Chemical Storage and Management

Chemical Purchasing

Chemical Registration

Container Labeling

Chemical Transfer Piping

Safety Data Sheets

Exposure Monitoring

Air Monitoring

Hazardous Products Evaluation

Minimizing Chemical Exposures

Minimizing Accidental Spills and Contamination

Chemical Storage

Hazardous Waste Disposal

Chemical Purchasing

The procurement of chemicals or chemical products is one of the first opportunities to facilitate chemical safety in the lab. The following considerations are recommended:

• When purchasing new chemicals for use in the lab, always order the smallest amount needed to complete a project.
• When possible, purchase the lowest concentration of a chemical.
• Review the Safety Data Sheet and identify whether a less hazardous substitute could be purchased. Consider ordering less hazardous materials if the same research objectives can be achieved.
• Contact other laboratories through the LabConnect listserv and inquire whether another department may have excess amounts of the same chemical available for use.
• Prior to ordering, determine its hazards and assure the space is approved for the chemical hazard and anticipated quantities.
• Review the Safety Data Sheet to become aware of any unique waste handling or disposal needs.

Chemical Registration

University personnel using hazardous materials in their research and/or teaching laboratories, or any other space where chemicals are used/stored, must generate an inventory listing and update it annually. This policy resulted from negotiations with the State Fire Marshall related to chemical use and storage, and concerns raised by accidents at other universities as well as the Federal Bureau of Investigation. The registration process has been vetted through the University Environmental Health and Safety Committee as well as the Chemical Safety and Hazardous Materials Management Committee, and the Occupational Health and Safety Committee. Registration is completed through EHS' Safety Management System. For additional information, please contact EHS at 231-3600. This requirement is relevant to all departments, colleges, laboratories, centers, and institutes where work is performed using hazardous materials or where conditions exist that could result in immediate or serious harm. The registration is required to be updated annually.

You can begin the registration of your chemicals and/or the creation of your lab or workgroup in the SMS by click here.

To download instructions on using the SMS, click here.

Container Labeling

Three types of chemical containers used in the lab or work areas are subject to container labeling requirements:

1. Primary or original manufacturer containers have labels that are prepared by the manufacturer.
2. Secondary containers have labels referred to as alternative workplace labels that are prepared by the user of the chemical container. Secondary containers are defined as containers into which chemicals are transferred from the original manufacturer container for use in a lab or work area.
3. Transfer containers are used solely to transfer chemicals from a labeled container to a secondary container or for immediate use. Such containers may not require a label when immediately emptied.

The labeling requirements for each of these container types is described below and summarized in this Table. Lab personnel or other users must understand the information conveyed by the manufacture on the primary container labels and how to prepare and understand any alternate workplace container labels.

Primary or Original Manufacturer's Labels

Chemical manufacturers, importers, or distributors are required by OSHA to label, tag or mark each container of hazardous chemicals with the following label elements after they classify the hazards of the chemical in accordance with OSHA's Hazard Communication Standard 29 CFR 1910.1200:

• Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
• Product Identifier is how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be used both on the label and in section 1 of the SDS for any given chemical.
• Signal Words on the label alert the reader to the relative severity of hazard posed by that chemical. There are only two words used as signal words, "Danger" and "Warning." Within a specific hazard class, "Danger" indicates a more severe level of hazard, and "Warning" indicates a less severe level of hazard. There will only be one signal word on the label no matter how many hazards a chemical may have. If a chemical has more than one hazard and one of the hazards warrants a "Danger" signal word, then "Danger" should appear on the label, even if its other hazards warrant the "Warning" signal word.
• Pictograms are graphic symbols used to communicate specific information about the hazards of a chemical. OSHA requires chemical hazards to be conveyed via pictograms on primary labels. Each pictogram is determined by the specific OSHA hazard classification(s). See OSHA's nine pictograms and corresponding hazards below.
  
• Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: "Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin." The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it.
• Precautionary Statements describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements:
  • prevention (to minimize exposure)
  • response (in case of accidental spillage or exposure, emergency response, and first-aid)
  • storage
  • disposal

The following general label requirements apply to all primary containers:

• Original manufacturer chemical containers must always be labeled.
• Original containers without adequate identifying labels shall not be accepted from the supplier.
• Labels must be legible and in English.
• Chemical container labels cannot be defaced or in any way be made illegible (until the container is empty and ready for disposal or reuse).
• Labs should routinely inspect chemical inventories for fading, cracking or loose labels on containers.
• Immediately replace primary labels that have (1) faded, (2) become damaged to the point of being illegible, (3) become brittle or (4) fallen off.
• Primary labels of existing chemical inventory that are intact and legible do not need to be replaced with labels containing the new 5 element format of labeling. However, in the event a primary label has been removed, damaged or defaced, lab personnel must re-label existing primary containers as follows:

When primary containers require relabeling, lab personnel may:

1. label the container in accordance with the alternate workplace labeling described in the section below (most simple method) or
2. obtain a new label containing the 5 label elements:
   • create one using information from the Safety Data Sheet,
   • use a purchased labeling software, or
   • photocopy an existing 5 element label.

See also OSHA Brief on Labels and Pictograms

Secondary or Alternate Workplace Labels

When a chemical is transferred from the primary (or original manufacturer's) container to a different container for use, lab personnel must label, tag or mark such secondary workplace containers.

OSHA has not changed the general requirements for workplace labeling. Chemical labels must include both (1) product identifier and (2) hazard identification using words, pictures, symbols, or a combination of these. The goal is to provide at least general information on secondary containers about the identity and hazards of the chemicals which, in conjunction with other information immediately available, can inform users with specific information about physical and health hazards associated with the hazardous chemical.

In order to be acceptable, a label must convey the required information clearly, legibly and in English. Where other languages are spoken in the work area, information may be presented on labels in other languages in addition to the required English words. Virginia Tech does not mandate any single labeling system. Labs can continue to use their current labeling system (NPFA, HMIS, etc.) as long as all of the required information is immediately available to employees when they are in their work areas, and the information is consistent with the hazards conveyed on the new safety data sheets.

Regardless of the system selected, lab or workplace management must train all lab personnel on the workplace labeling system the lab plans to use. Training content must include understanding the labeling system and accessing other information available in the workplace, which together provide workers with all of the relevant hazard information they need to use a chemical safely.

There are currently many labeling systems in use; the best programs utilize a simple labeling system that is readily recognizable and easily understood. Any worker should be able to quickly identify the general hazard of a material and the severity of the hazard by glancing at the label.

The following summarizes the secondary or alternate labeling options available:

1. Create your own container labels. Labs may create their own labeling system using the following guidelines:
   • The full chemical name(s) (as it appears on the SDS) and the primary or general hazard can be written directly on the container, or written/printed on a label to be affixed to the container.
   • For commonly recognized chemicals, the standard chemical formula (not structural formula) or an abbreviation or trade name for the chemical(s)/reagent and the primary or general hazard can be written directly on the container, or written/printed on a label to be affixed to the container.
     • Examples: NaOH, EDTA, IPA, HCl, EtBr, PBS (and % or concentration). If work spaces are shared by individuals with different levels of knowledge of such, this is not recommended.
   • An identifying code from a lab notebook or reference sheet can be used to identify the chemical. This also must be used in conjunction with the primary or general hazard which can be written directly on the container, or written/printed on a label to be affixed to the container.
   • If a container is too small or identity name is too large, a codified name may be used on the container when defined in a lab notebook or reference sheet that is accessible to all. When many chemical names are needed, readily accessible lab notebook references may be used and primary hazards must also be communicated in the notebook or in the general work space using word, symbols or pictograms.
   • The primary or general hazards can be conveyed on container labels using words, pictures, symbols or a combination of these that provide at least general information about the hazards of the chemical.
2. Use established workplace container labeling systems. Labs may use established secondary workplace container labeling systems that display ratings of several hazards and the name of the chemical. Commonly used systems include National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS). A new GHS HMIS system is also available.
   
   Labs may continue to use systems such as (NFPA) diamonds or HMIS requirements for workplace labels as long as the lab workers have immediate access to the specific hazard information (typically via safety data sheets or container labels). A lab using NFPA or HMIS labeling must, through lab-specific training, ensure that lab personnel are fully aware of:
   • the hazards of the chemicals used and
   • how to correctly interpret the hazard rating scheme used; i.e., some systems use numbering schemes in which hazard levels increase with increasing numerical order, whereas others use a decreasing number scheme to indicate increasing hazard levels.
3. Use of the 5 element labels are not required for secondary labels but labs may choose to use them.

