Guidelines for Writing Your Chemical Hygiene Plan

Training provided to workers must cover the physical and health hazards of chemicals in the work area and measures workers can take to protect themselves.

• By Jerry Laws
• Jul 15, 2019

The OSHA Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450, referred to as the Laboratory standard), lists the mandatory requirements of a written Chemical Hygiene Plan (CHP) to protect lab workers from harm caused by hazardous chemicals. The plan is to contain policies, procedures, and responsibilities for protecting workers from the health hazards associated with the hazardous chemicals used in that particular workplace.

The standard applies only to employers that are engaged in the laboratory use of hazardous chemicals as defined in the standard. It defines "Laboratory use of hazardous chemicals" as meaning the handling or use of such chemicals in which all of these conditions are met:

1. Chemical manipulations are carried out on a "laboratory scale."

2. Multiple chemical procedures or chemicals are used.

3. The procedures involved are not part of a production process, nor in any way simulate a production process.

4. "Protective laboratory practices and equipment" are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

An OSHA fact sheet¹ lists eight required elements in a Chemical Hygiene Plan, as listed below.

Required Plan Elements
1. Standard operating procedures relevant to safety and health considerations for each activity involving the use of hazardous chemicals.

2. Criteria the employer will use to determine and implement control measures to reduce exposure to hazardous materials, with particular attention given to selecting control measures for extremely hazardous materials.

3. A requirement to ensure that fume hoods and other protective equipment are functioning properly and identify specific measures the employer will take to ensure proper and adequate performance of such equipment.

4. Information to be provided to lab personnel working with hazardous substances, including the contents of the Laboratory standard and its appendices; the location and availability of the employer’s CHP; permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard; the signs and symptoms associated with exposures to hazardous chemicals used in the laboratory; the location and availability of known reference materials on the hazards, safe handling, storage, and disposal of hazardous chemicals found in the laboratory—including, but not limited to, the Safety Data Sheets received from the chemical supplier.

5. Circumstances under which a particular laboratory operation, procedure, or activity requires prior approval from the employer or the employer’s designee before being implemented.

6. Designation of personnel responsible for implementing the CHP, including the assignment of a Chemical Hygiene Officer and, if appropriate, establishment of a Chemical Hygiene Committee.

7. Provisions for additional worker protection for work with particularly hazardous substances, which include reproductive toxins and substances that have a high degree of acute toxicity. Specific consideration must be given to the following provisions and shall be included where appropriate:

• Establishment of a designated area.
• Use of containment devices, such as fume hoods or glove boxes.
• Procedures for safe removal of contaminated waste.
• Decontamination procedures.

8. The employer must review and evaluate the effectiveness of the plan at least annually and must update it as necessary.

OSHA's fact sheet states that the training provided to workers must cover:

• Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.).
• The physical and health hazards of chemicals in the work area.
• Measures workers can take to protect themselves from the hazards, including specific procedures the employer has implemented to protect workers from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and PPE to be used.
• The applicable details of the employer's written Chemical Hygiene Plan.

Medical Exams/Surveillance
The employer must provide all personnel who work with hazardous chemicals an opportunity to receive medical attention, including any follow-up examinations which the examining physician determines are necessary, under these circumstances:

• Whenever a worker develops signs or symptoms associated with a hazardous chemical to which the worker may have been exposed in the laboratory, the worker must be provided an opportunity to receive an appropriate medical exam.
• Where exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance must be established for the affected worker(s) as prescribed by the particular standard.
• Whenever an event takes place in the work area, such as a spill, leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure, the affected worker(s) must be provided an opportunity for a medical consultation to determine the need for a medical exam. All medical exams and consultations must be performed by or under the direct supervision of a licensed physician and be provided without cost to the worker, without loss of pay, and at a reasonable time and place, according to the agency's fact sheet.

Reference
1. https://www.osha.gov/Publications/laboratory/OSHAfactsheet-laboratory-safety-chemical-hygiene-plan.html

This article originally appeared in the July/August 2019 issue of Occupational Health & Safety.