Chemical Hygiene Plan
This web-based Chemical Hygiene Plan and lab specific-Chemical Hygiene Plan must be readily available to personnel in Virginia Commonwealth University facilities where hazardous chemicals are present.
Chemical Hygiene Plan (CHP) and the associated tools have been provided to support the efforts of VCU to manage personnel exposure to hazardous materials and to meet requirements established by regulatory and industry standards, such as the Occupational Safety and Health Administration (OSHA) regulations for “Hazard Communication” (29 CFR 1910.1200), “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450), and the Department of Environmental Quality (DEQ) standards for hazardous waste disposal. This Chemical Hygiene Plan includes processes and information designed to help responsible officials conduct a hazard assessment of potentially hazardous chemicals in the workplace and to train employees in appropriate, safe working practices. Each laboratory has the responsibility of developing its own Lab Specific-Chemical Hygiene Plan.
The Chemical Hygiene Officer shall review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary. Laboratory members are responsible for reviewing the VCU Chemical Hygiene Plan and the Lab Specific-Chemical Hygiene Plan annually.
President, Provost and Senior Vice Provost for Research
- The responsibility to promote the importance of safety.
- Promoting the attitude and culture of safety among the university employees.
- Supporting the safety program that will protect employees from the effects of chemical agents.
- Ensuring that the deans, directors, department heads provide adequate time and recognition for the employees who carry safety responsibilities.
Environmental Health and Safety: Laboratory Safety Office
- Partner with each laboratory to monitor the overall effectiveness of the CHP.
- Assist with personnel training and training videos through BioRaft.
- Provide technical guidance.
- Contact Lab Safety at 804-828-1392 for assistance.
- Designate a Chemical Hygiene Officer (qualified by training or experience) to coordinate the requirements of the CHP.
- The Chemical Hygiene Officer (CHO) designation may be in addition to other employee titles held such as Principal Investigator (PI), Lab Manager, Supervisor, etc.
- It is crucial that all laboratory personnel assume responsibility for laboratory safety.
- All employees/students should have access to pertinent safety information through their supervisory staff and through BioRaft.
Laboratory Safety Liaisons/Building Manager
- 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.
- Coordinating and tracking department members and training on BioRaft.
Chemical Hygiene Officer
- Implementing CHP requirements.
- Completing Hazard Assessment Forms and updating them when change occurs.
- Developing appropriate means of communication for informing the chemical/product users of associated hazards and precautionary measures (e.g. safety signage, labeling and Standard Operating Procedures).
- Ensuring people working with hazardous materials are knowledgeable of the contents of the CHP and have reviewed both the VCU CHP and lab specific Personal- CHP annually.
- 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. The SDSs can be stored electronically on BioRaft, as a hard copy, or both.
- Compiling a Chemical Inventory on BioRaft and updating annually; ensuring each chemical has a corresponding SDS.
- Confirming all required training is completed and that employees/students are proficient with regard to skills training.
- Reviewing the CHP annually and updating as needed.
- Documenting an annual laboratory review.
- Partnering with EHS-SRM to assure proper CHP implementation and ongoing maintenance.
Laboratory Employees / Students
- Act responsibly when using, handling, or storing hazardous chemicals.
- Wear appropriate Personal Protective Equipment (PPE).
- Use prescribed engineering controls.
- Follow administrative control practices as described in the CHP.
- Share/report safety concerns with the PI or CHO.
The Laboratory Safety Committee (LSC) meets periodically to provide oversight, review metrics and make recommendations to improve laboratory safety and maintain a positive safety culture at VCU. The committee focuses on overall accident and injury reduction, chemical safety and physical hazards. It fills the space between VCU’s Radiation Safety Committee and Biosafety Committee. The LSC also evaluates safety in other areas that are grant funded and academic in nature, including art safety, field research safety, teaching labs, and machine/shop safety. Additional concerns identified by Environmental Health and Safety may be brought to the committee for review. The LSC has representation from all Schools and Colleges on campus and is chaired by a senior faculty member at VCU.
Regular safety meetings foster a culture of safety and community in the laboratory. Meetings should be scheduled at the same time as often as necessary to maintain safety awareness and safe work practices. The following list provides some guidelines for effective safety meetings:
- Maintain a routine with the meetings. Each laboratory is different. Schedule the meetings often enough so lab staff is kept up-to-date. Some labs may need to meet weekly; others need only schedule monthly or even quarterly meetings. For example, meetings can be scheduled every other Tuesday at 9:30 a.m.
