UNIVERSITY OF WISCONSIN OSHKOSH
The intent of this Laboratory Safety and Chemical Hygiene Plan for the University of Wisconsin Oshkosh is:
1. To protect laboratory employees and students from health hazards associated with the use of hazardous chemicals in our laboratories;
2. To assure that our laboratory employees and students are not exposed to substances in excess of the permissible exposure limits (PEL's) as defined by the Occupational Safety and Health Administration (OSHA) and codified in 29 CFR 1910.1000, Table Z-1; and
3. To assist our laboratories' regulatory compliance with the OSHA
Laboratory Standard as codified in 29 CFR 1910.1450.
This plan will be available to all employees and students for review and a copy will be located in the following areas:
Chemistry Stockroom, HS 449
Biology Stockroom, HS 135
This plan will be reviewed annually and updated as necessary.
I. Standard Operating Procedures
A. Specific standard operating procedures for our laboratories are attached to this plan as Appendix A.
B. Laboratory instructors have the responsibility to maintain safe standard operating procedures and maintain or revise the procedures as necessary or needed.
C. The EH & S Officer, has the responsibility to conduct periodic laboratory inspections. At a minimum, an annual inspection will be done in each lab while the laboratory is in use.
D. The chairpersons of the Biology and Chemistry Departments
shall have the responsibility to see that this overall management plan
is implemented and followed.
II. Control Measures to Reduce Employee Exposure to Hazardous Chemicals:
1. Adequate ventilation is essential for maintaining safe levels of exposure. It shall be the responsibility of the laboratory supervisor to discontinue laboratory operations if ventilation is judged to be inadequate for any reason, such as equipment breakdown or accidental spillage.
2. Fume hoods shall be used for all operations which have the potential to produce gases vapors or fumes exceeding the PEL or TLV as given on the appropriate MSDS. Fume hoods shall not be used as chemical storage areas. Storing materials in fume hoods reduces their efficiency, and could lead to inadvertent mixing of incompatible chemicals. Where such use is necessary, it shall be designated as a storage area, not for operations and will be posted as such.
3. Fume hood airflow velocities will be checked annually by Facilities Management Personnel. Inspection results will be posted on each fume hood. Fume hoods with inadequate face velocities will be prominently marked as not suitable for use until repaired.
4. Air quality monitoring will be performed if laboratory supervisors report a condition which might lead to excessive exposure levels as given on the appropriate MSDS.
Storage and Handling
A current inventory of all hazardous chemicals shall be maintained. The Biology and Chemistry Storeroom Managers are responsible for preparing, maintaining and annually updating the hazardous materials inventory for all academic (teaching) laboratories. Faculty/staff assigned personal research areas are responsible for preparing, maintaining and annually updating a hazardous materials inventory for his/her assigned area.
Chemical inventories shall be kept to a minimum in working laboratories. Chemicals shall be stored in a safe manner utilizing, for example, chemical storage cabinets for corrosives and flammables. Chemicals shall be segregated by chemical characteristics to avoid incompatibilities. Alphabetical storage may be used only if chemical characteristics are compatible.
All chemical containers shall be kept capped or lidded when chemicals are not being withdrawn or added. This includes hazardous waste accumulation containers.
Adequate security for chemical storage areas is essential to minimize theft possibilities. Labs shall be locked when competent individuals are not present. Competent individuals shall be those persons trained by a supervising faculty/staff member or principal investigator to perform their work safely, recognize hazards and take appropriate action.
PPE(Personal Protective Equipment)
Routine laboratory personal protective equipment should include protective eyewear when working with hazardous chemicals. Gloves should be worn for work with strong corrosives or with acutely toxic chemicals. Special procedures may require special protective equipment. Faculty/staff supervising special procedures are responsible for ensuring that protective equipment is used and special operating procedures are followed. See Appendix C for Campus Eye Protection Policy.
Respirators may only be worn when engineering controls cannot keep exposure to chemicals below permissible exposure levels (PELs) set by OSHA. Employees may not wear a respirator until they have completed required elements of the Campus Respirator Program. Please contact the EH & S Office for additional information.
FMC coordinates annual fire extinguisher inspections. All faculty/staff are required to maintain clear access and visibility of fire extinguishers.
