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Introduction

The University of Pennsylvania continually strives to provide a learning, teaching, and research environment free from recognized hazards. Pursuant to Occupational Safety and Health Administration Regulations (29 CFR 1910.1450 and 1910.132) the University establishes this Chemical Hygiene Plan (CHP) to protect employees and students from potential health hazards associated with the handling, use, and storage of hazardous chemicals in laboratories.

Scope

The Chemical Hygiene Plan applies to all laboratories at the University of Pennsylvania, except those clinical laboratories located in the Hospital of the University of Pennsylvania (HUP). The hospital has its own Chemical Hygiene Plan.

The safe storage, use and disposal of chemicals in the laboratory requires policies for the protection of students, employees, and the environment. Chemicals, which include reagent grade materials through trade name products and wastes, are the focus of increased regulatory actions by federal, state and local governments. The purpose of this Chemical Hygiene Plan is to provide the chemical user with basic safety information regarding the use of chemicals. This Chemical Hygiene Plan forms the foundation of the safe use of chemicals in the laboratory. The Chemical Hygiene Plan is an adjunct to the University of Pennsylvania Hazard Communication Program, copies of which are available at the Office of Environmental Health and Radiation Safety, 3160 Chestnut Street, Suite 400, phone 215-898-4453.

The manual is not intended as an encyclopedia of chemicals and their hazards; it will not contain listings of hundreds of chemicals that employees may encounter while working in research and development. Although numerous chemicals may be mentioned for the most part they will serve as illustrations for broad categories of hazards, except in the case of chemical incompatibility charts or listings.

Biological Safety

The safe use and development of biological organisms requires control measures similar to those found in chemical safety. However, biological agents may have the added dimension of self-replication. See the University of Pennsylvania Biological Safety Manual, for proper work practices involving biological agents.

Radiation Safety

The safe use and development of radioactive materials require control measures similar to those found in chemical safety. However, the use of radioactive materials has additional requirements. See the University of Pennsylvania Radiation Safety User's Guide for safe work practices involving radioactive materials

Responsibilities

A. The University Environmental Health and Radiation Safety Committee (EHSC) is responsible for recommending to the Vice Provost for Research the minimum requirements of the CHP that all laboratories must follow. The EHSC will review the CHP in December of each year.

B. Deans and/or department chairpersons are responsible for establishing and maintaining compliance with the CHP. To this end, deans and department chairs may wish to designate safety officers within the Schools or departments. A designated safety officer should hold the rank of associate professor or full professor.

C. A Principal Investigator (PI) [Laboratory Supervisor] has the overall responsibility for compliance with the CHP in his or her laboratory. This responsibility may not be shifted to inexperienced or untrained personnel. The investigator must assure that:

  1. laboratory workers and others entering laboratory know and follow chemical hygiene rules.
  2. lab attire is worn and that a laundry service is provided for lab coats
  3. appropriate protective equipment is provided, is in working order and is used as detailed in Section XV.
  4. appropriate training (as detailed in Section II and XV) has been provided to all occupants of the laboratory.
  5. unsafe acts, conditions or inadequate facilities are reported to their Chair/Director, Departmental Safety officer or Environmental Health and Radiation Safety.
  6. chemical registration is performed. The use of certain toxins is restricted by CDC regulations and may require laboratory registration.

D. Individual laboratory workers are responsible for:

  1. planning and conducting each operation in accordance with the standard operating procedures (SOP) outlined in this CHP.
  2. wearing a lab coat and safety glasses in the laboratory
  3. developing good laboratory hygiene habits.
  4. reporting unsafe acts or conditions to their principal investigator or Environmental Health and Radiation Safety.

E. The Office of Environmental Health and Radiation Safety (EHRS) is responsible for working with faculty, staff, students, and others to develop and implement appropriate chemical hygiene practices and procedures. To accomplish this:

  1. The director of EHRS or his designee shall be the University Chemical Hygiene Officer.
  2. EHRS will establish procedures to:
  3. monitor the procurement, use, and disposal of chemicals used in laboratory.
  4. assure, on a periodic basis, that appropriate laboratory chemical hygiene are conducted and that records are maintained.
  5. help PI's develop precautions and adequate facilities.
  6. know the current legal requirements for regulated substances.

F. Wherever hazardous chemicals are used a written chemical hygiene plan must be developed and implemented. The Chemical Hygiene Plan (CHP) must be capable of protecting laboratory workers and others from the health hazards associated with the hazardous chemicals used in the laboratory.

This manual serves as the reference document for all Chemical Hygiene Plans developed at the University of Pennsylvania.

The Chemical Hygiene Plan (CHP) must be:

  1. Available in the laboratory for laboratory workers, safety officers, EHRS.
  2. Consistent with the University safety policies.

G. According to federal regulations and standards, the Chemical Hygiene Plan (CHP) must include at a minimum:

  1. Standard operating procedures (SOP's) for each activity that uses hazardous materials. The SOP's may be generic in nature, that is, similar operations using chemicals of the same general class may be covered by one SOP.
  2. Criteria used to determine the risk associated with chemicals and the procedures used. For example, material safety data sheets (MSDSs) may be used for this determination. NOTE: To avoid underestimating risks, it must be assumed that a mixture is more toxic than its most toxic component and that all unknown substances are toxic.
  3. Criteria used to determine and implement control measures to reduce laboratory workers' exposure to hazardous chemicals including engineering controls, the use of personal protective equipment, and hygiene practices. Particular attention must be given to the selection of control measures for chemicals known or suspected of being carcinogens, reproductive hazards, or acutely toxic chemicals.
  4. Provisions for laboratory worker training must be commensurate with the severity of the hazard that the laboratory worker is exposed. Specialized training may be required for laboratory workers using carcinogens, reproductive hazards, or acutely toxic chemicals.

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