CHEMICAL HYGIENE PLAN

OSHA 29CFR 1910.1450

TO INCREASE SAFE ACTIVITIES IN LABORATORIES

REVISED FEBRUARY 2013

 TABLE OF CONTENTS
PAGE(S)
A. INTRODUCTION 1-3

1. OBJECTIVES
2. COVERED ACTIVITIES
3. ORGANIZATION AND RESPONSIBILITIES
a) CHEMICAL HYGIENE OFFICER
b) FACULTY
c) DEPARTMENT TECHNICIANS
d) STUDENTS

B. GENERAL LAB SAFETY 3-5

1. GOOD HABITS
2. UNATTENDED OPERATIONS
3. WORKING ALONE

C. EMERGENCY PLANNING 5

1. EMERGENCY EQUIPMENT
2. EMERGENCY EXITS
3. EMERGENCY COMMUNICATION
4. EVACUATION PLANS

D. EMERGENCY PROCEDURES 5-7

I. CHEMICAL SPILLS
II. CHEMICAL CONTAMINATION
III. FIRE
IV. INJURY

E. SAFETY EQUIPMENT 7-9

1. EQUIPMENT LIST
2. EQUIPMENT INSPECTION
3. PPE
4. FUME HOODS
5. SIGNS AND LABELS

F. CHEMICAL SAFETY 10-13

1. PROCUREMENT
2. HAZARDOUS CHEMICALS
3. STORAGE
4. FLAMMABLE AND COMBUSTIBLE LIQUIDS
5. COMPRESSED GASES
6. PARTICULARLY HAZARDOUS SUBSTANCES
7. PEROXIDE FORMERS
8. REACTIVE CHEMICALS
9. CONTROLLED SUBSTANCES

G. CHEMICAL WASTE DISPOSAL 13-15

1. INDENTIFYING HAZARDOUS WASTE

2. REGULATED NON-HAZARDOUS WASTE
3. WASTE MANAGEMENT
4. SECURITY AWARENESS

H. INFORMATION AND TRAINING 15

I. EXPOSURE MONITORING AND MEDICAL SURVEILENCE 15

J. OTHER SAFETY PROGRAMS 15

 OCCUPATIONAL EXPOSURE TO HAZARDOUS CHEMICALS IN LABORATORIES

OSHA - 29CFR 1910.1450

OVERVIEW

The “Lab Standard” of the Occupational Safety and Health Administration (OSHA) is designed to keep employees aware of
(and to reduce the exposures to) hazards associated with chemicals used in laboratories. It is an exception from the more
universal OSHA Hazard Communication Standard for operations where chemicals are used in a non-routine, non-
production manner by workers with at least some education and training in science. The “laboratory use” of chemicals is
defined by the Standard as chemical procedures using small quantities of hazardous chemicals on a laboratory scale and not
as part of a production process in an environment where protective laboratory practices and equipment are in common use.
The Lab Standard also goes beyond the Hazard Communication Standard in requiring a designated responsible employee
(the Chemical Hygiene Officer), requiring specific precautions for “particularly hazardous substances”; employer provided
medical consultation, and a specific program for ensuring the effectiveness of engineering control measures.

CHEMICAL HYGIENE PLAN FOR

WESTERN NEW ENGLAND UNIVERSITY

A) INTRODUCTION

1. OBJECTIVES

To have in place a working Chemical Hygiene Plan applicable to the needs of all persons involved in laboratory
procedures including faculty, adjunct faculty, department technicians, other staff, and students.

To enhance the learning experience by promoting safe laboratory operations.

To reduce exposure to hazardous chemicals through a hierarchy of source reduction, engineering controls,
administrative controls, and personal protective equipment.

To be prepared for emergency situations.

To reduce waste generated in laboratories by improving experiment design and including opportunities for reuse
and recycling.

To comply with the OSHA Lab Standard and other OSHA regulations pertaining to potential hazards found in the
covered laboratories.

2. ACTIVITIES COVERED BY THIS CHEMICAL HYGIENE PLAN

This Plan covers all laboratory activities from the following disciplines. This specifically includes any course,
research, or other work associated with: 1) The Chemistry and Biology Departments within the College of Arts
and Sciences 2) The Biomedical and Civil/Environmental Departments within the College of Engineering 3) The
Neuroscience Department within the College of Arts and Sciences 4) The College of Pharmacy and 5) Acoustical
science activities within the Mechanical Engineering Department.

3. ORGANIZATION AND RESPONSIBILITIES

Ensuring compliance with federal, state, and local safety regulations is the responsibility of the University
Environmental, Safety and Recycling Manager (ESRM). Plans written for this purpose will be negotiated with all
of the affected faculty and staff. Input is welcome from all staff and this plan will be maintained to reflect a
consensus of opinion of those parties covered by the Plan. This plan will go into effect when it is posted on the
Environmental, Safety and Recycling Manager’s web page, accessible from the University’s main website.
Specific responsibilities are as follows:

A) Chemical Hygiene Officer.

The University ESRM will serve as Chemical Hygiene Officer (CHO) for the purposes of this plan. The CHO will
be responsible for the following:

• Maintain the master of the University’s Chemical Hygiene Plan and draft corrections, revisions,
and additions for review by faculty and staff. The CHO will make this Plan and related
documents available on the Environmental, Safety and Recycling Manager’s web page available
through the University’s main web site.

