats, smocks, scrub suits, gowns, rubber or coated aprons, coveralls, uniforms, and pierce-resistant jackets and vests.
• Minimum required PPE that must be worn at all times in a laboratory or technical area is full-length pants (or equivalent).
• Lab coats (or equivalent protective garments) must be worn by all employees working with hazardous materials as determined by a hazard assessment.
• Flame resistant lab coats are required when handling pyrophoric, air/water reactive materials, open flames, and highly flammable liquids.

PPE Selection for Eye Face and Neck Protection

• Safety glasses should be worn for eye protection from flying particles, acids or caustic liquids, welding, light that could injure eyes (lasers, ultraviolet, infrared and radiation), and infectious body fluids. Adequate eye protection requires the use of hardened glass or plastic safety spectacles with side shields. Safety glasses used in the laboratory must comply with the Standard for Occupational and Educational Eye and Face Protection (Z87.1) established by the American National Standards Institute (ANSI). Use safety glasses for minor splash hazards, goggles for moderate hazards, and goggles combined with a face shield for severe hazards such as working with pressurized systems, large volumes of hazardous chemicals or any procedure that may cause splashing. .
• Side shields on safety glasses offer some protection from objects approaching from the side but do not provide adequate splash protection. Wear chemical splash goggles or full-face shields when significant liquid splash hazards exist.
• Goggles provide a tighter face seal than safety glasses and are not for general laboratory use. Wear them when there is a hazard from splashing chemicals or flying particles. For example, wear goggles when using glassware under reduced or elevated pressure or when using a glass apparatus in combustion or other high-temperature operations. Impact-protection goggles have perforated sides to provide ventilation and reduce lens fogging but do not offer full protection against chemical splashes. Use chemical goggles with splash-proof sides for protection from harmful chemical splash. There are also specific goggles and masks for glassblowing and intense light sources such as welding or lasers.
• Goggles or safety glasses alone do not meet ANSI standards for face and neck protection. For greater protection from flying particles and harmful liquids, wear a face shield to protect the face and throat — critical if your work puts you at risk of hazardous material splashes or flying debris from possible explosions. For full protection, wear a pair of safety glasses or goggles (depending on the hazard) in combination with a face shield. Consider using a face shield or mask when operating a vacuum system that may implode or conducting a reaction with explosive potential. Always use a UV-blocking face shield when working with transilluminators or other devices that produce ultraviolet radiation.

PPE Selection for Laboratory Foot Protection

• Closed toe/heel shoes to protect feet from chemical spills and sharp objects must be worn at all times in a laboratory or technical area.

PPE Selection | Hand Protection

• Wear proper protective gloves for potential contact with corrosive or toxic materials, materials of unknown toxicity, sharp-edged objects, and very hot or cold materials.
• Select gloves based on the material handled, the particular hazard involved, and their suitability for the operation conducted. Not every glove is good for every application.
• Perform a risk assessment before making your selection. 
• Common glove materials include neoprene, polyvinyl chloride, nitrile, butyl and natural rubbers (latex). These materials differ in their resistance to various substances.
• Chemicals eventually permeate all glove materials. However, gloves are safe for limited periods if one knows the specific use and glove characteristics, such as thickness and permeation rate and time. 
• Use disposable surgical-type gloves for incidental contact. 
• Consider double gloving (wearing two gloves on each hand) when handling highly toxic or carcinogenic materials. 
• Use heavy-duty gloves for non-incidental contact and gross contamination. 
• Wear sturdier gloves such as leather for handling broken glassware, inserting glass tubes into rubber stoppers, and similar operations where you do not need protection from chemicals. 
• Use insulated gloves when working at temperature extremes. 
• Do not wear woven gloves while working with cryogens as the liquid may work its way through the glove to your hand. 
• Use gloves specifically designed for work with cryogens. 
• Gloves worn for working with elevated temperatures may not be appropriate for working with extremely low-temperature liquids. 
• For work with liquid pyrophoric chemicals outside of a glove box, appropriate hand protection must include chemically resistant outer gloves (Ansell 25-201 NeoTouch® neoprene gloves) on top of an approved flame resistant (FR) inner glove or glove liner (Ansell 70-200 Kevlar Liner gloves).
• If flame-resistant gloves compromise dexterity due to the nature of the work, contact the Lab Safety Office (804) 828-1392 for guidance. 
• Never reuse disposable gloves.

PPE Selection for Hearing Protection

• A variety of hearing protectors, including earplugs and earmuffs, are available for employees whose workplace reaches critical noise levels. 
• Situations, where employees are routinely exposed to elevated noise levels, must be evaluated by VCU Industrial Hygiene.

Other Criteria for Selecting Lab Clothing

• Wear liquid-resistant fabric or coatings when spills or splashes are anticipated.
• Non-disposable garments must be capable of withstanding sterilization in case they become contaminated.
• Consider closure types and location for ease of use.
• Consider antistatic properties.

PPE for Respiratory Protection

• All respirator use, including powered air purifying respirators and filtering face-piece respirators (i.e., dusk masks or disposables such as N95s) require approval by SRM before use by faculty, staff and students. 
• Respiratory protection should only be used when effective engineering controls such as a fume hood or a bio-safety cabinet are not available to minimize inhalation exposure to chemical gasses, vapors or particulates. 
• Anyone who may be at risk of exposure can contact the VCU Respiratory Protection Program Administrator to be evaluated and included in the program.