Eye wash stations and emergency showers shall be available in areas where the eyes or body of a person may be exposed to injurious materials. Eye wash and emergency showers shall be in an accessible location that requires no more than 10 seconds to reach and shall be identified with highly visible signage. Eye wash stations should be flushed monthly by designated personnel. Emergency showers shall be checked by Facilities staff with maintenance documented on the attached tag. Employees will be instructed on the location and proper use of eye wash and emergency showers.
Provisions for additional employee protection must be in place for work with particularly hazardous substances including select carcinogens, reproductive toxins, and substances which have a high degree of acute toxicity. Provisions will include designating areas for their use, use of containment devices such as a fume hood or glove boxes, safe removal of contaminated waste and appropriate decontamination procedures. The Campus policy on the use of Carcinogens is found in Appendix B.
Hazardous Waste Management
All waste generated in Campus laboratories must be managed in accordance
with the University of Wisconsin Oshkosh procedures.
III. Maintenance of Fume Hoods and other Protective Equipment
A. Fume hoods will be inspected at a minimum of once a year by physical plant personnel. Copies of fume hood inspections will be sent to the EH&S Office Fume hoods will be labeled with fume hood inspection dates.
B. The supervisor of Facilities Management is responsible for annual fire extinguisher inspections. Any deficiencies of fire extinguishers in terms of number of extinguishers or locations of extinguishers will be brought to the attention the EH&S Officer.
C. Eyewash and safety shower inspections will be documented as in II.
D. Routine laboratory inspections may be conducted by EH&S Officer
as often as deemed necessary. The schedule of any inspections, checklists,
and reports will be kept in EH&S Office.
IV. Enforcement of Chemical Hygiene Plan
Department Chairpersons shall, when deficiencies in laboratory procedures or equipment pose a significant threat to the safety of lab personnel or students, suspend laboratory operations - in part, or in the whole until the deficiencies are corrected.
If suspension of laboratory operations is necessary, a written report
will be filed with the campus EH&S Officer within 24 hours.
V. Hazardous Chemical Labeling
A. The required information on a hazardous chemical container label is:
Identity of the hazardous substance
Appropriate hazard warning
Name and address of manufacturer
Vendors are responsible for ensuring that their products are delivered with the proper labeling. If an unlabeled container is discovered with the initial shipment from the vendor, it should be refused at time of delivery or sent back to the vendor it came from.
B. Even though vendors have the primary responsibility in labeling containers of hazardous chemicals, UW Oshkosh is responsible for labeling containers of chemicals drawn from the storage containers received from the vendor. At a minimum, these labels will have the identity of the contents written out in full in English and a hazard warning. The labeling and maintenance of labeling for substances used in academic (teaching) laboratories is the responsibility of the Biology and Chemistry Storeroom Managers.
C. Portable containers that are for immediate use by one person during one class period or shift are not required to be labeled. To be defined as a portable container, the container cannot be used for storage nor can it be transferred to another person without passing on the chemical's name and hazards.
D. Waste containers shall have the contents, date of generation,
and generators name listed on its label in addition to the words "Hazardous
Waste." Additional information which will aid in proper waste disposal
should also be included on the label if known.
VI. Hazardous Chemical Inventory
A. The Biology and Chemistry Storeroom Managers have the responsibility
preparing, maintaining, and annually updating the hazardous materials inventory for all laboratories in Halsey Science Center except for assigned research laboratories. The faculty/staff person responsible for individual research laboratory areas will be responsible for inventory maintenance for these laboratories.
B. The hazardous materials inventories will be kept in Chemistry Storeroom, HS-449 and the Biology Storeroom, HS-135. Copies of these inventories shall be submitted to the EH&S Officer as they are updated (electronic copies are acceptable).
C. The content of the inventory will include the following.
1. The chemical or proper name of the substance as listed on the MSDS.
2. Location of chemicals on site.
VII. Material Safety Data Sheets (MSDS)
A. Each department will maintain a central MSDS file for each hazardous chemical for 30 years after the last date the chemical was received on site. Faculty, staff and students will have access to MSDS files during normal office hours. Copies will be available on written request to the EH & S Office.
B. The Biology and Chemistry Storeroom managers will have the responsibility
of maintaining MSDS files for their respective departments with the exception
of assigned research laboratories. Faculty members responsible for individual
research labs are responsible for maintaining MSDS files for these labs.
VIII. Employee and Student Information and Training
A. Each employee covered under this standard will be provided with information and training to inform them of the hazards of the chemicals present in their work area. The training will be arranged by the EH & S Office, as requested.
