Components of a chemical hygiene plan
What is a Chemical Hygiene Plan?
A Chemical Hygiene Plan (CHP) is a requirement of what is often referred to as the Laboratory Standard, which is the Occupational Safety and Health Administration’s (OSHA) promulgated standard titled Occupational exposure to hazardous chemicals in laboratories (29 CFR 1910.1450).
This standard sets forth safety and health considerations for the unique work carried out in laboratories where hazardous chemicals are handled in limited amounts on short timescales, and where procedures and chemicals may change often.
The standard applies to employers that are engaged in “laboratory use of hazardous chemicals” in a non-production environment, although it does include quality control labs that may be a part of production operations.
The laboratory employer must designate a Chemical Hygiene Officer (CHO) who is responsible for implementing the CHP. The CHO is a person “qualified by training or experience” that will provide technical guidance on the development of the CHP.
For some employers, the CHO may be the same individual as the Environmental Health and Safety Manager (EHS) or Safety Manager, but in other cases, these positions may be held by two different people. The information we will discuss is aimed at individuals who may be new to the process of developing a CHP.
A CHP is a formal, written plan that is meant to address the policies and procedures used by an employer to ensure the safety of laboratory workers. The Laboratory Standard does outline the required components, which we will review and discuss next.
Components of a Chemical Hygiene Plan
There are several required components to be considered during the development of a CHP. Emphasis on exposure risk and the type of controls that are necessary to limit those exposures to laboratory workers should be a high priority. A CHP is all about providing a structured and controlled plan that ensures a safe and healthy environment for laboratory workers. This is where software solutions come in handy to provide the infrastructure you need for managing these processes.
Safety controls to reduce exposure
A CHP must outline the criteria of how to determine the appropriate control measures and the implementation of these control measures in order to reduce employee exposure.
You will need to consider engineering controls, such as chemical fume hoods and ventilation systems, personal protective equipment (PPE), and hygiene practices.
If the lab handles extremely hazardous chemicals, such as hydrofluoric acid, more attention and detail to necessary control measures for those types of chemicals should be emphasized in the CHP.
Standard operating procedures (SOP).
Each activity that requires the use of hazardous chemicals must have a SOP in place. The SOP should outline how to conduct the lab task safely. For this step, you will want to understand how much of the chemical is being used, potential exposure routes, and how the hazardous waste will be handled.
Safety controls, such as the required use of a chemical fume hood or what PPE (such as a face shield or lab coat) should be worn, need to be identified for the task at hand. The SOP should always consider the life cycle of the hazardous chemical being used.
If any procedures require advanced approval before implementation, those pre-approval activities must be identified in the CHP.
Ensure fume hoods and other protective equipment are functioning properly
Chemical fume hoods are one of the engineering methods that allow for the ventilation of airborne contaminants as exhaust out of the building. The fume hood sash creates a barrier from and containment of fires and small explosions.
Correct performance and functionality of protective equipment are vital to keeping the employee safe from hazardous chemical exposure. The CHP should identify and discuss key measures to ensure the functionality and continued performance of protective equipment.
This may mean pointing out the alarm system, maintenance schedule, etc. A quick example of a functionality test that is common practice and can easily be conducted is the ‘tissue test.’ Tape a piece of tissue to the bottom of the fume hood sash to ensure proper airflow. However, measures taken to ensure proper performance should also be thoroughly described and included.
Description and location of safety information
The CHP will outline the necessary information that will be provided to laboratory workers.
This includes the location and accessibility of the CHP and chemical reference materials including safety data sheets (SDSs), the symptoms and signs of chemical exposure, permissible exposure limits (PELs) for OSHA regulated chemicals, and recommended exposure limits for hazardous substances without an OSHA standard.
Additionally, employers are responsible for training employees in all of these areas.
Medical consultation and examinations
Details of when and how medical consultations and examinations are to be conducted will be described in the CHP. Employers are to offer no-cost medical consults and exams when workers are exposed to concentrations above the PELs or if a spill creates the possibility of exposure.
Designation of CHO and Chemical Hygiene Committee
The CHP should include the designation of the CHO, who is responsible for implementing the CHP. If appropriate or necessary, the establishment of a Chemical Hygiene Committee will be included as well.
Information regarding additional protection towards particularly hazardous chemicals
When employees are working with extremely hazardous substances, including select carcinogens, reproductive toxins, and substances with acute toxicity, additional protection for working with these types of chemicals should be provided.
Annual reviews and updates
It is a good idea to include a revision control page that will document necessary updates on an as-needed basis and capture when annual reviews are completed.
In addition to the requirements above, you want to consider how robust the CHP must be in order to provide sufficient information necessary for protecting employees from the health hazards associated with hazardous chemical use.
The establishment of a Chemical Hygiene Committee may be a productive endeavor so that there are multiple opportunities for review and input during the development of the CHP. Since the lab environment is dynamic and requires keen attention to detail, the CHP is arguably the most important document in the lab.