- Start and end ON TIME. Everyone is busy. 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. The easiest way to keep the meeting running smoothly is by having an agenda. 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 of every meeting. Ensure all attendees have access to the minutes.
- 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.
- Ask for help. Contact EHS-SRM for assistance and guidance for safer lab practices or to facilitate training.
Virginia Commonwealth University 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 responsible officials in the development of lab-specific Standard Operating Procedures (SOPs). A completed Laboratory Hazard Assessment Form facilitates compliance with all required health and safety regulations and grant requirements including, but not limited to, Virginia Occupational Safety and Health (VOSH), National Fire Protection Association (NFPA), the Department of Transportation, and the Environmental Protection Agency (EPA).
Hazard Assessment Procedure
- Hazard assessments must be completed at least annually or 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., following specific guidelines on the Safety Data Sheets for the chemicals that will be used in the laboratory). Please contact EHS-SRM at 804-828-1392 if you require assistance in completing the Laboratory Hazard Assessment Form.
- Prioritize and decide how administrative and engineering controls, as well as personal protective equipment will be implemented.
- Once hazards are identified and the controls are chosen, complete the laboratory hazard assessment form. This assessment should be utilized to develop the standard operating procedures for each protocol, including the safety components.
Hierarchy of Hazard Controls
Eliminating hazards whenever possible is the best way to ensure a safe laboratory. However, since not all hazards can be removed, it is good practice to use the following hierarchy of controls:
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.
- The second best way to control a hazard would be to exchange a more hazardous chemical with a less- or non-hazardous material. An example would be to use GelSafeTM as a replacement for ethidium bromide (EtBr) for nucleic acid staining.
- If a hazard cannot be eliminated or a safer substitute cannot be found, the next best approach is to use engineering controls to keep the hazard from reaching the worker. This could include methods such as enclosing a chemical process in a Plexiglas "glove box," using mechanical lifting devices; or 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).
- In addition to engineering controls, or if engineering controls cannot be implemented right away, administrative controls must be considered. Administrative controls involve changes in workplace policies and procedures. Administrative Controls in a laboratory would include: ensuring that all personnel have received the specific training required for them to conduct their work safely, implementing and enforcing Standard Operating Procedures 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
- The use of personal protective equipment (PPE) is a way of controlling 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. Examples of personal protective equipment for the laboratory may include: respirators, gloves, goggles, and protective clothing.
Personal protective equipment is the least effective method for protecting workers from hazards and must be used as a last line of defense in case all other measures fail. 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 space be sure to complete a Lab Specific Chemical Hygiene Plan to determine the PPE required for work with a particular hazardous material.
Principle Investigator PPE Responsibilities:
- PI and employee supervisors at VCU are required to enforce PPE requirements in their laboratories.
- Complete a Personalized CHP to determine the appropriate PPE for their lab.
- Update laboratory Safety Signage to indicate required PPE.
- Provide disposable PPE for visitors and FMD staff when necessary.
- Ensure employees are properly fitted and trained to use their assigned PPE.
- Confirm employees know how to use, maintain, and store their PPE in safe, sanitary conditions.
- Communicate and provide documented training on these topics to each employee required to use PPE:
- Type of PPE selected
- When the employee is required to use the 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
Employee PPE Responsibilities
- Ask if PPE is needed to perform your assigned tasks.
- Demonstrate full understanding of the use and limitations of your PPE.
- Wear only the PPE assigned for a specific job assignment or task.
- Tell your supervisor if the hazards of the task change.
- Inspect the condition and fit of your PPE before each use.
- Avoid altering or compromising the effectiveness of your PPE.
- Clean, maintain, and store your assigned PPE in a ready-to-use and sanitary condition at all times.
- Use university-issued PPE only for university job functions and tasks.
PPE Selection | 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 personnel working with hazardous materials as determined by a hazard assessment.
- Flame resistant lab coats may be required when handling pyrophoric, air/water reactive materials, open flames, and certain quantities of flammable liquids.
PPE Selection | Eye/Face/Neck Protection:
- Safety glasses - Eye protection is indicated for flying particles, acids or caustic liquids, welding, light that could injure eyes (lasers, ultraviolet, infrared, 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.