Prevent the Spread of Contaminants

• Remove all PPE before leaving the workplace.
• Never wear lab coats, gloves, coveralls or other potentially contaminated PPE to public locations such as cafeterias, restrooms, elevators, offices or other off-site areas.
• Clean and store PPE as described in training and according to manufacturer's instructions.
• Always wash your hands after removing PPE and before leaving the work area.
• Do not reuse disposable gloves.
• Have lab coats and coveralls laundered regularly by a designated vendor.
• Do not take contaminated clothing home or to any other undesignated site for laundering.

General Laboratory Safety Training

Anyone working in a laboratory at VCU is required to complete general laboratory safety training on SciShield which includes:

• Review of laboratory rules and regulations, including the VCU CHP
• Recognition of laboratory hazards
• Types of engineering controls and PPE
• Signs and symptoms associated with exposures to hazardous chemicals
• Chemical exposure monitoring
• Procedures for disposing of hazardous chemical waste
• Fire safety and emergency procedures

All employees and students working in VCU laboratories must take the following laboratory safety classes provided on Scishield:

• Fundamentals of Laboratory Safety that provides a general overview on laboratory safety for laboratory workers.
• Principal Investigators Responsibilities that is designed to give the PI the foundation needed to create a strong safety culture in the laboratory.
• Hazardous Waste Management in Laboratories that trains laboratory workers on specific requirements for establishing and maintaining a satellite accumulation area for hazardous (chemical) waste created in the laboratory as part of laboratory experimental procedures.

Laboratory Specific Training

PIs and laboratory supervisors must also provide training specific to their operations. Topics that require specific training include:

• Location and use of the Lab-Specific Chemical Hygiene Plan, SDS(s), BioRAFT and other regulatory information.
• Review of emergency management plan, including location of emergency equipment and exit routes
• Use of engineering controls, administrative controls and PPE to mitigate hazards
• Specialized equipment
• SOPs
• Review of reference materials (e.g., SDS) on hazards, handling, storage and disposal of hazardous chemicals
• Specialized procedures and protocols
• Particularly hazardous substances including physical and health hazards, potential exposure, medical surveillance and emergency procedures
• Many of these topics are covered in the Worker's Right to Know Statement. VCU requires each person working in a laboratory or technical area receives a one-time site specific orientation.
• Laboratory-directed training is required on a regular basis to promote a strong safety culture.

Documentation of Training

Accurate record-keeping is a critical component of health and safety training. EHS-SRM maintains records of all safety training that is provided through BioRAFT. Departments or laboratories are responsible for documenting all other health and safety training, including safety meetings, one-on-one training, and any third-party in-class or online training. Electronic copies of the training should be uploaded onto BioRAFT; however, if hard copies are maintained, documentation should be located in the laboratory safety manual. For lab-directed training include a sign-in sheet with details such as date, topics discussed and who leads the training. PIs and laboratory supervisors can review training histories for EHS-SRM taught training or online courses taken through BioRAFTby clicking the training tab. For questions, email vcubioraft@vcu.edu.

Resources

Safety Documents

• Biosafety Manual [PDF]
• Select AgentsSelect Agents [PDF]
• Hot Works Program Hot Works Program [PDF]

Fact Sheets

• Several SOPs for hazards often seen in laboratories
• Chemical Waste Management Program [PDF]

Laboratory Safety Training

In laboratory settings, PIs and CHOs must make sure that all employees and students who use hazardous chemicals complete the necessary training. Upon completion of all laboratory-specific training, documentation of the training must be retained for verification and review. Training should be site- and laboratory-specific based on findings from the initial hazard assessment. Annual refresher training and/or updates to training and/or the CHP should include new and/or different laboratory procedures as needed.

PIs and CHOs must convey information about specific chemical(s) to employees before they are assigned to complete tasks involving the material(s): 

• SDS sheets that include the location and method of filing (hard copy or electronic)
• If the department is using a specific labeling system, describe how it functions 
• Emergency Procedures and EAP requirements
• A list of hazardous chemicals and review of SDS sheets
• Symptoms of exposure and routes of transmission (e.g. inhalation hazards, skin absorption, etc.)
• Methods of protection: administrative controls, engineering controls, and the use and limitations of PPE
• Proper use, storage and disposal of hazardous materials

Additionally, each year, all laboratory employees must complete the Fundamentals of Laboratory Safety in SciShield. These training modules provide a general understanding of chemical safety in the laboratory but do not replace or substitute for laboratory-specific training. 

The SciShield Course Directory provides various online safety modules that are targeted at training laboratory staff on hazards they might encounter at VCU. 

Chemical Inventory

A current inventory of all potentially hazardous chemicals must be maintained for every chemical stored, used or produced within each laboratory. The laboratory chemical inventory should be updated annually, or more often if warranted. All VCU laboratories must maintain their chemical inventories using the SciShield inventory management system. Additionally, all laboratories must complete a chemical reconciliation of their chemical inventory at least annually. More information on how to complete the chemical reconciliation on SciShield can be found here (see the second video titled “Reconciliation for Group/Laboratory Members”).

 

Chemical Management

Chemical Management as per Hazard Assessment

Labeling Systems

The NFPA labeling system was developed in the 1950s. Each label is divided into sections (diamond or rectangle with bars), color-coded and numbered zero through four with specific meanings. See NFPA 704 for more information.

• All containers must be labeled. Original containers without an adequate identifying label may not be accepted from the supplier. Labels must, at a minimum, state the chemical name (as it appears on the SDS and chemical inventory), the manufacturer, importer, or supplier name and contact information, and the chemicals' hazard information. Existing labels on incoming containers must not be removed or defaced unless the container is immediately marked with the required information.
• Secondary or "transfer" containers must be labeled if the chemical will not be used within one work shift or if the container will not be constantly attended to and under the user’s immediate supervision. Always label secondary storage containers. This will eliminate confusion where there are more than one unlabeled containers in use, and will ensure that container content is known in the event of an emergency where outside personnel may be involved. Secondary container labeling must include the name of the substance and any hazard warnings, like the original container.
• Labels or other forms of warning must be legible, in English and prominently displayed on the container. If modifications are necessary, the labeling system should be communicated to (and understood by) all personnel in the work area. Containers may be labeled in languages other than English as long as English is also used. For example, if English and Spanish is used, labels would say both “Ethyl Alcohol” and “Alcohol Etilico” or; “Acetic Acid” and “Acido Acetic”.

