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2 Environmental Health and Safety Management System 2.A INTRODUCTION 10 2.A.1 Environmental Health and Safety Policy 10 2.A.2 Management Commitment 10 2.A.3 Planning 10 2.A.4 Implementation 12 2.A.5 Performance Measurement and Change Management 12 2.A.6 Management Review of EHS Management System 13 2.A.7 Example Management System: Department of Energy Integrated Safety Management System 13 2.B CHEMICAL HYGIENE PLAN 14 2.C SAFETY RULES AND POLICIES 15 2.C.1 General Safety Rules 15 2.C.2 Working Alone in the Laboratory 17 2.C.3 How to Avoid Routine Exposure to Hazardous Chemicals 18 2.C.4 General Housekeeping Practices in the Laboratory 19 2.D CHEMICAL MANAGEMENT PROGRAM 20 2.D.1 Chemical Procurement 20 2.D.2 Chemical Storage 21 2.D.3 Chemical Handling 22 2.D.4 Chemical Inventory 22 2.D.5 Transporting, Transferring, and Shipping Chemicals 23 2.D.6 Chemical Waste 23 2.E LABORATORY INSPECTION PROGRAM 23 2.E.1 Types of Inspection Programs: Who Conducts Them and What They Offer 24 2.E.1.1 Routine Inspections 24 2.E.1.2 Self-Audits 24 2.E.1.3 Program Audits 24 2.E.1.4 Peer Inspections 24 2.E.1.5 Environmental Health and Safety Inspections 24 2.E.1.6 Inspections by External Entities 25 2.E.2 Elements of an Inspection 25 2.E.2.1 Preparing for an Inspection 25 2.E.2.2 Inspection Checklists 25 2.E.2.3 Conducting the Inspection 26 2.E.2.4 Inspection Report 26 2.E.2.5 Corrective Actions 26 2.E.3 Items to Include in an Inspection Program 26 2.F EMERGENCY PROCEDURES 27 2.F.1 Fire Alarm Policy 27 2.F.2 Emergency Safety Equipment 27 2.F.3 Chemical Spill Policy 28 2.F.4 Accident Procedures 29 2.G EMPLOYEE SAFETY TRAINING PROGRAM 29 9
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10 PRUDENT PRACTICES IN THE LABORATORY 2.A INTRODUCTION 2.A.1 Environmental Health and Safety Policy Many people are interested in an organization’s ap- proach to laboratory environmental health and safety Top management should set in place procedures to (EHS) management including laboratory personnel; define, document, and endorse a formal EHS policy customers, clients, and students (if applicable); suppli- for an organization. The policy should clearly outline ers; the community; shareholders; contractors; insur- the roles and expectations for the organization, faculty, ers; and regulatory agencies. More and more organiza- EHS personnel, and individual employees or students. tions attach the same importance to high standards in It should be developed in communication with labo- EHS management as they do to other key aspects of ratory personnel to ensure that all major concerns are their activities. High standards demand a structured adequately addressed. approach to the identification of hazards and the evalu- The EHS policy should state intent to ation and control of work-related risks. A comprehensive legal framework already exists for • prevent or mitigate both human and economic laboratory EHS management. This framework requires losses arising from accidents, adverse occupa- organizations to manage their activities in order to tional exposures, and environmental events; anticipate and prevent circumstances that might result • build EHS considerations into all phases of the in occupational injury, ill health, or adverse environ- operations, including laboratory discovery and mental impact. This chapter seeks to improve the EHS development environments; performance of organizations by providing guidance • achieve and maintain compliance with laws and on EHS to integrate EHS management with other as- regulations; and pects of the organization. • continually improve EHS performance. Many features of effective EHS management are identical to management practices advocated by pro- The EHS policy and policy statement should be ponents of quality assurance and business excellence. reviewed, revalidated, and where necessary, revised The guidelines presented here are based on general by top management as often as necessary. It should principles of good management and are designed to be communicated and made readily accessible to all integrate EHS management within an overall manage- employees and made available to relevant interested ment system.1 By establishing an EHS management parties, as appropriate. system, EHS risks are controlled in a systematic proac- tive manner. 2.A.2 Management Commitment Within many organizations, some elements of EHS management are already in place, such as policy and Management commitment to EHS performance is risk assessment records, but other aspects need to widely recognized as one of the elements most critical be developed. It is important that all the elements to EHS program success and to the development of a described here are incorporated into the EHS man- strong culture of safety within an organization. There- agement system. The manner and extent to which fore, the management system document establishes individual elements are applied, however, depend on management commitment with a formal statement of factors such as the size of the organization, the nature of intent, which defines examples of how performance its activities, the hazards, and the conditions in which goals are supported. Examples of how this commit- it operates. An initial status review should be carried ment is supported include the following: out in all organizations that do not have an established EHS management system. This initial status review • Establish methods to use energy more efficiently, will provide information on the scope, adequacy, and reduce waste, and prevent accidents. implementation of the current management system. • Comply with laws, regulations, and organiza- Where no formal management system exists, or if the tional requirements applicable to their operations. organization is newly established, the initial status • Improve EHS performance continually. review should indicate where the organization stands • Conduct periodic assessments to verify and vali- with respect to managing risks. date EHS performance. Figure 2.1 illustrates the major elements of an EHS management system. 2.A.3 Planning Planning is an integral part of all elements of the 1Ageneral definition of a management system is “a series of ele- management system and to be effective involves the ments for establishing policy, objectives, and processes for imple- design and development of suitable processes and mentation, review, and continual improvement.”
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11 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM I. Environmental Health and Safety (EHS) Policy • Develop or review EHS policy • Share management commitment to the policy with all personnel II. Planning V. Management Review • Identify EHS concerns • Assess risk and control capability • Engage management in the identification of • Identify legal requirements applicable to the objectives and targets of the EHS policy organization • Perform annual management review • Develop a process to keep track of legal • Document decisions and recommendations requirements and changes in laboratory work • Establish objectives and targets for the EHS policy IV. Performance Measurement, Audits, and Change Management III. Implementation • Track key performance measurements • Develop a process and organizational structure for • Establish a system to investigate incidents and communications take appropriate actions • Define a group to make decisions regarding external • Establish processes for controlling risks communications associated with changes to operations • Define roles and responsibilities • Develop and implement training as needed • Define a process for maintaining documents • Establish an organizational structure for responding to emergencies and accidents Overview of environmental health and safety management system. FIGURE 2.1 Figure 2-1.eps organizational structure to manage EHS aspects and tions, environmental incident investigations, root- their associated risk control systems proportionately cause analysis, trend analysis), to the needs, hazards, and risks of the organization. • internal audits and/or external agency audits, Planning is equally important to deal with health risks • fire and building codes, that might only become apparent after a long latency • employee feedback concerning unsafe work con- period. It also establishes objectives that define the ditions or situations, criteria for judging success or failure of the manage- • emerging issues, ment system. Objectives are identified on the basis of • corporate/institution goals, and either the results of the initial status review, subsequent • emergency management. periodic reviews, or other available data. Various sources of information are used to identify Once applicable EHS aspects are identified, a risk- applicable EHS aspects and to assess the risk associated based evaluation is performed to determine the poten- with each. Examples include, but are not limited to, tial impact and adequacy of existing control measures. information obtained from the following: If additional controls or corrective actions are needed to reduce risks to acceptable levels, they are integrated • hazard/exposure assessment, into business planning. Categorizing each item in this • risk assessment, manner allows gaps that are identified to be prioritized • inspections, and incorporated, based on level of importance and • permits, available resources. • event investigations (injury and illness investiga- Care should be taken when developing and dis-
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12 PRUDENT PRACTICES IN THE LABORATORY seminating new controls and corrective actions. If reviewed before a contract is awarded. All con- requirements are perceived by laboratory personnel tractor personnel should be required to comply as unnecessarily onerous, there is potential for lower with the sponsoring organization’s safety policies compliance within the organization and a loss of cred- and plans. ibility on the part of EHS personnel. While understand- ing that some individuals will never be convinced of Though it is the responsibility of each individual re- the need for new controls, it is important to provide searcher to ensure that work is performed in a prudent clear, supported justifications for changes to existing and safe manner, achieving a safe laboratory environ- protocols to encourage adoption of the new policies ment is a cooperative endeavor between management, and procedures. EHS personnel, and laboratory personnel. Regulations, policies, and plans will never cover every contingency, and it is important for these different groups to com- 2.A.4 Implementation municate with each other to ensure that new situations The design of management arrangements should can be handled appropriately. One way to ensure that reflect the organization’s business needs and the nature the needs of all groups are being met is by creating of their risks. However, there should be appropriate safety committees consisting of representatives from activity across all elements of the model (policy; plan- each part of an organization. In this forum, safety ning; implementation; performance measurement, concerns can be raised, information can be distributed audits, and change management; and management to affected parties, and a rough sense of the efficacy of review). policies and programs can be gained. Specifically the organization should make arrange- ments to cover the following key areas: 2.A.5 Performance Measurement and Change Management • overall plans and objectives, including employees and resources, for the organization to implement The primary purpose of measuring EHS perfor- its policy; mance is to judge the implementation and effective- • operational plans to implement arrangements to ness of the processes established for controlling risk. control the risks identified; Performance measurement provides information on • contingency plans for foreseeable emergencies the progress and