On January 31, 1990, the Occupational Safety and Health Administration (OSHA) promulgated a final rule for occupational exposure to hazardous chemicals in laboratories. All university laboratories are covered by this ordinance. The compliance date was set to be January 31, 1991.
This new regulation dictates that every laboratory must write and distribute what is termed a Chemical Hygiene Plan (CHP). This plan lies at the heart of the safety program. The CHP must include the necessary work practices, procedures and policies to ensure that employees are protected from all potentially hazardous chemicals in use in the work area. Among other requirements, this standard provides for employee training and information exchange, hazard identification, and in prescribed cases, medical consultation and examinations.
This document is provided not only to satisfy a requirement, but also to serve as a testament to the University's concern about everyone's well being. This plan compliments the SEAS Safety Manual. The manual, originally published in 1983, and substantially revised in 1990 and 1998, offers advice on the safe use of chemicals as well as other issues such as electrical, laser, fire, machine shop, and compressed gas safety. Your local safety officer has a hard copy of this manual.
Please read the CHP as well as the Safety Manual. Both publications should provide you with enough information so that you will be able to conduct your research incident free. Despite the fact that SEAS has historically taken a leadership role in lab safety, the bottom line is that you must exercise good judgment and common sense. Never use any chemical or any new procedure without first becoming thoroughly familiar with any possible associated hazards. Think before you act, is the best advice.
The Associate Dean for Administration has overall responsibility and authority for the safety of personnel in the School of Engineering and Applied Sciences (SEAS) as assigned to him by the President. In the Physics and Earth & Planetary Sciences Departments that responsibility falls upon the Lab Directors. The SEAS/Physics/EPS Chemical Hygiene Officer holds the supervisor of each research group responsible for the safety of individuals within their domain and for the implementation of the OSHA final rule on the Occupational Exposure to the Hazardous Chemicals in Laboratories. Accordingly, supervisors and lab technicians are responsible for the implementation of safety practices within their group or laboratories, including all necessary action to assure compliance with University and department safety guidelines and any other applicable local, state, and federal regulations.
Although compliance with safety regulations, cooperation with safety inspections, and attendance at appropriate safety education programs is mandatory, this is only as a partial discharge of ones responsibility for safety. Regulations cannot anticipate every possible hazard, and inspections are not foolproof. Every person working in the department must participate in the spirit of this Chemical Hygiene Plan if it is going to be successful.
DELEGATION OF RESPONSIBILITIES AT HARVARD
PRESIDENT
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FAS ENVIRONMENTAL COMPLIANCE OFFICER
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ASSOCIATE DEAN FOR ADMINISTRATION in SEAS -- PHYSICS & EPS LAB DIRECTORS
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DEPARTMENTAL CHEMICAL HYGIENE OFFICER (Lenny Solomon)
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LAB SUPERVISOR / LAB TECHNICIAN
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INDIVIDUAL RESEARCHER
The Chemical Hygiene Officer (CHO) is an employee designated by the department, and who is qualified by either training or experience, to provide technical guidance in the development and implementation of the CHP.
The CHO will perform the following tasks:
The Principal Investigators (PI) shall provide continuing support in an effort to ensure that their research is conducted within the guidelines as set forth in the CHP. Each investigator will try and stress to their students and staff the importance of conducting all research in a safe, prudent manner. The P.I. will insist that their students and technicians receive safety training that is appropriate to their research and are provided with the appropriate personal protection equipment (PPE).
In laboratories that are a central departmental facility, the Lab Supervisor will provide the focus for conducting research in a safe manner. Each Lab Supervisor will try and stress to the students and staff the importance of lab safety. Lab Supervisors will be members of the department's Safety Committee and might offer training to student users of the facility.
At risk, of course, is the safety and well-being of the personnel working in the laboratory, regardless of where official responsibility might lie. It is imperative, therefore, that the properties and hazards associated with any chemical are fully understood by each lab worker before that chemical is brought into the laboratory. Material Safety Data Sheets (MSDS) are available for every chemical as well as several reference books. One can obtain MSDS sheets from the CCOHS on-line database , or from the Department of Environmental Health and Safety. In addition, if one has any questions pertaining to the properties of any given chemical, contact the CHO. All lab personnel must read the department's safety manual and CHP. It is his or her responsibility to conduct their research in accordance to these rules and regulations.
The Safety Committee is charged with trying to ensure that programs are in place that will help prevent any accidents from taking place whether they be chemical in nature or due to some other hazard. The CHO will work closely with the department's safety committee to help promulgate safe practices in the handling of chemicals. The safety committee will also play a role in the inspections of laboratories and in safety training.
The Faculty of Arts and Sciences (FAS) Environmental & Safety Compliance Officer (ESCO) will act as a liaison between FAS, the Department of Environmental Health and Safety (EH&S), and individual departments regarding any policy issues. He or she will also act to monitor overall compliance with this OSHA final rule.