- 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 - 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 using glass apparatus in combustion or other high-temperature operations. Impact-protection goggles have perforated sides to provide ventilation and reduce fogging of the lens 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.
- Face shields - 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 (which 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 | Laboratory Foot Protection:
- Minimum required PPE that must be worn at all times in a laboratory or technical area is closed toe/heel shoes to protect feet from chemical spills and sharp objects.
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 (the wearing of 2 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 | 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 the Industrial Hygiene department, here at VCU.
PPE Selection | Other criteria for selecting lab clothing include:
- Liquid-resistant fabric or coatings when spills or splashes are anticipated
- Non-disposable garments must be capable of withstanding sterilization should they become contaminated
- Closure types and location for ease of use
- Antistatic properties
- All respirator use including Powered Air Purifying Respirators (PAPRs) and filtering face-piece respirators (also referred to as dusk mask 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 Bio-safety Cabinet are not available to minimize inhalation exposure to chemical gases, vapors or particulates. Anyone who may be at risk to exposure can contact the VCU Respiratory Protection Program Administrator to be evaluated and included in VCU's Respiratory Protection Program.
Prevent the spread of contaminants:
- Remove all PPE before leaving your 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 protective equipment 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 for laundering, or to any other undesignated site.
General Laboratory Safety Training
Anyone working in a laboratory at VCU is required to complete General Laboratory Safety training on BioRAFT, which includes:
- Review of laboratory rules and regulations, including the lab specific Chemical Hygiene Plan
- Recognition of laboratory hazards
- Types of engineering controls and personal protective equipment
- Signs and symptoms associated with exposures to hazardous chemicals
- Chemical exposure monitoring
- Procedures for disposing of hazardous chemical waste
- Fire safety and emergency procedures
- Information required by CCR Title 8 Section 3204
All employees and students working in VCU laboratories must take following basic laboratory safety classes provided on BioRAFT:
- Fundamentals of Laboratory Safety | A general overview on laboratory safety for laboratory workers.
- Principal Investigators Responsibilities | Designed to give the PI the foundation needed to create a strong safety culture in the laboratory.
- Hazardous Waste Management in Laboratories | Will train lab 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/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 personal protective equipment to mitigate hazards
- Specialized equipment
- Standard Operating Procedures (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. It is a Virginia Commonwealth University requirement that each person working in a laboratory or technical area receives a one-time site specific orientation.
- Lab-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 trainings, including safety meetings, one-on-one training, and any third-party in-class or online trainings. Electronic copies are encouraged to be uploaded onto BioRAFT, however if hard copies are maintained, documentation should be located in the laboratory safety manual. For lab-directed trainings please include a sign-in sheet with sufficient details such as date, topics discussed, and who lead the training. Training histories for EHS-SRM taught training's or online courses taken through BioRAFT are available for review to PIs/Laboratory Supervisors through the Training Tab located on BioRAFT. Any questions about the employee training records available here can be directed to email@example.com.
VCU has a number of tools available for laboratories to complete appropriate training, including:
In laboratory settings, PIs/CHOs must ensure all necessary training is completed for employees and students who will be using hazardous chemicals. Upon completion of all laboratory-specific training, documentation of the training must be retained for verification and review. Training shall 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 shall include new and/or different laboratory procedures as needed.
The following information on the specific chemical(s) should be conveyed to personnel prior to being assigned to work tasks involving the material(s):
- Review of SDS sheets including 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 Emergency Action Plan requirements;
- 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 Personal Protective Equipment (PPE); and
- Proper use, storage, and disposal of hazardous materials.
Additionally, all laboratory staff are required to complete annual laboratory safety training on BioRaft titled Fundamentals of Laboratory Safety. These training modules provide a general understanding of chemical safety in the laboratory but do not replace or substitute for laboratory-specific training.
The BioRaft Course Directory provides various online safety modules that are targeted at training laboratory staff on hazards they might encounter here at VCU.
A current inventory of all potentially hazardous chemicals is required to be maintained for every chemical stored, used, or produced within each laboratory. The laboratory chemical inventory should be updated on an annual basis, or more often if warranted. All VCU laboratories are required to maintain their chemical inventories using the BioRAFT inventory management system.
