(14) Procedures Requiring Prior Approval
14.1 - OSHA Requirement
The Chemical Hygiene Plan shall include . . . the circumstances under which a particular laboratory operation, procedure, or activity shall require prior approval from the employer or the employer's designees before implementation.
14.2 - Chemistry Department Implementation of the OSHA Requirement
a. Departmental training requirements ensure that all lab workers have received traditional, sensible guidelines for chemistry laboratory practice. However, there is diversity among lab workers, depending on their educational level and years of experience. With this in mind, the PI should establish and communicate basic ground rules for when individuals require prior approval and from whom (for example, an undergraduate from a supervising graduate student).
b. OSHA mandates special provisions for handling particularly hazardous substances (see Section 15). A lab worker using one of these substances for the first time is required to get prior approval from the PI. [44]
c. Certain hazardous procedures, for example those involving radioactive or biohazardous materials, recombinant DNA, or animals, may require prior University or external approval. Information is available from EHS.
d. The presence in wastes of multiple hazards (chemical, radioactive and/or bio-) often complicates disposal. Because there may be no convenient outlet for such wastes, the PI should contact EHS prior to conducting experiments that may generate them.
References:
[44] The remainder of this section is adapted from the UIUC CHP.