Laboratory Requirements: Chemical Hygiene Plan
The Chemical Hygiene Plan (CHP) summarizes policies and procedures to protect laboratory workers from, and inform them of, hazards inherent to their work with chemicals.
The Chemical Hygiene Plan applies to faculty, classified staff, paid graduate students, and work-study students who work in university chemical laboratories. There are two basic components of the CHP:
- General laboratory procedures are provided below, and
- Laboratory-specific documentation (pdf | doc) that must be completed by the Prinicple Investigator and maintained on site.
Personnel who work with chemicals in a non-laboratory setting are covered by a Hazard Communication Plan.
Responsibility for laboratory safety is assigned to several parties at Virginia Tech.
- Chief Executive Officer (CEO) (i.e. the University President) - This individual has ultimate legal responsibility for the university's compliance with this program.
- Chemical Hygiene Officers (CHO) - These individuals are designated by the department and are responsible for completing the Laboratory-Specific Documentation (pdf | doc), overseeing the implementation of the plan, and reviewing/revising the plan at least annually.
- University Chemical Hygiene Officers (UCHO) - The EHS Associate Manager of Laboratory Safety serves in this capacity and is responsible for developing general information and guidelines for laboratories.
- Laboratory Chemical Hygiene Officers (LCHO) - Each "laboratory unit" shall designate an individual to serve in this capacity. These individuals are responsible for developing and documenting the Laboratory-Specific Documentation (pdf | doc)for the unit, and will ensure implementation, such as training and inspection coordination. A "Summary of Duties" for these individuals can be found in Laboratory-Specific Documentation.
- University Laboratory Safety Committee (ULSC) - This committee oversees compliance with the Chemical Hygiene Plan and any additional relative information contained within this program. Responsibilities include annual review of the plan and assignment of disciplinary actions necessary to deal with non-compliance. Membership will consist of research faculty and safety professionals. Appointments will be made by the Office of the Provost.
- Department Heads have the responsibility for safety compliance within the department, including but not limited to: ensuring that Principle Investigators are aware of the Chemical Hygiene Plan requirements and mandating laboratory unit participation in the program. Departmental safety officers or committees may serve in the delegation of this responsibility.
- Principle Investigators (PI) - Research group leaders and instructional laboratory supervisors have the responsibility for appointing a LCHO.
- Laboratory Workers - are responsible for planning and conducting each laboratory operation in accordance with the Chemical Hygiene Plan's "Laboratory-Specific Documentation ", and for developing good personal chemical hygiene habits. Additional information is provided in the "Summary of Duties".
The UCHO conducts or facilitates safety training seminars on a regular basis, and acts as a consultant to laboratory personnel for related issues.
The LCHO is responsible for informing employees of the following:
- The Chemical Hygiene Plan location within the unit and general contents,
- The laboratory-specific documentation location within the unit and general contents,
- The OSHA Lab Standard, available from www.osha.gov,
- The required reading list for the specific laboratory, including standard operating procedures (SOPs), and the Training Documentation Form, which must be signed and filed with the plan, and
- The location of MSDS and how to obtain them.
Responsible persons for establishing new research protocols in a lab should carefully review all operations for potential risks or hazards. The materials and chemical by-products should be understood before starting the experimental process. Once information and advice about the hazards has been obtained, appropriate protective procedures should be developed and positioning of equipment should be planned.
The storage, handling, and consumption of food and drink is prohibited in certain high risk laboratories, such as carcinogenic research labs, biological labs, pesticide labs, and labs containing highly toxic compounds. Additionally, some departments have rules prohibiting food in any laboratory.
Work with chemical or physical hazards (e.g. high voltage, mechanical hazards not known to be intrinsically safe) or any other work that might prove immediately dangerous to life and health (IDLH) shall not be conducted alone in any Virginia Tech laboratory. It is recommended that all laboratory work be conducted with a partner or co-worker, or in proximity to others, in case of emergency.
Chemicals should be stored in a defined storage area (safety cabinet or approved room). 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.
These materials are covered by Federal and State policies. Please contact your Department Head or Director for guidance.
- Controlled substances - Anyone who engages in activities with controlled substances (e.g drugs) included on the Drug Enforcement Agency (DEA) Schedules I - V must obtain DEA registration. Refer to the DEA website for a listing of substances in Schedules I-V. Use of these materials also requires registration with the State of Virginia.
- Listed Chemicals - DEA requires vendors to identify each purchasing agent according to CFR 21, Part 1310.07, "Proof of Identity" before selling any of their designated Listed Chemicals. The actual procedure and required paperwork may vary between vendors. Please contact your Department Head or Director for assistance in completing the Proof of Identity Paperwork.
- Ethanol - Purchase and shipment are also regulated by Federal and State agencies. In order to simplify this process, Virginia Tech's Chemistry Department is currently the authorized point of contact for the University (College of Veterinary Medicine excluded). If you wish to order ethanol, please contact the Chemistry Stockroom Manager.
Any material not used or no longer needed must be handled according to regulatory requirements. Preferably, they should be returned to the vendor. If this is not possible, contact EHS for assistance as needed. Individuals holding licenses to use Controlled Substances and/or Listed Chemicals in their research must meet the requirements set forth by DEA and Virginia. Please contact your Department Head or Director for additional information.
Laboratory Waste Storage
Failure to follow proper waste storage requirements listed below may result in citations and/or fines by the EPA.
- A laboratory may accumulate up to 55 gallons of hazardous waste, or one quart of "P-listed waste". If a lab accumulates more than these limits, it has three days to have the excess removed from the lab to the EHS Hazardous Waste Accumulation Area. Refer to the EPA P-list, to identify which materials are included.
