CHEMICAL HYGIENE PLAN
KENYON COLLEGE
GAMBIER, OHIO
FOREWORD
Kenyon College has developed this Chemical Hygiene Plan (CHP) in compliance with the Occupational Safety and Health Administration (OSHA) Laboratory Standard Rules and Regulations. This Laboratory Standard is published as an amendment to 29CFR1910, Subpart Z and is identified as Section 1910.1450. The title of that amendment is "Occupational Exposure to Hazardous Chemicals in Laboratories" (see Appendix D). OSHA defines a hazardous chemical as a substance for which there is statistically significant evidence, based on at least one scientific study, showing acute or chronic harm may result from exposure to that chemical. At Kenyon College the following have been designated as laboratories for the purpose of applying the Laboratory Standard:
Department of Art
Department of Chemistry
Department of Biology
Department of Psychology.
The purpose of the Laboratory Standard is to protect laboratory employees from harm due to chemicals while they are working in a laboratory. In addition to academic and administrative employees who spend a significant amount of their time working or teaching in a laboratory, the Laboratory Standard also includes as "laboratory employees" those office, custodial and maintenance persons who, as part of their duties, regularly spend a significant amount of their working time within a laboratory environment. Students, as laboratory assistants paid by Kenyon College, are also covered by the Laboratory Standard.
Kenyon College, in meeting the requirements of the Laboratory Standard, will keep records of employee exposure to hazardous chemicals, provide employees with training and information regarding chemical and physical hazards (see Appendix A), and access to medical consultation and examination (see Appendix B). Training will include information about material safety data sheets (MSDSs), chemical labels, permissible exposure limits (PEL) or threshold limit values (TLV). Measurement of the concentration of any chemical will be made for which a PEL or TLV may have been exceeded. Where this Laboratory Standard applies, it supersedes the Hazard Communication Standard, 29CFR 2910.1200 for those laboratories designated above.
For the Kenyon College CHP, the Director of Environmental Health and Safety (EHS) is designated as the Chemical Hygiene Officer (CHO). This person acts as the representative of the President of the College who has the ultimate responsibility for chemical safety. The CHO also reports to the Vice President for Finance as that person designated by the President for overseeing any financial implications of the CHP and chemical safety; the CHO also reports to the Provost and the Dean for Academic Support in regard to academic matters of the CHP.
A printed copy of the CHP will be provided to any employee of the laboratories designated above, by the CHO, upon request. Copies will be available from the CHO to any other interested parties. The current version is also available electronically via the internet at http://www2.kenyon.edu/depts/environmental/chp2.htm or by accessing the Kenyon homepage, clicking "Administration" and then "Environmental Health and Safety."
As of March 26, 2001 the following persons are identified:
Robert A. Oden, Jr., President
Ronald A. Sharp, Acting Provost
Joseph G. Nelson, Vice President
for Finance
Richard L. Switzer, Dean for
Academic Support
Ellen A. McComb, Director of
EHS.
THE CHEMICAL HYGIENE PLAN FOR KENYON COLLEGE
A. STANDARD OPERATING PROCEDURES
A1. General Rules
A2. Person Hygiene
A3. Protective Clothing and Equipment
A4. Housekeeping
A5. Prior Approval
A6. Spills and Accidents
B. SPECIFIC SAFETY PROCEDURES
B1. Toxic Chemicals
B2. Flammable Chemicals
B3. Reactive Chemicals
B4. Corrosive Chemicals and Contact Hazard Chemicals
C. CONTROL MEASURES AND EQUIPMENT
C1. Ventilation
C2. Flammable Liquid Storage
C3. Eyewash Fountains and Safety Showers
C4. Respirators
C5. Vapor Detection
C6. Fire Extinguishers
C7. Fire Alarms/Smoke or Heat Detectors
D. PROCEDURES FOR CARCINOGENS, REPRODUCTIVE TOXINS, ETC.
E. RECORDS AND RECORD KEEPING
F. Program Update and Evaluation of Effectiveness
APPENDIX A--Employee Information and Training
APPENDIX B--Exposure Assessments, Medical Consultations and Examinations
APPENDIX C--The Kenyon Emergency Response Plan
APPENDIX D--The Laboratory Standard,
29CFR1910.1450
THE CHEMICAL HYGIENE PLAN
FOR KENYON COLLEGE
2. Contact lenses should not be worn when working in a laboratory or chemical
storage area.