Chemical Management as per Hazard Assessment
Labeling Systems: The NFPA Labeling System was developed in the 1950s and the label is divided into sections (diamond or rectangle with bars), each color-coded and numbered 0 through 4 to have specific meanings. See NFPA 704 for more information.
- All containers must be labeled. Original containers without an adequate identifying label shall 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 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, just as 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). In general, 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 (ex. HCl gas) are the exception. All chemicals must be stored according to their hazard classification. The PI/CHO should delineate storage areas within the laboratory that can be segregated according to hazard class. In general, store chemicals in the lab according to the following recommendations:
- Safely space shelves and racks to accommodate the upright removal of the largest chemical container; prevent tipping and dripping with adequate clearance.
- Keep hazardous materials away from heat and direct sunlight to prevent the degradation of chemicals and deterioration of storage containers and labels.
- Do not store hazardous materials (except cleaners) under sinks.
- Avoid chemical stockpiling; procure hazardous chemicals as needed.
- Limit storage of hazardous materials in fume hoods. Air flow may be compromised.
- Conduct periodic cleanouts to minimize accumulation of old or unused chemicals.
- Keep all food (including gum), beverages, tobacco and open cosmetics outside the laboratory.
- Store corrosives below the average range of eye-level.
- The location of each chemical should be included on the Chemical Inventory List.
Chemical Hazard Classifications
- Acids: Have a pH from 1 to 7. They are corrosive (“burn” skin), have a sour taste (e.g. lemons, vinegar), contain hydrogen ions (H+), when dissolved in water, they turn blue litmus paper to a red color. Examples of acids are: Hydrochloric, Sulfuric and Acetic.
- Bases: Have a pH from 7 to 14.They are corrosive ('burn' skin), have a soapy feel, they turn red litmus paper to a blue color. Examples of bases are: 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 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. 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 of pyrophorics 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 10 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/drink items with any kind of chemicals or flammables.
Globally Harmonized System (GHS) of Classification and Labeling of Chemicals
OSHA in its recent adoption of the United Nation’s 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 Safety Data Sheets (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 safety data sheet
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 current 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. Laboratory Safety Signage
Ordering Chemicals: Accomplished through the individual department or the PI. Before purchasing a chemical, the PI / CHO / Lab Staff should consider the following:
- What is 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.
- 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.
- Can the chemical be managed safely once it is delivered to the department? Does the chemical present any unique risks?
- Is the chemical 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.
- Can the waste 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 Safety Data Sheet (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.
- Chemical deliveries should be limited to areas equipped to handle them, usually a loading dock, receiving room, or the actual 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 receipting for chemicals classified as dangerous goods by either the US Department of Transportation (DOT) or International Air Transport Association (IATA) must be trained and certified to do so. Safety and Risk Management provides training and certification for personnel performing this task. The training schedule is posted on the SRM website at this link: Handling Dangerous Goods Information
- 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 gases 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.
Chemicals Classified as Controlled Substances by the US 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 Office of Research and Innovation outlines the procedures and requirements for these chemical types in a VCU Policy titled “Using Controlled Substances for Research” (in the VCU Policy Library at this link: Using Controlled Substances for Research ) and in its manual titled “Use of Controlled Substances Manual” (on the Research Compliance Matrix website at this link: Use of Controlled Substances in Research Manual )
Development of Standard Operating Procedures (SOPs)
A standard operating procedure (SOP) is a written document explaining how to safely work with all specific laboratory hazards. SOPs are needed 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 document 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, 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.
Safety Data Sheets (SDSs)
Chemical manufacturers and importers must evaluate their materials to determine if they are hazardous. If they are considered to be hazardous, a Safety Data Sheet (SDS) must be prepared and sent to end users. These were formerly referred to as Material Safety Data Sheets (MSDSs). It is essential the end user has access to the information and becomes familiar with 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, as hard copies, or in both formats so 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 shall 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 / material.
- SDSs must be readily available at all times to laboratory personnel, either electronically or as hard copies.
Development of Emergency Action Plan (EAP)
Each laboratory shall have an Emergency Action Plan. The PI or CHO ensures all personnel receive training on how to respond to small spills, evacuate the work area in the event of a major chemical spill, fire, water main break, or other non-routine emergency event. Every laboratory worker should know how to use more than one exit to evacuate the building. Contact EHS 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 workers 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 unsure as to whether or not a spill can be cleaned up safely, call for assistance immediately.
