Safety Regulatory Requirements 

The Occupational Safety and Health Administration (OSHA) regulation for “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450), referred to as the Laboratory Standard, lists the mandatory requirements of a written Chemical Hygiene Plan (CHP) to protect lab workers from harm caused by hazardous chemicals. The CHP contains policies, procedures, and responsibilities for protecting workers from the health hazards associated with the hazardous chemicals used in the laboratory workplace.

OSHA established the Laboratory Standard on the basis that:

1) laboratories typically differ from industrial operations in the use and handling of hazardous chemicals

2) a different approach from OSHA’s substances-specific health standards is warranted to protect laboratory workers

The standard applies to laboratories engaged in the use of hazardous chemicals as defined in the standard.
It defines “Laboratory use” as work with substances in which all of the following conditions are met:

• Chemical manipulations are carried out on a laboratory scale.
• Multiple chemical procedures are used.
• Protective laboratory practices and equipment are available and commonly used.
• The procedures involved are not part of a production process whose function is to produce
  commercial quantities of materials, nor do the procedures in any way simulate a production process.

VCU Chemical Hygiene Plan

The VCU Chemical Hygiene Plan (CHP) and the associated tools have been provided to support the efforts of Virginia Commonwealth University (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.

The VCU Chemical Hygiene Plan includes guidance and information designed to help Principal Investigators conduct a hazard assessment of potentially hazardous chemicals in their lab spaces and to use as a guide to train employees in appropriate, safe working practices. Each laboratory has the responsibility of personalizing this plan to fit the specific requirements of the laboratory and all staff, volunteers, and students and are required to take both the VCU BioRAFT required training as well as lab-specific training.

Chemical Management

Storage Requirements

All hazardous chemicals must be stored in a safe manner according to industry standards. Chemical storage areas must be clearly labeled and marked, and all chemicals must be segregated according to hazard class. Please review the VCU Chemical Hygiene Plan for more information on chemical storage. Old, expired, and legacy chemicals must be disposed of from the laboratory. 

Hazardous Chemical Volume Limits

There are regulatory and code limits to storing and using hazardous chemicals in all VCU buildings.  These limits are based on a number of factors including storage capabilities, fire suppression, and building floor level. The best practice is to have no more than 20 Liters of flammable chemicals in a laboratory at any given time.  Exceptions to this must be reviewed by EHS.   Laboratory staff must manage their inventory appropriately and purchase chemicals as needed and not in bulk. The ChemTracker module in BioRAFT can assist laboratories in ensuring compliance with volume limits.

Old, expired, and Legacy Chemicals Removal information

The lab safety team reserves the right to remove any chemicals that pose a safety risk in the laboratory. These include old, expired, and legacy chemicals.  Additionally, any large quantities of hazardous chemicals that are improperly stored or are above code limits may be removed from the laboratory.