Safety & Environmental Management

Chemical Hygiene Plan

Revised: April, 2000

The intent of this chemical hygiene plan for the University of Wisconsin-Green Bay is:

  1. To protect laboratory employees and students from health hazards associated with the use of hazardous chemicals in our laboratories; and
  2. To assure that our laboratory employees and students are not exposed to substances in excess of the permissible exposure limits (PEL's) as defined by the Occupational Safety and Health Administration (OSHA) and codified in 29 CFR 1910.1000, Table Z-1; and
  3. To assist our laboratories' regulatory compliance with the OSHA Laboratory Standard as codified in 29 CFR 1910.1450.
This plan will be available to all employees and students for review, and a copy will be located in the the following areas: This plan will be reviewed annually and updated as necessary by the chemical hygiene officers.

Table of Contents:
  1. Standard Operation Procedures
  2. Control Measures to Reduce Employee Exposure to Hazardous Chemicals
  3. Maintenance of Fume Hoods and other Protective Equipment
  4. Enforcement of Chemical Hygiene Plan
  5. Hazardous Chemical Labeling
  1. Hazardous Chemical Inventory
  2. Material Safety Data Sheets (MSDS)
  3. Employee and Student Information and Training
  4. Medical Consultation and Examination
  5. Signage
  6. Responsibilities Under the Chemical Hygiene Plan
Appendix A Appendix F
Appendix B Appendix G
Appendix D Appendix H
Appendix E  
Note: These open on new pages

Standard Operating Procedures
  1. Specific standard operating procedures for our laboratories are attached to this plan as Appendix A.
  2. Laboratory instructors have the responsibility to maintain safe standard operating procedures and maintain or revise the procedures as necessary or needed.
  3. Jill Fermanich, University Safety Manager, has the responsibility to conduct periodic laboratory inspections. At minimum, an annual inspection will be done in each lab while the laboratory is in use.
  4. The chairpersons of Natural and Applied Science and Human Biology, Charles Rhyner and Donna Ritch, shall have the responsibility to see that this overall management plan is implemented and followed.
  5. NAS and HB shall each designate a Chemical Hygiene Officer who has primary departmental responsibility for the implementation and maintenance of this plan. NAS has appointed John Lyon and HUB has appointed Donna Ritch as Chemical Hygiene Officers.
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II. Control Measures to Reduce Employee Exposure to Hazardous Chemicals

Ventilation
  1. Adequate ventilation is essential for maintaining safe levels of exposure. It shall be the responsibility of the laboratory supervisor to discontinue laboratory operations if ventilation is judged to be inadequate for any reason, such as equipment breakdown or accidental spillage.
  2. Fume hoods shall be used for all operations which have the potential to produce gases, vapors or fumes exceeding the PEL or TLV as given on the appropriate MSDS. Fume hoods shall not be used as chemical storage areas. Storing materials in fume hoods reduces their efficiency, and could lead to inadvertent mixing of incompatible chemicals. Where such use is necessary, it shall be designated as storage area, not for operations and will be posted as such.
  3. Fume hood air flow velocities will be checked annually by Campus Safety staff. Inspection results will be posted on each fume hood. Fume hoods with inadequate face velocities will be prominently marked as not suitable for use until repaired.
  4. Fume hood users will follow recommended guidelines listed in Appendix I.
  5. Air quality monitoring will be performed if laboratory supervisors report a condition which might lead to excessive exposure levels as given on the appropriate MSDS. Campus Safety staff will coordinate monitoring. The results of monitoring will be kept by the CHO. The CHO will communicate air quality testing results to laboratory workers within 15 days of receipt of the results.
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Storage and Handling

A current inventory of all hazardous chemicals shall be maintained. Laboratory Technicians are responsible for preparing, maintaining and annually updating the hazardous materials inventory for all academic (teaching) laboratories. Faculty/staff assigned personal research areas (see Appendix F for list) are responsible for preparing, maintaining and annually updating a hazardous materials inventory for his/her assigned area.

Chemical inventories shall be kept to a minimum in working laboratories. Chemicals shall be stored in a safe manner utilizing, for example, chemical storage cabinets for corrosives and flammables. Chemicals shall be segregated by chemical characteristics to avoid incompatibilities. Alphabetical storage may be used only if chemical characteristics are compatible.

All chemical containers shall be kept capped or lidded when chemicals are not being withdrawn or added. This includes hazardous waste accumulation containers.

Adequate security for chemical storage areas is essential to minimize theft possibilities. Labs shall be locked when competent individuals are not present. Competent individuals shall be those persons trained by a supervising faculty/staff member or principal investigator to perform their work safely, recognize hazards and take appropriate action.

