(4) Standard Operating Procedures (SOPs)
4.1 - OSHA Requirement
The Chemical Hygiene Plan shall include . . . standard operating procedures relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals.
4.2 - Chemistry Department Implementation of the OSHA Requirement
The Chemistry Department has traditionally relied for guidance on the American
Chemical Society handbook, Safety in Academic Chemistry Laboratories, and will
continue to do so. Department-specific information is given in Appendix
II.
The standard operating procedure for a particular situation may simply be to follow generally accepted practice. Guidelines familiar to chemists are outlined here in Section 4. However, there are times when an SOP must be substantially modified for a specific lab situation, or when one is not available; for these, the PI must ensure that an SOP be written and a record maintained.
4.3 - Controlling Chemical Exposure
Each laboratory worker should minimize personal and coworker exposure to the
chemicals in the laboratory. General precautions for handling and using chemicals
follow:
a. Consult Material Safety Data Sheets (MSDSs) for chemical substances (see Section 9).
b. Consider substitution of a less toxic chemical for a more toxic one.
c. Assume that a chemical mixture is at least as toxic as its most toxic component.
d. Label chemicals and equipment with appropriate hazard notations.
e. Be familiar with the symptoms of exposure for the chemicals with which you are working and the precautions necessary to minimize exposure (see section 5 on personal protective equipment).
f. Avoid skin contact with chemicals. After skin contact with a toxic or hazardous chemical, wash thoroughly and seek assistance if necessary.
g. Even if you wear gloves, wash your hands thoroughly after working with hazardous chemicals. Wash thoroughly before you leave the laboratory.
h. Be sensible in your grooming and work attire. In lab situations where you will be doing wet chemistry, observe the following practices: Tie back long hair. Do not wear artificial fingernails, which are a fire hazard. Wear fitted clothing, preferably long and of natural fabric. Wear flat closed shoes. Do not wear plastic jewelry.
i. Add reagents together slowly. Add concentrated solutions to dilute ones with stirring.
j. Keep your work area clean and uncluttered, and be sure it is reasonably clean and clear at the end of each work day or operation.
k. Use judgment about when to work in the hood. For example, work in the hood with lachrymators, foul-smelling compounds, suspected carcinogens, or teratogens (reproductive toxins).
l. Do not use mouth suction for pipeting or starting a siphon.
m. Do not eat or drink, handle, or store food or beverages in the laboratory area or in laboratory refrigerators. Do not use laboratory glassware or utensils for food or beverages. Do not apply cosmetics in a lab area.
n. Use a bottle carrier for secondary containment when you transport reactive chemicals (e.g. strong acids or bases, flammables) from the stockroom or into common areas such as hallways or elevators.
o. Do not smoke in the Chemistry Building.
p. Consult the PI for additional specific precautions to be implemented, based on the toxicological characteristics of individual chemicals.
4.4 -Laboratory Equipment
a. Inspect all laboratory equipment on a periodic basis and replace or repair as necessary. Don't neglect to check electrical cords.
b. Use laboratory equipment only for its intended purpose or an appropriate modification.
c. Handle and store glassware in such a manner as to minimize breakage.
d. Shield evacuated glass apparatus to contain chemicals and glass fragments should implosion occur.
4.5 - Waste Storage
This and the next two sections contains specific EPA requirements.
a. Consult the EHS webpage for University policy [14] and Appendix II for Chemistry Department policy.
b. Follow prudent practice to segregate waste according to hazard class, disposal requirements, etc. Have separate containers for halogenated and non-halogenated materials and for corrosives.
c. Label each waste container. The specific wording "Hazardous Waste" must be used unless the contents are entirely innocuous.
d. Remove or completely efface a previous label - that is, do not double-label.
e. On each label, give the hazard class (for example, corrosive). List the contents, as described in the next section.
f. EHS requires that contents greater than 1% be specifically listed on the label or the manifest.
i. It may not be practical to track serial additions to containers by multiple workers. In this situation, each addition to a waste container should be noted so that there is a complete record of the contents. The amount of each component need not be specified.
ii. In general, if a component is present in less than 1%, it need not be listed.
iii. However, certain metals must be listed in any amount: arsenic, barium, cadmium, chromium, lead, mercury, silver, and selenium.
iv. Note: The list of contents may be on the manifest, not necessarily on the label. A sheet might be posted in lab on which workers could make their entries. The information on this sheet could ultimately be consolidated for the manifest.
g. Keep waste containers tightly closed with screwcaps other than at times when material is being transferred to them.
h. Provide secondary containment which holds the volume of the largest container or at least 10% of the volume of all containers in the accumulation area.
i. Do not transfer waste from the room in which it was generated, other than for final disposal. For an exception to this rule, you may establish a storage area [15].
j. Use the red container approved and provided by EHS for "sharps": syringe needles, disposable syringes, and razor blades. Note that a disposable syringe (not simply its needle) must be discarded intact in the "sharps" container.
4.6 - Waste Treatment
a. OLD - Do not attempt to process waste so as to make it less hazardous, but rather dispose of it according to EPA regulations. The only exception is simple neutralization of acids or bases.
b. NEW - The policy is being developed in accord with new EPA guidelines and will be distributed for separate approval.
4.7 - Waste Disposal
a. Do not pour chemical waste down the drain.
b. Dispose of waste within one week of a container's being filled. EHS has a convenient pickup every Wednesday at the Chemistry Building. Waste cannot be transferred to a larger container for the purpose of extending the storage period.
c. At pickup, waste containers must bear the EHS label, with hazard boxes checked. Manifests must accompany all waste for disposal. Labels and manifests may be obtained from Joan Conforte.
d. There are certain situations in which a container should not be emptied for bulking because of a specific hazardous component. In addition to checking the applicable boxes on the EHS label, clearly and prominently write the name of the specific compound and its hazard, and the words "not for bulking."
e. Only containers that are acceptable for disposal will be taken. Flasks, beakers, etc, are not acceptable containers. Acceptable containers must be tightly closed and in good condition. EHS staff have the final decision on what an acceptable container is.
4-8 - Planning for Emergencies
a. Be familiar with the Chemistry Department procedure and policies for emergencies (see Appendix II).
b. Post emergency numbers by lab phones. Update the phone list annually.
c. Check emergency equipment on a regular basis to ensure its readiness. This includes fire extinguishers, hood alarms, eyewashes, and specific items such as spill containment equipment.
d. Be sure the lab first aid supplies are adequate. If your lab has hydrogen fluoride, stock your kit with the antidote calcium gluconate and learn how to use it.
e. Before any lab work, develop a specific emergency plan for the particular procedure you will be following. Plan for fire, chemical spill, and personnel exposure. If you will be working with a chemical that is particularly hazardous or odiferous, inform the office of the Director of Labs in advance.
f. Immediately evacuate the building every instance the fire alarm sounds. If possible, stabilize reactions before leaving. Close hood doors. (Be aware that because the hoods shut down when the fire alarm is activated, they may not be functioning at the time when you return to lab).
g. Pay attention to hood alarms and take appropriate action.
h. Do not do lab work out of easy communication range of other people.
References:
[12] OSHA (29 CFR) Laboratory Standard. Hereafter, all sections titled "OSHA Requirement" refer to this Standard.
[13] The majority of section 4 is adapted from the University of Vermont CHP. References cited therein are Safety in Academic Chemistry Laboratories (American Chemical Society, latest edition); Prudent Practices for Handling and Disposing of Hazardous Chemicals (National Research Council, 1995).
[14] Environmental Health and Safety policies on main campus hazardous waste management.
[15] The requirements for a storage area may be obtained
from EHS.