3. Appropriate eye protection should be used at all time; see section A3.
4. When working with flammable chemicals, no sources of ignition should
be present
that could cause fire or explosion in the event of a vapor release or liquid
spill.
5. Tip resistant shields should be used whenever an explosion or implosion
could
occur during a laboratory procedure.
6. During chemical use, employees should be aware of the following:
e. Proper laboratory personal hygiene practices.
f. Methods for transporting chemicals within the facility.
2. Avoid inhaling chemicals, do not sniff to identify chemicals.
3. Do not use mouth suction to pipet anything, use a pipet bulb.
4. Wash with soap and water, not solvents, before leaving the laboratory.
5. Do not drink, eat, smoke, or apply cosmetics in the laboratory.
6. Do not bring food, beverage, tobacco, or cosmetics into areas where
chemicals are
stored or used.
2. Gloves made of material known to be resistant to permeation by a given
chemical
should be tested by air inflation (do not inflate by mouth) for the absence
of
pin-hole leaks. These should be worn during work with corrosive liquids.
3. Long or short sleeved and long legged clothing is recommended.
4. Gloves resistant to permeation by given chemicals should be worn when
working
with allergenic, sensitizing or toxic chemicals. Testing for leakages should
be
done as in 2.
5. Low heeled shoes with fully covering uppers should be worn, avoiding
those with
open toes and woven materials.
6. When exposure by inhalation is likely to exceed the threshold limits
described in
MSDSs (or another reference), work should take place under a hood. If fume
hood
space is not available, a respirator that reduces exposure to below the
threshold
limit should be used.
7. Waste containers will be labeled as to type and stored in designated areas.
8. Spills must be cleaned immediately with materials specified by the MSDS.
Waste
disposal of the chemical and cleaning materials must be according to chemical
type.
9. Working surfaces and floors need to be cleaned regularly.
10. Chemicals should not be stored in aisles or stairways, on desks or
lab benches,
on floors or in hallways, or left overnight on shelves over the workbenches.
2. All chemical containers must be labeled with at least the identity of
the
contents and the hazards they present to users.
3. All work areas, especially laboratory benches, must be clutter free.
4. All aisles, hallways and stairs must be free of chemicals.
5. Chemicals should be placed in their assigned storage areas at the end
of each
work day.
6. The contents of unlabeled containers are to be considered waste at the
end of the
work day and are to be disposed of as such at that time.
7. Wastes must be correctly labeled and stored in appropriate containers.
8. Spills should be cleaned immediately with disposal of the chemical and
cleaning
materials in the correct waste disposal containers.
9. Working surfaces and floors should be cleaned regularly.
10. No chemicals will be stored in workplace aisles, desks, laboratory
benches or
floors. No chemicals will be left overnight on shelves above workbenches.
1. A new laboratory procedure or test is to be performed.
2. Toxic limit concentrations could be exceeded or other harm is possible.
3. A change in procedure or test is need. "Change is procedure or test"
is defines as
follows:
a. A 10% or greater increase or decrease in the amount of one or more chemicals
used.
b. A substitution or deletion of any of the chemicals in a procedure.
c. A change in other conditions under which the procedure is to be conducted.
4. Failure of equipment or safeguards such as fume hoods or clamped apparatus occurs.
5. Unexpected results are apparent.
6. Members of the laboratory staff become ill, suspect that they or others
have been
exposed or suspect failure of safeguards.
All laboratory
procedures must contain a written description of safety practices
incorporating
the applicable precautions described in this section. Employees should
read and
understand these practices before commencing a procedure.
2. If a TLV, PEL or comparable value is not available, the animal or human
median
inhalation lethal concentration information, LC50 will be checked.
A value less
than 200 ppm or 2000 mg/m3 (when administered continuously for
one hour or less)
will require the use of a fume hood, glove box, vacuum line or similar
device that
is equipped with appropriate traps and/or scrubbers. If none is available,
the
chemical will not be used.
1. Chemicals with a flash point below 2000F (93.30C) will be considered fire hazards.
2. OSHA standards and the National Fire Protection Association (NFPA) guidelines
for
flammability apply to the use of flammable chemicals in the laboratory.