current status of the arrangements and to mitigate their effects (e.g., prevention, pre- (strategies, processes, and activities) used by an orga- paredness, and response procedures); nization to control risks to EHS. Measurement informa- • plans covering the management of change of tion includes data to judge the management system by either a permanent or a temporary nature (e.g., associated with new processes or plant work- • gathering information on how the system oper- ing procedures, production fluctuations, legal ates in practice, requirements, and organizational and staffing • identifying areas where corrective action is neces- changes); sary, and • plans covering interactions with other interested • providing a basis for continual improvement. parties (e.g., control, selection, and management of contractors; liaison with emergency services; All of the components of the EHS management sys- visitor control); tem should be adequately inspected, evaluated, main- • performance measures, audits, and status reviews; tained, and monitored to ensure continued effective • corrective action implementation; operation. Risk assessment and risk control should be • plans for assisting recovery and return to work reviewed in the light of modifications or technologi- of any staff member who is injured or becomes ill cal developments. Results of evaluation activities are through work activities; used as part of the planning process and management • communication networks to management, em- review, to improve performance and correct deficien- ployees, and the public; cies over time. • c lear performance and measurement criteria Periodic audits that enable a deeper and more critical defining what is to be done, who is responsible, appraisal of all of the elements of the EHS manage- when it is to be done, and the desired outcome; ment system (see Figure 2.1) should be scheduled and • education and training requirements associated should reflect the nature of the organization’s hazards with EHS; and risks. To maximize benefits, competent persons • document control system; and independent of the area or activity should conduct the • contractors should have written safety plans and audits. The use of external, impartial auditors should qualified staff whose qualifications are thoroughly be considered to assist in evaluation of the EHS man-
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13 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM agement system. When performing these reviews, The outputs from management review should in- it is important that the organization have a plan for clude any decisions and actions related to possible following up on the results of the audit to ensure that change to EHS policy, objectives, and other elements problems are addressed and that recognition is given of the management system, consistent with the com- where it is deserved. mitment to continual improvement. The concept of change management in the laboratory The management system review ensures a regular environment varies markedly from methods typically process that evaluates the EHS management system prescribed, for example, in manufacturing operations. in order to identify deficiencies and modify them. By its very nature, the business of conducting experi- Systemic gaps, evidence that targets are not being ments is constantly changing. Therefore, it is a part of met, or compliance issues that are discovered during everyday activities to evaluate modifications and/or compliance or risk assessments indicate a possible technological developments in experimental and scale- need for revision to the management system or its up processes. As such, a number of standard practices implementation. are used to identify appropriate handling practices, containment methods, and required procedures for 2.A.7 Example Management System: conducting laboratory work in a safe manner. Several Department of Energy Integrated examples of these practices include Safety Management System • identification of molecules as particularly hazard- One example of a common EHS management system ous substances (PHSs),2 which specifies certain is that used by the Department of Energy (DOE). The handling and containment requirements and the agency’s Integrated Safety Management (ISM) system, use of personal protective equipment (PPE); adopted in 1996, is used at all DOE facilities, and has • approval and training for new radioisotope users; been used as a model for other agencies and institu- • completion of biosafety risk assessments for the tions. The system consists of six guiding principles and use of infectious agents; and five core management safety functions. The principles • Material Safety Data Sheet (MSDS) review of and functions in DOE Policy DOE P 450.4 (DOE, 1994), chemicals being used. outlined below, require planning, identification of hazards and controls before work begins, and for work to be performed within these defined and planned 2.A.6 Management Review of EHS methods. Management System Top management should review the organization’s Principles: EHS management system at regular intervals to ensure its continuing suitability, adequacy, and effectiveness. • Line management responsibility for safety. Line This review includes assessing opportunities for im- management is directly responsible for the protec- provement and the need for changes in the manage- tion of the public, the workers, and the environ- ment system, including the EHS policy and objectives. ment. As a complement to line management, the The results of the management review should be Department’s Office of Environment, Safety, and documented. Health provides safety policy, enforcement, and Among other information, a management review independent oversight functions. should include the following: • Clear roles and responsibilities. Clear and un- ambiguous lines of authority and responsibil- • results of EHS management system audits, ity for ensuring safety shall be established and • results from any external audits, maintained at all organizational levels within the • communications from interested parties, Department and its contractors. • extent to which objectives have been met, • C ompetence commensurate with responsi- • status of corrective and preventive actions, bilities. Personnel shall possess the experience, • follow-up actions from previous management knowledge, skills, and abilities that are necessary reviews, and to discharge their responsibilities. • recommendations for improvement based on • Balanced priorities. Resources shall be effectively changing circumstances. allocated to address safety, programmatic, and op- erational considerations. Protecting the public, the workers, and the environment shall be a priority 2The term “particularly hazardous substances” is used by Occu- whenever activities are planned and performed. pational Safety and Health Administration (OSHA) and defined in • Identification of safety standards and require- the Laboratory Standard 29 CFR § 1910.1450. (For more information ments. Before work is performed, the associated see Chapter 4, section 4.C.3.)
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14 PRUDENT PRACTICES IN THE LABORATORY hazards shall be evaluated and an agreed-upon meet mission, safety, productivity, quality, envi- set of safety standards and requirements shall be ronmental, and other objectives. High reliability established which, if properly implemented, will is achieved through a focus on operations, con- provide adequate assurance that the public, the servative decision making, open communications, workers, and the environment are protected from deference to expertise, and systematic approaches adverse consequences. to eliminate or mitigate error-likely situations. • Hazard controls tailored to work being per- • Oversight for performance assurance. Compe- formed. Administrative and engineering controls tent, robust, periodic, and independent oversight to prevent and mitigate hazards shall be tailored is an essential source of feedback that verifies to the work being performed and associated expectations are being met and identifies op- hazards. portunities for improvement. Performance as- • Operations authorization. The conditions and surance activities verify whether standards and requirements to be satisfied for operations to be requirements are being met. Performance assur- initiated and conducted shall be clearly estab- ance through conscious, directed, independent lished and agreed upon. previews at all levels brings fresh insights and observations to be considered for safety and per- Functions: formance improvement. • Organizational learning for performance im- • Define the scope of work. Missions are translated provement. The organization demonstrates ex- into work, expectations are set, tasks are identified cellence in performance monitoring, problem and prioritized, and resources are allocated. analysis, solution planning, and solution imple- • Analyze the hazards. Hazards associated with the mentation. The organization encourages openness work are identified, analyzed, and categorized. and trust, and cultivates a continuous learning • Develop and implement hazard controls. Appli- environment. cable standards and requirements are identified and agreed upon, controls to prevent/mitigate More information about the DOE ISM system can be hazards are identified, the safety envelope is es- found at www.directives.doe.gov. tablished, and controls are implemented. The DOE ISM system is only one example of an EHS • Perform work within controls. Readiness is con- management system, and many others exist. It is im- firmed and work is performed safely. portant that each organization develop a management • Provide feedback and continuous improvement. system to meet the needs of the organization. Small Feedback information on the adequacy of con- organizations or those that do not handle particularly trols is gathered, opportunities for improving the hazardous materials should not be tempted to “over- definition and planning of work are identified and engineer” the system. If the burden of organizational implemented, line and independent oversight is oversight and management of the ESH program is not conducted, and, if necessary, regulatory enforce- appropriately tied to the organizational risk, then the ment actions occur. safety program may lose credibility in the eyes of the people it supports. In addition, in 2006, and in recognition of a gap within the management system, DOE identified four 2.B CHEMICAL HYGIENE PLAN supplemental safety culture elements. These, as de- scribed in DOE Manual DOE M 450.4-1 (DOE, 2006), The foundation of all management system ap- are as follows: proaches is the identification of EHS concerns, which if not adequately controlled, can result in employee in- • Individual attitude and responsibility for safety. jury or illness, adverse effects on the environment, and Every individual accepts responsibility for safe regulatory action. One of the most critical EHS aspects mission performance. Individuals demonstrate a for laboratories is the requirement for chemical safety, questioning attitude by challenging assumptions, which in the United States is specifically regulated by investigating anomalies, and considering poten- OSHA Laboratory Standard, 29 CFR § 1910.1450, Occu- tial adverse consequences of planned actions. All pational Exposure to Hazardous Chemicals in Laboratories. employees are mindful of work conditions that This standard was created to minimize employee expo- may impact safety, and assist each other in pre- sure to hazardous chemicals in the laboratory and sets venting unsafe acts or behaviors. forth guidelines for employers and trained laboratory personnel engaged in the use of hazardous chemicals.3 • Operational excellence. Organizations achieve sustained, high levels of operational performance, encompassing all DOE and contractor activities to 329 CFR § 1910.1450 (1990), http://www.osha.gov/.
