FAQs about the Chemical Hygiene Plan
In the summer of 1996 I was appointed to be the Chemical Hygiene Officer (CHO) for Wittenberg. This is a bureaucratic position required the Occupational Health and Safety Administration (OSHA). One of my goals will be to try very hard to minimize bureaucracy, but not at the expense of safety or at the expense of skirting the law. I will also try to minimize jargon that accumulates in federal regulations or otherwise explain the jargon to which we must become accustomed.
The CHO position at some small colleges constitutes between 0.25 and 0.75 FTE. I get no release time for this appointment. This is not a position I sought, but accepted in the spirit of community service with the recognition that I was logical choice based on my training in chemistry and my vocational and avocational interests in health and safety issues. Administratively, I report to the Provost.
Since 1970, OSHA has developed an extensive list of regulations that govern the safety of workplaces in the United States. (OSHA’s part of the Code of Federal Regulations is Section 29; see http://gabby.osha-slc.gov/OshStd_data/ for more than you care to know.) Around 1981 it became apparent that the regulations governing large-scale chemical industry plants were inappropriate for small-scale laboratories. Throughout the 1980’s OSHA began drafting new sets of regulations for small-scale laboratories where the production and sale of chemicals and other hazardous substances was not the main focus of the organization. Obviously, academic research labs were in this category and many organizations (including the American Chemical Society) weighed in with advice and recommendations about appropriate regulations regarding academic labs. In 1990, OSHA promulgated a new section of the Code of Federal Regulations (29 CFR 1910.1450) that applied to small-scale labs. This standard is now commonly referred to as the "Lab Standard."
(The other OSHA regulation that you should be familiar with is the "Hazard Communication Standard," 29 CFR 1910.1200. In the business, we call this "HazComm." All businesses in the United States are obliged through this standard to inform their employees of the presence of various hazards in the workplace and conduct training sessions to that effect. John Paulsen presents the HazComm training annually. HazComm applies to all Wittenberg employees.)
The Lab Standard requires that the University write and implement a Chemical Hygiene Plan (CHP) and designate a CHO. The CHP describes various safety requirements by which we should (must) all operate in labs. The CHP is a "living document" inasmuch as it must be reviewed every year and is open to revision. It is designed both for your use (as a user) and to meet certain requirements. (These goals may not always seem compatible.) My overall goal will be to make the CHP both a document that will be useful to us and will be "OSHA-approved." At times, of course, what we may want in a CHP gets superseded by what OSHA wants/demands.
Perhaps this seems like an obvious questions. But understanding the range of answers will help us implement the CHP smoothly.
Beyond government regulations, there are two other important reasons why we should be paying more attention to safety in academic laboratories. The first is that I believe that we have a professional and moral obligation to make Wittenberg a safe place to work. This is not to suggest that we have been cavalier about this issue up to now, but rather to propose that we approach this more conscientiously in the future. We could rightly point out that we have an excellent track record of safety, and, given the inherent dangers in all labs, we can applaud ourselves for having operated safely over the years. However, we now know more about dangers in the lab that we did 10, 20 and 30 years ago, and practices that were once common are now forbidden (as they should be). Mouth-pipetting was once common; it is now unthinkable even though we could note particular situations such as pipetting saline, where the danger is minimal. Chemists now wear goggles in all lab situations as a matter of habit when 25 years ago these protective devices were only worn when an expected danger was at hand. As professionals, we are obliged to stay abreast of the current modes of prudent lab safety and practice these habits daily.
A second reason - with both professional and moral grounding - is the need to pass on to our students the best training that will serve them in the future. It would be unthinkable to me to graduate a chemistry student who was not steeped in issues of lab safety. For the past 3 years, the Chemistry Department has been using a booklet, "Working Safely With Chemicals" in Chem 121. Thus, all science students are getting a good dose of safety training. (The Chemistry Department has also introduced students to the majors issues of lab safety in the pre-lab sessions of general chemistry for over 20 years.) In sending our students off to professions with inherent dangers, we must take every step possible to ensure that they graduate with a repertoire of safety habits and a safety consciousness. For example, most, perhaps all, biology students should be keenly aware of issues related to bloodborne pathogens; physicists should know whether it’s voltage or amperage that kills; geologists should be aware of the dangers of field work; artists should know about long-term exposures to paint solvents. (Since, by definition, the CHP only deals with hazardous substances (chemicals), pathogens and electricity are not strictly covered by it.)
