Creating—and Maintaining—an Effective Chemical Hygiene Plan

By Phil Molé, EHS and Sustainability Expert, VelocityEHS

OSHA’s Laboratory Standard (29 CFR 1910.1450) covers workers in laboratories where relatively small quantities of chemicals are used on a non-production basis. Hazardous chemical use in other contexts, including quality control testing or any production of chemicals for commercial sale, is regulated under other standards. All employers covered by the Standard must develop a Chemical Hygiene Plan (CHP) that addresses the methods the employer will use to ensure worker safety. Let’s review strategies for ensuring your CHP is consistent with OSHA requirements.

Required Elements

OSHA mandates that CHPs must be written and must contain the following elements:

• Standard operating procedures (SOPs) for each activity involving chemical use.
• Criteria the employer will use to determine and implement control measures to reduce exposure, including engineering controls and use of personal protective equipment (PPE).
• Measures keep fume hoods and other protective equipment well-maintained and properly functioning.
• Description of information to be provided to lab personnel working with hazardous chemicals, including locations and availability of the CHP and safety data sheets (SDSs), signs and symptoms of chemical exposure, and permissible exposure limits (PELs) for workplace chemicals.
• Summary of circumstances in which lab activities would require approval from the employer before implementation.
• Designation of personnel responsible for implementing the CHP, including the Chemical Hygiene Officer.
• Provisions for additional protections for employees working with particularly hazardous substances, including designated areas, containment devices, and waste handling.
• At least annual review of the plan and updates as needed.
• Training on chemical safety, PPE and measures to prevent exposure.
• Medical exams and consultation, to be provided under the supervision of a licensed physician and without cost to all workers exposed to concentrations above the action level (AL) or PEL, or after an event such as a spill creates a likelihood of exposure.

Best Practices

The requirements for a CHP seem straightforward, but maintaining compliance is not always easy. The main challenge is keeping the plan up-to-date once it is completed. New chemicals will likely continue to enter the lab, posing new hazards and prompting review and revision of the plan.

SDSs for new materials must be obtained and properly stored, and updates to the workplace labeling system made where necessary. Put technology on your team! A good cloud-based and mobile-engaged chemical management solution can help with managing SDSs, and provide right-to-access to all employees while online or offline. The better solutions also provide container-level visibility of your chemical storage footprint, improving employee awareness needed for safe work. Software tools for inspections and audits can also help ensure that labels on all chemicals received from suppliers are not removed or defaced, per regulatory requirements. Using these tools in conjunction with well-communicated written procedures for procurement, risk analysis and hazard communication help keep everything running smoothly.

Remember to plan for personnel changes, too. Many compliant CHPs lose effectiveness when the person responsible for it leaves the company or changes job responsibilities. Sharing the responsibility among several employees disperses the knowledge needed before turnover occurs, and training plans prepare new team members for shifting roles. Software can help to keep the right people informed and easily provide and document training.

With the right planning and tools, you’ll be able to create and maintain a CHP that keeps your business in compliance, and your workers safe.

Hear more from Phil Molé about developing and managing your chemical hygiene at the upcoming webinar on May 24, Chemical Hygiene Plans: Developing Your CHP for Compliance with the Revised Hazard Communication Standard and Other Requirements. Register now.