The University of Arizona

Risk Management Services

Laboratory Chemical Safety Manual

Table of Contents

July 2010, version 1.2
This document replaces all previous versions of the UA Chemical Hygiene Plan

General Laboratory Chemical Safety Practices

2. Environmental And Medical Surveillance

Hazards associated with chemical use are ever present and may change with time. In order to stay abreast of these hazards and to act in a proactive fashion to ensure that hazards are adequately controlled, operations must be periodically scrutinized and problems that are discovered must be promptly addressed.

2.1) Validation of Safety Equipment: All laboratory safety equipment must be inspected and tested on a regular basis to ensure their proper functioning.

2.1.1) Fume Hoods, Fume Hood Alarms, Emergency Eyewashes, Safety Showers, and Fire Extinguishers: Fume hoods must be inspected and tested by Facilities Management (FM) at least annually. This inspection and testing shall include calibration and maintenance of fume hood alarms, if present. Fume hood exhaust systems also receive quarterly preventive maintenance to minimize equipment failure and emergency shutdowns. Fume hood exhaust fans are turned off to perform this periodic maintenance activity. Turning off fume hood exhaust systems presents a potential chemical exposure hazard for both lab occupants and any maintenance personnel who might be on the roof. FM must notify lab personnel about fume hood exhaust system preventive maintenance shutdowns. Lab workers must not use fume hoods during fume hood shutdowns (see: Fume Hood Exhaust System Maintenance Procedure). Emergency eyewashes and safety showers must be inspected and tested by FM at least quarterly. Excluded in this quarterly inspection and testing by FM are the sink-mounted eyewashes. Laboratory supervisors are required to inspect and test these devices quarterly. Fire extinguishers must be inspected and tested by FM annually. Laboratory supervisors are required to conduct monthly inspections of fire extinguishers (monthly inspection procedures are available by contacting RMS at 621-1790). Inspection and testing shall be conducted in accordance with FM Testing Procedures (for information, call FM at 621-3000). At the time of the inspection and testing, these devices shall receive a sticker or tag indicating when last inspected and tested and by whom and, in the case of fume hoods, what type of use it is certified for (e.g. general chemical use, toxic gas use) and the maximum sash open position. Eyewash tags for sink-mounted eyewashes are available from RMS by calling 621-1790. Any device that does not perform up to the standards outlined in FM Testing Procedures shall receive a sticker or tag indicating that it is not functioning properly and must not be used until it has been repaired or modified. Activities requiring such devices, shall cease until these repairs or modifications occur. If the fume hood, fume hood alarm, emergency eyewash, safety shower, and fire extinguisher in your area have not been inspected in accordance with the above-mentioned schedule, call FM at 621-3000 and submit a work request. There is no charge for these services.

2.1.2) Other Safety Equipment: Supervisors or their appointed designees must ensure that safety equipment other than that mentioned above is inspected and maintained by the user at a frequency which is recommended by the manufacturer and/or a frequency which will ensure their proper and safe functioning.

2.2) Laboratory Chemical Safety Self-Evaluations: Periodically, laboratory chemical safety self-evaluations must be conducted by supervisors or their appointed designees to identify and correct acts and conditions inconsistent with this Manual. These self-evaluations are done using the Laboratory Chemical Safety Self-Evaluation Checklist – PDF format.

2.2.1) The frequency of self-evaluations should be proportional to the magnitude of risk imposed. Self-evaluations must be conducted at least annually. Self-evaluations are also required whenever new chemicals, processes, procedures or equipment presenting new classes of health, safety, or environmental concerns are introduced into the laboratory.

2.2.2) Means of correcting discovered hazards and/or protecting individuals from the hazards shall be determined and implemented promptly by the supervisor.

2.2.3) Unsafe conditions which cannot be corrected by the supervisor must be reported to the next higher level of management. Activities associated with unsafe conditions shall cease until the conditions are corrected.

2.3) Formal Laboratory Inspections: Formal laboratory inspections may be conducted by representatives of the interim Chemical Safety Committee (iCSC) or their designees with or without a representative of an outside regulatory agency (e.g. OSHA, EPA) on a scheduled, random or as-needed basis.