The Department of Environmental Health and Safety (EH&S), will provide any and all resource material and expertise necessary in order to conduct research in a safe manner. EH&S is staffed with safety engineers, industrial hygienists, pest control professionals, radiation safety officers, etc. that are available to answer any safety related questions. EH&S conducts their own lab inspections on a yearly basis and is responsible for the certification of all fume hoods. EH&S keeps on file all published MSDS's and makes them available to anyone in the community. A representative of EH&S also attends every departmental safety meeting.
A good, basic practical text that addresses chemical safety in the laboratory is entitled "Prudent Practices for Handling Hazardous Chemicals in Laboratories" (Committee on Hazardous Substances in the Laboratory, Assembly of Mathematical and Physical Sciences, National Research Council; National Academy Press, Washington D.C.; 1981). This reference is available through the CHO. Much of the following has been taken from this text.
All chemicals need to be stored in appropriate containers and in appropriate storage cabinets. Flammables should be stored in vented, fire retardant cabinets, or in fume hoods. Acids and bases should be stored in separate areas. Corrosives should be stored in special cabinets designed for that purpose. All chemicals must be labeled and dated. In addition, the person who ordered the chemical should write his or her name on the bottle.
Catalogs for the various types of commercially available cabinets can be made available by calling the CHO. If research grants cannot support the acquisition of the proper storage facilities, call the CHO who will try to obtain the funds for the purchase.
The School of Engineering and Applied Sciences,the Physics, and EPS Departments have made provisions for an appropriate medical evaluation or examination whenever an employee or student exhibits signs or symptoms associated with an overexposure to a hazardous chemical used in his or her laboratory.
SEAS/Physics/EPS will provide a medical consultation to the lab worker in all cases where a specific event takes place, such as a chemical spill or leak, when there is reason to believe that an overexposure to a toxic substance has occurred. A consultation will be available if an area is chronically found to have a concentration of a hazardous material in excess of the Action Level or Permissible Exposure Level (PEL)as recommended by OSHA. Information regarding OSHA's standards can be found in the Code of Federal Regulations (CFR29). The medical consultation is provided to determine the need for a further medical exam or treatment. The above will be done in a reasonable time period, at no cost to the worker.
The researcher and CHO will try to provide the attending physician with the following information:
Upon evaluation and examination, the attending physician will submit a written opinion to the department which will include the following:
A variety of specialized apparel and safety equipment are commercially available. The CHO has several catalogs that are available for perusal. One must investigate the properties of each chemical in order to choose the appropriate safety gear. For advice regarding the proper choice of PPE one should ask either the PI or EH&S.
Safety gear is required under certain circumstances. Costs incurred for the acquisition of most safety equipment are chargeable to research grants. Equipment used in conjunction with course work is purchased by the department. If for one reason or another an investigator does not have the funds to purchase the required safety gear, please call the CHO to arrange financing.
Below, are some of the more common items in general use:
Harvard is obligated to maintain records of all accidents, and situations that require monitoring of one sort or another. These will be maintained in accordance with the OSHA standard. These will include accident reports, follow-up medical reports, exposure monitoring documentation, training, fume hood evaluations , and lab inspection reports.
On the door of each laboratory there should be a list of the names and phone numbers of people to call if there is an emergency in that laboratory. In addition, any acute hazards associated with that lab should be listed. Forms for this information can be found on this site.
Prominent signs showing the locations of safety showers, eye wash stations, fire extinguishers, fire alarms, fire blankets, exit routes, and other critical safety related equipment, are required.
Fume hoods must be labeled indicating the face velocity and the date of the last inspection. All refrigerators must be labeled indicating if they are used for chemical storage or food storage (they are NOT to be combined).
If any lab worker is in need of a sign of any type, please call the CHO.
BEFORE one works with chemicals, one is obligated to understand what one would have to do in case of an accident. Small chemical spills are a relatively routine occurrence in a research lab and each worker must plan ahead for this type of event.
The correct procedures to be taken should be written down and posted in each laboratory. Location of emergency exhaust switches should be clearly labeled. Spill kits have been provided by the department and are conveniently located in our laboratory space.
If an accident occurs of sufficient magnitude that precludes the cleanup by local personnel, the Cambridge Fire Department can be called in with their "Hazmat" team. This should only be done, however, in cases where a "clear and present danger" exists. Most spills can be handled locally.
If a spill does occur, the CHO should be informed. If appropriate, the nature of the spill will be discussed at a safety meeting to see if future spills of that type can be prevented.
Various training tools are available for the researcher. The Safety Committee maintains both books and videos on a wide variety of safety issues. Call the Chair of the Safety Committee if you wish to borrow any of these materials.