Emergency Preparedness: To prepare for spills, you should: (1) learn about the hazards of the chemicals in your laboratory, (2) write response procedures to address those hazards, and (3) 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, ensure 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.
First Steps When a Spill Occurs: Communication and Determination
- Whenever a chemical spill or release is discovered, the CHO and/or laboratory workers should notify the PI or EHS, 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, and complex spills, which require outside assistance. A simple spill is defined as one that
- does not spread rapidly
- does not endanger people or property except by direct contact, and
- does not endanger the environment.
- Three basic steps should be taken to determine whether a spill is simple or complex: (1) evaluating the spill's risks; (2) evaluating quantities; and (3) 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) 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. The following information will help you determine whether you have a simple spill:
- the type of chemical(s) spilled,
- the quantity,
- the hazardous characteristics of the spilled chemical(s),
- the location,
- the proper method for cleaning up the spill,
- the personal protective equipment available, and the training of the laboratory’s personnel
For larger or more hazardous spills, immediately call EHS at 828-1392 for assistance. For after-hours emergencies, call 828-9834.
Recommended Procedures for Cleaning up Simple Spills
Steps for a spill cleanup:
- Prevent the spread of dusts and vapors.
- 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.
- 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.
- 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.
- 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.
- Dispose of the wastes. Keep cleanup materials separate from normal trash. Contact OEHS 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 OEHS.
- Decontaminate the area and affected equipment. Ventilating the spill area may be necessary. Open windows or use a fan.
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 personal protective equipment. 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 rarely present an imminent hazard unless the spill occurs in an area with extremely 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 OEHS at 828-1392 for assistance. OEHS has a special mercury vacuum designed for clean-ups.
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. Such documentation can be used to avoid similar instances in the future.
- Worker Safety and Training: All workers 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. Workers who clean up their own spills must be trained according to their laboratory's Chemical Hygiene Plan. Workers 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 in the actual 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).
- larger containers stored closer to the floor;
- containers stored on shelves away from the shelf edge to minimize the danger of falling;
- storage shelves with lips to reduce the danger of falling;
- regular inspection of the integrity of containers; and
- secondary containment (for example, placing a sturdy plastic container under primary waste receptacles to contain possible overflow).
- To minimize spills during transport, a laboratory should integrate the following:
- use transport carts when appropriate,
- use specific safety containers, (i.e., use a metal container for flammables)
- use rubberized buckets,
- straps to secure containers, and ensure
- lab workers 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; and
- bonding and grounding containers when flammable liquids are involved.
- damaged equipment of any kind should be reported to the PI and Facilities Maintenance.
- Be vigilant of conditions in the laboratory, such as
- reducing clutter and unnecessary materials,
- eliminating tripping hazards and other obstructions, and
- having all needed equipment readily available before starting work.
Safety Glasses/ 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: Everyone in a lab must conform to the following at all times:
- Clothing which 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 be long enough to 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 which leave skin inadequately protected 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: Contact lens wearers 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 & beverages: Food and beverages (including gum) are not allowed in the laboratory.
Head Phones: Headphones are not permitted to be worn in the lab.
Virginia Commonwealth University 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.
Information about: Hazardous Chemical Waste Pick Up Procedures
Schedule your: Chemical Hazardous Waste Pick up Request
Any laboratory equipment contaminated or potentially contaminated with biological material, chemicals, or radioisotopes must be decontaminated prior to being cleared by EHS personal for moving. All equipment must be in a clean, sanitary condition before pickup, regardless if 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 lab must initiate a material appropriate decontamination process. It is important that laboratory personnel properly decontaminate their laboratory equipment from hazardous chemicals (flammable, corrosive, reactive, toxic) prior to allowing VCU movers or moving contractors to transport the equipment to Surplus or another lab space.
- Wash equipment with soapy water over areas where chemicals were spilled or stored.
- Spray with water and towel dry.
All equipment used with radioactive material MUST be officially decommissioned by EHS Radiation Safety staff prior to relocation, repair or disposal.
For items used in conjunction or in contact with RADIOACTIVE materials, insure that no radioactivity may be detected with survey equipment and/or incidental swipe tests.
Where INFECTIOUS / 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.