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15 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM The OSHA Laboratory Standard defines a Chemical (e.g., information on biological safety in a laboratory Hygiene Plan (CHP) as “a written program developed that only works with inorganic materials). and implemented by the employer which sets forth procedures, equipment, personal protective equip- 2.C SAFETY RULES AND POLICIES ment and work practices that are capable of protect- ing employees from the health hazards presented by Safety rules and regulations are created to protect hazardous chemicals used in that particular work- laboratory personnel from unsafe work practices and place.” “Where hazardous chemicals as defined by exposure to hazardous materials. Consistently follow- this standard are used in the workplace, the employer ing and enforcing the safety rules in order to create a shall develop and carry out the provisions of a written safe and healthful laboratory environment in which to Chemical Hygiene Plan.” The CHP is the foundation work will help encourage a culture of safety within the of the laboratory safety program and should be re- workplace. What follows is a description of laboratory viewed and updated, as needed, on an annual basis to safety rules, but these will not cover every contingency. reflect changes in policies and personnel. A CHP that Part of the culture of safety is communication and is facility specific can assist in promoting a culture of discussion about safety hazards within the laboratory, safety to protect employees from exposure to hazard- so that new concerns can be addressed as quickly as ous materials. possible. Topics included in a CHP are 2.C.1 General Safety Rules 1. individual responsibilities for chemical hygiene within the organization (see Boxes 2.1, 2.2, and Below are some basic guidelines for maintaining a 2.3), safe laboratory environment. 2. emergency preparedness and facility security issues, 1. To ensure that help is available if needed, do 3. personal apparel and PPE, not work alone if using hazardous materials or 4. chemical management, performing hazardous procedures. 5. laboratory housekeeping, 2. To ensure that help is available in case of emer- 6. standard operating procedures, gencies, laboratory personnel should not deviate 7. emergency action plan (EAP) for accidents and from the assigned work schedule without prior spills, authorization from the laboratory supervisor. 8. safety equipment, 3. Do not perform unauthorized experiments. 9. chemical waste policies, 4. Plan appropriate protective procedures and the 10. required training, positioning of all equipment before beginning 11. safety rules and regulations, any operation. Follow the appropriate stan- 12. facility design and laboratory ventilation, dard operating procedures at all times in the 13. medical and environmental monitoring, laboratory. 14. compressed gas safety, 5. Always read the MSDS and the label before us- 15. laboratory equipment, ing a chemical in the laboratory. 16. biological safety, and 6. Wear appropriate PPE, including a laboratory 17. radiation safety. apron or coat, at all times in the laboratory. Everyone, including visitors, must wear appro- Determining what belongs in the CHP for a given priate eye protection in areas where laboratory laboratory should be the result of conversations be- chemicals are used or stored. tween the Chemical Hygiene Officer (CHO), the direc- 7. Wear appropriate gloves when handling hazard- tor of the laboratory, and laboratory personnel. The ous materials. Inspect all gloves for holes and laboratory director and the individuals performing defects before using. the research are responsible for following safe prac- 8. Use appropriate ventilation such as laboratory tices, and they are the people most familiar with the chemical hoods when working with hazardous work being performed. However, they are less likely chemicals. to be familiar with all relevant regulations, standards, 9. Contact the CHO or the EHS office if you have and codes than the CHO, and they may benefit from questions about the adequacy of the safety equip- assistance in identification and assessment of hazards ment available or chemical handling procedures. within the laboratory. Thus there must be commu- 10. Know the location and proper use of the safety nication across the groups to ensure that the CHP is equipment (i.e., eyewash unit, safety shower, complete and that it contains no irrelevant information fire extinguisher, first-aid kit, fire blanket, emer- gency telephone, and fire alarm pulls).
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16 PRUDENT PRACTICES IN THE LABORATORY BOX 2.1 Chemical Hygiene Responsibilities in a Typical Academic Institution Chemical Hygiene Officer (CHO) associated with a hazardous chemical to which the employee may have been exposed in the laboratory; The duties of the CHO vary widely from one institution to here exposure monitoring reveals an exposure level W another but may include the following: routinely above the action level for an Occupational • stablish, maintain, and revise the Chemical Hygiene E Safety and Health Administration–regulated sub- Plan (CHP). stance for which there are exposure monitoring and • reate and revise safety rules and regulations. C medical surveillance requirements; • erve on appropriate safety committees. S henever a spill, leak, explosion, or other occurrence W • onitor procurement, use, storage, and disposal of M resulting in the likelihood of a hazardous exposure oc- chemicals. curs, a medical consultation to ascertain if a medical • onduct regular inspections of the laboratories, prepara- C examination is warranted. tions rooms, and chemical storage rooms, and submit Department Chairperson or Director detailed laboratory inspection reports to administration. • aintain inspection, personnel training, and inventory M • ssumes responsibility for personnel engaged in the A records. laboratory use of hazardous chemicals. • versee chemical inventory updates. O • rovides the CHO with the support necessary to imple- P • ssist laboratory supervisors in developing and maintain- A ment and maintain the CHP . ing adequate facilities. • fter receipt of laboratory inspection report from the A • now current legal requirements concerning regulated K CHO, meets with laboratory supervisors to discuss cited substances. violations and to ensure timely actions to protect trained • eek ways to improve the chemical hygiene program. S laboratory personnel and facilities and to ensure that the • ttend CHO training that is conducted by the institution. A department remains in compliance with all applicable • ncourage laboratory personnel to attend specialized E federal, state, university, local, and departmental codes training that is provided by the institution (i.e., first-aid and regulations. training, fire extinguisher training, and gas cylinder • rovides budgetary arrangements to ensure the health P training). and safety of the departmental personnel, visitors, and • otify employees of the availability of medical attention N students. under the following circumstances: • erves as chair of the departmental safety committee S henever an employee develops signs or symptoms W 11. Maintain situational awareness. Be aware of Visitors, including children, are permitted in labora- the hazards posed by the work of others in the tories where hazardous substances are stored or are in laboratory and any additional hazards that use or hazardous activities are in progress as long as may result from contact between materials and they are properly protected. If minors are expected in a chemicals from different work areas. laboratory (e.g., as part of an educational or classroom 12. Make others in the laboratory aware of any spe- activity), ensure that they are under the direct super- cial hazards associated with your work. vision of qualified adults at all times. The institution 13. Notify supervisors of any chemical sensitivities should have a review process regarding minors in the or allergies. laboratory, and prior to their arrival, scheduled activi- 14. Report all injuries, accidents, incidents, and near ties should be approved. Other laboratory personnel misses as directed by the organization’s policy. in the area should be made aware that minors will be 15. For liability, safety, and security reasons, do not present. allow unauthorized persons in the laboratory. No pets are permitted in laboratories. Note that ser- 16. Report any unsafe conditions to the laboratory vice animals are not pets. They are highly trained and supervisor or CHO. may be present in a laboratory. However, a clean, safe 17. Properly dispose of all chemical wastes. Follow area should be provided where the animal can wait. organizational policies for drain and trash dis- To prevent some common laboratory accidents: posal of chemicals. 1. Always protect hands with appropriate gloves
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17 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM and appoints a faculty member and a graduate student Contacts the appropriate person, as designated by the member, if applicable, to serve on the departmental department chairperson, to report problems with the safety committee. facilities or the chemical fume hoods. Departmental Safety Committee Laboratory Personnel • eviews accident reports and makes appropriate recom- • eads, understands, and follows all safety rules and R R mendations to the department chairperson regarding regulations that apply to the work area. • lans and conducts each operation, laboratory class, or proposed changes in the laboratory procedures. P • erforms laboratory inspections on an annual basis, or P research project in accordance with the departmental as needed. Prepares a detailed inspection report to be and institutional CHP . • romotes good housekeeping practices in the laboratory submitted to each faculty member/laboratory supervisor. P or work area. • ommunicates appropriate portions of the CHP to stu- Laboratory Supervisor C dents in the work area. • nsures that laboratory personnel comply with the E • otifies the supervisor of any hazardous conditions or N departmental CHP and do not operate equipment or unsafe work practices in the work area. handle hazardous chemicals without proper training and • ses PPE as appropriate for each procedure that involves U authorization. hazardous chemicals. • lways wears personal protective equipment (PPE) that A • mmediately reports any job-related illness or injury to the I is compatible to the degree of hazard of the chemical. supervisor. • ollows all pertinent safety rules when working in the F laboratory to set an example. Facilities, Maintenance, and Custodial • eviews laboratory procedures for potential safety prob- R Service Personnel Assigned to lems before assigning to other laboratory personnel. Laboratories and Laboratory Areas • nsures that visitors follow the laboratory rules and as- E • sumes responsibility for laboratory visitors C ompletes training on CHP awareness. • nsures that PPE is available and properly used by each • E U nderstands how to read and use MSDSs. • laboratory employee and visitor. K nows hazards of the chemicals being used. • aintains and implements safe laboratory practices. • M O btains information about hazards in the work area from • onitors the facilities and the chemical fume hoods to M lab personnel before work is started. ensure that they are maintained and function properly. when cutting glass tubing. To avoid breakage, do Alaimo (2001) it states that “[w]ork should be absolutely not attempt to dry glassware by inserting a glass forbidden unless there are at least two people present”. rod wrapped with paper towels. Always lubricate The OSHA Laboratory Standard states “Avoid working glassware with soap or glycerin before inserting alone in a building; do not work alone in a laboratory rods, tubing, or thermometers into stoppers. if the procedures being conducted are hazardous.” Ac- 2. To reduce the chances of injuries from projectiles, cidents are unexpected by definition, and if a person is when heating a test tube or other apparatus, never working alone when one occurs, his or her ability to re- point the apparatus toward yourself or others. spond appropriately could be severely impaired, which 3. Be sure that glassware has cooled before touching could result in personal injury or death and catastrophic it. Hot glass looks just like cold glass. facility damage. Thus it is imperative that, whenever 4. Dilute concentrated acids and bases by slowly working in the laboratory, others are actively aware of pouring the acid or base into the water while your activities. If faced with a situation where you feel stirring. it is necessary to work alone in a laboratory: 1. Reconsider the need. Are the increased risks to 2.C.2 Working Alone in the Laboratory your health and safety really outweighed by the It is not prudent to work alone in a laboratory. The return? American Chemical Society states that one should, 2. Reconsider the timing and setup of the work. Is “[n]ever work alone in the laboratory” (ACS, 2003). In there any way to accomplish the required tasks during a time when others will be present?
