Centre College Chemical Hygiene Plan

Table of Contents

ACKNOWLEDGEMENTS
INTRODUCTION
GENERAL POLICY AND RESPONSIBILITIES WITHIN THE CHP
CENTRE COLLEGE'S CHEMICAL HYGIENE PLAN
IDENTIFICATION OF CHO AND THE DIVISION III SAFETY COMMITTEE
STANDARD OPERATING PROCEDURES
PROCEDURE-SPECIFIC SAFETY PROCEDURES
CONTROL MEASURES AND EQUIPMENT FOR HAZARDOUS CHEMICALS
SPECIAL PROCEDURES FOR PARTICULARLY HAZARDOUS CHEMICALS
EMPLOYEE TRAINING AND INFORMATION
MEDICAL CONSULTATION AND EXAMINATION
USE OF RESPIRATORS
DISPOSAL OF USED CHEMICALS
RECORDS
UPDATING/MODIFICATION OF CHP

ACKNOWLEDGEMENTS

I prepared this Chemical Hygiene Plan for Centre College during the summer of 1991. Although I wrote substantial parts of the plan, I do not claim its authorship. In the preparation of this plan, I consulted 29 CFR 1910 and several plans from other institutions. What was found was a wealth of pertinent, useful information expressed in more than one document in exactly; or virtually identical language, without reference. It proved to be impossible to determine the original author(s). I inferred that it was common practice in these plans to use substantial amounts of written information without the usual referencing and quoting of materials found in more scholarly work. I have also, uneasily, followed this approach. If it is important to know what is my original work and what was used from other sources, I will provide that information. In closing, let me indicate that substantial material is included herein, without the usual referencing, from three sources: Model Chemical Hygiene Plan for Kentucky School Districts by M. N. Howard and F. B. Howard, Developing a Chemical Hygiene Plan by J. A. Young, W. K. Kingsley, and G. H. Wahl, Jr., and A Model Chemical Hygiene Plan for Laboratories by T. J. Gile.

Prepared by: Marshall Wilt

INTRODUCTION

The January 31, 1990 Federal Register (pages 3300-3335) published OSHA's "Laboratory Standard" applicable to certain employers some of whose employees work with hazardous chemicals. It is commonly accepted that colleges such as Centre College meet the criteria for applicability for the Laboratory Standard and are hence subject to its regulation as stated in 29CFR1910.1450. The state of Kentucky, through its own OSHA, has adopted the federal Laboratory Standard and is thus Centre's immediate governmental regulatory agency in this area. One mandatory aspect of the Laboratory Standard is the development of a Chemical Hygiene Plan (CHP). This document is a statement of Centre's CHP.

OSHA (Federal Register/Vol. 55, No. 21, p. 3328) defines a hazardous chemical as one "for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles, that acute or chronic health effects may occur in exposed employees." This is a very broad definition which applies to numerous chemicals commonly used in science education. The purpose of the Lab Standard is to protect employees from exposure to potentially harmful levels of hazardous chemicals. Centre shall strive to extend that protection to its employees and also its students. The Lab Standard is a performance standard in that it relates to achieving certain protective results; it does not rigidly specify procedures for obtaining results: it gives employers the latitude to decide upon institutionally-appropriate procedures for providing protection from exposure to hazardous chemicals. It is within this context that the following CHP has been developed.

GENERAL POLICY AND RESPONSIBILITIES WITHIN THE CHP

Centre College strives to provide a safe laboratory environment for its employees and students, and believes that these groups have the right to know about potential health hazards associated with their work with chemicals. Upon request, the College through its CHP will provide descriptions of our policies regarding laboratory safety, procedure, potential hazards, and training to appropriate employees and students. Centre encourages them to make suggestions concerning chemical safety to the Chemical Hygiene Officer (CHO) identified below.

The President as chief administrative officer ultimately carries responsibility for safety in Centre's chemical operations. He may choose to delegate some parts of that responsibility to his chief instructional officer, the Dean of the College. The College shall appoint a Chemical Hygiene Officer who reports to the President or his delegate, the Dean of the College, and has the responsibility of developing and implementing the CHP. In these responsibilities the CHO will work with the Chair of the Division of Science and Mathematics and with the College Safety Committee described below. Part of the responsibility of the CHO is the training of faculty, staff, and student assistants who work with hazardous chemicals.