General Chemical Storage Guidelines

Chemicals must be stored in a defined storage area (safety cabinet for flammables or in an approved room or on segregated shelves). Avoid storing chemicals on laboratory bench tops or in fume hoods. Certain highly toxic materials that must be stored in a fume hood or glove box (ee.g., HCl gas) are the exception. All chemicals must be stored according to their hazard classification. The PI or CHO should delineate storage areas within the laboratory that can be segregated according to hazard class. Store chemicals in the lab by:

• Safely spacing shelves and racks to accommodate the upright removal of the largest chemical container; prevent tipping and dripping with adequate clearance.
• Keeping hazardous materials away from heat and direct sunlight to prevent the degradation of chemicals and deterioration of storage containers and labels.
• Not storing hazardous materials (except cleaners) under sinks.
• Avoiding chemical stockpiling; procure hazardous chemicals as needed.
• Limiting storage of hazardous materials in fume hoods, which could compromise air flow.
• Conducting periodic cleanouts to minimize accumulation of old or unused chemicals.
• Not bringing food (including gum), beverages, tobacco and open cosmetics into the laboratory.
• Storing corrosives below the average range of eye-level.
• Keeping track of the location of each chemical in the chemical inventory list.

Chemical Hazard Classifications 

• Acids: Have a pH from one to seven. They are corrosive (“burn” skin); have a sour taste (e.g., lemons or vinegar); contain hydrogen ions (H+); when dissolved in water, they turn blue litmus paper to a red color. Examples include: hydrochloric, sulfuric and acetic acids.
• Bases: Have a pH from 7 to 14.They are corrosive ('burn' skin); have a soapy feel; turn and red litmus paper to a blue color. Examples include: sodium hydroxide, bleach and ammonium hydroxide.
• Carcinogens: A substance or agent that can cause cells to become cancerous by altering their genetic structure so that they multiply continuously and become malignant. Asbestos, DDT and tobacco smoke are examples of carcinogens.
• Corrosives: The U.S. Department of Transportation definition specifies liquids and solids that either destroy human skin within a certain time period or corrode steel or aluminum greater than ¼ inch per year. The EPA defines corrosives as either liquids that corrode steel greater than ¼ inch per year or aqueous wastes with a pH of 2.0 or less or 12.5 or greater.
• Oxidizers: Oxidizers react with other chemicals by giving off electrons and undergoing reduction. Uncontrolled reactions of oxidizers may result in a fire or an explosion, causing severe property damage or personal injury.
• Pyrophorics: Pyrophoric liquids, solids and gasses are materials that may ignite or react violently when exposed to air.  Many pyrophorics are also water reactive.  Examples include white phosphorus and metal hydrides, such as sodium hydride.
• Toxins: Include heavy metal compounds such as: arsenic, barium, cadmium, chromium, lead, mercury, silver, selenium, etc. Pesticides such as, Aldrin, arsenic pentoxide, arsenic trioxide, cacodylic acid, chlordane, copper cyanides, Dieldrin, dimethylcarbamoyl chloride, Endrin, Lindane, pentachlorophenol, strychnine, etc.

Flammable and Combustible Liquids 

• Store flammable and combustible liquids away from oxidizers and heat producers.
• House flammable and combustible liquids in excess of 25 gallons (per room) in approved flammable storage cabinets (under the hood or stand-alone); limit liquids in secondary containers (i.e., squeeze bottles) to ten gallons or less.
• Adhere to OSHA regulations for safe storage: 60 gallons of Class I and/or Class II liquids or 120 gallons of Class III liquids per cabinet. Class I liquids cannot be stored in a basement or pit without an approved ventilation system.
• Use only approved and well-labeled refrigerators and freezers for storing flammable liquids. Never store food or drink with chemicals or flammables.
• Dispensing of any flammable liquids from a container that is five-gallons or larger requires proper grounding and bonding. If grounding and bonding is not possible, flammable liquids must be purchased in smaller quantity containers and poured safely under a certified fume hood. (OSHA 29 CFR 1910.106(h)(7)(i)(b); NFPA 45 9.3.1, 9.3.3)

Globally Harmonized System (GHS) of Classification and Labeling of Chemicals

OSHA in its recent adoption of the United Nations’ GHS Classification and Labeling of Chemicals has modified its Hazard Communication Standard to include: 

• Revised criteria for classification of chemical hazards;
• Revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements;
• A specified format for SDSs (formerly Material Safety Data Sheets); and
• Related revisions to definitions of terms used in the Hazard Communication Standard.

Requirements for Employee Training on Labels and SDS

OSHA has been modifying provisions of other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards, to ensure consistency with the modified Hazard Communication Standard requirements.

More information on the hazard communication standard, including the link to the Federal Register notice, can be found on OSHA's hazard communication safety and health topics page at www.osha.gov/dsg/hazcom/index.html

Entrance Door Signage

The entrance door to each laboratory should be labeled with a safety sign. The sign should be updated whenever the contact information and/or the hazard levels of designations change. A single sign should be utilized for each room and/or laboratory area. The hazard information should reflect the conditions unique to that space. Visit the Laboratory Safety Signage page for more information. 

