Chemical Hygiene Plans

A: Per the OSHA Hazard Communication Standard (29 CFR 1910.1200) and the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450; also known as the OSHA Laboratory Standard), a hazardous chemical is any that is capable of: 1) causing an acute or chronic health condition in humans, including simple asphyxiation through oxygen depletion (e.g. nitrogen, helium, carbon dioxide, etc.); 2) adversely impacting the environment; and/or 3) inducing physical injury or damage through the release of energy (e.g. flammable substances, explosives, shock sensitive, etc.).  The following hazardous chemicals are covered by the CHP:

• Flammable liquids or solids
• Corrosive liquids or solids
• Organic peroxides
• Oxidizing material
• Carcinogens, mutagens, or teratogens
• Toxic or poisonous materials
• Environmental toxins
• Inhalants, controlled substances, or other drugs with hazardous properties
• Reactive solids or liquids (pyrophoric, air/water reactive, etc.)
• Explosive materials
• Compressed gas cylinders and lecture bottles
• Cryogenic materials
• Any other hazardous substance not excluded by the following section.

The following are not considered hazardous chemicals subject to the CHP:

• Consumer products (e.g. cigarette lighters) in the workplace that contain hazardous materials and are for personal use
• Prescription and over-the-counter medication taken by personnel
• Biohazards
• Radioisotopes
• Gasoline, oil, or other mechanical fluids found in University- owned or private vehicles and considered integral to the vehicle’s operation
• Hazardous materials that are part of the building (e.g. lead paint) or contained in an article (e.g. furniture)
• Non-hazardous substances (e.g. water, agarose, sand, glass beads, etc.).

The chemical hygiene plan provides a basis to inform laboratory workers about hazardous chemicals at the laboratory location. Chemical hygiene plans relieve laboratories from difficult duties required under other state and federal regulations. This template is also designed to simplify compliance with federal environmental protection laws and regulations.

While the lab-specific chemical safety guide is designed to document all the safety practices specific to a laboratory, it doesn’t have all the elements that are required by OSHA’s Laboratory Standard (such as the description of how we ensure that fume hoods are functioning, provisions for medical consultation, and our policy for handling prior approvals). The campus chemical hygiene plan includes the required OSHA elements, outlines specific responsibilities, and provides a place for documenting University of Tennessee policies related to chemical safety.

It depends. If the same experiments, chemicals, and laboratory personnel use all locations, then the same chemical hygiene plan can be used. If different experiments, chemicals, and laboratory personnel are in each location, then a specific chemical hygiene plan should be for each location.

If you have an up-to-date lab-specific chemical hygiene plan that meets the requirements of 29 CFR 1910.1450, that can be used as the laboratory chemical hygiene plan.

Currently, we do not require submission. The lab can save their CHP in the Chemical Inventory SharePoint Site so that it can be easily accessible to everyone in the lab. However, the chemical hygiene plan must be submitted upon request and this can always be sent to the Chemical Safety Officer for review if you want to. The fillable PDF version should make this easy. If you need assistance, please contact the EHS Lab Safety Services.

It depends. The lab chemical hygiene plan is designed to ensure compliance with the lab standard. If your department CHP covers all the elements in the template, is consistent with the campus CHP (though it can be more restrictive), and covers the procedures specifically performed in your laboratory, then you should be fine. Often, however, the departmental CHP will likely need to be supplemented to include your specific operations. The lab can pick out Lab Specific Forms from Step 2 to supplement existing CHP.

Maintaining a paper copy is not necessary if everyone has access to the documents. These are designed to be useful documents so if paper copies increase access, then they should be printed. By updating the Excel file in the Chemical Inventory SharePoint Site all lab members and EHS will have access to the CHP.

Typically, lab operations cannot be described in one SOP so generating multiple copies of the SOP form is necessary. Having a separate template for this section available makes it easier to generate multiple SOPs.

No, that is not the intent of the SOP form. The procedure is often described elsewhere – such as a book, journal article, or lab procedure manual. The purpose of the SOP form is to document all the required safety aspects of the procedure. You should reference the actual procedure in the chemical hygiene plan SOP form.

Many lab procedures are simply variations on the same theme. In instances where the safety considerations are the same then it is appropriate to cover the procedures on the same form. Just make sure all procedures are listed that cover the SOP.

No. The CHP template provides a means to document training, but if you should have a system that already works for you then that is acceptable.

The lab chemical hygiene plan is partially about complying with the regulations, but more importantly, it is about ensuring that proper hazard assessments are performed, and training is done. Documenting safety practices is important. The old days of oral tradition just does not work in today’s academic laboratories. There have been some well-documented instances where lab-specific safety policies were not followed because they were not written down and were not really understood. These resulted in significant accidents. When completed it should be a useful document for all who work in the lab.