Each laboratory-teaching faculty or staff member is responsible for planning and conducting laboratory work consistent with the CHP and other relevant safety considerations. These members have the responsibility of ensuring that their student assistants follow appropriate safety practices and that enrolled students do likewise. Students have the responsibility of following the CHP and should be required to sign a form stating that they have been provided relevant safety instructions. Other Centre supervisors whose employees use hazardous chemicals must insure that those people follow the CHP. Where appropriate Centre's employees should consult the CHO for advice on the planning and implementation of safe practices for the use of chemicals.

The CHO shall occasionally monitor operations to ensure that practice is consistent with the CHP.

If a disagreement regarding safety develops between a laboratory teaching faculty or staff member, or another employee, and the CHO, and the matter cannot be resolved in discussions involving the Division III Chair or the Director of Public Safety, the CHO will report the matter to the Dean of the College.

CENTRE COLLEGE'S CHEMICAL HYGIENE PLAN

The materials below constitute Centre's CHP. Some of the vocabulary is not in general use and is used in a specific, sometimes technical manner. The reader is referred to Appendix E for a glossary of relevant terms. Copies of the CHP are readily available through the CHO, Division III faculty whose teaching utilizes chemicals, the art program, the Director of Public Safety, and the staff of the Director of the Physical Plant.

IDENTIFICATION OF CHO AND THE DIVISION III SAFETY COMMITTEE

Centre's CHO is Cheryl Mayes, Physical Sciences Lab Coordinator and Campus Safety Officer. Her office is in Olin 021, and her telephone numbers are: (859) 238-8745 (office) and 222-6780 (pager).

The College Safety Committee shall consist of the members appointed by the Division III Chairperson and will assist the CHO in the implementation of the CHP.

STANDARD OPERATING PROCEDURES

The following standard procedures will be used when working with hazardous chemicals. This section is adopted from Young, Kingsley and Wahl.

PROCEDURE-SPECIFIC SAFETY PROCEDURES

All laboratory instructions to students must contain a written description of specific safety practices incorporating the applicable precautions described in the following five sections. Instructors should ensure that students are aware of these practices before commencing a procedure. Employee supervisors should do likewise. Always plan operations to use the minimum quantities of the safest materials consistent with the objective.

Procedures for Toxic Chemicals

The MSDS's for many of the chemicals used in the laboratory will state recommended limits or OSHA-mandated limits, or both, as guidelines for exposure. Typical limits are threshold limit values (TLV), permissible exposure limits (PEL), and action levels. When such limits are stated, they will be used to assist the instructor and chemical hygiene officer in determining the safety precautions, control measures, and safety apparel that apply when working with toxic chemicals. Consult the CHO and/or Appendix C for PEL values of chemicals under consideration for laboratory use. Pay particular attention to Table Z-2 for substance-specific standards.
  1. When a TLV or PEL value is less than 50 ppm or 100 mg/m3, the user of the chemical must use it in a properly operating fume hood, glove box, vacuum line, or similar device, which is equipped with appropriate traps and/or scrubbers. If these devices are not available, no work should be performed using that chemical.
  2. If a TLV, PEL, or comparable value is not available for that substance, the animal or human median inhalation lethal concentration information, LC will be assessed. If that value is less than 200 ppm or 200 mg/m3 (when administered continuously for one hour or less), then the chemical must be used in an operating fume hood, glove box, vacuum line, or similar device, which is equipped with appropriate traps and/or scrubbers. If none is available, no work should be performed using that chemical. See MSDS's and/or the CHO for relevant data.
  3. Whenever laboratory handling of toxic substances with moderate or greater greater pressures will be likely to exceed air concentration limits, laboratory work with such liquids and solids will be conducted in a fume hood, glove box, vacuum line, or similar device, which is equipped with appropriate traps and/or scrubbers. If none are available, no work should be performed using the chemical.
  4. Additional special procedures apply to "acutely " toxic chemicals, as explained below.

Procedures for Flammable Chemicals

In general, the flammability of a chemical is determined by its flash point, the lowest temperature at which an ignition source can cause the chemical to ignite momentarily under certain controlled conditions.
  1. Chemicals with a flash point below 200 degrees F (93.3 degrees C) will be considered "fire hazard chemicals."
  2. OSHA standards and the National Fire Protection Association (NFPA) guidelines on when a chemical is considered flammable apply to the use of flammable chemicals in the laboratory. In all work with fire-hazard chemicals, follow the requirements of 20CFR, subparts H and L; NFPA Manual 30, "Flammable and Combustible Liquids Code"; and NFPA Manual 45, "Fire Protection for Laboratories Using Chemicals." Consult labels and MSDS's for relevant data.

