Chemical hygiene plan best practices
Life sciences organizations that use hazardous chemicals in laboratory settings should have a written chemical hygiene plan to help protect employees from health hazards associated with those chemicals. A chemical hygiene plan describes the procedures, controls, training and responsibilities used to reduce employee exposure and support safe laboratory operations.
Chemical hygiene plans are addressed in OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories standard 1910.1450, which applies to employers engaged in the laboratory use of hazardous chemicals.
Understanding hazard communications (HazCom) and chemical hygiene plans
Hazard communication (HazCom)
The HazCom standard applies to employers with workplaces where exposure to hazardous chemicals could occur. OSHA classifies a hazardous chemical as “any chemical which is classified as a health hazard or simple asphyxiant in accordance with the Hazard Communication Standard (1910.1200).”
Chemical hygiene plan
Chemical hygiene plans are stricter and are required to be maintained by employers whose business utilizes hazardous chemicals in a laboratory setting. These plans help protect employees from health hazards associated with laboratory chemical use and establish procedures, controls, training and responsibilities to support safe operations.
Determining employee exposure
If the chemicals used are regulated by a standard that requires monitoring, monitoring should be completed. The applicable standard should also be used to determine:
- If and when periodic resampling should occur
- When sampling can be terminated
- How employee notified of monitoring results
If respirators are required to maintain exposure below the Permissible Exposure Limit (PEL) then the employer shall provide the proper respiratory protection at no cost to the employee.
Training employees to work with hazardous chemicals
Training should be provided before employees start working with hazardous chemicals, prior to assignment that includes new exposures/ chemicals, and as needed determined by the employer. Training topics described in the OSHA standard include:
- The contents of the standard and its appendices
- The location and availability of the chemical hygiene plans
- Applicable occupational exposure limits
- Signs, and symptoms of exposure
- The location of known reference materials on chemical hazards
- Safe handling, storage, and disposal of chemicals
Some of this information can be found in the chemical(s)’s safety data sheet (SDS), which is a valuable tool that can be used to support the training provided to employees.
Training should also address:
- Methods and observations that can be used to detect the presence or release of hazardous chemicals, such as monitoring, visual appearance or odor
- Physical and health hazards of chemicals in the work area
- Actions employees can take to protect themselves from hazards
- The employer’s chemical hygiene plan
Key components of a chemical hygiene plan
The goal of the chemical hygiene program is to protect employees from health hazards associated with hazardous chemicals in a lab setting. The following are some of the main components of a chemical hygiene plan (the full standard with all the regulatory requirements can be found in the Helpful links section below. The plan should be reviewed annually and should be readily available.
- Standard operating procedures for safety and health
- Criteria used to identify and implement controls (containment devices, PPE, etc.), and provisions for additional controls if employees are working with particularly hazardous substances
- Details on the methods that will be used to maintain fume hoods and protective equipment so they function properly
- Provisions for medical consultation and medical examinations
- Establish designated areas
- Identify a person responsible for implementing the plan, and a chemical hygiene officer
- A chemical hygiene committee can be established as well if needed
- Employee training (initial, prior to assignment of new exposures, etc.)
- Procedures for decontamination, and safe removal of contaminated water
- Maintain safety data sheets
- Record keeping (monitoring measurements, medical consultations and exams)
When medical consultation is recommended
Employees should be given the opportunity to receive medical attention when:
- The employee is experiencing applicable signs and symptoms
- Exposure monitoring is routinely above action level
- An exposure event occurs (leak, spill, explosion, etc.)
If a medical exam occurs as a result of an exposure, the physician should be provided with:
- The identity of the hazardous chemical or chemicals involved
- A description of conditions under which exposure occurred (quantitative data could be provided if available)
- A description of the signs and symptoms the employee is experiencing