Chemical Acquisition

Ordering Chemicals

Departments or PIs can order chemicals. Before purchasing a chemical, the PI, CHO or laboratory staff should consider the following:

• The minimum quantity that is sufficient for current use. Bulk purchases are not necessarily cheaper. Compressed gas cylinders, including lecture bottles, should normally be purchased from suppliers who accept return of empty cylinders. Please note that the purchase of high hazard chemicals as defined by this plan, require Lab Safety Committee approval prior to purchasing or storing. For more information refer to the “High Hazard Chemical Work in Laboratories” section.
• Fire codes regulate quantities of flammable and combustible chemicals. For these materials, a maximum allowable quantity for laboratory storage should be established according to the capacity of the flammable cabinet.
• Make sure that the chemical can be managed safely once it is delivered to the department and does not present any unique risks.
• Consider whether the chemical is unstable. Inherently unstable materials may have very short storage times and should be purchased just before use to avoid losing a reagent and creating an unnecessary waste of material and time.
• Make sure the waste can be managed satisfactorily. Identify a method for proper waste disposal before the chemical is ordered.
• A purchase order for a chemical should include a request for a SDS if the chemical is new to the lab or the SDS has been updated by the manufacturer. Many chemical suppliers send a SDS only with the initial order of a chemical. Subsequent orders of the same chemical are not normally accompanied by a SDS.

 Receiving Chemicals

• Chemical deliveries should be limited to areas equipped to handle them, usually a loading dock, receiving room or the laboratory where the chemical will be used and/or stored. Carts designed to move various types of chemical containers, including gas cylinders, should be used to ensure safe relocation.
• Personnel receiving chemicals classified as dangerous goods by either the U.S. Department of Transportation or International Air Transport Association must be trained and certified to do so. SRM provides training and certification for personnel performing this task. Information for dangerous goods training can be found here. After registering for and taking the course, individuals must take and pass the dangerous goods test, which will be facilitated by the instructor of the course. Incoming packages should be promptly opened by trained/certified personnel and inspected to ensure containers are in good condition. Unpacked chemicals should be stored safely. Periodic inspections of storage areas also should be done so that leaks from damaged containers are contained as soon as possible.
• Transportation of chemicals within the department must be done safely. Single boxes of chemicals in their original packaging can be hand carried to their destination if they are not too heavy.
• Cylinders of compressed gasses should always be secured on specially designed carts and never be dragged or rolled. The cap or regulator should always be securely in place.
• When packages are opened in the laboratory, laboratory personnel should verify that the container is intact and is labeled, at a minimum, with an accurate name on a well-adhered label. Labels placed by the manufacturer should remain intact. New chemicals should be entered into the laboratory's inventory promptly and moved to the appropriate storage area.

Management of Peroxide Forming Chemicals (PFCs)

OSHA standard 29 CFR 1910.1450 (Hazardous Chemicals in the Laboratory) requires work practices conducive to a safe work environment with hazardous chemicals. Certain chemicals can become volatile when undergoing certain processes, such as distillation, while some chemicals may become unstable over time by exposure to environmental conditions such as air and light. Such chemicals may form explosive peroxide crystals that become a danger to people working in the laboratory. Improper management of peroxide forming chemicals can lead to expensive disposal costs, damage to property if they react or explode, and injury or death to people working in the laboratory.  

Peroxide-forming chemicals are usually categorized by how readily they form explosive compounds. A list of categories and chemicals that are routinely found in laboratories can be found here. Note that a common chemical, Isopropyl Alcohol (2-Propanol), has recently been added as a chemical of concern to manage as a peroxide-forming chemical (typically the distilled product can readily form explosive peroxides, but stored isopropyl alcohol should be evaluated based on container and storage conditions). Best practices for management of PFCs include:

• Review the SDS for each chemical before purchase and use it to make sure that the necessary safety protocols are in place and there is a proper space to appropriately store items.
• Only purchase the amount necessary for experiments, and be mindful of the recommended shelf life for the chemicals. Avoid purchasing in bulk quantities for lower costs, as the cost to properly dispose of unused chemicals will cost more long term.
• Always write the date received and date opened on the chemical container that is a possible peroxide former.
• Add any new containers to the laboratory chemical inventory on Chemtracker via BioRAFT/SciShield. Note that ChemTracker enables the ability to search for hazard types in the laboratory’s chemical inventory, including categories of “Unstable with age” that will include possible peroxide-forming chemicals. 
• Store peroxide formers in a dedicated, well-ventilated area away from incompatible materials. Keep containers tightly sealed when not in use. Avoid exposing peroxide formers to direct sunlight and extreme temperatures. Do not store peroxide formers for longer than the recommended shelf life.
• Regularly check for signs of peroxide formation, such as crystalline residues or pressure buildup. Contact EHS-SRM if any signs are observed on or inside containers.
• Wear appropriate PPE including safety goggles, lab coats and gloves when handling peroxide formers. Minimize exposure to air by working quickly and efficiently when handling these chemicals. Use only approved tools and equipment.
• All personnel working with peroxide formers must receive proper training in the safe handling and storage of these chemicals. The PI is responsible for creating and updating lab specific SOPs for all PFCs.
• Regularly test for the presence of peroxides in older or long-stored chemicals using appropriate testing methods. Keep a record of testing and results for each container kept in the inventory for more than the recommended storage time. Dispose of chemicals with peroxide concentrations above safe levels. Contact EHS-SRM for proper disposal and handling instructions. Do not handle any containers that appear to be cloudy or have visible peroxide formation on or inside the container. Dispose of peroxide formers that are no longer needed through a designated waste disposal service. 
• Maintain records of the purchase, storage, testing and disposal of peroxide formers. Note that during the annual laboratory safety assessment, EHS-SRM staff will review the chemical inventory, including peroxide-forming chemicals. If any containers of chemicals that fall into this category are found without dates written on the label, or the dates are unknown, the containers must be disposed of.

