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How to Prepare a Chemical Hygiene Plan

This document provides the background information required to establish safe working practices for chemical use and handling. The responsibility for implementation and enforcement of safe work practices is the responsibility of the principal investigator of each laboratory. This document functions as both a training tool and a reference source.

Standard Operating Procedures

The Office of Environmental Health and Radiation Safety has developed Standard Operating Procedures (SOP) for 14 classes of chemical and physical hazards commonly found in University Laboratories. These SOP's define the minimum use and handling procedures permitted at the University. Adherence to the SOPs by all University of Pennsylvania lab workers is mandatory. It is the responsibility of the principal investigator of each laboratory to review the SOPs and assure that the protective equipment and procedures outlined are in place.

Documentation Requirements

The principal investigator must complete and sign the Chemical Hygiene Work Plan (See example in Appendix E) for his or her laboratory after reviewing all the items outlined in the Standard Operating Procedures applicable to the laboratory. The completed document must be posted in the laboratory by October 1 of each year; when research conditions change; or when new research is initiated.

Each laboratory will display a room sign which provides safety information to visitors and non-research support personnel. The principal investigator is responsible for providing the correct information for the room sign to the Office of Environmental Health and Radiation Safety (Section VII and Appendix I). EHRS will

 

Because of the special hazards associated with the storage of chemicals outside of a laboratory (such as a hallway or in a shared use area) all such storage must be identified. The principal investigator is responsible to complete a Chemical Storage Sign form and return it to the Office of Environmental Health and Radiation Safety (See Appendix J). EHRS will provide the sign and assure that appropriate warning information is included.

Researchers are encouraged to complete the Chemical Hygiene Self Inspection form in Appendix K. This document guides you through an audit of your lab.

Training Requirements

Principal investigators should assure that all laboratory workers are provided with information and training to ensure that they are appraised of the hazards of chemicals present in their work area. This training is mandated by OSHA. In fulfillment of part of this training requirement, the principal investigator shall assure that all new laboratory workers attend Laboratory Safety at Penn (Chemical Hygiene training) provided by Environmental Health and Radiation Safety. Laboratory workers shall attend Refresher Training each year following attendance of initial Chemical Hygiene training. Training schedules are posted on the EHRS website (www.ehrs.upenn.edu). A list of lab safety training programs are listed on the inside back cover of this manual.

The following topics are covered in Chemical Hygiene Training:

  1. The contents of the OSHA standard 29 CFR 1910.1450 and its appendices that shall be available to employees (available from Environmental Health and Radiation Safety).
  2. The location and availability of the University of Pennsylvania's Chemical Hygiene Plan.
  3. The location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory. This may include Material Safety Data Sheets and other reference sources.
  4. The existence of Standard Operating Procedures and their applicability to the laboratory.
  5. The existence of a Chemical Hygiene Work Plan and its applicability to the laboratory.
  6. The emergency procedures provided in the University of Pennsylvania Safer Living Guide.

Additional training provided by the principal investigator should be as specific to the activities conducted in the laboratory as possible. It should include:

  1. The permissible exposure limits for OSHA regulated substances (or published exposure limits for hazardous chemicals where there is no applicable OSHA standard) for chemicals used in their lab. (available from EHRS)
  2. Signs and symptoms associated with exposures to hazardous chemicals used in their laboratory. (available from EHRS)
  3. Health risks (both chemical and physical) posed by the experimental procedures conducted in their lab.
  4. The existence and location of all designated areas in the laboratory.
  5. The selection and use of personal protective equipment appropriate for laboratory tasks. See section XV for additional information on personal protective equipment.

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