The labs in which we teach and work and the experiences in which our students engage should constantly reinforce a consciousness of safety at both the overt and subtle levels. Surely, modeling good behavior on our part is a critical step in this training.
The Lab Standard affects "labs" on campus where hazardous materials are encountered. Wittenberg, like most campuses, has designated the following academic departments as under the jurisdiction of the CHP and CHO: Chemistry, Biology, Psychology, Geology, and Physics. I intentionally listed these in an order which suggests the degree to which daily operations might be affected by the CHP. (As CHO, I chose not to include the Art Department formally and legally, but I will be communicating with them occasionally since many issues related to exposure to chemicals directly affect their professional lives.)
All employees in these Departments who work with hazardous substances will need to be aware of and follow the Lab Standard. Secretaries are excluded since they do not handle hazardous substances (beyond the degree already covered by HazComm). Some faculty who do not handle hazardous substances will be excluded. I will leave it to the individual faculty members to decide if they should exclude, or include, themselves. It is my expectation that most science faculty should consider themselves as "employees who work in labs that use hazardous chemicals." In this situation, just about all chemicals should be considered "hazardous" even though many chemicals present a very low hazard. Students are generally excluded since there are not employees. However, all students who are (paid) lab teaching assistants or (paid) research assistants fall under the Lab Standard.
If you believe that your functions at Wittenberg will not fall under the guidelines mentioned above, you will not need CHP training. If you anticipate having students work for you in a summer research lab and/or as a lab TA next year, please alert them to the requirement of "Lab Standard training."
This is a written plan that has the following elements (taken directly from "1910.1450"):
· employee information and training about the hazards of chemical in the work area, including how to detect their presence or release, work practices and how to use protective equipment, and emergency response procedures;
· the circumstances under which a particular laboratory operation requires prior approval from the employer;
· standard operating procedures for work with hazardous chemicals;
· criteria for use of control measures, such as engineering controls or personal protection equipment;
· measures to ensure proper operation of fumehoods and other protective equipment;
· provisions for additional employee protection for work with "select carcinogens" and for reproductive toxins or substances that have a high degree of acute toxicity;
· provisions for medical consultations and examinations of employees; and
· designation of a chemical hygiene officer.
I recognize that some of these statements begin to raise concerns about the ease and convenience of continuing to teach and conduct research projects. I take it as part of my job as CHO to help articulate the Lab Standard so that the teaching/learning environment is enhanced, and not inhibited.
Let me present an overview of some of the changes that will occur.
1) All lab employees will need to participate in a training program that familiarizes each of us with the CHP. The Office of Human Resources will keep track of who has gone through this training as part of our personnel files. Students who have taken Chem 121 will have had some training due to the safety component that is part of that course, but this alone will not meet the training required.
2) As we review the safety programs in each department, we will have access to funds to improve safety conditions.
3) I will work with Departments to revise the Chemical Hygiene Plan.
4) The University, though me, will work on arrangements to have MSDS’s "readily accessible" for labs.
5) The CHO be will available as a resource person for safety concerns in all labs.
6) Annual lab inspections will be required
What does CHP training involve?
As noted above, every lab worker will need to partake of a Lab Standard training session. These trainings will be conducted every semester. Reading through the CHP prior to the training session will be helpful.
Much like the HazComm training, OSHA looks favorably upon some record that shows that the employee has a basic grasp on the main issues of the training. This suggests some quiz, and I will follow that pattern. The agenda for the training session will be:
1. Distribute the CHP in advance, and require that everyone read the CHP prior to the training session.
2. Most of the training session will involve a quick walk-through of the CHP. It is no exaggeration to suggest that we could spend 4-5 hours discussing all the safety issues contained in the CHP. We won’t! I will hit some of the high(est) points, and let most of the session be a Question-and-Answer session where you supply questions and concerns that might have been raised as you read the CHP. I will supply answers.
3. At the end of the session, I will administer a short quiz whereupon you can demonstrate your mastery of the very basic aspects of our CHP. This document becomes part of your personnel file.
The CHP is available on-line at /academics/chemistry/chp.html. You can also request a hard copy and/or an electronic copy (Word document) by email to: firstname.lastname@example.org.