FLORIDA A&M UNIVERSITY ENVIRONMENTAL HEALTH & SAFETY DEPARTMENT CHEMICAL HYGIENE PLAN COLLEGE OF PHARMACY AND PHARMACEUTICAL SCIENCES
Chemical Hygiene Plan For College of Pharmacy & Pharmaceutical Sciences Introduction 2 Scope and Application 2 Roles and Responsibilities 2 Chemical and Hazard Identification 4 Standard Operating Procedures 4 Controlling Chemical Exposure 4 Fume Hood Performance Evaluation 5 Information and Training 6 Prior Approval for Laboratory Procedures 8 Medical Examinations and Consultations 8 Particularly Hazardous Substances 10 Laboratory Inspections and Audits 12 APPENDICES Forms 29 CFR 1910.1450 29 CFR 1910.1200 29 CFR 1910.1003 Report On Carcinogens Reproductive Toxins Materials with High Acute Toxicity IARC Monographs 29 CFR 1910.1000 Table Z NFPA 49,325,704 Spill Response Information 1
Introduction This Chemical Hygiene Plan was developed in response to the Federal Occupational Health and Safety Administration (OSHA) regulation, Occupational Exposures to Hazardous Chemicals in the Laboratory (29 CFR 1910.1450), commonly referred to as the Laboratory Standard. The purpose of this Chemical Hygiene Plan is to provide guidelines for prudent work practices and procedures for the laboratory use of chemicals, and to protect laboratory personnel from the potential health hazards of the chemicals they encounter in the workplace. All laboratory personnel must be made aware of this plan. New employees should review the plan and receive safety training before beginning work with hazardous chemicals. The plan is available to all laboratory personnel at all times. Scope and Application The Laboratory Standard Occupational Exposures to Hazardous Chemicals in the Laboratory (29 CFR 1910.1450) covers employees who work with hazardous chemicals in laboratories. At Florida A & M University, this program applies to all individuals working with hazardous chemicals in chemistry laboratories. Work with hazardous chemicals outside of laboratories is covered by the Hazard Communication Standard 29 CFR 1910.1200. Roles and Responsibilities Department Chemical Hygiene Officer Dr. Philip Bigelow is the Chemical Hygiene Officer for the College of Pharmacy & Pharmaceutical Sciences and is responsible for developing and implementing this Chemical Hygiene Plan. The Chemical Hygiene Officer is also responsible for the following: 1. Review and update the Chemical Hygiene Plan at least annually. 2. Investigate accidents and chemical exposures within the department. 3. Act as a liaison between the College of Pharmacy and Environmental Health and Safety (EHS) for laboratory safety issues. 4. Maintain records of training, exposure monitoring and medical examinations. 5. Ensure laboratory Instructors chemical and procedure-specific training. 6. Approve laboratory Instructors return to work following a chemical exposure requiring medical consultation. 7. Review and approve use of particularly hazardous substances. 2
Principal Investigators / Laboratory Coordinator 1. Ensure laboratory instructors attend general laboratory safety training given by EHS. 2. Ensure laboratory Instructors understand how to work with chemicals safely. 3. Provide chemical and procedure-specific training as needed. 4. Provide laboratory Instructors with appropriate engineering controls and personal protective equipment needed to work safely with hazardous materials. 5. Ensure such equipment is used correctly. 6. Ensure laboratory Instructors complete and submit Particularly Hazardous Substance Use Approval forms and submit them for approval before using Particularly Hazardous Substances. 7. Review and approve work with particularly hazardous substances. 8. Provide laboratory Instructor with MSDS notebook of hazardous materials used in the laboratory. Environmental Health and Safety (EHS) 1. Provide consultation for safe work practices for hazardous chemicals 2. Provide general training. 3. Provide safe working guidelines for laboratory Instructors. Develop and maintain the Laboratory Safety Manual containing the safety guidelines. 4. Inspect laboratory fume hoods annually. 5. Conduct exposure monitoring as needed. 6. Audit the departmental program periodically. 7. Review the Model Chemical Hygiene Plan at least annually. 8. Conduct limited laboratory safety inspections annually. 3
Laboratory Instructor 1. Attend the mandatory laboratory safety training provided by EHS. 2. Review the Departmental Chemical Hygiene Plan. 3. Follow procedures and laboratory practices outlined in the Departmental Chemical Hygiene Plan and the Laboratory Safety Manual provided by EHS. 4. Adhere to all University and departmental safety policies and procedures and comply with safety directives issued by Principal Investigators and CHO. 5. Review MSDS Notebook. 6. Use engineering controls and personal protective equipment, as appropriate. 7. Report all incidents, accidents and potential chemical exposures to the principal investigator and the Departmental Chemical Hygiene Officer. 8. Document specific operating procedures for work with particularly hazardous substances, including carcinogens, reproductive toxins and chemicals with high acute toxicity. Chemical and Hazard Identification Chemical manufacturers or distributors perform an assessment of the physical and health hazards of each chemical they produce. This information is included in a material safety data sheet (MSDS) and, in part, on container labels. The manufacturer's label should be kept intact. When a chemical is transferred to another container for storage, the new containers should be labeled with the name of the product, the chemical constituents and hazard warnings. Material safety data sheets received with chemical shipments must be maintained and readily accessible to laboratory workers. MSDS s for stockroom chemicals withdrawn from the Department stockroom are available from the stockroom attendant. Laboratory personnel who receive an MSDS should keep it in the laboratory with easy access to all laboratory personnel. MSDS s for most laboratory chemicals may be obtained from Environmental Health and Safety and through the web pages of the company from which the chemical was ordered. 4