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18 PRUDENT PRACTICES IN THE LABORATORY BOX 2.2 Chemical Hygiene Responsibilities in a Typical Industry Research Facility • rovides opportunity for communication between plant Chemical Hygiene Officer (CHO) P sites. • ualified by training or experience to provide technical Q • acilitates continuous improvement of safety policies and F guidance in the development and implementation of the practices. provisions of the Laboratory Standard. • eets at least annually to review CHP and training. M • versees implementation and communication of the O Laboratory Standard. Line Management • onducts appropriate audits. C • acilitates continuous improvement of safety policies and • ompletes CHP training. F C • mplements the CHP including but not limited to prac- practice. I , • cts as liaison between Environmental Health and Safety, A tices and procedures for the following: Environmental Affairs, and laboratory management. particularly hazardous materials, • hairs and schedules meetings of chemical hygiene C prior-approval process, coordination committee (CHCC). laboratory inspections. • nsures that Chemical Hygiene Plan (CHP) and training • upervises CHP training by all laboratory personnel. E S • upports and enforces laboratory standards program. courses are reviewed annually; S • evises the CHP per CHCC instructions. • rovides ongoing ownership. R , P • acilitates revisions of the CHP and requisite training • nsures that local safety procedures are written, training F E courses. is provided, and procedures are followed. • pproves/reviews all prior-approval chemical uses. • esignates a local chemical hygiene contact (CHC) (by A D • aintains minutes and other documents for CHP imple- M site, building, division, or department). mentation and makes available for CHCC. Site/Area Chemical Hygiene Contact Chemical Hygiene Coordination Committee • ompletes CHP training. C • erves as contact person for CHO and laboratory person- The committee includes the CHO and representatives from S business area (appointed by line management). These repre- nel for site/area CHP implementation. • epresents site/area on CHCC. sentatives are referred to as site chemical hygiene contacts. R 3. If the timing of the task cannot be changed and handled improperly. The Swiss physician and alche- you still feel it must be accomplished during a mist Theophrastus Phillippus Aureolus Bombastus von period when the laboratory is empty, is there any Hohenheim (1493–1541), who took the name Paracel- other person trained in laboratory procedures sus later in life in homage to Celsus, a Roman physi- who can accompany you while you work? cian, is known as “the father of toxicology.” Paracelsus 4. If not, is there anyone else within the building is famous for his quote, “What is it that is not poison? who could act as a “buddy” to check on you pe- All things are poison and nothing is without poison. riodically during the time that you feel you must It is the dose alone that makes a thing not a poison” work alone? (Dillon, 1994). Today, in that same spirit, trained labora- 5. If no one can accompany you and you cannot tory personnel are encouraged to reduce personal risk find a “buddy,” do not proceed with the work. by minimizing exposure to hazardous chemicals and The situation is unsafe. Speak to your supervi- by eliminating unsafe work practices in the laboratory. sor or the organizational safety office to make The OSHA Laboratory Standard defines a hazardous arrangements to complete the work in a safe chemical as one “for which there is statistically signifi- manner. cant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed 2.C.3 How to Avoid Routine Exposure to persons.” Note that this definition is not limited to toxic Hazardous Chemicals chemicals and includes corrosives, explosives, and Many chemicals and solutions routinely used in other hazard classes. Routes of exposure to hazardous laboratories present a significant health risk when materials include contact with skin and eyes, inhala-
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19 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM • resents CHP compliance or implementation concerns/ Staff P issues to the site/area management. • lans and conducts all research in accordance with Work P • eets and reviews laboratory inspection issues. M Control, the CHP supplemental CHPs, and relevant sub- , • nsures availability of the CHP E . ject areas. • aintains site/area documentation for CHP M . • nsures that hazardous chemicals are procured, labeled, E • oordinates prior-approval process of chemicals sub- C bar coded, handled, inventoried, stored, used, and ject to Occupational Safety and Health Administration properly disposed of in accordance with laboratory pro- substance-specific standards. cedures and the applicable CHP . • oordinates and reviews annual laboratory inspections. C • hall be knowledgeable of hazards in their work area S • oordinates written reports of laboratory inspections and C and the proper practices and procedures to minimize distributes to management. all chemical exposure. Consults available information • ommunicates with site safety office regarding site/area C sources such as the Material Safety Data Sheet database, compliance issues. training courses, Web searches, the supervisor, and • erves as technical resource for CHP questions and S health and safety personnel to identify hazards. interpretations. • ears the appropriate personal protective equipment W • nsures that staff follow the controls identified in the E and follows the work controls that have been identified. research safety summaries. • nsures that new hazardous chemicals are bar-coded E • hall be knowledgeable of the requirements for procure- S and that the inventory is updated as required in the Main- ment, use, and disposal of the chemicals used in their tenance of Hazardous Materials Inventory procedure. projects. • evelops good personal chemical hygiene habits. D • uggests and implements ways to minimize all chemical S • romptly reports spills, accidents, or abnormal events to P exposures. immediate line manager. • romptly reports spills, accidents, and employee expo- P • rovides feedback to principal investigator, laboratory P sures to the appropriate person. space manager, and immediate line manager identify- • ssists during investigations. A ing changes that may have introduced new hazards • nsures that an inventory of hazardous materials is main- E for determination of the need for reevaluation of the tained and updated in accordance with the requirements research safety summaries and ensuring continuous of the Maintenance of Hazardous Materials Inventory improvement. procedure, facility safety basis documents, and facility use agreements. tion, ingestion, and injection. Acute exposure is defined and powders; and physical hazards include cryogenic as short durations of exposure to high concentrations liquids, electrical equipment, lasers, compressed gas of hazardous materials in the workplace. Chronic expo- cylinders and reactions that involve high pressure sure is defined as continual exposure over a long period or vacuum lines. (For more information about these of time to low concentrations of hazardous materials hazards within a laboratory, see Chapter 4, sections in the workplace. Overexposure to chemicals, whether 4.D and 4.E.) a result of a single episode or long-term exposure, can An array of controls exists to protect laboratory per- result in adverse health effects. These effects are catego- sonnel from the hazards listed above. Engineering con- rized as acute or chronic. Acute health effects appear trols (e.g., laboratory chemical hoods and gloveboxes), rapidly after only one exposure and symptoms include administrative controls (e.g., safety rules, CHPs, and rashes, dizziness, coughing, and burns. Chronic health standard operating procedures), and PPE (e.g., gloves, effects may take months or years before they are di- laboratory coats, and chemical splash goggles) are all agnosed. Symptoms of chronic health effects include designed to minimize the risks posed by these hazards. joint paint, neurological disorders, and tumors. (For Work practices to minimize exposure to hazardous more information on toxicity of laboratory chemicals, chemicals can be found in Chapter 6. see Chapter 4, section 4.C.) In addition to the hazards associated with the chemi- 2.C.4 General Housekeeping Practices in cals themselves, flammable, reactive, explosive, and the Laboratory physical hazards may be present in the laboratory. Re- active hazards include pyrophorics and incompatible Good housekeeping practices in the laboratory has chemicals; explosive hazards include peroxide formers a number of benefits. For example, in terms of safety,