In all
work with fir hazard chemicals, the requirements of 29CFR, subparts H and
L; NFPA
Manual 30, Flammable and Combustible Liquids Code and NFPA Manual 45, Fire
Protection for Laboratories Using Chemicals will apply.
3. Fire hazard chemicals should be stored in flammable solvent storage
areas or in
cabinets designed for flammable materials.
4. Fire hazard chemicals should be used only in vented hoods and away from
sources of
ignition.
Note: It is recognized that fume hoods are not currently available for
all areas
in the Department of Art where fire hazard chemicals are used and that
certain organic liquids such as acetone and other solvents may occasionally
need to be used at a sink or on a work bench in other academic departments.
1. A reactive chemical is one that:
a. Is described as such in Bretherick or the MSDS.
b. Is ranked by the NFPA as 3 or 4 for reactivity.
c. Is identified by the DOT as:
-An oxidizer.
-An organic peroxide.
-An explosive, class A, B or C.
d. Fits the EPA definition of reactive in 40CFR261.23.
e. Fits the OSHA definition of unstable in 29CFR1910.1450.
f. Is known or found to be reactive with other substances.
2. Reactive chemicals must be handled with safety precautions, including
segregation
in storage and avoidance of mixtures with all other chemicals without prior
approval and appropriate ppe.
a. Fits the OSHA definition of corrosive in Appendix A of 29CFR1910.1200.
c. Is known or found to be corrosive to living tissue.
2. A contact hazard chemical is an allergen or sensitizer that:
a. Is so identified or described in the MSDS or on the label.
b. Is so identified or described in the medical or industrial hygiene literature.
c. Is known or found to be an allergen or sensitizer
3. Corrosive chemical handling precautions include wearing safety goggles
and/or
face shield, permeation tested gloves (checked for holes).
C. CONTROL MEASURES AND EQUIPMENT
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 should be familiar with the precautions to be
taken, including
the use of engineering and other safeguards. Laboratory supervisors
should be
alert to the malfunction 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.
2. Fume hoods should provide 70 to 90 linear feet per minute of air flow.
b. Apparatus used inside the hood should be placed on the floor of the
hood at
least six inches away from the front edge.
c. Fume hood sashes should be lowered at all times except when adjustment
of the
apparatus inside is required.
d. The hood fan should be operating whenever a chemical is inside the hood
even
when there is no work in progress.
e. Employees must be aware of power failure or hood failure procedures
and must be
able to call maintenance repair personnel if necessary.
f. Hood vent ducts and fans should be inspected frequently to insure that
they are
clean and clear of obstructions.
g. Chemicals, apparatus or other materials should never be stored inside a hood.
a. The spring loaded closure should never be disabled.
b. The flame arrester screen must be maintained in place and replaced if
punctured
or damaged.
Note: Fire hazard chemicals are often packaged in glass containers. Use
caution
in storing them in such containers.
2. Cabinets designed for the storage of flammable materials should be maintained
according to manufacturers' instructions, including electrical grounding.
Additional safety practices include the following:
a. Only compatible materials should be stored in the cabinets.
b. Paper, cardboard and other combustible materials should not be stored
in
cabinets.
2. Eyewash fountains and safety showers must be checked by measuring the
water flow
at selected intervals. Prompt repair is required for any equipment that
does not
meet the water flow requirements.
b. All employees who are likely to need to use respirators must be trained
in
their proper use, inspection and maintenance (see NIOSH Guide to Industrial
Respiratory Protection, US Department of Health and Human Services
Publication. No. 87-0116, NIOSH, Cincinnati, 1987, for details.).
D. PROCEDURES FOR CARCINOGENS, REPRODUCTIVE
TOXINS, SUBSTANCES THAT HAVE
A HIGH DEGREE OF ACUTE TOXICITY
AND CHEMICALS OF UNKNOWN TOXICITY
Procedures
for laboratory work with greater than 10 mg of any carcinogen, reproductive
toxin, substance
that has a high degree of acute toxicity or a chemical whose toxic
properties
are unknown will be bound by the following:
2. Reproductive toxin: Any substance described as such in the applicable
MSDS (other
definitions may apply, for example: Any substance identified as a reproductive
toxin by the Oak Ridge Toxicology Information Resource Center, 615-576-1746,
or
for teratogens: Any substance identified as such in Thomas H. Shepard,
Catalog
of
Teratogenic Agents, 6th ed., Johns Hopkins Press, 1989).