Transfer Container Labels

If a lab transfers hazardous chemicals from a labeled container to a portable container that is only intended for immediate use by the employee who performs the transfer, no labels are required for the portable container. However, it is best practice to always label secondary containers in the event the user is distracted or a spill occurs. Labeling will eliminate confusion where there are more than one (unlabeled) containers in use, and ensure that container content is known in the event of an emergency where outside personnel may be involved. Transfer container labeling must include the name of the substance and hazard warnings consistent with alternative workplace labeling described above.

See also: OSHA Brief- Hazard Communication: Standard Labels and Pictograms.

Chemical Transfer Piping

Work activities are often performed in areas where chemicals are transferred through pipes. These pipes are not required to be labeled; however, the employee needs to be aware of potential hazards. Prior to starting work in areas having unlabeled pipes, the employee should contact his/her supervisor to determine:

• The identity of the chemical in the pipes,
• The potential hazards of the chemical, and
• Necessary safety precautions to be taken to protect the employee.

Safety Data Sheets

Chemical manufacturers and importers must evaluate their products 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.

It is essential that the end user have access to the information and become familiar with the hazards prior to working with the substance. Each department or work area must maintain a SDS for each hazardous chemical (or product) they use.

• Information must be stored in an area that is accessible to all personnel who will be working with the hazardous chemical/product.
• The SDSs may be maintained in paper or electronic form, so long as they are readily available to all personnel during the work shift. If SDSs will be stored electronically or on the internet, personnel must have access to a computer with file or internet access. Even if SDSs are stored electronically, hard copies of SDS must be filed if there is not an emergency back-up system for power/equipment failures.
• SDSs must be available upon request in a reasonable time period, generally within 1-2 hours.

SDSs must contain the following sections:

• Identification (includes product name, manufacturer or distributor and contact information, recommended use and restrictions on use)
• Hazard identification
• Composition/information on ingredients
• First Aid measures
• Fire fighting measures
• Accidental release measures
• Handling and storage
• Exposure controls/personal protection
• Physical and chemical properties
• Stability and reactivity
• Toxicological information

Information is available on reading a Safety Data Sheet.

Exposure Monitoring

If engineering controls are being used, such as working within a properly functioning fume hood or glove box, exposure is not expected. However, if engineering controls are not functioning properly, or have not been employed, air monitoring may be warranted. Examples include: fume hood failure, glove box failure, chemical spill, gas leak, explosion, or fire. Contact EHS at 231-5985 to arrange employee exposure monitoring.

Air Monitoring

For more information regarding EHS services and requirements for substances with a Permissible Exposure Limit (PEL), click here.

Hazardous Product Evaluation

Employers must review SDSs for chemicals/products used in the workplace to determine if they may be hazardous to personnel during work applications. Contact EHS for assistance if information provided is confusing or unclear.

If a chemical/product presents either a physical hazard or a health hazard, it is considered a hazardous product, and therefore be included in the plan.

Physical Hazards Combustible liquids Compressed gases Explosives Flammables Organic peroxides Oxidizers Pyrophorics Unstable (reactive) chemicals Water-reactive chemicals

Health Hazards Carcinogens Corrosives Highly toxic chemicals Irritants Sensitizers Toxic Target organ effects Hepatotoxins (liver) Nephrotoxins (kidney) Neurotoxins (nervous system) Hemato-poietic system (blood) Pulmonary (lungs) Reproductive (chromosomal damage or fetal effects) Cutaneous (dermal layer of the skin) Optical (eye or vision)

In addition to hazardous products, the following are examples of items that should be evaluated by the designated responsible person to determine whether or not they should be included in the department's Hazard Communication Plan.