B. Laboratory teaching assistants will be provided training prior to their supervision over other students. This training will be provided by the EH & S Office, as requested.
C. Research Assistants will receive training from their research supervisor.
D. Students will be provided training during initial laboratory sessions of each course. Such training will be documented via student signature on a training acknowledgement form. Course instructors are responsible for student training.
E. Documentation of employee training will be maintained in the EH & S Office.
F. Training will include:
1. The contents of 1910.1450, the Laboratory Standard, and its appendices
2. The contents, availability, and location of the written Laboratory Safety and Chemical Hygiene Plan.
3. Information concerning the OSHA permissible exposure limits including discussion of the meaning of all terms, significance of exposure, and location of copies of the exposure limits.
4. Signs and symptoms associated with exposure to hazardous chemicals in laboratories.
5. Location of reference materials including all MSDSs for chemicals in the laboratories. The MSDS format will be reviewed to assure all employees are familiar with their content and can use such sheets to obtain additional information as necessary.
6. Methods to detect the presence or release of chemicals in their work areas. This information will include air monitoring information, odor thresholds, etc.
7. Specific information concerning the physical and health hazards of the chemicals in laboratory work areas.
8. Specific information regarding the inventory of chemicals in the laboratory.
9. Specific information regarding measures to protect employees from
chemical hazards including specific work practices, standard operating
procedures, emergency procedures, and personal protective equipment.
IX. Medical Consultation and Examination
A. The Laboratory Standard mandates that employers provide medical attention, examinations, and follow-up examinations at the physician's discretion. This medical attention, etc. is required under the following circumstances:
1. Whenever an employee develops signs and/or symptoms associated with a hazardous chemical to which they may have been exposed; or
2. Whenever exposure monitoring reveals an exposure level above the OSHA action level or exposure above the permissible exposure level for OSHA regulated substances; or
3. Whenever an event takes place in the work area such as a spill, leak, explosion, or other occurrence which results in the likelihood of a hazardous exposure. Such an occurrence requires an opportunity for medical consultation for the purpose of determining the need for a medical examination.
B. Departmental Chairpersons shall provide the examining physician the following information:
1. Identity of the hazardous chemical to which the employee may have been exposed,
2. A description of the conditions of exposure including exposure date if available,
3. A description of the signs and symptoms of exposure, if any, that the employee is experiencing, and
4. A copy of the relevant MSDS.
C. The employer shall request a written opinion from the physician including:
1. Recommendations for future medical follow-up,
2. Results of examination and associated tests,
3. Any medical condition revealed which may place the employee at increased risk as the result of chemical exposure, and
4. A statement that the employee has been informed by the physician of the results of the examination or consultation and told of any medical conditions that may require additional examination or treatment. The material returned by the physician shall not include specific findings and/or diagnoses which are unrelated to occupational exposure.
D. Department Chairpersons have the responsibility to maintain a
file concerning any events and resultant medical examinations or consultations.
Copies of any medical examination request and results shall be sent to
the EH& S Officer.
A. Appropriate signage will be placed on laboratory doors/entryways, in laboratory areas, and in chemical storage areas. Signage will include:
1. Emergency Response Procedures.
2. Phone numbers of emergency responders.
3. Notification of any particular potential hazards such as ionizing
XI. Responsibilities Under the Chemical Hygiene Plan
A. The chairpersons of the Biology and Chemistry Departments, shall have the responsibility to see that this overall management plan is implemented and followed.
B. Department Chairpersons/Faculty and Staff in conjunction with the EH& S Office , have primary concentration responsibility for the implementation and maintenance of the Laboratory Safety and Chemical Hygiene Plan. In addition these individuals will have the following responsibilities:
1. Annual review and update of the Laboratory Safety and Chemical Hygiene Plan (if necessary).
2. Maintenance of records of
a. laboratory inspections
b. air monitoring
c. medical consultation
d. accident/incident reports
3. Provide examining physician necessary information when a medical consultation is required.
C. The EH & S Officer will have the following responsibilities:
1. Conduct annual lab inspections.
2. Conduct air quality monitoring in laboratories when requested. Provide regular faculty and teaching assistant training as requested.
3. Assist in proper disposal of hazardous waste.
D. The laboratory instructor has the primary responsibility of maintaining safe standard operating procedures as listed in Appendix A of the Laboratory Safety and Chemical Hygiene Plan. In addition the laboratory instructor has the following responsibilities:
1. Provide student training as described in the Laboratory Safety and Chemical Hygiene Plan. Documentation of student training will be maintained by the instructor.