3. Substance with a high degree of acute toxicity: Any substance for which
the LD50
data described in the MSDS causes the substance to be classified as a "highly
toxic chemical" as defined in ANSI Z129.1.
6. Designated area: A hood, glove box, portion of a laboratory or an entire
laboratory room designated as the only area where work with quantities
of the
inimical chemicals in excess of the specific limit shall be conducted.
2. Use high efficiency particulate air (HEPA) filters or high efficiency
scrubber
systems to protect vacuum lines and pumps.
3. Store inimical chemicals or remove them from storage.
4. Decontaminate a designated are when work is completed.
D4. Jewelry
should not be worn during work within the designated area since it is
difficult to decontaminate.
D5. Long
sleeved or frequently laundered clothing and gloves known to resist permeation
by the chemicals being used should be worn when working in designated areas.
2. It is desirable to develop a system that retains documents related to
distribution
and maintenance of MSDSs, to safety training of employees and to employee
suggestions. These documents should possibly be retained for the lifetime
of the
institution. An example might be use of an MSDS sign off record for each
hazardous
chemical used or handled by employees, each employee certifying by dated
signature
that the MSDS was read and understood (not OSHA required at this time).
3. It is often desirable to keep records developed internally that document
employee
exposure complaints and suspected exposures, regardless of the outcome
of an
exposure assessment. Other incidents also might be documented for future
reference.
a. Safety suggestions from employees should be kept to use in making revisions
to
safety programs. Those not feasible may be valid at a later date.
b. Near miss reports should be written when employees are involved in or
witness
events that could have caused harm but did not. Such reports are useful
in
making changes in procedures intended to prevent future occurrences.
c. Repair and maintenance records including suggested corrective actions
and
condition of equipment can be applied to decisions concerning maintenance
procedures and equipment replacement.
d. Employee complaint records are useful during investigations.
4. Other EPA, federal and state agency required reports must be maintained.
E. RECORDS AND RECORDKEEPING
This
section reviews the value of documenting an employer's compliance with
the
Laboratory
Standard which is required by 29CFR1910.20. This information is general;
it
does
not include the details necessary for compliance.
1.
The Laboratory Standard requires that records of air concentration monitoring
results, exposure assessments, medical consultations and examinations be
maintained
for at least 30 years and that they be accessible to employees or their
representatives.
2.
It is desirable to develop a system that retains documents related to distribution
and maintenance of MSDSs, to the safety training of employees and to significant
employee suggestions for many years, perhaps for the lifetime of the institution.
3.
In addition to required records, it is desirable to keep records developed
internally that document employee exposure complaints and suspected exposures,
regardless of the outcome of an exposure assessment. Other incidents
also might be
documented for future reference. Examples include:
a. All major safety suggestions from employees, including those that
are not
appropriate at the present, but may be useful in the future.
b. Near-miss reports from employees who are participants or witnesses
to events
that could have caused harm, but did not. These are useful in developing
changes in procedures for accident prevention.
c. Repair and maintenance records for control systems, indicating
quality of
equipment maintenance and replacement needs.
d. Employee complaints, investigations and outcomes. These
can provide insight
into defect and malfunction problems for the future even if nothing is
done
when the complaint occurs.
4.
Records required by the EPA and other Federal and state agencies dealing
with
adverse effects of chemical exposure as in sections 8(c) and 8(e) of the
Toxic
Substances Control Act (40CFR716 and 717) will be maintained.
F. PROGRAM UPDATE AND EVALUATION OF EFFECTIVENESS
Kenyon's
Chemical Hygiene Program will be updated and evaluated on an as need basis
or
at
least annually. Changes will be made by the Director of Environmental
Health and
Safety
upon the recommendation of members of the four departments whose laboratories
fall
under the requirements of the OSHA Laboratory Standard.
Employees who have had instruction
and/or training for similar work that they will be doing
here may feel training at Kenyon
is not needed. If so, an evaluation by the supervisor for
the employee's work area should
be conducted to determine understanding of the issues above.