The Safety Committee also organizes and promotes a series of safety talks each Spring entitled the Safety Seminar Series. Everyone is urged to attend any of the talks or seminars that is relevant to their work environment. Talks are usually given on the handling of hazardous chemicals, chemical spills, radiation and laser safety, compressed gases, as well as sessions teaching CPR and First Aid.
It is illegal to pour almost anything down the drain. Most chemicals must be gotten rid of through Harvard's chemical waste disposal program. For more information, call 496-3322.
As a general rule, the air in a chemical laboratory should not be recycled to other parts of the building. As such, the chemical lab should be at a negative pressure in comparison to offices and corridors, and other public spaces. The number of room air changes in chemical labs should be between 4 to 12 per hour.
In this era of excessive use of energy for heating and air conditioning, the rule of thumb for ventilation of chemical laboratories can be in direct conflict with the desire to conserve energy. Depending upon the details of the individual experiments, there certainly are circumstances where not having 100% outside air presents no danger. Such being the case, each lab must be individually analyzed to ensure that the personnel are not at risk if the recycling rule is being violated.
General ventilation in a laboratory is primarily intended to increase the comfort level of the worker. When one is working with toxic substances, one cannot rely on the building system for protection. Transfer, storage, and actual experiments involving toxic substances should normally be confined to a fume hood. In some cases a "canopy" exhaust system can be used. All vacuum pump exhausts must be separately vented if they pump toxic gases.
At least one fume hood should exist in every laboratory where chemicals are used. Before work in a hood is undertaken, the hood should be checked to verify that it is in working order. All fume hoods at the university are tested on a yearly basis by the Department of Environmental Health and Safety. If there is any question as to a hood's performance, call EH&S at 5-2852 and ask for an evaluation ASAP.
Hoods are primarily meant to be used as protection devices when using toxic materials. They are not designed to be storage facilities. Indeed, one can run into trouble if one stores different classes of chemicals in one hood without fully understanding possible reactions from dripping bottles or minor spills. Vented storage cabinets should be the primary instrument for the storage of chemicals.
Based upon the types of chemicals being used in any given hood, emergency plans should be developed in the event of a hood breakdown or power failure. This should be posted near each hood.
Only chemicals that are actively being used should be stored. When acquiring chemicals, only the absolute minimum amounts should be ordered, regardless of price breaks. It is normally much more expensive to get rid of chemicals than it is to buy them.
All chemicals should be properly stored. Flammables must be stored in vented flammable storage cabinets. Acids and bases must be physically separated. Corrosives should be stored in special containers designed for that use. If research grant money is not available for the purchase of the appropriate storage facility, call the chairman of the Safety Committee for advice.
Safety Showers and eyewash stations should be located within close proximity of all chemical work. These stations should be clearly labeled, fully accessible, and the showers should be tested at least twice per year. The eye wash stations should be run once a week.
The general rule is to buy and store the smallest amount of chemicals possible. This is important from several vantage points. Obviously, the smaller the quantities, the less likelihood of a serious accident. Secondly, when one purchases inordinate quantities, it tends to sit on shelves or in cabinets for years. Thirdly, the cost of disposing of chemicals through the hazardous waste program is extremely expensive. Think before you buy.
Up to Table of ContentsThere are some classes of chemicals that are extremely dangerous. High hazard chemicals include select carcinogens, reproductive toxins, and "very deadly" toxins. Another particular danger are the repercussions of putting together two incompatible chemicals.
A select carcinogen is a substance that is; (1) regulated by OSHA as a carcinogen; or (2) is listed under the category "known to be carcinogens" in the Annual Report on Carcinogens published by the National Toxicology Program; or (3) is listed in Group 1 by the International Agency for Research on Cancer.
When working with a select carcinogen, one must work in a designated area such as a fume hood or a glove box. One must clearly understand the safe procedures for the disposal of contaminated waste, and one must have a clear knowledge of contamination procedures.
Before working with a carcinogen, call EH&S for advice.
A mutagen is a substance that changes hereditary genetic material contained in every living cell.
When working with a mutagen, one must work in a designated area such as a fume hood or a glove box. One must clearly understand the safe procedures for the disposal of contaminated waste, and one must have a clear knowledge of contamination procedures.
Before working with a mutagen, call EH&S for advice.
A substance that may be fatal or cause damage to target organs as a result of a single or short term exposure. Substances such as hydrogen cyanide, hydrogen sulfide, and nitrogen dioxide are considered to have high acute toxicity.
A substance that can cause moderate damage to target organs as a result of chronic exposure at relatively low levels.
When working with highly acute or moderately chronic toxic materials, one must work in a designated area such as a fume hood or a glove box. One must clearly understand the safe procedures for the disposal of contaminated waste, and one must have a clear knowledge of contamination procedures.
Before working with a highly acute or moderately chronic toxic material, call EH&S for advice.
| Send comments or suggestions to solomon@huarp.harvard.edu | Last Updated: Thu Apr 10 14:43:35 2008 |
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