Standard Operating Procedures The Laboratory Safety Manual developed, maintained and distributed by EHS provides general principles for working safely with hazardous chemicals. Principal Investigators, and laboratory Instructors are encouraged to develop and implement more detailed guidelines for specific operations and chemicals in their laboratories. Controlling Chemical Exposure The following criteria are used to determine and implement control measures to reduce exposures to hazardous chemicals. Exposure Monitoring Exposure monitoring is conducted by EHS upon request if there is reason to believe that exposure levels for a particular substance may routinely exceed either the action level or the permissible exposure limit set forth by OSHA. Individuals may contact EHS directly at 599-3442 or by notifying Mr. Andy Balogh, Director, EHS. Results of the monitoring will be made available by EHS to the individual(s) monitored, their Principal Investigator, and the Departmental Chemical Hygiene Officer within 15 working days of the receipt of analytical results. Based on the monitoring results, periodic monitoring may be scheduled at the discretion of EHS, in accordance with applicable federal, state and local regulations. Control Measures Engineering Controls are the primary means of control for exposure to hazardous chemicals. Local ventilation, including fume hoods, ducted biosafety cabinets, glove boxes, vented storage cabinets, and vented canopies are the most common types of engineering controls. Upon request, EHS provides assistance in determining the appropriate type of engineering controls for specific operations. Protective equipment, including gloves, face shields, safety glasses, safety goggles, lab coats and aprons, are used when engineering controls are not sufficient to adequately control exposure. Specifically, this equipment is used to prevent exposure to the skin or eyes. Personal protective equipment is carefully selected to ensure that it is compatible with the chemicals used. Information about selection of appropriate protective equipment is available in the Laboratory Safety Manual. When feasible engineering controls are not adequate to reduce inhalation exposure to acceptable levels, a respirator may be used to minimize exposure to airborne contaminants. Use of a respirator is subject to approval by EHS and must be in accordance with the University Respiratory Protection Policy. 5
Administrative Controls It may be necessary to supplement engineering controls and protective equipment with administrative controls, such as restricting access to an area, restricting use of particular chemicals to a limited group of people, or limiting the length of exposure. Fume Hood Performance Evaluation EHS technical staff evaluates laboratory fume hoods at least annually. An inspection sticker is affixed to each hood to document the evaluation and to provide information to the hood user regarding the measured performance and operational status of the hood. The Laboratory Safety Manual has more information about the safe operation of laboratory hoods and the hood survey program. In the event that a hood does not appear to be operating properly, hood users may contact EHS at 599-3442 for a performance evaluation. Plant Operations Maintenance conducts routine maintenance and repair of fume hoods. Hood users may route requests for hood repair directly to Physical Plant Service Response at 599-3250. EHS does not initiate fume hood maintenance or ensure that it is completed. Upon request, EHS will re-inspect the fume hood following maintenance or repairs. Information and Training All laboratory personnel must receive Laboratory Safety Training when they are first assigned to a work area where hazardous chemicals are present and before assignments involving new exposure situations. General Laboratory Safety Training is provided by EHS. The Principal Investigator provides more specific training for particular materials or operations in a particular work area. EHS MANDATORY Laboratory Safety Training EHS provides Mandatory Laboratory Safety Training sessions each year and by request. Contact EHS at 599-3442 to request training sessions. The general training offered by EHS covers the following topics: 1. An overview of the OSHA Laboratory Standard. Full text of the standard is available on the Internet at http://www.osha-slc.gov/oshstd_data/1910.1450. And is included as an attachment to this document. 2. The content and availability of the Departmental Chemical Hygiene Plan and Laboratory Safety Manual. 3. The availability of material safety data sheets and how to use them. 4. An explanation of permissible exposure limits for chemicals. 5. An overview of methods to recognize hazards, how to evaluate hazards, and common methods to prevent and control exposure. 6