• Maintain the University’s Material Safety Data Sheet Master File and on-line E-Binder.

• Provide safety training for all laboratory employees and support staff and maintain records of
this training.

• Conduct exposure evaluations and monitoring as necessary.

• Assist faculty and staff in establishing safety procedures relevant to this plan.

• Represent the University in regulatory inspections of the laboratory areas.

• Review reported laboratory accidents and develop recommendations as necessary.

• Conduct a periodic inspection program as to ensure the working condition of laboratory

engineering controls and safety equipment.

• Ensure compliance with the regulations regarding hazardous wastes generated in the
laboratories.

B) Faculty

• Follow the policies and procedures of this Chemical Hygiene Plan in their laboratories.

• Assess the potential hazards of laboratory work (including research and or coursework) by
considering all factors including the hazards of the stock chemicals, potential release of energy
from a reaction, equipment hazards, and the hazards of chemicals created by the experiment.

• Select laboratory practices that reduce the risk of injury or chemical exposure. Chemical
substitution, the use of smaller containers, the use of available engineering controls, and other
techniques should be considered when selecting experiment procedures.

• Forward a copy of all Material Safety Data Sheets (MSDS) received to the ESRM office at CUB
204. At least one copy should be added to an accessible collection within the department.

• Maintain original labels on chemicals and create new labels for non-original containers or other
stock preparations of hazardous chemicals using the University’s automated chemical label
maker system available at the Environmental Compliance and Safety web page.

• Add additional precautionary labels to containers of chemicals listed on the “Particularly

Hazardous Substance List”.

• Instruct students at the beginning of each semester on the location and use of safety equipment in
the laboratory.

• Inform staff, students, and visitors under their supervision of the specific hazards and required
safety procedures associated with the work being performed.

• Arrange for immediate response to injuries or other emergencies in areas under their supervision
or within their notice.
 • File a Work Request or report to Facilities Management (or the ESRM) for any unsafe
conditions that cannot be immediately remedied.

• Ensure that students are verbally informed of the safety precautions detailed in the experiment
instructions for each lab session.

• Keep all hazardous chemicals stored in centralized chemical storage rooms, storage cabinets, or
chemical storage refrigerators. Hazardous chemicals should not be stored in offices, lecture
halls, or fume hoods.

• Prepare all necessary additional paperwork required as laid out in this plan when laboratory
work involves “Particularly Hazardous Substances”.

• Attending safety training given by the CHO.

• Reporting of all accidents, spills or injuries to an immediate Supervisor and the Public Safety
Department. This is to include arrangements for immediate response to injuries or other
emergencies in areas under their supervision or within their notice.

C. Department Technicians and Stock Room Manager.

• Follow the policies and procedures within this Chemical Hygiene Plan within their laboratories.

• Forward a copy of any MSDS received to the Environmental, Safety and Recycling Manager.

• Reporting of all accidents, spills or unsafe conditions to the Faculty in Charge.

• Maintain original labels on chemicals and create new labels for non-original containers or other
stock preparations of hazardous chemicals using the College’s automated chemical label maker
system available at the Environmental Compliance and Safety web page

• Add additional precautionary labels to containers of chemicals listed on the “Particularly

Hazardous Substance List”.

• File a Work Request or report to Facilities Management (or the ESRM) for any unsafe
conditions that cannot be immediately remedied.

• Label hazardous waste and move it to the secured accumulation areas when the container is full
or no longer needed.

• Attend Safety Training given by the CHO.

D. Students

• Work in a safe and responsible manner.

• Follow directions for experiments as outlined by Faculty members.

• Wear proper protective equipment (i.e. safety glasses) as instructed by Faculty.

• Follow emergency procedures, report all spills or accidents to Faculty immediately.

• Follow other individual Departmental laboratory requirements as communicated via

use agreements and or written contracts.
B) GENERAL SAFETY PRECAUTIONS WHEN WORKING IN A LABORATORY

1. Develop Good Habits

Assume that all chemicals in the laboratory, regardless of state (liquid, powder, gas), may pose a potential hazard
and learn to temper curiosity with knowledge.

Examine every container before moving it or opening it. Is the container in good condition? Is there chemical
residue on the outside warranting the use of gloves or other personal protective equipment? Are there warnings on
the container label? Is the cap securely attached? Do the contents appear like they should appear? Are there signs
of sedimentation, oxidation, or possible contamination? If the answer to any of these questions is yes, do not
touch the container. Contact the ESRM (X1634) to have the container researched.

Keep all laboratory work areas as uncluttered as possible.

2. Learn

Know where to find, and how to use, the safety equipment in the laboratory. Note the location of the emergency
exits, fire blankets, fire extinguishers, first aid kits, drench hoses, eye wash stations, and emergency showers.

Learn the meaning of terms used on safety labels identifying the types of hazards or proper precautions for using a
chemical. Become familiar with other resources for chemical information including reference books and catalogs,
D’Amour Library resources, and the University’s Material Safety Data Sheet “eBinder” available on the ESRM
web page.

3. Do Not

Do not pipette ANYTHING by mouth. Rubber bulbs and pipetteing devices are available.