• Wood or wood products that have been treated with a hazardous chemical, and wood that may be subsequently sawed or cut generating dust must be included. (Wood products not treated and not sawed/cut are exempt and do not need to be included.) For example, carpenters who cut/saw/sand wood should include wood in the plan because exposure to some wood dusts may result in potential adverse health affects.
• Articles, that under normal use conditions, have a potential for chemical release must be included, for example, drill bits. (Articles that have no potential for chemical release are exempt and do not needed to be included.)
• Consumer products (that pose a physical or health hazard) used for a duration and frequency greater than what regular consumers would experience must be included. (Consumer "over-the-counter" products used for the same/less duration and frequency than a normal consumer would use are exempt and do not need to be included.) For example, cleaning products used by a custodian or housekeeper should be included in the plan because exposure will be greater than what a regular consumer would experience.
• Nuisance particles which pose a physical or health hazard must be included. (Nuisance dust and particles that do not pose a physical or health hazard do not need to be included.) For example, grain dust.

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Minimizing Chemical Exposures

Because all substances are potentially hazardous - given the right dose and exposure - general precautions for handling chemicals should be adopted. Even for substances with no known significant hazard, exposure should be minimized. In general:

• Avoid skin contact (absorption hazard).
  • Use appropriate personal protective equipment and apparel. Refer to EHS's Personal Protective Equipment Program for more information.
  • Inspect gloves, confinement boxes, hoods, aprons, etc. for contamination or holes which might compromise their protection qualities.
• Avoid inhalation.
  • Do not purposely sniff chemicals.
  • When possible, work with hazardous chemicals/products inside a properly functioning fume hood (for laboratory applications) or in a well-ventilated area.
  • Where engineering controls, such as the use of fume hoods, glove boxes, non-hazardous chemical substitution, or local exhaust ventilation systems are not possible, appropriate respiratory protection should be used. Refer to EHS's Respiratory Protection Program for more information.
• Avoid ingestion.
  • Never taste chemicals.
  • Never pipette laboratory chemicals by mouth suction.
  • Do not eat/drink in areas where chemicals are in use. Contamination of food/drink is possible.
  • Do not store food/drink near chemicals. Chemical vapors may be absorbed by food.
  • Chemicals and chemical equipment must not be allowed in areas designated for the consumption, storage, and handling of food stuffs.
  • Never use laboratory glassware or other containers to store or serve food/beverages.
  • Food must never be stored in the same refrigerator or freezer as chemicals or biological samples. Refrigerators, freezers, microwaves, ovens, etc. designated for food storage and use must be labeled "FOOD ONLY". Refrigerators, freezers, microwaves, ovens, etc. designated for laboratory use must be labeled "FOOD OR BEVERAGE MUST NOT BE STORED IN THIS UNIT".
  • Thoroughly wash hands after handling or using chemicals.
  • Do not smoke in areas where chemicals are in use. Per university policy No. 1010 ( pdf ), smoking is not permitted inside any Virginia Tech building.

Minimizing Accidental Spills and Contamination

In order to avoid accidental spills and/or contamination, proper storage, use, and handling procedures must be established and followed.

• Only a quantity of hazardous chemicals that will used during that shift are permitted out of approved storage locations.
• Work areas must be kept clean and orderly.
• Containers should be kept tightly sealed. Stoppers and other loosely fitting lids are not acceptable for permanent chemical storage.
• Chemicals or products that are no longer needed should be disposed of properly. Do not simply pour liquids down the drain! If the container label does not specify the proper disposal method, contact EHS at 231-2982 for guidance. Chemicals no longer needed or used are considered waste and should be disposed of through EHS. Refer to the section on waste removal.
• Chemical containers should be inspected regularly for signs of leaking, rust, or deterioration which may make them inherently dangerous (ex. crystal formations).
• When it is necessary to move chemical containers "in-house", additional precautions may be necessary. Flammable liquids or corrosives should be transported in an appropriate safety-carrying container. Compressed gas cylinders must be in an upright position, regulators removed, cylinder caps in place, and secured in a cart manufactured for such purposes.

Chemical Storage

Proper storage of hazardous products is an important part of a departments' program. It minimizes the risk of fires, explosions, accidental spills or releases, and helps to maintain a safe path of egress for building occupants in the event of an emergency.

This is an example of poor storage! Specific information regarding storage may be found on the product container label or the SDS. Unless otherwise specified by the manufacturer, store chemicals in a cool, dry, well-ventilated location that is out of direct sunlight. General guidelines for each type of hazardous chemical are provided below.