6. The use, function and selection of personal protective equipment. 7. Emergency procedures for fire, injury, chemical exposure, and chemical spill situations. 8. Chemical waste disposal procedures at FAMU. Departmental Information and Training All new laboratory workers must attend a short orientation given by Mr/Ms., Principal Investigator(s), before being issued a key or assignments in the laboratory. During this orientation, the laboratory Instructor(s) is/are made aware of the following information: 1. The location of the Departmental Chemical Hygiene Plan. 2. The Chemical Hygiene Plan for the college of Pharmacy & Pharmaceutical Sciences is maintained in hard copy in the office of Dr. Philip Bigelow at Room Dyson Pharmacy Building. 3. Nature and potential health and safety risks of specific hazardous substances used by the laboratory Instructor. Each Principal Investigator ensures that each individual working in his or her laboratory understands the hazards of and how to properly handle the materials in the laboratory. The Principal Investigator maintains the relevant files, including the MSDS Notebook, in Room Dyson Pharmacy Building.. 4. Proper handling, under all circumstances of hazardous substances used in the laboratory. 5. Location and availability of reference materials, including MSDS s for hazardous chemicals used or stored in the laboratory. 6. Emergency contacts in the College of Pharmacy and Pharmaceutical Sciences. 7. Evacuation procedures. 8. Specific training needed to perform job. 9. Importance of personal protective equipment and how to obtain it. 10. Overview of the various waste streams, including chemical, radioactive, medical and solid waste streams. 11. Location and availability of reference materials, including MSDS s as described under Chemical and Hazard Identification in this Chemical Hygiene Plan. 7
In addition to the training given during orientation and that given by EHS, the Principal Investigator or Lab Manager ensures that each individual working in his or her laboratory understands the following: Training Records Nature and potential health and safety risks of specific hazardous substances used by the laboratory worker: Proper handling, under all circumstances, of hazardous substances used in the laboratory. EHS maintains a database of attendance for mandatory and requested training sessions given by EHS. The Attendance lists and list of all personnel who did not attend the mandatory training sessions are sent to the Chemical Hygiene Officer and FAMU General Counsel s Office after each EHS training session. Personnel are given every opportunity to attend both regular and special make up sessions. The original attendance records for EHS training sessions are maintained at EHS. In-house training records are maintained in the office of the Departmental Chemical Hygiene Officer. Prior Approval for Laboratory Procedures Individuals planning to use Particularly Hazardous Substances, as described later in this document, must complete a Particularly Hazardous Substance Use Approval Form and have it approved by the Principal Investigator and the Departmental Chemical Hygiene Officer prior to their initial use of the substance. Forms are available from the Departmental Chemical Hygiene Officer. Responsibility for determining whether a chemical is a Particularly Hazardous Substance rests jointly with the Principal Investigator and the individual planning to use the substance. Medical Examinations and Consultations Medical Consultation Policy Laboratory workers should seek medical attention under the following conditions: 1. If the individual experiences signs or symptoms associated with a hazardous chemical to which he or she may have been exposed in the laboratory. 2. Where exposure monitoring reveals an exposure level routinely above the OSHA action level or permissible exposure limit. 3. Whenever a spill, leak, explosion or other occurrence results in the likelihood of a hazardous exposure to a laboratory worker. All medical exams will be performed by or under the direction of physicians approved by the Office of University Personnel Relations, Jacquelyn Woods at 599-3611. These shall be provided at no cost to the worker, without loss of pay. 8
Incident Reporting. In the event of any incident that results in a possible overexposure to a chemical, regardless of whether any signs or symptoms of exposure are noted or whether the laboratory employee seeks medical attention, the laboratory employee should complete a Report of Possible Chemical Overexposure Form. Forms may be obtained from the Principal Investigator and/or Chemical Hygiene Officer. The completed form must be submitted to the Chemical Hygiene Officer and copies forwarded to EHS. Completed forms are retained by the CHO in his office at Dyson Pharmacy. Medical Consultation Procedure Reporting Employee Work-Related Injuries All work-related injuries are to be reported immediately to the Office of University Personnel Relations whether or not medical attention is required. All employees, including OPS are covered under the Workers Compensation Program. Only students who are employed by FAMU and are injured during the course of employment are covered by Worker s Compensation. The employee s personal physician should not treat work-related injuries. The immediate supervisor and/or human resources coordinator of the area must be notified and given complete details of the injury. PROCEDURES 1. If the injury is incapacitating or life threatening, arrangements must be made for immediate transport to an emergency medical provider. The following are options: Dial 911 for emergency medical transport Faculty or staff transport injured worker in a University owned vehicle. LAST RESORT faculty or staff transport injured worker in a personal owned vehicle. 2. If the injury is not incapacitating or life threatening, the University Personnel Office will seek approval for treatment via Protegrity Services, Inc. Not reporting work-related injuries in a timely manner may incur unapproved and out of pocket expenses to the employee. Most frequently used initial treatment facilities include the following and require approval prior to treatment: Patients First Patients First Patients First 3258 N Monroe St. 1160 Apalachee Parkway 505 Appleyard Drive 562-2010 878-8843 576-3988 Patients First Dr. Wilton R. Kane 2907 Kerry Forest Parkway 1705 Mahan Drive 668-3380 877-7164 9