Eating, drinking, or smoking in any laboratory is not allowed. This includes chewing candy or gum. No food or
beverages are allowed to be brought into any laboratory. Note that the mouth is a very susceptible route of entry
for chemical and microbiological agents. Personal habits that involve contact with the mouth are strongly
discouraged such as chewing on pencils or pens, or the application of cosmetics.

Do not ingest any reagents and do not attempt to breathe them in directly. If an odor sample is necessary, use a
cupped hand to move a diluted vapor toward the face.

Do not use glassware that is cracked or chipped. Examine all laboratory equipment for defects before beginning
work and seek replacement items from the instructor or the stock room manager when a negative condition is
discovered. When inserting glass tubing or thermometers into stoppers, lubricate the tubing and the hole in the
stopper with glycerol or water. Hold the tubing in a towel near the stopper and insert while twisting.

Carrying out of unauthorized experiments is strictly prohibited.

4. Do

Long hair, loose jewelry, and loose clothing should be secured. These items can cause accidents by disturbing
chemical containers, contribute to increased exposure by soaking up chemicals, or increase hazards by catching
fire or reacting to chemicals.

Keep your lab area as clean and uncluttered as possible

Leave all personal items (coats, non-essential books, etc.) outside of the laboratory or in an unused portion of the
laboratory. Coat racks are available for that purpose. Be certain that these items do not block exit routes or safety
equipment. Keep any personal items that may be necessary for an experiment (such as notebooks, pen, etc.) well
away from the chemical use area.

Use all of the personal protective equipment required for each chemical manipulation based on written experiment
instructions or knowledge of potential hazards.

Inform your instructor or supervisor about any accidents, spills, or potential hazards.
 Before leaving the laboratory, wash all glassware, equipment, and lab table tops. Note that if your work involved
microbial or potential infectious materials than the word wash should also include disinfection techniques.

If you wear gloves during an experiment, rinse the gloves off before removing them and then wash your hands
with soap and water.

5. Unattended operations
Class experiments and other chemical procedures should not be left unattended without proper precautions being
taken. Hazardous chemicals and other hazards associated with the procedures (heat, high voltage, etc.) should be
clearly labeled. Other instructors or lab users should be given reasonable notice about the experiment’s existence.
This will provide the opportunity for others to mention if they will be in need of that equipment or area, and also
allow for a determination on Housekeeping access during Third Shift. The following must be implemented for
unattended laboratory experiments:

1. The immediate work area (i.e. chemical fume hood, lab bench) must be marked with:

a. The names of ALL chemicals involved in the reaction

b. A physical or health hazard warning statement concerning the chemicals. (i.e. flammable,
keep away from flame)
c. A signal word (i.e. Notice, Caution, Warning, Danger)
d. Other hazard identification (i.e. electricity, heat)
e. Faculty Name and their emergency phone contact information

2. Material Safety Data sheets for all chemicals involved in the reaction must be in the laboratory.

6. Working alone
Students should never work alone, without supervision in a laboratory. A single student may conduct an
experiment only if an instructor is present. Faculty who wish for students to work without supervision must make
arrangements through the Department Chair and the ESRM. Additional training must be given to the student
concerning the hazards of the individual experiment. There are no restrictions on the use of laboratories by faculty
and technicians other than the general requirement to observe the safety practices noted in this plan.

C) EMERGENCY PLANNING
Emergency response requires planning. It is the responsibility of each Faculty member to evaluate the hazards of the
experiments being performed, and to determine appropriate emergency procedures. Faculty must make students aware of
any emergency procedure prior to the start of any laboratory experiment. The following is a listing of emergency numbers

Public Safety X1411 Using a University Phone

(413) 782-1411 Using a Cell Phone

Environmental Safety and Recycling Manager X1634 Using a University Phone

(413) 782-1634 Using a Cell Phone

Director of Facilities Management X1240 Using a University Phone

(413) 782-1240 Using a Cell Phone

1. Emergency Equipment and Exits

Emergency Equipment is essential to any response. The equipment (i.e. fire extinguishers, fire
Blankets, eyewash and safety showers) must never be blocked. A quick check (by a faculty
Member) prior to the start of a laboratory experiment to ensure emergency equipment is readily
available is a good practice.

Egress in and out of laboratories must be maintained at all times. Aisle space must be adequately maintained in
order to ensure proper evacuation.
 2. Emergency Communication and Evacuation Plans
Emergency response procedures have been established in the Western New England University Emergency
Handbook. These handbooks give detailed response instructions to a variety of likely emergency scenarios on
campus. Included with the procedures is an “Emergency Reference Map” which shows the Emergency Assembly
Point (EAP) for individual University buildings. The emergency assembly point for each building is the reporting
location for faculty and students in the event of a building evacuation. For convenience purposes, these
procedures and map are available on the ESRM’s webpage. The CHO will include these topics in the annual
refresher training provided to faculty.

D) EMERGENCY PROCEDURES

1. Chemical Spills
Faculty must understand the chemicals (and their quantities) used in particular laboratories in order to plan for
emergencies. This will help them understand the level of response potentially required in the event a substance
spills; and also help them understand what types of emergency information will need to be communicated to
students. All spills should be reported to Public Safety at X1411. Be cognizant of the location, material
involved and instructions given by Public Safety. If comfortable in doing so, use the following as guidance in
assessing spills to public safety.

a) Incidental Spills

Spills that involve chemicals in types and quantities which can be absorbed or otherwise controlled by
those in the immediate area. This spill control must take into account the safety of those responding and
ultimately impose no safety or other hazard.