Chemicals Classified as Controlled Substances by the U.S. Drug Enforcement Administration (DEA)

These chemicals are subject to additional regulation and control measures. Any laboratory using or supplying chemicals appearing on DEA’s List I or List II Regulated Chemicals must comply with all federal and state regulations.

The VCU Office of Research and Innovation outlines the procedures and requirements for these chemical types in the Using Controlled Substances for Research policy and in the Use of Controlled Substances in Research Manual.

Development of SOPs

An SOP is a written document explaining how to safely work with all specific laboratory hazards.  SOPs are necessary to meet not only federal or state regulatory requirements but also provide readily available guidance to workers as they perform laboratory tasks as well as act as a training tool. SOPs are required elements of the CHP and are written using the completed hazard assessment form as a prompt to assure safe working practices designed to prevent injuries and illnesses.

Three commonly used methods for organizing the content of SOPs are:

• Process distillation, synthesis, chromatography, etc.
• Individual hazardous chemical (arsenic, benzene, hydrochloric acid, etc.) 
• Hazardous chemical class (flammable, corrosive, oxidizer, etc.)

Each SOP can be used for chemical, biological, mechanical or as “other” if an SOP cannot be classified under the other three categories. Create SOPs for all laboratory functions and include safety components for each step of an experiment to comply with all safety requirements (e.g. PPE requirements or the use of fume hoods and/or other engineering controls.) For example, Xylene can be used in many ways. Structure the SOP so that the procedures ensure the safe use of Xylene in every application at a specific laboratory.

Resources

• VCU SOP Library
• VCU SOP Template [Word]

SDSs

Chemical manufacturers and importers must evaluate their materials to determine if they are hazardous. If they are considered to be hazardous, a SDS must be prepared and sent to end users. These were formerly referred to as material safety data sheets. The end user must have access to the information and know the hazards prior to working with the substance. 

• Each department or work area must maintain a SDS for each hazardous chemical or material in use. This may be done on BioRAFT so long as all members have access. 
• The SDSs may be filed and maintained electronically and/or as hard copies as long as they are readily available to all personnel during the work shift. If SDSs will be stored electronically or on the Internet, a computer should be available to lab personnel at all times. 
• Information must be stored in a location that is accessible to all personnel who will be working with the hazardous chemical or material.
• SDSs must be readily available at all times to laboratory personnel, either electronically or as hard copies.

Emergency Responses and Spill Clean up

Development of Emergency Action Plan (EAP)

Each laboratory should have an Emergency Action Plan. The PI or CHO should make sure all personnel receive training on how to respond to small spills and  how to evacuate the work area in the event of a major chemical spill, fire, water main break, or other non-routine emergency event. All laboratory personnel  should know how to use more than one exit to evacuate the building. Contact EHS-SRM at 828-1392 for guidance.

Spill Response Guidelines

If handled properly, a spill may be nothing more than a nuisance. If handled improperly, a spill can seriously disrupt your activities and the work of your colleagues. At worst, a spill can cause bodily harm or property damage. In most cases, laboratory spills involve small quantities of materials, and if precautions are taken, such a spill will present minimal hazards. Laboratory personnel are usually the most appropriate people to clean up the spills because they are more likely than others to be familiar with the spilled material's hazardous characteristics and can respond quickly. If personnel are not sure about whether or not a spill can be cleaned up safely, call for assistance immediately. 

Emergency Preparedness 

Prepare for Spills 

• Learn about the hazards of the chemicals in the laboratory, 
• Write response procedures to address those hazards, and
• Make sure that you have the equipment and training necessary to follow those procedures.

Know the Hazards

As an integral part of any laboratory work, hazardous or potentially hazardous properties of all chemicals used or produced in your laboratory must be identified. Ask EHS if you require assistance.

Write Spill Response Procedures

Every laboratory should develop written spill response procedures. Such procedures should detail the initial steps to take when a spill occurs and include such elements as staff responsibilities, communication methods, instructions on using spill response equipment, and spill cleanup and residue disposal. Communicate these procedures to all individuals who use chemicals or who might assist during spill cleanup. Periodically review and update these procedures as necessary. As SOPs are updated, communicate the changes to laboratory workers. The SOP template has a section for the writer to detail specific spill procedures and/or processes for the worker to follow.

Make Materials and Equipment Available

Before starting any work, verify that all necessary safety equipment and spill cleanup materials are available and in good working order. Additionally, make sure that the individuals who may be involved in spill response are properly trained in equipment use and spill cleanup procedures. Finally, regularly inspect all materials and equipment to ensure they will function properly when needed.

Communication and Determination for When a Spill Occurs

• Whenever a chemical spill or release is discovered, the CHO and/or laboratory personnel should notify the PI or EHS-SRM, even for small spills that laboratory personnel can handle.
• When a spill occurs, determine the appropriate response. There are two types of spills: 
• Simple spills, which you can clean up yourself. A simple spill does not spread rapidly, does not endanger people or property except by direct contact, and does not endanger the environment.
• Complex spills, which require outside assistance. 
• Determine whether a spill is simple or complex by: 
• Evaluating the spill's risks; 
• Evaluating quantities; and 
• Evaluating the spill's potential impact.
• To determine whether a spill is simple or complex (which is often the hardest part of spill response), you need to know (1) whether the hazard(s) posed by the spilled chemical and (2) the spill's potential impact. Both these factors are, in large part, determined by the spill's size. Determine whether you have a simple spill by: 
• Type of chemical(s) spilled
• Quantity
• Hazardous characteristics of the spilled chemical(s)
• Location
• Proper method for cleaning up the spill
• PPE available, and the training of the laboratory’s personnel

For larger or more hazardous spills, immediately call EHS at (804) 828-1392 for assistance.  For after-hours emergencies, call (804) 828-9834.