2.3.1) CSL-3 laboratories are most likely to be inspected, followed by CSL-2 laboratories and then CSL-1 laboratories.
2.3.2) Inspections maybe scheduled or unannounced. Scheduled inspections will be preceded by a notice of impending inspection.
2.3.3) At the time of the inspection, the representative(s) of the iCSC or their designees, alone or with representatives of outside regulatory agencies, will identify themselves and their intentions, to any laboratory personnel present. They will proceed to assess compliance with this Manual or other federal, state, and local safety, health, or environmental regulations.
2.3.4) Any findings shall be verbally relayed to the laboratory supervisor, if present.
2.3.5) A written inspection report, stating the results of the inspection, will be generated by the inspector.
2.3.6) A copy of the report will be given to the supervisor and a copy will be sent to their respective Department Head. The report will outline any violations or concerns and corrective actions required.

2.3.7) All life-threatening violations or concerns must be rectified by the supervisor immediately upon realization through appropriate channels. Failure to immediately rectify the concern may result in a shutdown or curtailing of the activity (see Section 2.6).
2.3.8) Non-serious violations or concerns must be rectified by the supervisor within 30 days.
2.3.9) Unsafe conditions which cannot be corrected by the supervisor must be reported to the next higher level of management. Activities associated with unsafe conditions must cease until the conditions are corrected.

2.4) Exposure Monitoring: RMS shall provide an exposure evaluation to any Lab Worker who, as a consequence of a laboratory operation, procedure, or activity, reasonably suspects or believes they have sustained an overexposure to a toxic substance. The exposure evaluation may consist of a subjective assessment based on documented odor and irritation levels or it may involve measuring or monitoring the individual's exposure. RMS is also available to conduct exposure monitoring as a preventative measure. For assistance, contact RMS at 621-1790.

2.4.1) RMS shall initially measure the employee's exposure to any OSHA-regulated substance which requires monitoring if there is reason to believe that exposure levels for that substance routinely exceed the action level (or in the absence of an action level, the Permissible Exposure Limit (PEL) listed in 29 CFR 1910.1000).
2.4.2) If the initial monitoring discloses exposures over the action limit or PEL, RMS shall immediately comply with the exposure monitoring provisions of the relevant OSHA standard.
2.4.3) RMS may terminate the monitoring in accordance with the relevant standard.
2.4.4) RMS shall notify employees of monitoring results in writing within 15 working days after RMS receives the monitoring results.

2.5) Medical Consultation and Medical Examination:

2.5.1) Employees shall have the opportunity to receive medical attention, including any follow-up examinations which the examining physician determines to be necessary, under the following situations: Whenever an employee develops signs or symptoms associated with a hazardous chemical to which he/she may have been exposed to in the laboratory, the person shall be provided the opportunity to receive an appropriate medical examination; Where exposure monitoring reveals an exposure level routinely above the action level (a regulatory exposure level that is requires some type of action) or in the absence of an action level, the PEL, for OSHA regulated substances for which there are exposure monitoring and medical surveillance requirements, medical surveillance shall be established for the affected person as prescribed by the particular OSHA standard, and 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 chemical exposure, the affected person shall be provided an opportunity for a medical consultation and possible medical examination.

2.5.2) All medical examinations and consultations shall be performed by or under the direct supervision of a licensed physician and shall be provided without cost to the employee, without loss of pay and at a reasonable time and place. Funding responsibility for medical examinations performed under this section is assigned to the employee's home department unless other arrangements have been made.

2.5.3) All routine medical consultations and examinations shall be approved by RMS. For assistance, call 621-1790.

2.6) Shutdown of Dangerous Activity: The Assistant Vice President of Research Compliance Policy or the Director of RMS are authorized to curtail or shutdown any University activity considered to constitute an imminent, serious danger to health, safety, or the environment.

2.6.1) In the event of such curtailment or shutdown, the supervisor, (e.g. Principal Investigator), the Department Head, applicable Dean, and the Vice President (VP) for Research, shall be immediately notified of the action and the factors leading to that decision.

2.6.2) In case of dispute, an order to curtail or shut down will remain in effect until the VP for Research (or their respective designee) determines in writing that the danger has passed or has been mitigated or that the order should be rescinded for other reasons.

2.6.3) Should the Assistant Vice President of Research Compliance Policy or Director of RMS disagree with the VP for Research's determination to restore a curtailed or shutdown the activity, the matter may be promptly appealed by either individual to the President. In the event of an appeal, the order to curtail or shutdown shall be in effect until the President determines otherwise.

Go to General Laboratory Chemical Safety Practices Section Three