If you discover, or are involved in an incidental spill, ensure notification is made to a supervisor. Clean
up the spill upon assurance that no safety hazards are imminent. Spill clean-up materials are available in
the laboratory areas.

b) Emergency Spills

Spills that involve chemicals in types and quantities which are uncontrolled, to the environment, or pose
significant health or physical hazards. These spills will likely require the services of emergency
responders (i.e. fire, police, etc…) due to their location and or hazard potential.

If you discover, or are involved in an emergency spill, ensure the notification is made to a supervisor and
the Public Safety Department. Evacuation of the lab should be coordinated.

2. Chemical Contamination
There are several paths for Chemical contamination. Injection, Inhalation, Absorption and Ingestion are the
primary sources of chemical contamination. In the event that a Student or Faculty member becomes contaminated
with a chemical or biological substance the following steps should be followed…

a) Report to an eyewash, drench hose and or safety shower and flush affected areas with copious
amounts of water.
b) Contact (or have someone contact) Public Safety X1411.
o Communicate contamination source
o Communicate contaminant
c) Remove any contaminated clothing while continuing to shower.
d) Follow Public Safety instructions.

3. Fire
a) Discovery of a Fire

If any faculty member or student detects smoke or other signs of fire, they should investigate only if it is safe
to do so.
 The appropriate response steps are: 1) Pull the fire alarm, 2) evacuate and 3) call Public Safety at X1411.
Finally, go directly to the designated Emergency Access Point as indicated in the Emergency Handbook.

Certain trained faculty members can attempt to fight fires only if the following conditions exist.

1. alarm has been pulled

2. escape route present
3. fire is small and contained
4. no flammable chemicals in immediate area

b) Hearing a Fire Alarm

If while working in the laboratory a faculty member or student hears a fire alarm, they should

1. return any operating equipment to it’s off position

2. ensure everyone is out of lab and close door
3. exit building (using stairs if on upper levels)
4. report to designated EAP.

4. Injury
Upon an injury or discovery of an injured person, students and faculty should stay with the injured person until
emergency personnel can arrive on scene. Someone else should be sent to make the call to Public Safety.
Keep the injured person calm while avoiding contact with blood or other bodily fluids. Do not move the injured
person unless they are in immediate danger (i.e. fire or spill).

E) SAFETY EQUIPMENT
1. Equipment List
Laboratory safety equipment consists of equipment and supplies intended to reduce exposure to chemicals and to
respond to spills and accidents. In general, this equipment will be maintained by academic faculty and technicians
with advice from the Chemical Hygiene Officer. The following outlines the different types of safety equipment
available in the laboratories.

a) Fire Extinguishers
b) Fire Blankets
c) First Aid Kits
d) Safety Showers and or Drench Hoses
e) Eye Wash Stations
f) Hoods
g) PPE
h) Spill Control Supplies
i) Chemical Hygiene Plan

2. Equipment Inspection
Each of these pieces of equipment serves an individual function in worker protection. Outside of fire
extinguishers and PPE, all of the above equipment is inspected, tested, flushed and or restocked by the CHO. The
following outlines the inspection schedule.

a) Monthly (during the academic year)

• Plumbed Eye/Face Washes and Drench Hoses; Activate valve to confirm operation and sanitize.

• Plumbed Safety Showers; Activate valve to confirm operation and sanitize.

• Bottled Eye Washes: Check date and replace if necessary.

• Fire Blankets and Spill Clean-up Supplies. Inspect and restock as necessary

• First Aid Kits. Inspect and restock as necessary

 • Fire Extinguisher. Ensure charged and at location.

• Chemical Storage Refrigerators: Check temperature, dated items, and inappropriate items.

b) Pre-Semester

• Safety Showers, Plumbed Eye/Face Washes, and Drench Hoses; Inspect to ANSI Z358.1

• Fire Blankets and Spill Clean-Up Supplies; inspect condition and restock as necessary,

• Fume Hoods; Quantitative and Qualitative inspection as detailed in this plan.

c) Annual

• Chemical Hygiene Plan; review and revise as necessary.

• Coordination of fume hood and Bio-Safety Cabinet certification. These are completed by a third
party vendor and funds are secured through each Department.

3. Personal Protective Equipment (PPE)

Please note that a variety of PPE apparel and safety equipment are commercially available.

The faculty member must investigate the properties of each chemical he or she is working with in order to ensure
they have the appropriate PPE. Note that PPE will always serve as the last line of experimental hazard defense
and follow established administrative and engineering controls. The CHO is available to discuss or advise on
appropriate PPE upon request.