Recommended Procedures for Cleaning up Simple Spills

Steps for a spill cleanup:

1. Prevent the spread of dust and vapors.
2. Neutralize acids and bases, if possible. Neutralize acids with soda ash or sodium bicarbonate. Bases can be neutralized with citric acid or ascorbic acid. The use of pH paper (if available) can determine whether acid or base spills have been neutralized.
3. Control the spread of the liquid. Contain the spill. Make a dike around the outside edges of the spill. Use absorbent materials such as vermiculite, cat litter or spill pads/pillows.
4. Absorb the liquid. Add absorbents to the spill, working from the spill's outer edges toward the center. Absorbent materials, such as cat litter or vermiculite work well, but are messy. Spill pillows/pads are not as messy as other absorbents, but they are more expensive.
5. Collect and contain the cleanup residues. The neutralized spill residue or the absorbent should be scooped, swept or otherwise placed into a plastic bucket or other container. For dry powders or liquids absorbed to dryness, double bag the residue using plastic bags.
6. Dispose of the wastes. Keep cleanup materials separate from normal trash. Contact EHS-SRM for guidance in packaging and labeling cleanup residues. If clean-up materials need to be removed from the spill site as soon as possible, call EHS-SRM.
7. Decontaminate the area and affected equipment. Ventilating the spill area may be necessary. Open windows or use a fan.

Special Precautions

The following precautions apply to chemicals that have hazardous characteristics. Note that some chemicals may exhibit more than one characteristic.

• Flammable liquids: Remove all potential sources of ignition. Vapors are what actually burn. Typically, vapors are heavier than air and accumulate near the floor. Flammable liquids are best removed through the use of spill pillows or pads. Spill pads backed with a vapor barrier are available from most safety supply companies. Because flammable liquids will probably be incinerated, avoid using inert absorbents such as cat litter.
• Volatile toxic compounds: Use appropriate absorbent material to control the extent of the spill. Spill pads/pillows or similar absorbents usually work best because they do not have the dust associated with cat litter or vermiculite.
• Direct contact hazards: Carefully select suitable PPE. Make sure all skin surfaces are covered and that the gloves you use protect against the hazards posed by the spilled chemical. When the cleanup is completed, be sure to wash hands and other potentially affected skin surfaces.

Mercury Spills and Mercury Thermometers

• Mercury spills rarely present an imminent hazard unless the spill occurs in an area with poor ventilation. The main exposure route of mercury is via vapor inhalation. Consequently, if metallic mercury is not cleaned up adequately, the tiny droplets remaining in surface cracks and crevices may yield toxic vapors for years.
• When a mercury spill occurs, first isolate the spill to prevent people from tracking the contamination to uncontaminated areas. A special mercury vacuum cleaner will provide the best method of mercury spill cleanup. Do not use a regular vacuum cleaner. Call EHS-SRM at 828-1392 for assistance. EHS-SRM has a special mercury vacuum designed for clean-ups.
• The purchase, use and storage of mercury thermometers is prohibited. If you find a mercury thermometer in the laboratory, please contact EHS-SRM for directions on proper disposal.

Documentation

After cleaning up a spill, a simple write-up should be prepared to document what happened, why, what was done and what was learned. This can be used to avoid similar instances in the future.

• Worker safety and training: All personnel entering a laboratory must be trained (or be accompanied by a trained person) about the laboratory's chemical risks and the actions to be taken during an emergency. Personnel who clean up their own spills must be trained according to their laboratory's CHP. Personnel who go into other work areas to assist with spills must be documented as having had additional special training.
• Disposal of spill cleanup materials: Clean-up materials from hazardous substance spills are regulated as hazardous waste. Follow VCU's guidelines for packaging, labeling and disposing of these materials.

 Spill Prevention Methods

Laboratory spills can occur during a chemical's storage, transportation or transfer as well as during an experiment. A spill prevention program for storage areas should include the following:

• Sturdy shelves and properly designed storage areas to minimize breakage and tipping
• Containers stored by hazard class (see Appendices D-2 and E)
• Store larger containers close to the floor
• Store containers on shelves away from the shelf edge to minimize the danger of falling
• Storage shelves with lips to reduce the danger of falling
• Regularly inspect the integrity of containers
• Secondary containment (e.g., placing a sturdy plastic container under primary waste receptacles to contain possible overflow)
• To minimize spills during transport:
• Use transport carts when appropriate
• Use safety containers (i.e., use a metal container for flammables)
• Use rubberized buckets
• Straps to secure containers
• Make sure laboratory personnel are properly trained and conscientious regarding safe practices
• For the transfer of liquids from one container to another, the risk of spills can be reduced by:
• Paying careful attention to the size of containers to avoid overfilling
• Using pumps or other mechanical devices rather than simply pouring directly into a container
• Providing spill containment to capture any leaks
• Bonding and grounding containers when flammable liquids are involved
• Damaged equipment should be reported to the PI and VCU Facilities Management
• Be vigilant of conditions in the laboratory by:
• Reducing clutter and unnecessary materials
• Eliminating tripping hazards and other obstructions
• Having all needed equipment readily available before starting work.