Procedure for Reactive Chemicals

A reactive chemical is one that:
  1. Is described as such on the container label or the MSDS.
  2. Is ranked by the NFPA as 3 or 4 for reactivity.
  3. Is identified by the DOT as
  4. Fits the EPA definition of reactive in 40CFR261.23.
  5. Fits the OSHA definition of unstable in 29CFR 1910.1450, or
  6. Is known or found to be reactive with other substances.
Handle reactive chemicals with all proper safety precautions, including segregation in storage and prohibition on mixing even small quantities with other chemicals without prior approval and appropriate personal protection and precautions. See MSDS's for safety procedures.

Procedures for Corrosive Chemicals and Contact Hazard Chemicals

Corrosivity, allergenic, and sensitizer information is sometimes given in manufacturers' MSDS's and on labels. Also, guidelines on which chemicals are corrosive can be found in other OSHA standards and in regulations promulgated by DOT in 49CFR and the EPA in 40CFR.

A corrosive chemical is one that:

  1. Fits the OSHA definition of corrosive in Appendix A of 29CF 1910.1200.
  2. Fits the EPA definition of corrosive in 40CRF261.22 (has a pH greater than 12 or less than 2.5), or
  3. Is known or found to be corrosive to living tissue.
A contact-hazard chemical is an allergen or sensitizer that:
  1. Is so identified or described in the MSDS or on the label.
  2. Is so identified or described in the medical or industrial hygiene literature, or
  3. Is known or found to be an allergen or sensitizer.
Except as noted in 1 of the section on PROTECTIVE CLOTHING AND EQUIPMENT, handle corrosive chemicals with all proper safety precautions, including wearing both safety goggles and face shield, gloves tested for absence of pin holes and known to be resistant to permeation or penetration, and a laboratory apron or laboratory coat.

Procedures for Teratogenic, Magnetic and Carcinogenic Chemicals

Chemicals in these categories are often identified as such on the appropriate MSDS's. A partial list of carcinogenic and teratogenic materials is included as Appendix H. Also see table 2-2 in Appendix C. Contact the CHO for advice in the case of uncertainty.
  1. Follow the operating procedures for these materials as given on the MSDS.
  2. Be aware that "select" carcinogens and some mutagenic and teratogenic compounds require the use of a designated area as described below. Carefully consider using a designated area when working with mutagenic or teratogenic materials.

CONTROL MEASURES AND EQUIPMENT FOR HAZARDOUS CHEMICALS

Chemical safety is achieved by continual awareness of chemical hazards and by keeping the chemical under control by using precautions, including engineering safeguards such as hoods.

Laboratory personnel and other employees should be familiar with the precautions to be taken, including the use of engineering and other safeguards. All engineering safeguards and controls must be properly maintained, inspected on a regular basis, and never overloaded beyond their design limits.

Ventilation

  1. Laboratory ventilation should be not less than ten air changes per hour (calculated). This flow is not necessarily sufficient to prevent accumulation of chemical vapors. Work with toxic chemicals that have low air concentration limits, or that have high vapor pressures, should always be done in a hood.

  2.  

     

    Fume hoods must provide adequate air flow. For Olin Hall fume hoods, adequate flow is defined in the Thermal Balance test report dated November, 1988. This report specifies a flow rate of 760 CFM for four-foot hoods, and 1750 CFM for eight-foot hoods. Auxiliary air flow is to be 532 CFM for a four-foot hood, 1225 CFM for an eight-foot hood. Tolerances are + 10%. Other fume hoods such as those in Young Hall must provide a minimum area- weighted average flow speed of 80ft/min.
    Users of fume hoods should be able to recognize obviously low air flow rates. Users should consciously check to see that air flow appears normal. Do not use a hood whose air flow appears abnormally low.

  3. Laboratory employees should understand and comply with the following:
  4. Air flow in chemical storage areas shall give not less than ten air changes per hour (calculated).
  5. Air flow rates for laboratory ventilation, fume hood exhaust (and auxiliary air where appropriate) and chemical store room ventilation shall be monitored just before each long term. This monitoring is the responsibility of the Chemical Hygiene Officer. Discrepancies, if any, will be corrected before use by our plant engineering staff supervised by Centre's Director of Physical Plant. A fume hood or laboratory with a serious air flow discrepancy (less than 50% of design flow as defined above) must not be used.