2. Report malfunction of safety equipment to the EH & S Office.
3. Promptly file an accident/incident report with the EH & S Office if an accident or spill should occur.
4. The laboratory instructor will not permit laboratory operation to continue if ventilation is judged to be inadequate for the procedure being conducted.
E. Biology and Chemistry Storeroom Managers will have the following responsibilities:
1. Will be responsible for maintaining teaching laboratory and stock room chemical inventories. This inventory will be updated annually.
2. Maintain inventories using safe storage methods.
3. Ensure that all containers are correctly labeled.
4. Maintain MSDS files on all chemicals in the inventory.
5. Proper disposal of hazardous wastes generated in the laboratories.
F. Facilities Management Personnel will conduct regular fume hood inspections and oversee the maintenance of eyewash stations and laboratory safety showers.
G. The Facilities Management Supervisor is responsible for annual fire extinguisher inspections.
H. Faculty assigned one and two person research laboratories or other research areas are responsible for meeting compliance with the OSHA Laboratory Standard for the area assigned to them. At a minimum this requires:
1. Adoption and implementation of the Laboratory Safety and Chemical Hygiene Plan.
2. All containers in laboratory are correctly labeled.
3. Maintain a hazardous chemical inventory with an annual update. A copy of the inventory should be submitted to the EH & S Office for inclusion in the campus inventory.
4. Maintain a current MSDS file of all hazardous chemicals in the inventory and present in the laboratory. Copies should be submitted to the EH & S Office for inclusion in the campus MSDS file.
5. Establish and maintain standard operating procedures in the laboratory. Establish additional procedures for carcinogens, reproductive hazards and other acutely hazardous substances.
6. Complete and document an annual laboratory inspection. Ensure
that fume hood (if present) is operating properly, eye wash stations are
inspected annually and flushed
weekly, emergency showers inspected annually, and all safety equipment in good operating condition.
7. Ensure that all students and employees using laboratory have received training as listed under VIII. F.
8. Ensure that appropriate personal protective equipment is available for all students and employees using the laboratory.
9. Ensure that all waste disposal follows current legal requirements.
STANDARD OPERATING PROCEDURES
I. Accidents and Spills
A. Eye contact: promptly flush eyes with water for a prolonged period (15 minutes) and seek medical attention.
B. Ingestion: follow the instructions on the MSDS
C. Skin Contact: promptly flush the affected area with water and remove contaminated clothing. If a symptom persists after washing, seek medical attention. Use safety shower if necessary.
D. Clean up: promptly clean up spills, using appropriate apparel and equipment and dispose of properly.
II. Avoiding Routine Exposure
A. Use appropriate personal protective equipment.
B. Do not smell or taste chemicals except as directed by an instructor. Vent any apparatus which may discharge toxic chemicals (vacuum pumps, distillation columns, etc) into local exhaust devices.
C. Inspect gloves and test glove boxes before use.
III. Eating, smoking, etc.
A. Do not eat, smoke, drink, chew gum or apply cosmetics in areas where laboratory chemicals are present; always wash hands thoroughly after handling chemicals before eating.
IV. Equipment and Glassware
A. Handle and store laboratory glassware with care to avoid damage. Do not use damaged glassware.
B. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Use only for its intended purpose.
V. Compressed gas cylinders: handle with care. Do not move without protective cap and secure tank at all times. Anyone handling compressed gas cylinders must watch the video “ Compressed Gases: Safe Handling Procedures”, # V-6800 published by the American Chemical Society.
VI. Mouth Suction
A. Do not use mouth suction for piping or starting a siphon.
VII. Personal Apparel
A. Confine long hair and loose clothing. Wear shoes at all times in the laboratory, however, do not wear sandals or perforated shoes.
VIII. Person Protection
A. See Appendix D for eye protection policy.
B. Wear appropriate gloves when the potential for contact with toxic materials exist; inspect the gloves before each use, wash them before removal, and replace them periodically.
C. Use any other protective and emergency apparel and equipment as appropriate or as directed by instructors.
D. Remove laboratory coats immediately upon significant contamination.
A. Before beginning any new operation seek information and advice on potential hazards and how to avoid exposure or injury.