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20 PRUDENT PRACTICES IN THE LABORATORY BOX 2.3 Chemical Hygiene Responsibilities in a Typical Governmental Laboratory • ommunicates hazard and safety information, on a con- Chemical Hygiene Officer (CHO) C tinuing basis, to researchers and staff using the labora- • s given authority by the Director of Safety Services Divi- I tory space. sion to provide technical guidance in the development • ommunicates issues concerning the laboratory space C and implementation of the provisions of the Chemical to the laboratory space group leader. Hygiene Plan (CHP). • eriodically conducts walk-throughs of the laboratory P • nterfaces with safety, radiological protection, quality, I space according to the division or directorate annual health, and other organizations, as requested, on chemi- performance plan. cal hygiene matters. • cts as a mentor for laboratory occupants, encouraging A • nows current policies, procedures, and legal require- K safe chemical hygiene practices. ments concerning use and handling of chemicals in • ssists in preparation of research safety summaries (RSSs) A laboratories (such as Occupational Safety and Health relevant to his or her assigned laboratory. Administration Laboratory Standard 29 CFR § 1910.1450, Occupational Exposure to Hazardous Chemicals in Line Management Laboratories). • nsures that the CHP is reviewed annually. • nsures that the staff knows and follows the rules from E E the CHP and that it is fully implemented. • nsures that laboratory personnel and guests under their Divisional Chemical Hygiene Officer(s) (DCHO) E supervision receive appropriate site-specific information • s appointed by division directors (line management) to I and training on the hazards of the chemicals in the assist in the development and implementation of the CHP workplace at the time of their initial assignment. and supplemental CHP within their respective division. • nsures updates are made to RSSs and training when E • orks with division management in implementing ap- W new chemical hazards are introduced into the workplace. propriate chemical hygiene practices. The role of the • nsures that hazards associated with reaction intermedi- E DCHO may be performed by division/facility safety ates and products that will be synthesized are identified officer/representatives. and analyzed. • evelops appropriate addendums to the CHP as nec- D , • nsures that appropriate controls are established and E essary, to address division-specific hazards or to meet documented in the RSS. Subject matter experts may division-specific requirements. provide assistance. • hould be knowledgeable in chemical handling, use, S • nsures that the staff has adequate facilities, personal E and disposal techniques and requirements. protective equipment, equipment, and training to han- dle and use the chemicals that are currently on inventory Laboratory Space Manager in the laboratories. • aintains a laboratory-space posting for each laboratory. • nsures that the required personal protective equipment M E • mplements laboratory access controls and monitors I (PPE) is available and in working order and that appropri- compliance. ate training on the use and limitations of PPE has been provided and documented. it can reduce the number of chemical hazards (health, the chances of samples becoming confused or con- physical, reactive, etc.) in the laboratory and help con- taminated and keeping equipment clean and in good trol the risks from hazards that cannot be eliminated. working order. More information about housekeeping Practices that encourage the appropriate labeling and practices can be found in Chapter 6, section 6.C.3. storage of chemicals can reduce the risks of mixing of incompatible chemicals and assist with regulatory 2.D CHEMICAL MANAGEMENT PROGRAM compliance. From a security standpoint, order in the laboratory makes it easier to identify items out of One of the most important components of a labora- place or missing. And finally, good housekeeping can tory safety program is chemical management. Pru- help reduce scientific error by, for example, reducing dent chemical management includes the following processes.
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21 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM 2.D.1 Chemical Procurement compatibility. In the event of an accident involving a broken container or a chemical spill, incompatible According to the nonmandatory OSHA Laboratory chemicals that are stored in close proximity can mix Standard (Appendix A, section D.2(a), Chemical Pro- to produce fires, hazardous fumes, and explosions. curement, Distribution, and Storage), “Before a substance Laboratory personnel should read the MSDS and heed is received, information on proper handling, storage, the precautions regarding the storage requirements of and disposal should be known to those who will be in- the chemicals in the laboratory. A detailed chemical volved.” The standard further states that “No container compatibility table is included in Chapter 5, section should be accepted without an adequate identifying 5.E.2, Table 5.1. label. Preferably, all substances should be received in a To avoid accidents, all chemical containers must be central location.” These procedures are strongly recom- properly labeled with the full chemical name, not ab- mended. Personnel should be trained to identify signs breviations, and using a permanent marker. All transfer of breakage (e.g., rattling) and leakage (e.g., wet spot vessels should have the following label information: or stain) on shipments and such shipments should be refused or opened in a hood by laboratory staff. • chemical name, Some organizations have specific purchasing poli- • hazard warnings, cies to prohibit unauthorized purchases of chemicals • name of manufacturer, and other hazardous materials. The purchaser must • name of researcher in charge, and assume responsibility for ownership of the chemical. • date of transfer to the vessel. Because of the possibility of a chemical leak or release and subsequent exposure, chemical shipments should Incoming chemical shipments should be dated only be received by trained personnel in a laboratory or promptly upon receipt, and chemical stock should central receiving area with proper ventilation. Neither be rotated to ensure use of older chemicals. It is good administrative offices nor the mail room is appropriate practice to date peroxide formers upon receipt and date for receipt or opening of chemical shipments. again when the container is opened so that the user can When preparing to order a chemical for an experi- dispose of the material according to the recommenda- ment, several questions should be asked: tions on the MSDS. Peroxide formers should be stored away from heat and light in sealed airtight containers • What is the minimum amount of this chemical with tight-fitting, nonmetal lids. Test regularly for that is needed to perform the experiment? Is it peroxides and discard the material prior to the expira- available elsewhere in the facility? Remember, tion date. (For more information about storage and when ordering chemicals, less is always best. Pru- handling of peroxides, see Chapter 4, section 4.D.3.2, dent purchasing methods will save storage space, and Chapter 6, section 6.G.3.) money, and disposal costs. Larger containers re- When storing chemicals on open shelves, always use quire more storage space and will incur additional sturdy shelves that are secured to the wall and contain disposal costs if the chemical is not used. ¾-in. lips. Do not store liquid chemicals higher than 5 • Has the purchase been reviewed by the CHO to ft on open shelves. Do not store chemicals within 18 in. ensure that any special requirements can be met? of sprinkler heads in the laboratory. Use secondary con- • Is the proper PPE available in the laboratory to tainment devices (i.e., chemical-resistant trays) where handle this chemical? appropriate. Do not store chemicals in the laboratory • What are the special handling precautions? chemical hood, on the floor, in the aisles, in hallways, in • Where will the chemical be stored in the laboratory? areas of egress, or on the benchtop. Chemicals should • D oes the laboratory chemical hood provide be stored away from heat and direct sunlight. proper ventilation? Only laboratory-grade explosion-proof refrigera- • Are there special containment considerations in tors and freezers should be used to store properly the event of a spill, fire, or flood? sealed and labeled chemicals that require cool storage • Will there be additional costs or considerations in the laboratory. Periodically clean and defrost the related to the disposal of this chemical? refrigerator and freezer to ensure maximum efficiency. Domestic refrigerators and freezers should not be used 2.D.2 Chemical Storage to store chemicals; they possess ignition sources and can cause dangerous and costly laboratory fires and To lessen risk of exposure to hazardous chemicals, explosions. Do not store food or beverages in the labo- trained laboratory personnel should separate and ratory refrigerator. (For more information, see Chapter store all chemicals according to hazard category and 7, section 7.C.3.)