A variety of PPE is readily available for student and faculty use. Below are some of the more common items
likely to be needed in the University laboratories:

a) Safety Goggles: various types of safety goggles are available in the Department stock rooms. Others
can be ordered directly from distributors. Goggles are intended for use when splashing or flying
particles are a potential hazard.
b) Safety Glasses: glasses are for use during routine laboratory operations. While glasses offer some
protection against flying objects and splashes, goggles should be worn in conjunction with glasses
when a splash is a likely occurrence.
c) Face Shields: full face shields are required when there is a danger of violent chemical reaction, or
splash work involving highly corrosive or caustic agents.
d) Gloves: skin contact is a major source of exposure to toxic chemicals. Proper gloves must be worn
when such a hazard exists. Since gloves are made from a wide variety of materials, one must be
careful to select the appropriate type for the material they are working with. The CHO has a copy of
the glove selection guide. This guide is available to Faculty as to select appropriate gloves based on
chemical use.
e) Lab Coats: Faculty should assess the experiment as to determine the necessity of a lab coat. Highly
toxic, flammable and microbial agents are a few instances when lab coats may be warranted.

4. Fume Hoods.
Fume Hoods are an important engineering control in working with chemicals. The hoods serve to exhaust
contaminated air away from the worker. The following represents the hood types, inspections and problem
reporting information that is applicable to the Univesity.

a) Laminar Flow Biological Safety Cabinets: One in the Biology department, one in
the Biomedical Engineering department, one in the Neuroscience department and two in the
School of Pharmacy. These cabinets are to be certified upon installation and then annually (or as
moved) from there. The inspection will be by a certified cabinet inspector.

b) Chemical Exhaust Fume Hoods: This includes two hoods in Sleith and the thirty-eight in the
Center for Sciences and Pharmacy (CSP).
 The following outlines who completes the inspection and at what timeframe:

• Sleith Units
• Prior to each semester by the ESRM
• At the request of a faculty member
• Following any major repair or renovation.

• CSP Units
• Annually by a Third Party Vendor
• At the request of a faculty member
• Following any major repair or renovation.

All of the hoods in the CSP are low flow/high efficiency. These hoods have been certified to
ASHRAE 110 to confirm the following minimum performance is maintained.

• Average face velocity of 70 fpm at the full open sash position.

• Minimum of six readings equally spaced to determine the average with no reading more
than 20% different than the average.
• Visual observation that determines an effective capture of indicator smoke at the countertop,
upper level and from 6” in front of the hood opening.
• Tracer Gas testing to ensure leakage <.05 ppm.

5. Signs and Labels

a) Signs are in place within the laboratory to denote the location of:

1. Safety Showers
2. Eyewashes
3. Fire Extinguishers
4. Exits

b) Labels must be in place on every chemical container. This labeling must be done according to
the following:

1. Original Containers: All of the hazardous chemicals arriving at the University should be
labeled by their manufacturer or distributor with the identity of the chemical(s) and the health or
physical hazard associated with the product. These labels need to be maintained in a readable
condition. This means they should be kept clean, uncovered, and facing outward. Someone
should be able to read the label without touching or moving the container.

2. Non-original Containers: If the label on an original container becomes unreadable, if the

contents are transferred to another container, or if the chemical is used in a stock solution, a new
label should be made.

This plan establishes as a standard, a text label based on the original supplier’s label or, if
unavailable, on the Risk Phrase noted in the Packaging and Labeling section of the International
Chemical Safety Cards (U.S. National Version) from the International Programme on Chemical
safety. These labels contain, at a minimum the:

• identity of the chemical (chemical name, not an abbreviation or formula)

• hazard(s) associated with that chemical (such as poison, corrosive, etc.)
• and, if appropriate, route of entry (such as inhalation, skin absorption)

A chemical on the OSHA Particularly Hazardous Substance list will also be required to have an
additional label noting the type of hazard. An additional pictographic warning should also be
used where space allows.

A web based information program is available for managing this task. The searchable CHP
Chemical Information System has a results page with a highlighted button if a preloaded label is
available. If no label is available send a notice to [email protected]. This program will print
on any compatible printer but is intended to be used with the Brother 9200 Label Makers
 Labels from this system should be printed with black on yellow stock. These labeling stations
will also be stocked with pictographic warning labels and labels for OSHA Particularly
Hazardous Substances.

Reaction vessels: The containers used for a chemical reaction do not need to be labeled if they
are in the use and under control of the person who transferred the chemical into the container
and if that person remains responsible for the container until its waste has been collected and the
container cleaned. Titration setups or other stock preparations left unattended or for use by more
than lab section should be labeled.

6. Emergency Gas Panels

These panels provide natural gas service to individual laboratories. By activating the switch to “on”, then
inserting your key and turning clockwise, gas service is activated. At the end of the lab the switch
should be turned to “off.” In an emergency, push the red button to immediately turn off the gas. Pressing
this button will also summon the University Public Safety Department. If the emergency button is
depressed, the panel will need to be reset using the key discussed above.

F) CHEMICAL SAFETY
1. Procurement
Chemicals required by Faculty for use in laboratories are purchased by the Department laboratory
Technician/Laboratory Manager. In some cases there is Departmental overlap and chemicals are ordered by the
same Technician/Manager. This Technician/Manager understands the current inventory of Departmental
Chemicals. The Technician/Manager is also the main contact for purchase orders and account numbers applicable
to chemical ordering. Allowing a single person per Department to order chemicals ensures the University will
minimize overstock and order errors. This single point control also helps the University maintain compliance
with:
a) Hazard Communication Standard: Proper labeling, Material Safety Data Sheets (MSDS)
obtainment, receiving and inventory of incoming chemicals.
b) Chemical Storage: The Proper storage of flammable/combustible materials, incompatible
materials and or corrosive materials is necessary to ensure worker and student safety.
c) Acutely Toxic Chemicals: These chemicals have limited use on Campus. Contact the CHO
with questions or to find out what chemicals are considered Acutely Toxic.