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PPE

Routine laboratory personal protective equipment should include protective eyewear when working with hazardous chemicals. Gloves should be worn for work with strong corrosives or with acutely toxic chemicals. Special procedures may require special protective equipment. Faculty/staff supervising special procedures are responsible for ensuring that protective equipment is used and special operating procedures are followed. See Appendix D for Campus Eye Protection Policy and a list of courses requiring eye protection.

Respirators may only be worn when engineering controls cannot keep exposure to chemicals below permissible exposure levels (PELs) set by OSHA. Employees may not wear a respirator until they have completed required elements of the Campus Respiratory Protection Program. Please contact the Safety Office for additional information.

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Safety Equipment

Operations coordinates annual fire extinguisher inspections. Public Safety staff do monthly visual inspection of Campus fire extinguishers. All faculty/staff are required to maintain clear access and visibility of fire extinguishers.

Eye wash stations and emergency showers shall be available in areas where the eyes or body of a person may be exposed to injurious materials. Eye wash and emergency showers shall be in an accessible location that requires no more than 10 seconds to reach and shall be identified with highly visible signage. Eye wash stations shall be flushed weekly by designated personnel. See Appendix G for a list of personnel responsible for weekly flushing. Eye wash stations will be tagged with flushing documented. Emergency showers shall be checked by Facilities staff with maintenance documented on attached tag. Employees will be instructed on the location and proper use of eye wash and emergency showers.

See Appendix H for Campus spill response policy.

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Additional Provision
Provisions for additional employee protection must be in place for work with particularly hazardous substances including select carcinogens, reproductive toxins, and substances which have a high degree of acute toxicity. Provisions will include designating areas for their use, use of containment devices such as a fume hood or glove boxes, safe removal of contaminated waste and appropriate decontamination procedures. Campus policy on use of Carcinogens is found in Appendix B.

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Hazardous Waste Management

All waste generated in Campus laboratories must be managed in accordance with policies found in the University of Wisconsin Green Bay Hazardous Waste Disposal Guide

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III. Maintenance of fume hoods and other protective equipment

  1. Fume hoods will be inspected at a minimum of once a year by physical plant personnel. Copies of fume hood inspections will be sent to the Safety and Risk Manger. The Safety and Risk Manger will do annual hood face velocity measurements. Fume hoods will be labeled with fume hood inspection dates. Failure for face velocities to meet required velocities will be reported to Facilities Management for action.
  2. The supervisor of Operations is responsible for semi-annual fire extinguisher inspections. Any deficiencies of fire extinguishers in terms of number of extinguishers or locations of extinguishers will be brought to the attention of Randy Christopherson, Director of Public Safety and the Chemical Hygiene Officers. In addition to the semi-annual inspections, Public Safety personnel conduct visual checks of fire extinguishers.
  3. Eyewash and safety shower inspections will be documented as in II. I.
  4. Routine laboratory inspections will be conducted by Jill Fermanich, University Safety Manager, at a minimum of once a year. The schedule of all inspections, checklists, and reports will be kept in the University Safety Manager's office, CL 823 C . Copies of inspections will be sent to the Chemical Hygiene Officers for action.
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IV. Enforcement of Chemical Hygiene Plan

The Chemical Hygiene Officers in consultation with the chairpersons, Charles Rhyner and Donna Ritch, shall have the authority to suspend laboratory operations - in part, or in the whole - if deficiencies in laboratory procedures or equipment pose a significant threat to the safety of the laboratory personnel or students.

If suspension of laboratory operations is necessary, a written report will be filed with the campus University Safety Manager, Jill Fermanich, and the chairpersons within 24 hours. A copy of the report with a written description of remedial actions taken to allow resumption of operations will be available in the NAS and HB offices.

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V. Hazardous Chemical Labeling

  1. The required information on a hazardous chemical container label is:
    • Identity of the hazardous substance
    • Appropriate hazard warning
    • Name and address of manufacturer
    Vendors are responsible for ensuring that their products are delivered with the proper labeling. If an unlabeled container is discovered with the initial shipment from the vendor, it should be refused at time of delivery or sent back to the vendor it came from.