If so demonstrated, the employee
shall provide the Director of Environmental Health and
Safety with the following information
to be entered into the Kenyon training database:
Employer
Location
Date of training.
A.
The employer will provide all employees, who use or work in areas where
hazardous
chemicals are present, with information and training concerning the hazards
of those
chemicals.
B. Information
and training must be provided after work is assigned and before work with
chemicals begins.
C. Information must include a general description and location of the following:
C1. The Laboratory Standard.
C2. The Chemical Hygiene Plan.
C3. PELs, action levels and other recommended exposure limits for hazardous
chemicals
used at Kenyon.
C4. Signs and symptoms associated with exposures to hazardous chemicals.
C5. MSDSs and other reference materials.
D. Training shall include:
D1. Methods and observations that may be used to detect the presence or
release of a
hazardous chemical.
D2. Hazards associated with the chemicals used at Kenyon.
D3. Ways employees can use to protect themselves from work hazards: work
procedures
and practices, personal protective equipment, emergency procedures.
APPENDIX B
EXPOSURE ASSESSMENTS, MEDICAL CONSULTATIONS AND PHYSICAL EXAMINATIONS
A. SUSPECTED EXPOSURES TO TOXIC SUBSTANCES
Whenever suspected employee exposure
to hazardous chemicals occurs to the extent that
harm may have been done to the employee, a medical consultation is in order.
If the
consultation determines that a medical examination should be conducted,
it will be
done at no cost or loss of workday time to the employee.
A1. Criteria for Reasonable Suspicion of Exposure to Hazardous Chemicals
1. It is a Kenyon policy to promptly investigate all reported incidents
in which
there is a possibility
of employee overexposure.
2. Events that might constitute overexposure include:
a. An uncontrolled leak, spill or other rapid release.
b. Direct skin or eye contact.
c. Display of any combination of the following symptoms: headache, rash,
nausea,
coughing, tearing, irritation of eyes, irritation of nose or throat, dizziness,
loss of motor dexterity or judgment, etc. Also, any of the following:
- Symptoms disappear when the person is removed from the exposure area.
a. Document date, location and names of the victim(s) and the person who
reported
the incident.
b. Interview the individuals listed above, recording essential information
about
the circumstances of the event.
3. Compare each victim's symptoms with symptoms described in pertinent
scientific
literature, if available.
4. Determine if the present control measures and safety procedures are adequate.
B. MEDICAL CONSULTATION AND EXAMINATION
b. Monitoring data indicates there could have been exposure above the action
level
or PEL for a chemical that has an established standard.
c. There is a spill, leak or other uncontrolled release of a hazardous chemical.
2. The physician should receive the following information:
a. Identity of the chemical(s) evident in the exposure.
b. Exposure conditions.
c. Symptoms the victim is experiencing.
3. The physician should supply the employer with a written report including
the
following:
a. Recommendations for follow-up, if any.
b. Record of consultation results, examination results (if conducted) and
any
tests conducted.
c. Conclusions concerning any other medical condition noted, that could
place
the employee
at a higher exposure risk than normal.
d. A statement that the employee has been informed both of the results
of the
consultation or examination and of any medical condition that may require
further examination, testing or treatment.
4. Written statements listed above should not reveal conditions unrelated
to an
exposure.
B1. Documentation
If the notified person determines
that evacuation is in order, evacuees should assemble in predetermined
locations, and one person at each location should report the names of everyone
at that location to the notified
person after making certain that the list of those present
is accurate.
Obviously, an emergency procedure plan requires planning by supervisory personnel and training of employees before it is needed. In the event of an emergency:
Primary contact notified is the Office of Security and Safety--
Emergency Number 911
Either the primary or secondary contact will notify the following people as appropriate:
Ellen
McComb, Director of Environmental Health and Safety,
5575 or home 740-397-2999
Ed Neal,
Assistant Superintendent of Buildings and Grounds,
5828 or home 740-397-3947
Larry
Hatton, Coordinator for Knox County Local Emergency Planning Commission,
740-393-6772 or home 740-397-6627.
Portions of this Chemical Hygiene
Plan have been adapted with permission from Young, J.A.; Kingly, W.K.;
Wahl, Jr., G.H. "Developing a Chemical Hygiene Plan;" American Chemical
Society: Washington, DC, 1990.