Flammable-Liquid Storage

  1. In the laboratory, fire-hazard chemicals (section VI b) in quantities greater than 500 ml should be kept in metal safety cans designed for such storage. The cans should be used only as recommended by the manufacturer, including the following safety practices:
  2. Cabinets designed for the storage of flammable materials should be properly used and maintained. Read and follow the manufacturer's information and and also follow these safety practices:

Eyewash Fountains and Safety Showers

  1. Eyewash fountains and safety showers shall be checked monthly during academic year to ensure proper operation and adequate water flow. Inspection is the responsibility of the Chemical Hygiene Officer, while prompt corrective action is the responsibility of the Director of the Physical Plant.
  2. Be sure that access to eyewash fountains and safety showers is not restricted or blocked by temporary storage objects or in any other way.

Respirators

  1. Employees should wear respirators whenever it is possible that engineering controls or work practices could become or are ineffective and that employees might be exposed to vapor or particulate concentrations greater than the PEL, action level, TLV, or similar limit, whichever is the lowest.
  2. The requirements of 29CFR 1910.134 should be followed, including in particular:

SPECIAL PROCEDURES FOR PARTICULARLY HAZARDOUS CHEMICALS

Definitions

Follow the procedures described below when performing laboratory work involving more than 10 mg of a particularly hazardous chemical. In particular, work only in designated areas. You must consult the CHO before beginning work with an inimical chemical.

EMPLOYEE TRAINING AND INFORMATION

The aim of the employee training and information program is to assure that all individuals at risk are adequately informed about: the physical and health hazards associated with hazardous chemicals present in the laboratory; the proper procedures to minimize risk of exposure; and the and the proper response to accidents.

It is the responsibility of the Chemical Hygiene Officer to conduct employee training sessions at least annually. All faculty graduate and student assistants whose teaching involves hazardous chemicals shall be trained as shall other employees (e.g., custodians and their supervisors) whose work assignments may bring them into contact with hazardous chemicals.

The Chemical Hygiene Officer may, if convinced that certain individuals already possess necessary information, excuse these individuals from training sessions. Also, if new student assistants are added after initial training at the beginning of an academic year, the Chemical Hygiene Officer may instruct these students' supervisor to administer the necessary training.

The CHO will maintain the records of the training received by each employee.

The training of employees generally shall include the following:

  1. The chemical hygiene standards, including the contents of 29 CFR Part 1910.1450;
  2. Location and contents of Centre's Chemical Hygiene Plan;
  3. Safe practices for handling hazardous chemicals and transporting them within the facility.
  4. The evaluation of hazards of chemicals on hand at Centre, including PEL's or other exposure limits;
  5. Labeling and storage practices, and information to interpret labels;
  6. Information on concepts necessary to understand reference materials, such as PEL, TLV, and LD .
  7. Location and content of MSDS's for chemicals in the school building, as well as other reference materials on the properties, safe handling, storage, and disposal of hazardous chemicals.
  8. Location and proper use of available protective apparel and equipment.
  9. The evaluation of signs and symptoms associated with exposures to hazardous chemicals used in the laboratory.
  10. Methods and observations to detect the presence or release of hazardous chemicals; and
  11. Appropriate procedures for responding to and reporting accidents involving chemical exposure.

MEDICAL CONSULTATION AND EXAMINATION

In the event that an employee is routinely exposed to levels of a hazardous chemical exceeding the PEL or TLV, or should an employee report or be observed to exhibit signs or symptoms of such an exposure, or if there has been an accident in which an employee probably received such an exposure, then the employee shall be provided the opportunity for a medical consultation to assess the need for a medical examination. If the results of the consultation indicate the need for a medical examination, one will be provided to the employee. All medical consultations and examinations shall be performed by the Centre College physician and shall be provided in a timely manner at no cost to the employee. The CHO will provide the physician with the identity of the chemical(s) involved in the exposure, exposure conditions, signs and symptoms of the exposure, and the relevant MSDS.

The college physician will provide a written record of consultations and/or examinations that will not reveal findings unrelated to the exposure but will include any recommendation for further medical follow-up, results of examinations and tests if administered, medical conditions of the employee which would put his or her at increased risk as a result of the exposure, and a written statement that the employee has been fully informed of the results of the consultation/examination. The CHO shall maintain copies of relevant records. Employees will be provided a copy of the record if desired.