X. Use of Fume Hoods
A. Fume hoods are to be used for any operation which may result in the release of toxic vapors or dust. As a rule of thumb, use a hood or other local ventilation device when working with any appreciable volatile substance with a PEL (Permissible Exposure Limit) of less than 50 ppm.
B. If possible, confirm hood performance before use. Long term storage of hazardous materials is forbidden, but when used for short term, storage shall be kept to a minimum and do not allow items to block vents or air flows.
XI. Waste Disposal
A. All waster shall be disposed of in a manner which is consistent with UW Oshkosh procedures.
XII. Working Alone
A. No one, (including Faculty/Staff) my work alone if the work involves the use or manipulation of hazardous materials, or if hazardous conditions may exist (e.g. high pressure, high voltage, vacuum systems). “Working Alone” means working out of sight or sound communications with another person for more than 5 minutes at a time. Overnight procedures involving high pressure, high voltage, or vacuum systems are only to be done when there is no other way of accomplishing this procedure and exposure to potential hazards are minimized.
B. Undergraduate students in scheduled courses must be supervised at all times. Students may not work out of hours for any scheduled course unless specific permission is granted by the faculty person supervising the labs and that no hazardous materials will be used and hazardous conditions do not exist.
C. Student researchers (both graduate and undergraduate) may never
work alone if working with hazardous chemicals or in a hazardous environment.
The OSHA Laboratory Standard requires provisions for additional employee (and student) protection when working with particularly hazardous substances including carcinogens and reproductive toxins. Provisions suggested include:
1. Establishment of a designated area for use.
2. Use of containment devices (i.e. fume hood).
3. Decontamination procedures.
UW Oshkosh has the following policy concerning the use of carcinogens in a laboratory setting:
Carcinogens may not be used in laboratories where a fume hood is not available. If carcinogens are being used in a laboratory with a functioning fume hood the following must be done.
1. Label carcinogens and the area appropriately.
2. Inform all employees and students of the nature of the hazard and the required work procedures.
3. Designate the fume hood as the area in which carcinogens are to be used.
4. Make sure the fume hood functions properly and employees and students know how to correctly use the hood.
5. Make sure goggles, gloves and lab aprons are used when handling carcinogens.
It is the responsibility of the faculty or staff person supervising
a laboratory to ensure that these procedures are followed.
EYE PROTECTION POLICY
All affected employees and students shall use appropriate eye or face protection when exposed to eye or face hazards from:
1. Flying particles
2. Molten metal
3. Liquid chemicals
4. Acids or caustic liquids
5. Chemical gases or vapors
6. Potentially hazardous light radiation
Employees and students exposed to flying particles must wear safety glasses. Employees and students exposed to 2, 3, 4 and/or 5 listed above must wear chemical splash goggles. Employees and students exposed to potentially hazardous light radiation shall use equipment with filter lenses that have a shade number appropriate for the work being performed.
All protective eye and face devices purchased after July 5, 1994 must comply with ANSI Z87.1-1989.
Experiments that involve special hazards such as concentrated acids or bases, systems under high pressure or reduced pressure, and techniques that use active metals such as sodium shall be conducted with extra precautions. The laboratory supervisor shall determine what additional eye protection should be used, such as full face shields or safety windows, in addition to chemical splash goggles.
The laboratory instructor is responsible for enforcing eye protection
policies in his/her laboratory. Laboratory Instructors must explain
course eye protection policies during the first class period. Normally
students will be required to purchase their own eye protection.
Incident reports are to completed and filed for the following circumstances.
1. Significant personal injuries, such as those incurred because of cuts, burns, electrical shock, etc. Report any incident where first aid is involved with the exception of minor cuts or burns. Any incident which requires treatment by an emergency responder or at the Student Health Center shall be reported.
2. Fires that require the use of a fire extinguisher.
3. Mercury spills other than breakage of a standard mercury thermometer.
4. Concentrated (>6 N) acid and base spills exceeding 100 ml.
5. All spills of flammable chemicals exceeding 100 ml.
6. All spills of toxic chemicals exceeding 100 ml.
7. Exposure incidents involving blood or other potentially infectious materials.
8. Any spill where a chemical is accidently released into the sewer
system or spilled onto the ground.
Incident reports shall be completed and forwarded to the EH& S Office. An Incident Report shall contain all of the following:
Date of the Accident
Personnel Involved (including all student names)
Description of the accident
Cause of the accident (if known)
Name of person submitting the incident report and their signature and date.