  2. Even though vendors have the primary responsibility in labeling containers of hazardous chemicals, UWGB is responsible for labeling containers of chemicals drawn from the storage containers received from the vendor. At a minimum, these labels will have the identity of the contents written out in full in English and a hazard warning. The labeling and maintenance of labeling for substances used in academic (teaching) laboratories) is the responsibility of Barb Troedel and Mark Damie, Laboratory Technicians.
  3. Portable containers that are for immediate use by one person during one class period or shift are not required to be labeled. To be defined as a portable container, the container cannot be used for storage nor can it be transferred to another person without passing on the chemical's name and hazards.
  4. Waste containers shall have the contents, date of generation, and generators name listed on its label in addition to the words "Hazardous Waste." Additional information which will aid in proper waste disposal should also be included on the label if known.
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VI. Hazardous Chemical Inventory
  1. Barb Troedel and Mark Damie, Laboratory Technicians have the responsibility of preparing, maintaining, and annually updating the hazardous materials inventory for all laboratories in the Laboratory Sciences Building except for assigned research laboratories. The faculty/staff person responsible for individual research laboratory areas will be responsible for inventory maintenance for these laboratories.
  2. The hazardous materials inventory will be kept in the LS stockroom, LS 302.
  3. The content of the inventory will include the following:
    1. The chemical or proper name of the substance as listed on the MSDS.
    2. Location of chemicals on site
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VII. Material Safety Data Sheets (MSDS)
  1. Each department will maintain a central MSDS file for each hazardous chemical for 30 years after the last date the chemical was received on site. Faculty, staff and students will have access to MSDS files during normal office hours. Copies will be available on written request to the chemical hygiene officers.
  2. Barb Troedel and Mark Damie, Laboratory Technicians, will have the responsibility of maintaining MSDS files for the Laboratory Sciences building with the exception of assigned research laboratories. Faculty members responsible for individual research labs are responsible for maintaining MSDS files for these labs. See Appendix F for a list of research laboratories and responsible faculty/staff.
  3. The MSDS file will be kept in the Chem Prep room, LS 310. A back-up MSDS file is located in the University Safety Manager's office, CL 823 C .
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VIII. Employee and Student Information and Training
  1. Each employee covered under this standard will be provided with information and training to inform them of the hazards of the chemicals present in their work area. The training will be provided by the University Safety Manager, Jill Fermanich, if requested.
  2. Laboratory teaching assistants will be provided training prior to their supervision over other students. This training will be provided at the beginning of the Fall semester by Jill Fermanich, the University Safety Manager, if requested.
  3. Research Assistants will receive training from their research supervisor.
  4. Students will be provided training during initial laboratory sessions of each course. Such training will be documented via student signature on a training acknowledgement form. Course instructors are responsible for student training.
  5. Documentation of employee training will be maintained in the University Safety Manager's office, CL 823 C .
  6. Training will include:
    1. The contents of 1910.1450, the Laboratory Standard, and its appendices. A copy of this regulation will be available in Room CL 823 C .
    2. The contents, availability, and location of the written Chemical Hygiene Plan.
    3. Information concerning the OSHA permissible exposure limits including discussion of the meaning of all terms, significance of exposure, and location of copies of the exposure limits. A copy of the limits is kept in Room CL 823 C .
    4. Signs and symptoms associated with exposure to hazardous chemicals in laboratories.
    5. Location of reference materials including all MSDSs for chemicals in the laboratories. The MSDS file is stored in LS 310. The MSDS format will be reviewed to assure all employees are familiar with their content and can use such sheets to obtain additional information as necessary.
    6. Methods to detect the presence or release of chemicals in their work areas. This information will include air monitoring information, odor thresholds, etc.
    7. Specific information concerning the physical and health hazards of the chemicals in laboratory work areas.
    8. Specific information regarding the inventory of chemicals in the laboratory. The inventory is stored in LS 302.
    9. Specific information regarding measures to protect employees from chemical hazards including specific work practices, standard operating procedures, emergency procedures, and personal protective equipment.
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IX. Medical Consultation and Examination
  1. The Laboratory Standard mandates that employers provide medical attention, examinations, and follow-up examinations at the physician's discretion. This medical attention, etc. is required under the following circumstances:
    1. Whenever an employee develops signs and/or symptoms associated with a hazardous chemical to which they may have been exposed; or
    2. Whenever exposure monitoring reveals an exposure level above the OSHA action level or exposure above the permissible exposure level for OSHA regulated substances; or
    3. Whenever an event takes place in the work area such as a spill, leak, explosion, or other occurrence which results in the likelihood of a hazardous exposure. Such an occurrence requires an opportunity for medical consultation for the purpose of determining the need for a medical examination.

  2. The Chemical Hygiene Officers shall provide the examining physician the following information:
    1. Identity of the hazardous chemical to which the employee may have been exposed,
    2. A description of the conditions of exposure including exposure date if available,
    3. A description of the signs and symptoms of exposure, if any, that the employee is experiencing, and
    4. A copy of the relevant MSDS.