2. Hazardous Chemicals
Not all chemicals are hazardous. In fact, most chemicals used at the University are non-hazardous in nature.
Hazardous chemicals are defined as those that exhibit either physical or health hazards to those utilizing them.
Chemicals capable of producing physical hazards include explosives, flammables, oxidizers, peroxides and other
unstable materials. Chemicals capable of producing health hazards include toxins, irritants, corrosives and
carcinogens. Note that the manufacturers of chemicals are required to inform users of the physical and health
hazards of their products. This is done through primarily through product labels and product MSDS Sheets.
MSDS sheets are available in the Campus Utilities Building Room 204 during normal work hours and on-line at
the University Environmental and Safety Compliance website anytime.

3. Hazardous Chemical Storage

Properly storing chemicals is more than just ensuring they are located within a secured room and protected from
extreme temperatures. Care to ensure that there is no comingling of incompatible materials and that containers are
properly labeled is vital to safe storage of chemicals. The following offers some simple guidance towards safe
storage of chemicals:

a) Store Chemicals in rooms isolated from work areas

b) Storage areas should not have direct sun exposure on bottles
c) Ensure all bottles are properly capped (with caps tightened) at the time of storage
d) Store chemicals on shelves that are firm and sturdy
e) Keep Inorganic materials separate from Organic Materials
f) Separate Acids from Bases and provide secondary containment when necessary
g) Store all flammable and combustible liquids in Flammable Cabinets
h) Perform an evaluation to determine if chemicals are still needed on a regular basis
4. Flammable and Combustible Liquids
When talking about laboratory safety, of significant importance is the management of flammable and combustible
liquids. Solvents, Alcohols, Dyes and fuels are an important part of many experiments and therefore can be
found in any laboratory stockroom. The safe storage, handling and usage of these materials will minimize the
potential for accidents. It is important to understand that there are several different classes of flammable and
combustible materials depending on applicable flashpoints and boiling points. A materials flashpoint (FP) is the
temperature at which vapors are given off in sufficient concentration to support combustion in air. A materials
boiling point (BP) is the temperature at which the vapor of the material is equal to atmospheric pressure.
These chemical properties can be located within a particular substances MSDS sheet. The classes of flammable
liquids are as follows:

a) Class IA FP <73(F) BP <100(F)

b) Class IB FP <73(F) BP >100(F)
c) Class IC 73(F) < FP < 100(F)
d) Class II 100(F) < FP < 140(F)
e) Class IIIA 140(F) < FP < 200(F)
f) Class IIIB FP > 200(F)

The storage of flammable and combustible liquids is highly regulated by the Springfield Fire Department. A very
specific quantity of each flammable liquid class is permitted within educational buildings. Furthermore, all
flammable liquids must be stored within a specifically constructed “control area” on a particular building floor and
within flammable liquid cabinets. The CHO routinely inspects storage areas to ensure that flammable liquid
storage is within regulations. If there are any questions concerning the storage of flammable liquids, please
contact the CHO.

The dispensing of flammable liquids is to be done under the fume hoods. Currently the University purchases
containers of flammable liquids in quantities <1 gallon in size. Dispensing into smaller containers to facilitate
laboratory classes is primarily done by the Lab Technician/Manager, in the hood, prior to the start of the lab.

5. Compressed Gas Cylinders.

Any cylinder under pressure is considered hazardous. Even room air, compressed into a cylinder, has the potential
to explode or propel the cylinder and cause considerable damage and injuries. Other gases will compound this
fundamental danger by releasing gases that might be flammable, toxic, or an asphyxiant. When a gas is released
from pressure the cooling effect may cause frostbite. And the weight of the cylinder, empty as well as full, can
make them difficult to maneuver creating additional potential for injury or damage. For these many reasons, the
following basic precautions should be observed:

• As with any hazardous chemical, every gas cylinder must have a label identifying its contents and the
associated hazard. This label should be visible at all times.
• Use a hand truck to move cylinders that cannot be easily carried.
• All cylinders must be chained or strapped.
• The valve protection cap will remain on the cylinder until it is in its final position and ready to use.
• Use a regulator that is designed for that gas and cylinder valve. Inspect the regulator and associated
hoses prior to use.

6. Particularly Hazardous Substances.

In addition to a general definition of “hazardous chemical”, the OSHA Lab Standard identifies a more select group
of chemicals that warrant more specific management practices. It is important to note that this list is subject to
revision due to regulatory changes by OSHA or by a change in chemical status by other organizations. The
following categories are:

a) Categories of Particularly Hazardous Substances

 “Select Carcinogens” is an attempt by OSHA to classify for special treatment (as cancer
causing agents only) those chemicals for which there is formal corroborative evidence
of this risk. It includes chemicals identified by OSHA and also chemicals identified by
two outside agencies both of which are continually testing and updating their findings.
 These agencies are the National Toxicology Program (part of the U.S. Centers for
Disease Control), which publishes an annual report, and the International Agency for
Research on Cancer, which publishes Monographs at the conclusion of a testing
program for a particular chemical.