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22 PRUDENT PRACTICES IN THE LABORATORY Highly hazardous chemicals must be stored in a deterioration, and container integrity.” Section D.2(d) well-ventilated secure area that is designated for this states, “Periodic inventories should be conducted, purpose. Cyanides must be stored in a tightly closed with unneeded items being discarded or returned to container that is securely locked in a cool dry cabinet the storeroom/stockroom.” Though Appendix A is not to which access is restricted. Protect cyanide contain- mandatory, compliance with the standard is an element ers against physical damage and separate them from of good laboratory management. On a basic level, you incompatibles. When handling cyanides, follow good cannot safely manage something if you do not know hygiene practices and regularly inspect your PPE. Use that you have it on-site. Thus, a system for maintain- proper disposal techniques. ing an accurate inventory of the laboratory chemicals Flammable liquids should be stored in approved on campus or within an organization is essential for flammable-liquid containers and storage cabinets. compliance with local and state regulations and any Observe National Fire Protection Association, Inter- building codes that apply. national Building Code, International Fire Code, and There are many benefits of performing annual physi- other local code requirements that limit the quantity of cal chemical inventory updates: flammables per cabinet, laboratory space, and building. Consult the local fire marshal for assistance, if needed. • ensures that chemicals are stored according to Store odiferous materials in ventilated cabinets. Chemi- compatibility tables, cal storage cabinets may be used for long-term storage • eliminates unneeded or outdated chemicals, of limited amounts of chemicals. • increases ability to locate and share chemicals in Rooms that are used specifically for chemical stor- emergency situations, age and handling (i.e., preparation rooms, storerooms, • updates the hazard warning signage on the labo- waste collection rooms, and laboratories) should be ratory door, controlled-access areas that are identified with appro- • promotes more efficient use of laboratory space, priate signage. Chemical storage rooms should be de- • checks expiration dates of peroxide formers, signed to provide proper ventilation, two means of ac- • ensures integrity of shelving and storage cabinets, cess/egress, vents and intakes at both ceiling and floor • encourages laboratory supervisors to make “ex- levels, a diked floor, and a fire suppression system. If ecutive decisions” about discarding dusty bottles flammable chemicals are stored in the room, the chemi- of chemicals, cal storage area must be a spark-free environment and • repairs/replaces torn or missing labels and broken only spark-free tools should be used within the room. caps on bottles, Special grounding and bonding must be installed to • ensures compliance with all federal, state, and prevent static charge while dispensing solvents. local record-keeping regulations, • promotes good relations and a sense of trust with the community and the emergency responders, 2.D.3 Chemical Handling • reduces the risk of exposure to hazardous materi- Important information about handling chemicals can als and ensures a clean and healthful laboratory be found in the MSDS. A comprehensive file of MSDSs environment, and must be kept in the laboratory or be readily accessible • may reduce costs by making staff aware of chemi- online to all employees during all work shifts. Trained cals available within the organization. laboratory personnel should always read and heed the label and the MSDS before using a chemical for the first Every laboratory should maintain an up-to-date time. Laboratory personnel should be familiar with the chemical inventory. A physical chemical inventory types of PPE that must be worn when handling the should be performed at least annually, or as requested chemical. Ensure that the ventilation will be adequate by the CHO. Although the software that is used to to handle the chemicals in the laboratory. One should maintain the inventory and the method of performing be familiar with the institutional CHP and EAP so that the chemical inventory will vary from one institution appropriate actions are taken in the event of a chemical to another, ultimately, the chemical inventory should spill, fire, or explosion. include the following information: • chemical name, 2.D.4 Chemical Inventory • Chemical Abstract Service number, The OSHA Laboratory Standard, Appendix A, sec- • manufacturer, tion D.2(b) (Chemical Procurement, Distribution, and • owner, Storage), states, “Stored chemicals should be exam- • room number, and ined periodically (at least annually) for replacement, • location of chemical within the room.
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23 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM Note that the chemical name should be listed with International Air Transport Association training for air its synonyms. This will allow for cross-indexing for shipments. DOT oversees the shipment of hazardous tracking of chemicals and help reduce unnecessary materials and has the authority to impose citations inventory. and fines in the event of noncompliance. (For more Important safety issues to consider when performing detailed information on the shipment of chemicals, see a chemical inventory are: Chapter 5, section 5.F.) • Wear appropriate PPE and have extra gloves 2.D.6 Chemical Waste available. • Use a chemical cart with side rails and secondary All chemical waste must be stored and disposed of containment. in compliance with applicable federal, state, local, and • Use a laboratory step stool to reach chemicals on institutional regulatory requirements. Waste containers high shelves. should be properly labeled and should be the mini- • Read the EAP and be familiar with the institu- mum size that is required. There should be at least 2 in. tion’s safety equipment. of headspace in the liquid waste container to avoid a • If necessary cease all other work in the laboratory buildup of gas that could cause an explosion or a con- while performing the inventory. tainer rupture. (For more information about handling of hazardous waste, see Chapter 8.) Once the inventory is complete, use suitable security precautions regarding the accessibility of the informa- 2.E LABORATORY INSPECTION PROGRAM tion in the chemical inventory. For example, precau- tions should be taken when the database shows the A program of periodic laboratory inspections helps location of Department of Homeland Security (DHS) keep laboratory facilities and equipment in a safe op- Chemicals of Interest in excess of DHS threshold quan- erating condition. Inspections safeguard the quality of tities. (For more information about laboratory security, the institution’s laboratory safety program. A variety see Chapter 10.) of inspection protocols may be used, and the organi- zation’s management should select and participate in the design of the inspection program appropriate for 2.D.5 Transporting, Transferring, and that institution’s unique needs. The program should Shipping Chemicals embrace the following goals: It is prudent practice to use a secondary containment device (i.e., rubber pail) when transporting chemicals • Maintain laboratory facilities and equipment in a from the storeroom to the laboratory or even short dis- safe, code-compliant operating condition. tances within the laboratory. When transporting sev- • Provide a comfortable and safe working environ- eral containers, use carts with attached side rails and ment for all personnel and the public. trays of single piece construction at least 2 in. deep to • Ensure that all laboratory activities are conducted contain a spill that may occur. Bottles of liquids should in a manner to avoid employee exposure to haz- be separated to avoid breakage and spills. Avoid ardous chemicals. high-traffic areas when moving chemicals within the • Ensure that trained laboratory personnel follow building. When possible, use freight elevators when institutional CHPs. transporting chemicals and do not allow other pas- sengers. If you must use a general traffic elevator, ask Approach these goals with a degree of flexibility. other passengers to wait until you have delivered the Consider the different types of inspection, the fre- chemicals. quency with which they are conducted, and who Always ground and bond the drum and receiving conducts them. A discussion of items to inspect and vessel when transferring flammable liquids from a several possible inspection protocols follows, but is drum to prevent static charge buildup. Use a prop- not all-inclusive. erly operating chemical fume hood, local exhaust, or Laboratory inspections are performed by EHS staff, adequate ventilation, as verified by monitoring, when the CHO, the safety director, laboratory staff, a safety transferring PHSs. committee, or an outside entity with the requisite quali- All outgoing domestic and international chemical fications and experience. The inspection checklist can shipments must be authorized and handled by the include sections on chemical storage, chemical waste, institutional shipper. The shipper must be trained in housekeeping, PPE, laboratory chemical hoods, gas U.S. Department of Transportation (DOT) regulations cylinder storage, emergency safety equipment, signs for ground shipments and must receive mandatory and labels, and facility issues.
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24 PRUDENT PRACTICES IN THE LABORATORY Following each inspection, a detailed report is sent pervisor and senior management have the opportunity to the laboratory supervisor and appropriate admin- to take a close look at the facilities and operations. They istration. Photographs taken during the inspection can discuss with individual workers issues of interest process can emphasize the critical nature of a violation. or concern that may fall outside the scope of the actual Consider giving special recognition to laboratories inspection. A constructive and positive approach to demonstrating good laboratory practice and those that observed problems and issues fosters an attitude of have demonstrated significant improvements in safety. cooperation and leadership with regard to safety and helps build and reinforce a culture of teamwork and cooperation that has benefits far beyond protecting 2.E.1 Types of Inspection Programs: Who personnel and the physical facilities. Conducts Them and What They Offer The audit begins with a discussion of the safety There are several types of inspection programs, each program and culture, and a review of operations, writ- providing a different perspective and function. A com- ten programs, training records, and pertinent policies prehensive laboratory inspection program includes a and procedures and how they are implemented in the combination of some or all of these programs. laboratory. A laboratory inspection that includes inter- views with laboratory personnel follows to determine the level of safety awareness. An open discussion with 2.E.1.1 Routine Inspections key personnel can ascertain how personnel, supervi- Trained laboratory personnel and supervisors sors, managers, and safety officers can better support should complete general equipment and facility in- each other. spections on a regular basis. For certain types of equip- This type of audit provides a much more comprehen- ment in constant use, such as gas chromatographs, sive view of the laboratory than a routine inspection. daily inspections may be appropriate. Other types of equipment may need only weekly or monthly inspec- 2.E.1.4 Peer Inspections tion or inspection prior to use if operated infrequently. Keep a record of inspection attached to the equipment One of the most effective safety tools a facility can or in a visible area. The challenge for any inspection use is periodic peer-level inspections. Usually, the peo- program is to keep laboratory