USE OF RESPIRATORS

Whenever exposure limits cannot be controlled below the TLV or PEL values of part V above by the use of fume hoods, one must use a respirator in accordance with the relevant standards. A possible example of such a situation might arise for a worker taking inventory for an extended period in a chemical store room. In such cases, Centre will provide the necessary respirator located in both the Young Hall and Olin Hall Stockrooms. Respirator training information is provided through its Department of Public Safety. See Appendix G for necessary information.

DISPOSAL OF USED CHEMICALS

This section of Centre College's chemical hygiene plan constitutes the College's disposal plan. The purpose of this plan is to minimize the harm to people, other organisms, and the environment from chemicals used at Centre College. This plan considers how used chemicals are to be collected, stored, and disposed of.

Centre College is considered a limited quantity generator because it generates less than 100kg of used chemicals per month. We have applied to the Kentucky Department of Environmental Protection and have been assigned the limited quantity generation number of KYD-985-082-726.

The first priority of the disposal program is to reduce the amounts, number of types, and the degree of hazard associated with our used chemicals. Employees should strive to reduce the number of different chemicals, and the scale of and hazard associated with their use. Avoid using hazardous chemicals if practical. Purchase chemicals only in the amounts needed in the near future, and consider methods of recovery and recycling of used chemicals.

Certain chemicals are suitable for drain disposal into the Danville sanitary sewer system. These chemicals are only those reasonably soluble in water. These materials must be flushed with a large (at least 100 times by volume) excess of water. A partial list of these chemicals is included in Appendix F.

Used chemicals which are not drain disposable and are no longer necessary are to be classified, segregated and placed into appropriate used-chemical containers for each of the following categories:

  1. Water immiscible solvents(e.g., diethyl and petroleum ether, mineral spirits, turpentine, gasoline, toluene, xylenes, benzene, ketones, etc.)
  2. Particularly hazardous chemicals (e.g., known or suspect carcinogens, mutagens, or teratogens, toxic inorganics like As, Cd, Ag, Cr, Se, Pb, Ba, etc.)
  3. Lubricating Oils
  4. Other chemicals (e.g., water or air reactive materials, peroxides, azides and other explosives, non-toxic inorganics).
If there is uncertainty about classification, see the CHO. Care should be taken not to mix incompatible used chemicals.

Note that elemental mercury is to be recycled. A storage container for used mercury is located in the chemical storeroom of Olin Hall, as is an apparatus for capturing spilled mercury.

It is anticipated that used chemicals in categories A and C will be stored in appropriate multiple-gallon containers as a mixture. Materials in categories B and D will often be stored in smaller, appropriately labeled closed glass containers. The label should identify the material and give a date and the name of the person adding the material to the storage site. The label should also identify any reactive, corrosive, toxic and/or biological health hazard.

Once each week used chemicals shall be taken from their temporary storage area (e.g.,laboratory generation site) to a central storage area such as the solvent storage room in Young Hall basement. Each involved faculty member or employee supervisor has the responsibility to ensure that this process is accomplished.

Central storage will continue until the end of May, at which time a licensed hauler will remove Centre's accumulated used chemicals and transport them to sites for either recycling, incineration, or landfill disposal. It is the responsibility of the Director of Public Safety to schedule and otherwise interface with the hauler, and to ensure that centrally stored unwanted Chemicals are removed from campus each May.

Everyone should understand that improper disposal of used chemicals by pouring them down the drain, adding them to mixed garbage, or evaporating them, perhaps in a hood, is unacceptable.

RECORDS

It is the responsibility of the CHO to maintain the following records. The records involving air-flow rates, spills, accidents, and medical consultations or examinations will be maintained for at least 30 years.
  1. Material safety data sheets.
  2. Chemical inventory including at least the quantity, hazard information and storage location.
  3. Safety inspections of Young and Olin Halls, print, etching and painting studios, RAC shop and physical plant location where hazardous chemicals are stored.
  4. Laboratory ventilation and fume hood airflow rates and monitoring and corrective actions.
  5. Chemical hygiene training records.
  6. Accident/incident reports. See Appendix H.
  7. Medical consultation/examination records.

UPDATING/MODIFICATION OF CHP

It is the responsibility of the CHO annually to evaluate Centre's CHP and to initiate changes where necessary to comply with regulations of external agencies or to improve safety and/or employee protection.