 “Reproductive Toxins” are chemicals which affect the reproductive capabilities

including chromosomal damage (mutations) and effects on fetuses (teratogenesis).

 “Acute Toxins” are chemicals which may be fatal as a result of a single exposure or
exposure of a short duration. This determination is based on published LD50
toxicological data for each chemical.

 “Skin Hazards” are chemicals that are not only toxic but are also readily absorbed
through the skin. This characteristic represents a serious hazard in a laboratory
situation for the following reasons. Skin absorption may not have the same warning
properties as inhalation hazards. Exposure reduction relies on Personal Protective
Equipment (gloves, lab coats, etc.), rather than more permanent engineering controls.
And in an academic laboratory, where participation and observation of chemical
reactions is the fundamental purpose of the use of chemicals, the necessary proximity
increases the potential for skin contact.

b) Procedures for use of Particularly Hazardous Substances.

Identifying: A list of chemicals will be maintained on the Environmental Compliance and Safety Web
Page. Searching this CHP Chemical Information System will result in a number of information resources
including that chemical’s presence on the OSHA particularly Hazardous Substances List. Chemicals that
are on the list, and are in common usage at Western New England, will have an “Experiment Design
Addendum” accessible from the search results.

c) Experiment Design Addendum:

A page describing the hazardous properties of a Particularly Hazardous Chemical and the necessary
safety precautions will be appended or integrated into to every experiment containing these chemicals.
The CHO, with the guidance of the faculty member, will draft these addenda to include the following
provisions:

 The identity of the chemical.

• An explanation of the hazard associated with this chemical including information on
target organ and route of entry.
• Designated work area including use of engineering controls.
• Requirements for personal protective equipment.
• Waste handling procedures.
• Decontamination procedures.

d) Labeling:

All containers containing any portion of a Particularly Hazardous Substance must be labeled with an
additional label provided by the University. These labels are needed to note whether this chemical
represents an acute or chronic exposure hazard. These labels are available at the Label Maker stations.
These University supplied labels are required for:

• Original containers when received

• Non-original containers for the chemical or stock solutions containing the chemical
• Waste collection containers

This additional label does not have to be added to reaction vessels as long as these vessels are not left
unattended and are in the control of the individual that transferred the chemical.
 7. Peroxide Forming Chemicals

Chemicals capable of forming explosive labels of peroxides must be labeled with the date of receipt at the
University. The most common peroxide forming chemicals at the University are ether compounds. While only a
few bottles are present at the University, they still must be handled conservatively. These compounds are to be
stored in a chemical storage refrigerator when not in use. A time-table for testing and reagent test strips for
peroxides are also kept in these refrigerators.

8. Other Reactive Chemicals

Reactive chemicals are those capable of releasing heat, energy or exploding upon interaction with water or air. A
few air reactive and water reactive chemicals were part of the most recent University inventory. Particular
attention must be paid to the labels for these chemicals as to ensure storage and or use does not render the material
unstable.

9. Controlled Substances
Controlled substances are those compounds regulated by the Drug Enforcement Agency and or the Massachusetts
Department of Public Health. These organizations have established a schedule for which compounds are further
regulated. The more severe the side effects (i.e. dependency), the higher the compound is regulated on the
schedule. The schedule or regulated substances includes…

Schedule I. Heroin, Mescaline

Schedule II. Cocaine, Morphine
Schedule III. Pentobarbital, Testosterone
Schedule IV. Valium, Ambien
Schedule V. Codeine, Opium
Schedule VI. Exempt Chemical Preparations for educational purposes

In order to purchase or maintain Controlled Substances Faculty must be registered and have a license with both the
DEA and DPH. Local DEA and DPH officials will coordinate an inspection of controlled substance use locations
prior to authorization. The Faculty must ensure that while at the University the substance is secure (i.e. locked) in
a room when not in use. These substances may not be used without the licensed Faculty person present at the time
of use.

Controlled substance disposal must be coordinated through the Drug Enforcement Agency. Any excess material
that requires disposal must be approved by the DEA in advance of disposal. Contact the ESRM with questions.

G) CHEMICAL WASTE DISPOSAL

In order to ensure proper disposal of chemical waste, a couple of decisions must be made as to whether or not the
material is still hazardous. These decisions must include comparing properties of the particular chemical waste in
hand to both Federal and State definitions and regulations. These definitions and regulations are included below…

1. How to Identify a Hazardous Waste

Waste is material which has served its original purpose or is no longer needed and is being discarded.
Hazardous Waste is defined by State and Federal regulations and must be collected for special disposal.
There are two primary types of hazardous waste at the University; LISTED WASTE and
CHARACTERISTIC WASTE:

a) Listed Wastes at the University:

• Most solvents including: acetone, benzene, toluene, xylene, and others

• Solvent mixtures containing the above such as "paint thinner" or "mineral spirits" or
aqueous solutions thereof.
• Chlorinated solvents: methylene chloride, trichloroethylene, “laminate adhesive" and
aqueous solutions thereof.
• Alcohols and ketones and aqueous solutions thereof.
• Restricted pesticides: chlordane, cresol, and others.
 b) Characteristic Wastes at the University:

• Ignitable: Solutions with a Flash point less then 140°F. (Note: Flammables have flash
points less than 100°F and Combustibles have flash points between 100°F and 200°F.).
Ignitable also pertains to flammable solids (i.e. carbon), oxidizers (i.e. Nitrates) and some
reactive materials.
• Corrosives: pH less than or equal to 2 or more than or equal to 12.5
• Reactivity: Unstable and readily undergoes violent changes, or reacts violently with water,
capable of detonating with an initiating source.
• Toxic: Known to cause a health hazard including the toxic metals and pesticides mentioned
above. This includes solutions or media contaminated with metals: lead, mercury, cadmium,
chromium and others as well as chloroform, benzene and other liquids with toxic
characteristics.