- Hazardous waste may be accumulated in labs as long as they are collected in containers near the point of generation. This area must be under the control of the lab workers and LCHO. Waste containers must then remain in the lab where they were filled until collected by EHSS authorized personnel.
- Hazardous waste containers must be in good condition, and must be made of a material that is compatible with the waste it contains.
- Containers must be closed except when adding waste. Failure to close the waste containers may constitute an effort to treat waste on site - illegally!
- The list of contents on the label must be updated whenever waste is added!
Certain chemicals require special handling and disposal. The following are some examples of these chemicals, and special handling instructions for them.
- Reactives - While all chemicals are reactive to some degree, special attention must be given to some inherently unstable and potentially reactive/explosive chemicals which are susceptible to rapid decomposition or reaction. These chemicals can react alone, or with other substances in a violent manner, giving off heat and toxic gases or leading to an explosion. Reactions of these chemicals often accelerate out of control and may result in injuries or costly accidents.
- Mercury - Elemental mercury should never be added to another chemical for disposal. Many of our waste disposal firms will not accept waste contaminated with mercury. Place mercury waste and debris (ex. broken thermometers or manometers) separately in a sealed container for collection by EHSS authorized personnel. Mercury spill clean up may require special assistance. Contact EHSS.
- Peroxide-formers - Some chemicals form explosive concentrations of peroxides with age (see list). When peroxides become concentrated by evaporation or distillation and are disturbed by heat, shock, or friction, they may explode with extreme violence. These substances must not be housed in labs for long periods of time. To minimize the hazard of peroxide formation, strictly observe the following safety guidelines.
- Picric Acid - When picric acid becomes desiccated (color changes, visible crystals or crystalline matrix formation in the cap), it forms picrate salts, which are an explosion hazard. Dry picric acid is classified as a class "A" explosive! It is shock-sensitive and can explode when disturbed. If you suspect that you have desiccated picric acid:
- Do not touch the container! The act of moving the container may be enough to detonate the material.
- Prevent all personnel from entering the area, or disturbing the container.
- Contact EHSS at 231-7611 or call 231-6411 and ask VT dispatch to notify EHSS immediately.
- Perchloric Acid - To minimize hazards related to perchloric acid, follow these recommendations.
- Piranha Solution - This solution is commonly used to remove organic residues from substrates; however, it can be dangerous. For more information, click here.
- Hydrofluoric Acid - Hydrofluoric acid (HF) is an extremely corrosive acid used for many purposes, including mineral digestion, surface cleaning, etching, and biological staining. Its unique properties make it significantly more hazardous than many of the other acids used on campus. The following safety guidelines must be used when working with HF.
- Acrylamide (gels, liquids, solids) - Commonly used in industry and research, particularly in the electrophoresis of DNA in polyacrylamide gels at Virginia Tech. Acrylamide in nearly all of its forms is toxic, and considered to be a potential human carcinogen. It is also listed as a potential teratogen. Because of its toxic nature, every precaution must be taken to properly and safely handle it. For more information, click here.
- Radioactive Material/Waste - Radioactive material must be registered with the university Radiation Safety Officer. Registration ensures that all individuals involved with radioactive material receive appropriate safety training and radiation monitoring badges, if required.
Suitable eyewash facilities and deluge showers must be available to all chemical laboratories where there is a potential for human contact with hazardous/caustic materials, and all pesticide mixing areas. Access must be within ten unobstructed seconds from the work area. (This shower most definitely is obstructed!) These safety devices are necessary for halting the damage incurred from a chemical splash to the eyes, or spill on the body. For more information, click here.
Laboratory fume hoods are ventilated enclosures designed to protect laboratory personnel from inhalation exposure to chemical vapors and dusts. Prior to purchasing, installing, or moving a fume hood, the LCHO must consult with EHSS for guidance. Fume hoods must be certified by EHSS.
Sample Hood Certification Sticker
Each laboratory must have an appropriate, functional, unobstructed portable fire extinguisher mounted on the wall three to four feet from the floor. For more information, click here.
All departments are required to have an Emergency Action Plan specific to the building where employees are located. This plan provides detailed information regarding actions to be taken by personnel in the event of an emergency, such as fire, explosion, injury, medical emergencies, chemical exposures, chemical spills, acts of terrorism, acts of nature (severe weather), etc. For more information on emergency planning, click here.
Minor spills of hazardous chemicals that pose little or no threat to the safety and health of personnel can be cleaned by competent departmental personnel by following the warning and cautions signs on the container's label or manufacturer's material safety data sheet (MSDS). A hazardous material emergency exists when cleanup of a spill of a hazardous material is beyond the level of knowledge, training, or ability of the staff in the immediate spill area or the spill creates a situation that is immediately dangerous to life and health of persons in the spill area or facility.
- Alert personnel in the immediate area of the spill and evacuate the room.
- Confine the hazard by closing doors as you leave the room.
- Use eyewash or safety showers as needed to rinse spilled chemicals off of personnel.
- Evacuate any nearby rooms that may be affected. If the hazard may affect the entire building, evacuate the entire building.
- Notify university police by calling 911 and provide the chemical name, location of the spill, size of the spill, number of injured persons (if any), and any environmental concerns, such as location of storm drains or streams. You will also need to provide your name and a telephone number. Always call from a safe location. Be prepared to spell chemical names.
Procedures for laboratory personnel to handle chemical, biological, or radiological spills are provided in the laboratory-specific documentation. Trained laboratory personnel are authorized to determine appropriate emergency response measures for their areas.
EHSS is responsible for conducting safety inspections of all university chemical laboratories, research stations, and chemical storage areas. These inspections allow EHSS to monitor compliance with the program and identify any problems inherent to the plan itself. The inspection form used by EHSS is provided for your convenience. It may be used as a guideline for establishing unit chemical safety programs.