  3. The employer shall request a written opinion from the physician including:
    1. Recommendations for future medical follow-up,
    2. Results of examination and associated tests,
    3. Any medical condition revealed which may place the employee at increased risk as the result of chemical exposure, and
    4. A statement that the employee has been informed by the physician of the results of the examination or consultation and told of any medical conditions that may require additional examination or treatment.
    The material returned by the physician shall not include specific findings and/or diagnoses which are unrelated to occupational exposure.

  4. The Chemical Hygiene Officer has responsibility to maintain a file concerning any events and resultant medical examinations or consultations.

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X. Signage
  1. Appropriate signage will be placed on laboratory doors/entryways, in laboratory areas, and in chemical storage areas. Signage will include:
    1. Emergency Response Procedures
    2. Phone numbers of emergency responders.
    3. Notification of any particular potential hazards such as ionizing radiation, etc.
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XI. Responsibilities Under the Chemical Hygiene Plan The chairpersons of NAS and HB, Charles Rhyner and Donna Ritch, shall have the responsibility to see that this overall management plan is implemented and followed.

The Chemical Hygiene Officers, John Lyon and Donna Ritch, have primary concentration responsibility for the implementation and maintenance of the Chemical Hygiene Plan. In addition the chemical hygiene officers will have the following responsibilities:

  1. Annual review and update of the Chemical Hygiene Plan.
  2. Maintenance of records of
    1. laboratory inspections
    2. air monitoring
    3. medical consultation
    4. accident/incident reports
  3. Provide examining physician necessary information when a medical consultation is required.
The University Safety Manager, Jill Fermanich, will have the following responsibilities:

  1. Conduct annual lab inspections and send results to the Chemical Hygiene Officers.
  2. Conduct air quality monitoring in laboratories when requested. Results of air quality monitoring will be sent to the Chemical Hygiene Officers.
  3. Provide regular faculty and teaching assistant training if requested.
  4. Assist in proper disposal of hazardous waste.
The laboratory instructor has the primary responsibility of maintaining safe standard operating procedures as listed in Appendix A of the Chemical Hygiene Plan. In addition the laboratory instructor has the following responsibilities:

  1. Provide student training as described in the Chemical Hygiene Plan. Documentation of student training will be maintained by the instructor.
  2. Report malfunction of safety equipment to the Chemical Hygiene Officers.
  3. Promptly file an accident/incident report with the Chemical Hygiene Officers if an accident or spill should occur.
  4. The laboratory instructor will not permit laboratory operation to continue if ventilation is judged to be inadequate for the procedure being conducted.
Laboratory Technicians, Barb Troedel and Mark Damie

  1. Technicians will be responsible for maintaining teaching laboratory and stock room chemical inventories. This inventory will be updated annually.
  2. Technicians will maintain inventories using safe storage methods.
  3. Technicians will ensure that all containers are correctly labeled.
  4. Technicians will maintain MSDS files on all chemicals in the inventory.
  5. Technicians are responsible for proper disposal of hazardous wastes generated in the laboratories.
Physical Plant personnel will conduct regular fume hood inspections and oversee the maintenance of eyewash stations and laboratory safety showers.

The Supervisor of Operations is responsible for semi-annual fire extinguisher inspections.

Faculty assigned one and two person research laboratories or other research areas are responsible for meeting compliance with the OSHA Laboratory Standard for the area assigned to them. A list of faculty/staff and laboratories for which they are responsible is found in Appendix F. At a minimum this requires:

  1. Adoption and implementation of a Chemical Hygiene Plan.
  2. All containers in laboratory are correctly labeled.
  3. Maintain a hazardous chemical inventory with an annual update. A copy of the inventory should be submitted to Jill Fermanich for inclusion in the campus inventory.
  4. Maintain a current MSDS file of all hazardous chemicals in the inventory and present in the laboratory. Copies should be submitted to Jill Fermanich for inclusion in the campus MSDS file.
  5. Establish and maintain standard operating procedures in the laboratory. Establish additional procedures for carcinogens, reproductive hazards and other acutely hazardous substances.
  6. Complete and document an annual laboratory inspection. Ensure that fume hood (if present) is operating properly, eye wash stations are inspected annually and flushed weekly, emergency showers inspected annually, and all safety equipment in good operating condition.
  7. Ensure that all students and employees using laboratory have received training as listed under VIII. F.
  8. Ensure that appropriate personal protective equipment is available for all students and employees using the laboratory.
  9. Ensure that all waste disposal follows current legal requirements.
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