Flammable/Combustible Liquids

Quantities permitted to be stored in one location are limited and must be confined to an approved storage cabinet/room. Flammable liquids stored outside of an approved cabinet in an emergency exit path are strictly prohibited. When selecting a flammable liquid storage cabinet, make sure it is both OSHA and NFPA compliant. All chemical storage rooms must be reviewed and approved by EHS.

Quantities of flammable and combustible chemicals located outside of storage cabinets/areas should be restricted to one day's supply or to what can be used during a single shift.

Flammable-Storage-Rated-Refrigerators must be used when flammable liquids must be refrigerated. This rating will be shown plainly on the front of the refrigerator. Refrigerator temperatures are typically higher than the flash points of most flammable liquids. Powerful explosions can occur when an inappropriately-rated refrigerator's open circuitry, typically located at the bottom of the unit, comes into contact with heavier-than-air fumes of flammable liquids. If there are non-flammable-rated refrigerators located in the laboratory, a highly visible, permanent label must be affixed that states: "Caution: Do Not Store Flammable Materials in this Refrigerator".

Safety cans are approved containers for secondary containment of flammable liquids. They prevent spillage and have spring-loaded safety caps that prevent vapors from escaping and act as a pressure vent if the can is engulfed in fire. They must be stored in approved flammable storage cabinets/rooms.

Compressed Gases

Compressed gas cylinders, if handled or stored improperly, can be dangerous. For more information on safe handling, use, storage, and transportation, click here.

Corrosives

Corrosive chemicals should be stored in safety-coated containers on shelves below eye level. This storage strategy helps prevent splashes of chemicals to the face and eyes in case a container is dropped and broken. Acids and bases must be stored in their proper chemical classes and segregated from other incompatible chemicals.

Incompatibles

Separate storage areas must be provided for chemicals that may react with each other and create a hazardous condition. Detailed information is available in Appendix B for laboratory applications. Chemicals commonly used in housekeeping should be reviewed for product incompatibilities and storage recommendations. To help determine which chemical groups are incompatible with other chemical groups, review information in the Incompatible Chemical Groups Table or Matrix.

Secondary containment and physical segregation of chemicals may be necessary. Rubber tubs are a convenient and economical solution for separating chemicals into compatible chemical groups. They should be clearly labeled for the chemical group. However, in the case of volatile, incompatible chemicals, there is no substitute for segregation in separate spaces. Chemicals, such as ether and glacial acetic acid, can react violently in the presence of nitric acid in an enclosed cabinet. Know your chemical inventory and store your chemicals properly and safely!

Carcinogens

Stock quantities of carcinogens must be stored in a designated area that is posted with the appropriate warning sign - "DANGER - CANCER HAZARD - AUTHORIZED PERSONNEL USE ONLY". Here's a listing of known human carcinogens that require special storage considerations.

Highly Toxic Chemicals

Highly toxic chemicals (rating of 3 or 4 on the NFPA Health Scale) must be stored away from fire hazards, heat and moisture, and be isolated from corrosive and reactive chemicals. Special care should be taken to ensure that toxic chemicals are not released into the environment.

• Access to the storage areas for highly toxic substances must be restricted.
• Highly toxic chemicals should be stored in unbreakable containers, or in unbreakable secondary containers.
• Cylinders of highly toxic gases should be stored in gas cabinets designed for that purpose, or in a functioning laboratory fume hood designed to contain the accidental release of the cylinder contents.

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.

Air, light, heat, mechanical shock, even water can cause decomposition of some highly reactive chemicals and initiate an explosive reaction. Specialized procedures and control equipment are needed to work safely with most reactive chemicals.
Two common types of reactive chemicals are water reactive and pyrophoric chemicals.

• Water reactive chemicals react violently with water. They may produce flammable hydrogen gas, or give off large amounts of heat.
• Pyrophoric chemicals ignite spontaneously when exposed to the oxygen and or moisture in air at or below 130oF. They must be stored under water, mineral oil or an inert dry atmosphere depending on the substance.

In cases where you must work with reactive chemicals, always read and understand the protocols for manipulating the chemicals and managing any chemical wastes appropriately.

Hazardous Waste Disposal

All hazardous waste must be properly disposed of through EHS. Waste that requires handling and disposal includes chemicals, radioactive materials, infectious materials, lead dust, and asbestos waste. For more information, go to waste disposal.