Information used to determine whether or not a chemical is a hazardous waste can be found on bottle
labels and or material MSDS sheets. A hazard warning on the label will provide some initial information
as to hazardous properties (i.e. Warning, Danger, and Toxic) for the material. Please contact the ESRM
for waste characterization guidance.

2. What about Non-Hazardous Waste

If the chemical waste does not fall under any of the categories outlined above it is Non-Hazardous Waste.
Non-Hazardous Waste must be compared with local Sewer (if liquid) and local Landfill (if solid)
regulations in order to ensure it is acceptable for disposal. Please contact the ESRM for sewer or trash
disposal questions.

a) Materials that CANNOT be disposed down the DRAIN:

• Any Liquid or Solid Hazardous Waste (See Above)

• Solid Material
• Oils and or greases
• Unknown materials
• Solution with high organic load (i.e. glycol solution)
• Solution with 5.5>pH>9
• Solution with oil or grease sheen
• Solution with high solids
• Solution with trace amounts of lead, arsenic or other heavy metal
• Solution with Copper, Nickel, Zinc
• Solution with infectious material
• Solution of Chlorinated Solvents

b) Materials that CANNOT be disposed in the trash:

• Any liquid or solid Hazardous Waste (See Above)

• Solids laden with solvents and or oils (i.e. fail one drop test)
• Aerosol cans that are not truly empty
• Spill clean up materials
• Reactive Chemicals
• Blood or Biologically laden material

3. What the Rules are for Handling Hazardous and Non-Hazardous Waste.
a) All materials must be placed in a container which is…

• Appropriate for the waste

• In Good Condition
• Remains tightly closed when not in use
• Has labels visible and legible

b) All containers must be labeled with…

 • The words “Hazardous Waste”
• The Hazard of the material (i.e. Toxic, Ignitable, Reactive, Corrosive)
• The ingredients of the Waste
• The Date the waste was generated

c) All labeled containers must be properly stored in…

• Hazardous Waste Central Storage Areas

• Satellite storage - Only if the container is still in use (i.e. other sections will add to it)
• Contact the Environmental Manager for proper storage of hazardous waste.

The Environmental, Safety and Recycling Manager will arrange (through a third party) for the
proper disposal of materials stored in these areas.

4. Security Awareness.
The hazardous components of the University's hazardous waste could be used in a deliberate attempt of assault,
environmental pollution or other illegal act. Waste cabinets should remain locked except when adding material.
Keys for the cabinets should be kept in the control of the person to whom they were distributed by the
Environmental, Safety and Recycling Manager (ESRM). Threats to these security precautions should be reported
to the ESRM at extension 1634. If these threats create an immediate danger to individuals or University property,
or the illegal use of a hazardous material is witnessed, contact Public Safety at their Emergency Extension, 1411.

H) INFORMATION AND TRAINING

All new employees in the departments covered by this plan will receive a written summary of the University CHP as part of
their new employee package from Career and Human Resources. The Campus Orientation Checklist for these employees
will include the requirement to receive a one-on-one session with the University’s Environmental, Safety and Recycling
Manager. Additional training materials for all employees, access to the University’s online MSDS file, and other chemical
safety information can be found at the Environmental Compliance and Safety website accessible from the Western New
England University main web Home Page.

I) EXPOSURE MONOITORING AND MEDICAL SURVEILENCE

The Lab Standard requires that employee exposure monitoring be done if “the employee's exposure to any substance regulated
by a standard which requires monitoring if there is reason to believe that exposure levels for that substance routinely exceed the
action level (or in the absence of an action level, the PEL).”

At the time of this CHP revision there are no apparent situations requiring exposure monitoring. However, this due in part to the
availability and efficiency of engineering controls, and the observance of administrative controls. Both of these factors comprise
the bulk of this CHP.

The University’s Environmental Compliance and Safety Manager will perform exposure monitoring in accordance with the
OHSA Lab Standard:

• if he or she suspects potential exposure

• at the request of a member of the faculty or

• at the request of the University Health Services.

Medical examinations and consultations performed under this CHP will be done by the University Health Service unless the
service is closed during an emergency situation.
J) OTHER SAFETY PROGRAMS

Work in the University wet laboratories may involve other hazards besides chemicals. It is important that Faculty
understand additional training may be required in these situations. Some examples of other safety programs include but
may not be limited to:

• Biological Safety - For work with BSL1 or BSL2 level materials

• Bloodborne Pathogens- For work with blood or other potentially infectious materials

Questions concerning additional training applicable to specific work can be addressed with the ESRM.

Environmental Safety and Recycling – Revised 2/2013