personnel continuously ple who fulfill this role work in the organization they vigilant. They need positive encouragement to develop serve, but not in the area being surveyed. Personnel the habit of inspection and to adopt the philosophy may participate on an ad hoc basis, or the institution that good housekeeping and maintenance for their may select specific individuals to be part of a more for- workspace protect them and may help them produce mal, ongoing inspection team. A peer inspection pro- better research results. gram has the intrinsic advantage of being perceived as less threatening than other forms of surveys or audits. Peer inspections depend heavily on the knowledge 2.E.1.2 Self-Audits and commitment of the people who conduct them. To supplement an inspection program, some institu- Individuals who volunteer or are selected to perform tions promote self-inspections within the laboratories. inspections for only a brief time may not learn enough Laboratory personnel may conduct their own inspec- about an operation or procedure to observe and com- tions for their own benefit or management may ask ment constructively. People who receive involuntary them to self-audit and report their findings, using the appointments or who serve too long may not maintain routine inspections as a check on the self-inspections. the desired level of diligence. This approach can be mutually beneficial, raising A high-quality peer-level inspection program re- awareness, promoting the institutional safety culture, duces the need for frequent inspections by supervi- and easing the burden on management. sory personnel. However, peer inspections should not replace other inspections completely. Walk-throughs by the organization’s leadership demonstrate com- 2.E.1.3 Program Audits mitment to the safety programs, which is key to their A program audit includes both a physical inspec- continuing success. tion and a review of the operations and the facilities. This type of audit is generally conducted by a team, 2.E.1.5 Environmental Health and Safety which includes the laboratory supervisor, senior man- Inspections agement, and laboratory safety representatives, and presents an excellent opportunity to promote a culture The organization’s EHS staff, the safety committee, of safety and prudence within an organization. The su- or an equivalent group may also conduct laboratory
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25 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM inspections on a routine basis. These inspections may conducting similar audits of peer institutions. More be comprehensive, targeted to certain operations or and more often, health and safety experts, facilities experiments, focused on a particular type of inspec- staff, and laboratory personnel from peer institutions tion such as safety equipment and systems, or audits form inspection teams that conduct inspections of each to check the work of other inspectors. other’s laboratories. Such an arrangement can be ben- Safety staff are not the only nonlaboratory person- eficial and economical. nel who may conduct safety inspections. Facility Many regulatory agencies promote institutions engineers or maintenance personnel may add con- conducting self-audits, by either consultants or peer siderable value to safety inspection programs. They auditors, and reporting the findings to the agency. are also given the opportunity to gain a better per- As an incentive, any violations noted in the self-audit spective on laboratory work. It is advisable to have may result in reduced or waived fines and fewer visits a representative from facilities engineering present from the agency inspectors. It is important to fully during inspections so physical deficiencies can be understand the regulatory agency’s self-reporting appropriately and clearly noted and understood and policy before implementing this option. In some cases, priorities set for correction. the institution must commit to remediating identified deficiencies within a specific time period. Finally, regulatory agencies may conduct announced 2.E.1.6 Inspections by External Entities or unannounced inspections on a routine or sporadic Many types of elective inspections or audits are basis. Laboratories and institutions should keep their conducted by outside experts, regulatory agencies, programs and records up-to-date at all times to be emergency responders, or other organizations. They prepared for such inspections. Any significant inci- may inspect a particular facility, equipment, or proce- dent or accident within a facility may trigger one or dure either during the preexperiment design phase or more inspections or investigations by outside agen- during operations. As a matter of safety and security, if cies. Evidence that the underlying safety programs are someone requests entry to a laboratory for the purpose sound may help limit negative findings and potential of an audit without a recognized escort, ask to see his penalties. or her credentials and contact the EHS office or other appropriate parties. 2.E.2 Elements of an Inspection Tours, walk-throughs, and inspections by regulatory or municipal organizations offer the opportunity to 2.E.2.1 Preparing for an Inspection build relationships with governmental agencies and the public. For example, an annual visit by the fire Whether an inspection is announced or unan- department serving a particular facility will acquaint nounced depends on the objective. There are many personnel with the operations and the location of par- advantages to announcing an inspection ahead of ticular hazards. If these individuals are ever called into time. By announcing and scheduling inspections, the the facility to handle an emergency, their familiarity inspectors are more likely to interact with the labora- with it will make them more effective. During their tory personnel and the supervisors. The inspection can walk-through, they may offer comments and sugges- be a good learning experience for all and will feel less tions for improvements. A relationship built over time like a safety-police action and more like a value-added helps make this input positive and constructive. service, with the right attitude and approach. How- If a pending operation or facility change may raise ever, if the objective is to observe real-time conditions public attention and concern, an invitation targeted to in preparation for a regulatory inspection, an unan- specific people or groups may prevent problems. Hold- nounced targeted inspection might be appropriate. ing public open houses from time to time helps build Before the inspection, have a checklist of inspection a spirit of support and trust. Many opportunities exist items, along with the criteria and the basis for each to apply this type of open approach to dealing with the issue. The criteria may be based on regulations, insti- public. An organization only needs to consider when to tutional policies, or recommended practices. Sharing use it and what potential benefits may accrue. the checklist with laboratory personnel prior to the Inspections and audits by outside consultants or peer inspection helps them perform their own inspections institutions are especially helpful to identify both best before and periodically after the inspection. practices and vulnerabilities. Many times, the inspec- Bring a camera. A photograph is much more effective tors bring with them experiences and examples from than a long explanation in convincing a manager that other laboratories that prove useful. When choosing a something needs attention. consultant, best practice is to find one with experience
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26 PRUDENT PRACTICES IN THE LABORATORY Be sure to follow up with the laboratory to ensure that 2.E.2.2 Inspection Checklists recommended corrections are made. Inspection checklists take a variety of formats and vary in length depending on the type and focus of the inspection. Although most inspection forms are paper, 2.E.2.5 Corrective Actions some are computer based. Make each inspection item In most cases, laboratory personnel will take the ap- a YES or NO question. Pose the issue so that a positive propriate corrective actions once they have been made outcome is a YES, making it easy to spot problems. aware of an issue. If the laboratory supervisor is not Always leave room for comments. supportive and the necessary changes are not made, There are a number of commercial products on the the inspectors and EHS and other appropriate indi- market offering Web-based applications that work on viduals in the organization will have to decide whether a laptop or notebook computer. Checklist programs the infractions are serious enough to put either the are available for handheld digital devices. Some may health or safety of laboratory personnel at risk or the download into spreadsheets or word-processing pro- institution at risk for violation of a regulation or code. grams. Others automatically create reports that can be The organization must decide what steps to take for e-mailed to recipients. All are intended to streamline those individuals or laboratory groups that are using the record-keeping and reporting process. unsafe work practices or are not in compliance with institutional policies or external regulations. 2.E.2.3 Conducting the Inspection When conducting an inspection, interacting with 2.E.3 Items to Include in an Inspection the individuals in the laboratory is important. Even if Program inspectors are mainly looking at equipment and con- The following list is representative, not exhaustive: ditions, laboratory personnel can provide a great deal of information and the conversation itself may foster • Required PPE is available and used consistently positive relationships between laboratory personnel and correctly (e.g., laboratory coat, gloves, safety and the group conducting the inspection. Speaking glasses, chemical splash goggles, face shield). with laboratory personnel also helps gauge how well • Compressed gas cylinders are secured correctly, training programs are working and provides feedback cylinders are capped if not connected for use, and for possible improvements to the laboratory safety proper regulators are used. program. • Limitations on where food and drink storage and Take notes and make comments on the inspection eating and drinking are allowed are observed. form to be able to recall the details and describe any • Electrical cords are off surfaces where spills of problems in the report. Where possible, take photo- flammable materials are likely, and cords are in graphs of issues that need particular attention. good condition, not displaying signs of excessive Point out problems as they are found and show wear (fraying, cords are not pinched). Equipment laboratory personnel how to fix them. If the problem not meeting National Electrical Safety Code Divi- is corrected during the inspection, make a note that it sion 1, Group C and D explosion-resistance speci- was resolved. fications are electrically inspected prior to use in the laboratory. (See Chapter 7, section 7.C.) • Laboratory chemical hoods have been tested and 2.E.2.4 Inspection Report are operated with inspection information visible, As soon as possible after an inspection, prepare a hoods are used properly, work is conducted inside report for the laboratory supervisor and others, as 6 in. from hood face, airflow is not significantly appropriate. This may include the CHO, the chair impeded by large pieces of equipment. or manager of the department, line supervisors, and • Vacuum glassware is inspected and maintained directors. Depending on the type and focus of the in- i n good condition, pressure reaction vessels spection, it may be helpful to hold a meeting with the with pressure relief and temperature/pressure key individuals to review the findings. measuring capability are used for high-pressure The report should include all problems noted during reactions. the inspection, along with the criteria for correcting • Health classification of materials is conducted them. If photographs were taken, include them in the (particularly for unknown compounds), and as- report. The report should also note any best practices sociated work practices and containment based on and any improvements since the last inspection. hazard/risk classification of the material are fol- Include a reasonable time line for corrective actions. lowed (e.g., low hazard, hazardous, particularly
