If you’re required to have a chemical hygiene, make sure it contains these elements.
Since 1990, OSHA has required facilities engaged in the use of chemicals in a laboratory to develop and implement a written chemical hygiene plan (CHP). OSHA requires these facilities to set forth procedures, equipment, PPE, work practices, training, and policies to help protect employees from the health hazards presented by hazardous chemicals used in their workplace.
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The CHP must be easily accessible and designed to protect employees from health hazards associated with hazardous chemicals in their specific laboratories. The plan can be maintained and available electronically as long as employees know how to access it.
The CHP has eight elements. It must:
- Describe standard operating procedures.
- Define criteria for implementation of control measures, which means deciding how the employer is going to protect employees. There is a general priority of protecting employees. The three-tier system: engineering controls, administrative controls, and PPE.
- Define (and document) procedures to maintain proper functioning of chemical fume hoods and protective equipment. This includes procedures such as checking the flow rate of hoods and verifying that equipment is working properly.
- Provide employee information and training.
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- Provide criteria for prior approval. Where you have processes or procedures where employees have to get prior approval (e.g., working alone) criteria allow employers to make arrangements for protection.
- Provide criteria for medical consultation and examination.
- Designate persons responsible for implementation of the CHP. Employers must designate responsibilities to a variety of people both in and out of lab, including the chemical hygiene officer (CHO) and others. The highest up person should sign the plan, saying that he/she has authorized the plan.
- Provide employee protection from particularly hazardous substances. Inventory chemicals and decide what in this category—for example, carcinogens and extremely reactive materials.
Employer Responsibilities under the CHP
- Develop and implement a written CHP
- Inventory all hazardous chemicals and ensure each has a safety data sheet (SDS)
- Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced
- Maintain any SDSs that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible to laboratory employees
- Train employees on physical and health hazards and protective measures
- Provide medical monitoring for employees (under certain circumstances)
Employee Responsibilities under the CHP
- Follow all procedures and policies relating to chemicals and follow appropriate laboratory procedures and rules as outlined in the CHP
- Refrain from operations without proper instruction and/or authorization
- Seek out and request information
- Wear appropriate PPE
- Report accidents and near-misses immediately, even minor injuries or exposures
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Responsibilities of the CHO
The chemical hygiene officer has overall responsibility for maintaining and establishing compliance with this plan and providing technical guidance. Specifically, the CHO:
- Updates the CHP, chemical and SDS inventories
- Provide training to all laboratory personnel
- Ensures that laboratory employees follow SOPs
- Ensures that safety equipment and engineering controls are utilized
- Ensures that personal protective equipment is utilized
- Conducts and documents inspections
- Assists in development of procedures for new or particularly hazardous operations
- Accident investigation and corrective action
- Maintains records