Dress Code in Teaching Labs

Safety Glasses and Goggles

Safety glasses must be worn in the laboratory at all times. There are NO exceptions. Chemical splash goggles may be worn but are not required in teaching labs where chemical splashes are less common. 

Laboratory Clothing and Footwear

• Wear clothing that covers the body from the neck to the ankles, shoulders and feet.
• Shirts (tops) which cover shoulders and underarms completely, as well as the back and entire abdominal area when standing, sitting or reaching.
• Pants and skirts must reach the ankle when standing or sitting. Skin should not be exposed between the bottom of the pants and top of the footwear, nor anywhere else except on the neck, and lower parts of arms. Clothing with holes that leave skin exposed are not allowed.
• Shoes must cover the entire foot. Footwear with open toes, open heels or other decorative openings are not allowed in the lab.

Contact Lenses

Individuals who wear contact lenses are encouraged to wear glasses (under their chemical splash goggles) in the laboratory. 

Hair

Hair longer than shoulder length must be tied back or constrained in such a way that there is no risk of it making contact with potential hazards. Rubber bands should be available in the laboratory.

Food and Beverage

Food and beverages (including gum) are not allowed in the laboratory.

Headphones

Headphones are not permitted to be worn in the lab. 

Waste Management

VCU handles and manages hazardous waste in accordance with the Resource Conservation and Recovery Act and commonwealth of Virginia regulations.

Any waste material generated by VCU must be recycled, treated, stored or disposed of at an authorized waste facility. Hazardous waste cannot be disposed of down the sink, in the trash or in or on the ground.

VCU properly disposes of its hazardous waste through a permitted treatment, storage and disposal facility.

Waste Appointments

Read more about Hazardous Chemical Waste Pick Up Procedures.

Complete the Chemical Hazardous Waste Pick up Request form to schedule your pickup.

VCU Laboratory Equipment Decontamination Procedures

Any laboratory equipment contaminated or potentially contaminated with biological material, chemicals or radioisotopes must be decontaminated prior to being cleared by EHS personnel for moving. All equipment must be in a clean, sanitary condition before pickup, regardless of whether it was or was not used with radioactive, chemical or biological agents. All instruments must be wiped down with soap and water or Simple Green solution. A visible examination should be made to check for evidence of spills. All instruments must be cleaned of all visible residue and encrusted material.

In addition, a potential hazard assessment must be made regarding the materials currently and previously used or stored in the instrument/equipment being dispositioned. Some potential hazards include but are not limited to: chemical, radioactive and infectious biohazard.

General Chemical Decontamination

Where there is the potential for hazardous chemical contamination, the laboratory must initiate a material-appropriate decontamination process. It is important that laboratory personnel properly decontaminate their laboratory equipment from hazardous chemicals (flammable, corrosive, reactive or toxic) prior to allowing VCU movers or moving contractors to transport the equipment to surplus or another laboratory space.

• Wash equipment with soapy water over areas where chemicals were spilled or stored. 
• Spray with water and towel dry. 

Radioactive Decontamination

All equipment used with radioactive material must be officially decommissioned by EHS-SRM Radiation Safety staff prior to relocation, repair or disposal.

For items used in conjunction or in contact with radioactive materials, make sure that no radioactivity is detected with survey equipment and/or incidental swipe tests.

Biological Decontamination

Where infectious or biohazardous materials were used or suspected, disinfect all surfaces with material specific effective disinfectants. Some biological agents may require specific decontamination procedures and labs should contact EHS if they believe the following procedures to not be appropriate:

• Spray down with a 10% solution of bleach. 
• Spray both the outside and inside of the equipment where contamination could have occurred. 
• Let equipment air dry overnight. 
• Some biological hazards (spore-forming bacteria, etc.) may require a stronger bleach solution or a different type of disinfectant.

Biological Safety Cabinets must be decontaminated by a NSF-approved vendor and will need to have the vendor’s clearance letter attached to the biosafety cabinet

All equipment should be reviewed on a case by case basis to ensure disinfectants will not damage the equipment being decontaminated and to ensure disinfectants are appropriate for the agent of concern. If equipment will not be given to surplus and is sensitive to bleach a 70% ethanol wipe down may suffice.

Under no circumstances will any laboratory equipment be allowed for service, storage or relocation without following the decontamination procedures outlined above. This includes the temporary storage of lab equipment in unsecured areas.

Ductless Fume Hoods

The use of ductless fume hoods in any setting at VCU is prohibited under any circumstances. EHS-SRM may review and grant use of ductless fume hoods on a limited prior approval basis . Prior approval from EHS-SRM for use  of ductless fume hoods requires the following information, which shall be reviewed during the annual laboratory safety inspection:

• Registration of equipment on the laboratory’s equipment inventory on BioRAFT/SciShield
• All fume hoods must be certified annually by an independent vendor
• Dates of filter changes must be posted on the outside of the unit along with the type of each filter
• A comprehensive list of chemicals permitted to be used in the fume hood, to include chemicals, amounts and over what time period

Volunteers and Minors 

Volunteering and shadowing opportunities at VCU represents a highly valuable experience for our university community. To ensure a safe and compliant environment, supervisors and sponsors must visit the Human Resources Volunteer Page and adhere to the mandatory onboarding protocols, especially when volunteers will be exposed to hazardous materials in university areas. Like other staff members, volunteers must undergo comprehensive safety training relevant to the potential hazards encountered while shadowing. This includes an annual review and adherence to the CHP.

To facilitate access to crucial health and safety information, the PI or supervisor must add volunteers to the laboratory’s SciShield profile. This inclusion guarantees that volunteers have access to critical documents such as SDS and SOPs. 