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27 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM hazardous materials and associated requirements for use of ventilated enclosures, disposal of waste, BOX 2.4 labeling of areas where work with high-hazard Excerpt from an materials is conducted, decontamination of work Inspection Checklista surfaces). Department/Group/Laboratory: • Access to emergency equipment is unobstructed Inspector: (e.g., safety showers, eyewash units, fire extin- Date: guishers), and equipment is maintained in good Building and Room: working order. Aisles are unobstructed and mini- Laboratory Supervisor: mum egress is maintained. Minimum clearance to sprinkler heads, as required by local building and LABORATORY ENVIRONMENT fire codes, is maintained. • Chemicals are properly stored and segregated Work areas illuminated Y N NA ( e.g., flammables, strong acids, strong bases, Storage of combustible materials minimized Y N NA peroxides). Aisles and passageways are clear and Y N NA • Personnel demonstrate ability to access MSDSs or unobstructed other chemical safety references and knowledge of Trash is removed promptly Y N NA handling requirements for various classifications of materials. No evidence of food or drink in active Y N NA • Rotating machinery and high-temperature de- laboratory areas vices have appropriate guards. Safety switches Wet surfaces are covered with nonslip Y N NA and emergency stops are working. materials • Associated egress corridors are unobstructed and Exits are illuminated and unobstructed Y N NA minimum egress as required by building and fire Proper management of hazardous materials Y N NA codes is maintained. Combustible and surplus and waste materials and equipment are removed from exit passageways. COMMENTS: ——————————————————————— Depending on the laboratory and the type of work Other elements of the checklist can include: conducted in it, other items may also be targeted for • Emergency equipment and planning inspection (Box 2.4). • Personal protective equipment • Signs, labels, plans, and postings 2.F EMERGENCY PROCEDURES • Electrical hazards • Storage 2.F.1 Fire Alarm Policy • Compressed gases and cryogenics • Pressure and vacuum systems When a fire alarm sounds in the facility, evacuate the • Laboratory hoods and ventilation laboratory immediately via the nearest exit. Extinguish • Security all Bunsen burner and equipment flames. If the fire • Training/awareness originates in your laboratory, follow all institutional policies regarding firefighting and suppression. Check aFor a full checklist, see the CD that accompanies this restrooms and other areas with possible limited audio book. or visual notification of an alarm before exiting the facility. Where necessary, provide assistance to per- sons with disabilities to ensure they are able to exit the facility. includes procedures for evacuation, ventilation 2.F.2 Emergency Safety Equipment failure, first aid, and incident reporting. 2. Fire extinguishers are available in the laboratory The following is a guide to safety equipment found and tested on a regular basis. If a fire extinguisher in a laboratory. is activated for any reason, make an immediate report of the activity to the CHO, fire marshal, 1. A written EAP has been developed and com- or appropriate individual responsible for fire municated to all personnel in the unit. The plan
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28 PRUDENT PRACTICES IN THE LABORATORY Low-flammability and low-toxicity materials that safety equipment so that the fire extinguisher is are not volatile (e.g., inorganic acids and caustic replaced in a timely manner. bases) 3. E yewash units are available, inspected, and tested on a regular basis. 1. Decontaminate any victim at the nearest safety 4. Safety showers are available and tested routinely. shower or eyewash unit. Take other appropriate 5. Fire blankets are available in the laboratory, as action as described in the MSDS. required. Fire blankets can be used to wrap a 2. Notify appropriate personnel immediately.4 burn victim to douse flames as well as to cover 3. Limit or restrict access to the area as necessary. a shock victim and to provide a privacy shield 4. Wear PPE that is appropriate to the degree of when treating a victim under a safety shower in hazard of the spilled substance. the event of a chemical spill. 5. Use chemical spill kits that contain an inert ab- sorbent to clean up the affected area if this action NOTE: Laboratory personnel should be taught can be accomplished without risk of additional that fire blankets can be dangerous if used incor- injury or contamination to personnel. If the spill rectly. Wrapping a fire blanket around a person is located on the laboratory floor, be aware that on fire can result in a chimney-like effect that some absorbents can create a slipping hazard. intensifies, rather than extinguishes, the fire. 6. Dispose of contaminated materials according to Fire blankets should never be used on a person institutional policy. when they are standing. (See Chapter 7, section 7. Complete an incident report and submit it to the 7.F.2.3 for more information on responding to appropriate office or individual. fires.) 8. Label all phones with emergency phone numbers. 6. F irst-aid equipment is accessible, whether Flammable solvents of low toxicity (e.g., diethyl through a kit available in the laboratory or by ether and tetrahydrofuran) request through the organization. 7. Fire alarms and telephones are available and ac- 1. Decontaminate any victims at the nearest safety cessible for emergency use. shower or eyewash unit. Take other appropriate 8. Pathways to fire extinguishers, eyewash units, action as described in the MSDS. fire blankets, first-aid kits, and safety showers 2. Alert all other personnel in the laboratory and are clear. the general vicinity of the spill. 3. Extinguish all flames and turn off any spark- 2.F.3 Chemical Spill Policy producing equipment. If necessary, turn off power to the laboratory at the circuit breaker. Laboratory personnel should be familiar with the The ventilation system must remain operational. chemical, physical, and toxicological properties of 4. Immediately notify appropriate personnel.4 each hazardous substance in the laboratory. Consult 5. Limit or restrict access to the area as necessary. the label and the MSDS prior to the initial use of each 6. Wear PPE that is appropriate to the degree of hazardous substance. Always use the minimal amount hazard of the spilled substance. of the chemical and use caution when transporting the 7. Use spill pillows or spill absorbent and nonspar- chemical. In the event of an accidental chemical release king tools to soak up the solvent as quickly as or spill, personnel should refer to the following general possible. Be sure to soak up chemicals that have guidelines. seeped under equipment and other objects in the Most laboratory workers should be able to clean up laboratory. If the spill is located on the laboratory incidental spills of the materials they use. Large spills, floor, be aware that some absorbents can create a for example, 4 L or more, may require materials, pro- slipping hazard. tective equipment, and special handling that make it 8. Dispose of contaminated materials according to unsafe for cleanup by laboratory workers themselves. institutional policy. Lab workers should be instructed to contact EHS per- 9. Complete an incident report and submit it to the sonnel to evaluate how to proceed with spill cleanup. appropriate office or individual. In the event that the spill material has been released to the environment, notify EHS personnel immediately. A release to the environment includes spills directly into a drain or waterway or onto land, such as grass 4The person to notify in case of an incident in the laboratory var- ies by organization. It may be the CHO, the safety director, on-site or dirt. security, or another party. Check with the organization to determine the appropriate individual or office.
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29 ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT SYSTEM 2.G EMPLOYEE SAFETY Highly toxic materials (e.g., dimethylmercury) TRAINING PROGRAM 1. Alert all trained laboratory personnel in the labo- Newly hired employees or students working in a ratory and the general vicinity of the spill and laboratory should be required to attend basic safety immediately evacuate the area. training prior to their first day. Additional training 2. Decontaminate any victims at a safety shower should be provided to laboratory personnel as they or eyewash unit in a safe location. Take other advance in their laboratory duties or when they are appropriate decontamination action as described required to handle a chemical or use equipment for in the MSDS. the first time. 3. Immediately notify appropriate personnel.4 Safety training should be viewed as a vital com- 4. Limit or restrict access to the area as necessary. ponent of the laboratory safety program within the 5. Do not attempt to clean up the spill. EHS person- organization. The organization should provide ongo- nel will evaluate the hazards that are involved ing safety activities that serve to promote a culture of with the spill and will take the appropriate safety in the workplace that will begin when the person actions. begins work and will continue for the length of their 6. Only EHS personnel and appropriate outside in- tenure. Personnel should be encouraged to suggest dustrial hygienists are authorized to decontami- or request training if they feel it would be beneficial. nate the area and dispose of the contaminated The training should be recorded and related docu- waste. ments maintained in accordance with organizational 7. Complete an incident report and submit it to the requirements. appropriate office or individual. Training sessions may be provided in-house by professional trainers or may be provided via online training courses. Hands-on, scenario-based training 2.F.4 Accident Procedures should be incorporated whenever possible. Safety In the event of an accident, follow all institutional training topics that may prove to be helpful to labora- policies for emergency response and notify the internal tory personnel include point of contact for laboratory safety and local emer- gency responders. All accidents involving personal in- • use of CHPs and MSDSs, jury, however slight, must be immediately reported ac- • chemical segregation, cording to your institution’s procedure. Provide a copy • PPE, of the appropriate MSDS to the attending physician, as • safety showers and eyewash units, needed. Complete an accident report (Figure 2.2) and • first aid and cardiopulmonary resuscitation, submit it to the appropriate office or individual within • chemical management, 24 hours of the incident. • gas cylinder use, • fire extinguisher training, • laser safety, and • emergency procedures.
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30 PRUDENT PRACTICES IN THE LABORATORY Personal Data Employee/Student Case No. Name Employee/Student Phone No. Employee/Student Investigation Date Dept. Investigator Name Employee Supervisor Event Details Employee/Student Statement ( Description of event—before, during, and after) Body Part Injured Event Location Event Date/Time / [lab, corridor, stairs, outside, etc.] Specific Location Reported Injury Date/Time / [building, floor, room, column] Injury Severity Car/Truck/Motorized Vehicle Surface Accident Type ____________________ Device Type Device Brand Contaminated Sharp Involved Needle Stick Accident report form. FIGURE 2.2 Figure 2-2 - accident report form.eps