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(1) Introduction and Legal Requirement for a Chemical Hygiene Plan (CHP)

The Occupational Safety and Health Administration document that mandates the establishment of a Chemical Hygiene Plan is Standard 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories [1]. In addition to this document, OSHA has web-posted fact sheets elucidating various provisions.

OSHA, recognizing the unique characteristics of the laboratory workplace, has tailored a standard for occupational exposure to hazardous chemicals in laboratories . . . Where hazardous chemicals are used [in] a laboratory covered by this standard, the employer [2] must develop and carry out the provisions of a written Chemical Hygiene Plan. The CHP must include the necessary work practices, procedures, and policies to ensure that employees are protected from all potentially hazardous chemicals in use in their work area [3].

The American Chemical Society lists the major elements required by OSHA to be included in the CHP. This list is given in the box on the following page and is the framework for the CHP [4] developed and adopted by the Chemistry Department at Stony Brook. OSHA mandates that the effectiveness of the CHP be evaluated annually by the employer and that it be available for OSHA inspection.

In designing our own, we have consulted web-posted plans from the University of Illinois at Urbana-Champaign [5] and the University of Vermont [6], and the plan from Stanford University. We have modified sections of the draft of the Stony Brook University Chemical Hygiene Plan [7]. A useful guide has been the American Chemical Society publication, Living with the Laboratory Standard [8], from which particularly illuminating selections are quoted in Appendix I. A list of references that includes our sources is given in section 16.

For the most part limited to issues specifically required by the OSHA (29 CFR) Laboratory Standard, this CHP may not address safety issues required by other regulatory bodies such as the Environmental Protection Agency. However, the following requirements are specifically noted in the text: EPA waste handling; lab and building security.

1. Standard operating procedures.

2. Criteria to determine and implement specific control measures such as engineering controls and personal protective equipment.

3. A requirement that fume hoods be functioning properly.

4. Information and training requirements. Specifically, employees must be informed of:

• the content of the OSHA (29 CFR) Laboratory Standard,
• the location of the CHP,
• the PELs or other recommended exposure limits,
• signs and symptoms of exposure to hazardous chemicals, and
• the location of reference material.

5. Training must include:

• the methods and observations to detect the presence or release of hazardous chemicals,
• the physical and health hazards of chemicals in the work area, and
• the measures employees can take to protect themselves from these hazards.

6. Circumstances under which a particular laboratory operation shall require prior approval from the employer.

7. Provisions for medical consultation and medical exams.

8. Designation of a Chemical Hygiene Officer.

9. Provisions for additional protection for work with select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity, including establishment of a designated area, use of containment devices, procedures for safe removal of wastes, and decontamination procedures.