Volunteers are prohibited from entering the lab unsupervised. A lab supervisor, manager or their designee (an employee assigned to the laboratory) must be present during all volunteer activities, ensuring the safety of both volunteers and the laboratory environment.

Minors

All programs or activities sponsored and hosted involving minors must register with the Protection of Minors Office and adhere to the onboarding requirements outlined on the Human Resources Volunteer Page. No persons under the age of 18 years old shall be permitted to be present in any laboratory setting for any reason without prior approval.The employee interested in bringing a minor to volunteer must achieve full compliance with the safety and protection of minors policy prior to the start of any volunteer opportunities.  

SRM has the following additional limitations on minors in hazardous locations or programs involving hazards:

Age Based Limitations

• Persons under 12 years of age are prohibited from entering laboratories.
• Persons aged 12-15 may not enter a laboratory or participate in educational research or clinical activities, unless the activity is an approved children and youth program. 

Additional Requirements Based on Hazards

Minors Aged 16 or 17 who are engaged in research/clinical activities may not work with any of the following materials:

• Biological Materials (see VCU’s Biosafety Manual for more information)
• HHS and USDA listed select agents and toxins
• Human pathogens 
• Permit required animal or plant pathogens or materials
• Toxins of biological origin with an LD50 of < 100ug/kg body weight 
• Agents/applications classified at BSL-2+, ABSL-2+ or greater

• Chemical Materials
  • Highly toxic chemicals LD50 < 300 mg/kg oral-rat (e.g. – Osmium Tetroxide, Acrylonitrile, Acetonitrile, Sodium Azide)
  • Pyrophoric materials
  • Explosives, shock sensitive and air or water reactive materials
  • Hydrofluoric acid, aqua regia
  • Compressed toxic, corrosive or pyrophoric gasses
  • Controlled substances

• Radiation (see VCU’s radiation safety manual for additional information)
• Radioactive Materials – sealed and unsealed sources
• X-Ray producing equipment
• Open beam lasers - class 3b or higher

• Physical Hazards/Locations:
  • High voltage equipment
  • Class 3 or higher shop equipment
  • Mechanical rooms
  • OSHA regulated confined spaces
  • Roof top, construction areas, power plants, facility shops commercial food preparation areas
  • Any area, indoors or out, containing operational power tools or machinery

Laboratory Safety Assessments

Laboratory safety assessments are conducted by the lab safety team on a yearly basis to:

• To make sure that the laboratory maintains a safe working environment, is compliant with safety regulations, and promotes a positive safety culture and accountability.
  
  
• For the lab safety team to provide guidance, answer or clarify any questions or issues, help with risk assessments, assist with finding solutions to laboratory issues, and partner with the research community to provide solutions to safety concerns.

Laboratory safety assessments will be conducted by scheduling blocks of time with a building, floor, laboratory or department and may include one or more lab safety team specialists visiting the lab. During this time period lab safety team members may:

• Visually inspect the laboratory for any safety concerns 
• Consult with laboratory staff on safety issues
• Remove old, expired and legacy chemicals
• Assist with mitigating findings when possible
• Deliver labels and other safety-related items
• Answer questions and provide clarification on safety concerns

Additionally, EHS-SRM may randomly enter any space at any time to conduct a safety audit. Any findings recorded outside of the annual laboratory safety assessment will be recorded on BioRAFT/SciShield as incidental findings, and the responsible parties shall have 30 days to resolve findings, subject to the VCU 30-60-90 escalation policy.

For more information, visit https://srm.vcu.edu/labs--research/lab-safety-assessments/.

High Hazard Chemical Work in Laboratories

Purchase, storage, use or synthesis of high hazard chemicals requires review and approval by EHS-SRM before work begins (OSHA 29 CFR 1910.1450). Examples of high hazard chemicals include:

• DOT class 1 explosives; any setups for hydrogenation reactions
• DOT class 2.3 poisonous gasses
• Heating of perchloric acid

Review and approval for all high hazard work must be submitted through the SciShield Chemical Safety Form. Ad Hoc High Hazard Committee will convene to conduct thorough reviews and provide necessary feedback, guidance, and approval of high hazard work in VCU laboratories. 

PIs are responsible for development of SOPs and submitting information to EHS-SRM and the Laboratory Safety Committee for review and approval prior to purchasing material or starting work. EHS-SRM reserves the right to request and review procedural processes for any work with hazardous materials or equipment. It is the responsibility of the PI of the laboratory to ensure proper SOPs, training, engineering controls and PPE are available and utilized for all laboratory members. Storage, use and disposal of hazardous material will also be evaluated.

High Hazard Lab Work Guidelines outline the requirements that laboratories must follow when working with high hazard chemicals defined in the document, including general information of hazards, work practices, safety controls and emergency procedures for each category.

Laboratory Closures

In the event that a laboratory is planned to close, it is the responsibility of the PI to notify EHS-SRMat least two months prior to the date the closure or relocation will take place. All chemical, biological and radioactive hazards must be accounted for during any closeout or space relocation. In addition, all equipment must be safely and properly decontaminated and prepared for moving or prepared for surplus. Please complete the Lab Closure or Relocation Request Form and a member of the EHS-SRM team will respond with more information and can assist with updating your laboratory information on SciShield.

Laboratory Relocations and Renovations

All laboratory relocations, construction and renovation projects at VCU should include SRM representatives at the design and scoping phase of the project. This process is focused on ensuring an accurate hazard inventory for new or renovated lab space is shared with the engineer of record responsible for codes/standards and that safety requirements are included in the design, commissioning and acceptance of the finished construction product.

To initiate a lab relocation or renovation please complete an eBuilder Project Review. This process ensures laboratories and shops are designed and constructed to provide required safety features appropriate for the proposed sand future use.