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The Best Chemical Hygiene Officer: Strategies for Success Presented by Dr. James A. Kaufman LSI Founder and President/CEO
The Laboratory Safety Institute The Professional Organization for Safety Conscious Scientists and Science Educators Teach, Learn, and Practice Science Safely
Presented by Dr. James A. Kaufman President/CEO Laboratory Safety Institute Natick, Massachusetts, USA (508) 647-1900 jim@labsafetyinstitute.org
About LSI TRAINING, AUDITS, & INSPECTIONS PROGRAM DEVELOPMENT REGULATORY COMPLIANCE World Safety 2014 Conferences AV (L11) & REFERENCE LIBRARY (A-9) INTERNET DISCUSSION LIST MINI-GRANTS, CONSULTATION CALLS
The Best CHO Webinar Topics CHO Qualifications Experience and Training Protecting the CHO s Liability What s in the Best CHO s CHP CHO Responsibilities How to Hire and Train CHOs How to get needed Resources
A Chemical Hygiene Officer should be an employee who is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan 29 CFR 1910.1450(b) 3
The Missing Word Enforce
Qualified by training or experience Training could include formal safety training, a degree in a safety-related field, and/or attendance at professional training courses Experience could include participation on a safety committee or, other safety-related responsibilities in the workplace
Provide Technical Guidance The Chemical Hygiene Officer sets the tone for a facility s response to the requirements of the Laboratory Standard. In order to provide the appropriate guidance on developing and implementing a CHP, the CHO must be familiar with the hazardous materials that may be encountered in the laboratory.
Issues in the Selection of the CHO Qualifications Education Training Supervisory experience Specific laboratory expertise
Issues in CHO Selection (continued) Communication skills Organizational support People skills Leadership Time to do a good job Compensation Liability
Requirements of the OSHA Lab Standard 29CFR1910.1450 (a) Scope and Application (b) Definitions
Chemical Hygiene Plan written program developed and implemented by the employer which sets forth procedures, equipment, ppe and work practices that (i) are capable of protecting employees from the health hazards presented by hazardous chemicals used in that workplace and (ii) meets the requirements of paragraph (e) of this section. 29 CFR 1910.1450(b)
Physical Hazards Physical hazard means a chemical that is classified as posing one of the following hazardous effects: Explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid, or gas); self reactive; pyrophoric (gas, liquid or solid); selfheating; organic peroxide; corrosive to metal; gas under pressure; in contact with water emits flammable gas; or combustible dust. The criteria for determining whether a chemical is classified as a physical hazard are in appendix B of the Hazard Communication Standard ( 1910.1200) and 1910.1200(c) (definitions of "combustible dust" and "pyrophoric gas").
(c) Permissible Exposure Limits OSHA PELs: TWA, STEL, Ceiling Eight Hours (0.75 ppm*); 15 Minutes (2 ppm); 0 Time (none*); *formaldehyde ACGIH TLVs (0.3 ppm Ceiling*) NIOSH RELs (0.016 ppm TWA*) IDLH (30 ppm*) New Use of the General Duty Clause
(d) Employee Exposure Determination The employer shall measure the employee s exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels for that substance routinely exceed the action level (or in the absence of an action level, the PEL).
www.labsafetyinstitute.org (e) Chemical Hygiene Plan Have a Written CHP Make It Accessible to Employees Elements and Specific Measures Review and Evaluate (at least) Annually
Two Important Words Must Should
www.labsafetyinstitute.org (e) Elements and Specific Measures i. Standard Operating Procedures ii. Control Measures: Determination and Implementation iii. Fume Hoods and Protective Equipment Function Properly iv. Information and Training Provisions
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www.labsafetyinstitute.org (e) Elements and Specific Measures v. Circumstances Requiring Prior Approval vi. Provisions for Medical Consultation and Examination vii. Description of Responsible Personnel viii. Provision for Additional Protection with Particularly Hazardous Substances
An Important Distinction Policy Instruction
www.labsafetyinstitute.org (f) Information and Training Employer Must Provide Re Workplace Hazards At Initial Employment & New Exposure Situations Information Training
www.labsafetyinstitute.org (f) Information Requirements Contents of Standard and Appendices Location and Availability of the CHP PELs, TLVs, and others Signs and Symptoms of Exposure Location and Availability of Known References
www.labsafetyinstitute.org (f) Training Requirements Methods and Observations to Detect Presence or Release of Hazardous Chemicals Physical and Chemical Health Hazards Protection & Emergency Procedures Training in the Employer s Chemical Hygiene Plan
CHO Responsibilities (revised/recommended) (a) Establishes, maintains, and revises the chemical hygiene plan (CHP). (b) Creates and revises safety rules and regulations. (c) Monitors procurement, use, storage, and disposal of chemicals. (d) Conducts regular inspections of the laboratories, preparations rooms, and chemical storage rooms, and submits detailed laboratory inspection reports to administration.
CHO Responsibilities (revised/recommended) (e) Maintains inspection, personnel training, and inventory records. (f) Assists laboratory supervisors in developing and maintaining adequate facilities. (g) Seeks ways to improve the chemical hygiene program. But wait there s more!
What Do Real CHOs Do? Responsibilities in the Job Description Responsibilities Beyond the Job Description
What Do Real CHOs Do? 1. Provide Training 2. Assist Departments and Researchers with Implementation. 3. Manage Hazardous Waste Program 4. Update CHP/Review 5. Conduct Inspections/ Audits 6. MSDS Maintenance 7. Maintain Hazardous Materials Chemical Inventory 8. Write Chemical Hygiene Plan 9. Check Performance of Fume Hoods 10. Respond to Safety Related Inquiries
What Do Real CHOs Do? 1. Respond to other Safety & Health Concerns 2. Hazard Communication 3. Indoor Air Quality 4. Respiratory Protocol 5. Hearing Conservation 6. Confined Space Entry 7. Radiation 8. Biosafety Issues 9. Asbestos Management 10. Ventilation
How to Hire the Best CHOs Safety Conscious v. Safety Unconscious Ask the Lab Safety Question Ask how they would deal with colleagues who won t comply Look for Windsocks Leadership Qualities Communication Skills People Skills
How to Train the Best CHOs Provide at least one professional development course per year Provide at least one professional conference (with membership) per year Provide resource materials for self study Provide for NRCC certification (www.nrcc6.org)
Important Resources Prudent Practices in the Laboratory National Academy Press Safety in Academic Chemistry Laboratories American Chemical Society Handbook of Chemical Safety Oxford Press Handbook of Laboratory Safety CRC Press Fire Protection Guide on Hazardous Materials and Code 45 National Fire Protection Association American National Standards Institute Standards
How the Best CHOs get resources for CHP Make a wish list $1,000 increments Fill out and sign the requisitions Put them in your desk drawer Wait for the end of the financial year
www.labsafetyinstitute.org FOUR SIMPLE QUESTIONS What are the hazards? What are the worst things that could happen? What do I need to do to be prepared? What are the prudent practices, protective facilities, and protective equipment needed to minimize the risk?
www.labsafetyinstitute.org Effective Safety Programs Caring Integration Rewards Repetition Participation
Questions and Answers Dr. James A. Kaufman LSI Founder and President/CEO The Laboratory Safety Institute Natick, MA 508-647-1900 info@labsafetyinstitute.org www.labsafetyinstitute.org