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LABORATORY SAFETY POLICY

1.0 PURPOSE and APPLICABILITY

1.1
The University believes it is prudent to minimize all chemical exposures. It is the University's intention to improve the health and safety of students, employees and the public by providing guidance regarding the safe handling of chemicals that are present in the laboratory.

1.2
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.

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2.0 DEFINITIONS and SCOPE

2.1
"Laboratory" means a facility, using relatively small quantities of hazardous chemicals on a non-production basis. "Dry" laboratories such as computer labs are not covered by this policy.

2.2
"Chemical Hygiene Plan" (CHP) is a written program setting forth procedures, equipment, and work practices to protect students and employees from the health hazards associated with laboratory work.

2.3
"Standard Operating Procedures" (SOPs) and "Fact Sheets" are documents that outline the minimum mandatory practices that University personnel must follow in order to safely work with a specific class of chemicals or type of hazard in the laboratory.

2.4
"OSHA", the Occupational Safety and Health Administration, is a federal agency under the Department of Labor that publishes and enforces safety and health regulations.

2.5
Occupational Exposure to Hazardous Chemicals in the Laboratory is an OSHA standard (29 CFR 1910.1450) that regulates laboratory workers engaged in non-manufacturing related work.



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3.0 ROLES and RESPONSIBILITIES

3.1
The University Environmental Health and Safety Committee (EHSC) will review major changes to the CHP.


3.2
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.


3.3
A Principal Investigator (PI) 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 PI must assure that:
  • laboratory workers and others entering laboratory know and follow chemical hygiene SOPs.
  • lab attire is worn and that a laundry service is provided for lab coats
  • appropriate training (as detailed in Section II and XV of the Chemical Hygiene Plan) has been provided to all occupants of the laboratory.
  • unsafe acts, conditions or inadequate facilities are reported to their Chair/Director, Departmental Safety officer or Environmental Health and Radiation Safety.
  • chemical registration is performed. The use of certain toxins is restricted by CDC regulations and may require laboratory registration.
  • The Principal Investigator must complete and sign the Chemical Hygiene Work Plan for his or her laboratory after reviewing the Standard Operating Procedures. 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.

3.4
Individual laboratory workers are responsible for:
  • planning and conducting each operation in accordance with the standard operating procedures (SOP) outlined in this CHP
  • wearing appropriate personal protective equipment including but may not be limited to a lab coat and safety glasses in the laboratory
  • developing good laboratory hygiene habits
  • reporting unsafe acts or conditions to their principal investigator or Environmental Health and Radiation Safety

3.5
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:
    • monitor the procurement, use, and disposal of chemicals used in laboratory.
    • assure, on a periodic basis, that appropriate laboratory chemical hygiene are conducted and that records are maintained.
    • help PI's develop precautions and adequate facilities.
    • know the current legal requirements for regulated substances.


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4.0 PROCEDURES

4.1
Training is provided by EHRS via live presentations and online programs.


4.2
Lab inspections are conducted by EHRS. Inspection results and corrective actions are provided to the PI for implementation.


4.3
Exposure Monitoring may be requested by Lab personnel if there is reason to believe that chemical exposure levels have exceeded, or are likely to exceed, the allowable regulatory level or the PEL.


4.4
Chemical waste is handled in accordance with Penn's Laboratory Chemical Waste Management Guidelines. Drain disposal of hazardous chemicals is not permitted.


4.5
Infectious waste is handled in accordance with Penn's Infectious Waste Management Guidelines.


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5.0 KEY REFERENCES

University of Pennsylvania Chemical Hygiene Plan

Chemical Waste Disposal Guidelines

University of Pennsylvania Formaldehyde Control Plan

Occupational Exposure to Hazardous Chemicals in the Laboratory

Prudent Practices in the Laboratory, National Research Council. ISBN 0-309-05229-7


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PROGRAM TOPICS:

1.    Purpose and Applicability

2.    Definitions and Scope

3.    Roles and Responsibilities

4.    Procedures

5.    Key References


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