The medical provider determines if additional treatment is needed and makes the referral to another provider upon approval by Protegrity Services, Inc. 3. Upon return from the medical provider, the employee should immediately contact the University Personnel Office (Ms. Jacquelyn Woods or Ms. Gillian Nolden at 599-3611). Copies of medical statements, return to work status reports and notices of follow-up should be provided to the Personnel Office. 4. Employees who work in out-of-city locations or employees who are injured (while on University business) off-campus should report to the nearest medical treatment provider in a medical emergency and then report to the University Personnel Office as soon as possible. In non-emergency situations, these employees should contact the University Personnel Office for referral to an approved medical treatment facility. The laboratory Instructor, Principal Investigator or Chemical Hygiene Officer must provide the physician with the identity of the hazardous chemicals encountered in the workplace and the conditions by which the employee was exposed. The material safety data sheet or other safety information resource should be provided to the physician. The examining physician will submit a written opinion to the employee and the Chemical Hygiene Officer using the Medical Consultation Form. The opinion shall not reveal any specific findings or diagnoses unrelated to the occupational exposure. The opinion will include the following information: 1. Recommendations for further medical follow-up; 2. Results of the medical examination, and any test results; 3. Any medical condition revealed during the examination that may place the worker at increased risk as a result of exposure to the hazardous chemical found in the workplace. Based on the physician's opinion, the Chemical Hygiene Officer shall approve the individual's return to work. 10
Particularly Hazardous Substances Particularly hazardous substances are defined to include select carcinogens, reproductive toxins and substances that have a high degree of acute toxicity (such as cyanides and dimethyl mercury). Select carcinogens include any substance that is included on any of the following lists of carcinogens: 1. OSHA Carcinogen List. See Appendices for more information. 2. Annual Report on Carcinogens published by the National Toxicology Program (NTP), including all of the substances listed as "known to be carcinogens" and some substances listed as "reasonably anticipated to be carcinogens" 3. International Agency for Research on Cancer (IARC), including all of Group 1 "carcinogen to humans" and some in Group 2A or 2B, "reasonably anticipated to be carcinogens" Reproductive toxin includes any chemical that may affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogens). High acute toxicity includes any chemical that falls within any of the following categories: 1. A chemical with a median lethal dose (LD 50 ) of 50 mg or less per kg of body weight when administered orally to certain test populations 2. A chemical with an LD 50 of 200 mg or less per kg of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) to certain test populations 3. A chemical with a median lethal concentration (LC 50 ) in air of 200 parts per million (ppm) by volume or less of gas or vapor, or 2 mg per liter or less of mist, fume, or dust, when administered to certain test populations by continuous inhalation for one hour, provided such concentration and/or condition are likely to be encountered by humans when the chemical is used in any reasonably foreseeable manner. A list of the more commonly used particularly hazardous substances is available in the Laboratory Safety Manual however, this list is not exhaustive. Consult the product MSDS or contact EHS for assistance in determining whether a substance is classified as particularly hazardous. 11
Before using a particularly hazardous substance, an individual must: 1. Complete a Particularly Hazardous Substance Use Approval Form. This form is available from the Departmental Chemical Hygiene Officer. 2. Submit the completed form to their supervisor or Principal Investigator for approval. 3. Submit the approved form to The Departmental Chemical Hygiene Officer for his approval. 4. Post the area where the substance will be used with a Designated Area sign, available from the departmental Chemical Hygiene Officer. Follow the procedures outlined in the approved form and in the Laboratory Safety Manual. The Particularly Hazardous Substance Use Approval Form provides documentation of the specific standard operating procedure for use of the substance. These procedures include the use of containment devices and personal protective equipment, decontamination procedures and procedures for safe removal of contaminated waste. Laboratory Inspections and Audits Laboratory Inspections EHS personnel conduct a limited laboratory inspection at the time of the fume hood performance evaluation. A summary of the inspection results and copies of the inspection forms are provided to the Chemical Hygiene Officer. Fire Extinguishers Bruce and Interstate personnel inspect fire extinguishers annually. Should a fire extinguisher be used or if the inspection is out-of-date, e-mail or call Henry James or Gene Jones at 599-8184. Safety Showers and Eyewash Fountains EHS Personnel inspect all safety showers and eyewash fountains annually. Contact EHS at 599-3442 if inspection is out-of-date or for any questions. 12
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