Chemical Hygiene Plan

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Approved Mar 1, 2023

Introduction

Purpose

Boston University (BU) is committed to the safe and compliant use of chemicals in the laboratory. The Chemical Hygiene Plan (CHP) sets forth the policies, procedures and guidelines in place to protect laboratory workers (and those supporting laboratories at BU), from the health hazards associated with hazardous chemical use in the laboratory. The CHP has been developed by Environmental Health and Safety (EHS), in collaboration with the Laboratory Safety Committee (LSC), and is reviewed annually by EHS and the LSC, or more frequently as needed.

The CHP fulfills the requirements set forth in U.S. Department of Labor Occupational Safety and Health Administration’s (OSHA) regulations “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450), referred to as the Laboratory Standard within this document.

According to the Laboratory Standard, the CHP must include:

• Standard Operating Procedures (SOPs) relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals;
• Criteria to determine and implement specific control measures to reduce employee exposure to hazardous chemicals, such as engineering controls and PPE;
• A requirement that an ongoing program be developed to ensure that fume hoods and other engineering controls are functioning properly and specific measures are taken to ensure proper and adequate performance of such equipment;
• Information and training requirements to ensure employees are apprised of the hazards of chemicals present in their work area;
• Circumstances under which a particular laboratory function will require “prior approval” before implementation;
• Provisions for medical consultation and medical exams for all employees who work with hazardous chemicals;
• Designation of personnel responsible for implementation of the CHP, including assignment of Chemical Hygiene Officer (CHO) and if appropriate, establishment of Chemical Hygiene Committee; and
• Provisions for additional employee protection for work with select carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity.

Scope and Applicability

This CHP applies to every laboratory or related facility at BU that uses or stores chemicals. This CHP also applies to every research laboratory or related research facility at or under the jurisdiction of Boston Medical Center (BMC); and does not cover non-research activities at BMC, such as clinical operations, which operate under a separate chemical hygiene plan administered by BMC. Questions about the CHP or the safe use of chemicals should be directed to the Laboratory Safety Coordinator, the Principal Investigator (PI), Research Core Director (RCD), Instructor/Lecturer, the LSC, or EHS.

In addition to the LSC, several other committees have authority to regulate certain aspects of work in laboratories. These committees may include the Radiation Safety Committee (RSC), the Institutional Biosafety Committee (IBC), and the Institutional Animal Care and Use Committee (IACUC). This document does not preempt any of the policies or procedures issued by the aforementioned committees. In cases where the jurisdictions of two committees overlap, the more stringent policy or procedure applies.

This CHP must be made available to all laboratory workers prior to the commencement of laboratory duties. In addition to the CHP, laboratory workers must be familiar with and adhere to all laboratory safety guidelines and procedures developed by their laboratory supervisor, EHS and other University departments, and any federal, state, or municipal regulatory agencies. This information must be provided by the PI, Research Core Director, Instructor/Lecturer at the time of an employee’s initial assignment to a work area where hazardous chemicals are present, and prior to assignments involving new exposure situations. This information should include the following:

• Permissible exposure limits (PELs), as specified in 29 CFR part 1910, subpart Z, for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard and;
• The signs and symptoms associated with exposure to the hazardous chemicals used in the laboratory; and
• The location and availability of reference material, including access to Safety Data Sheets (SDS) on hazards, safe handling, storage, and disposal.

Definitions

Hazardous chemical means any chemical that is classified as a health hazard or simple asphyxiant in accordance with the Hazard Communication Standard (§1910.1200).

Health hazard means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term “health hazard” includes chemicals that are carcinogens, toxic or highly toxic agents, reproductive toxicants, irritants, corrosives, sensitizers, hepatotoxicants, nephrotoxicants, neurotoxicants, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Highly Hazardous Chemical (HHC) means a chemical that has any health, physical or environmental hazards that require additional safety or environmental practices beyond those of a typical laboratory setting (i.e., requiring greater protection for personnel than standard PPE and/or engineering controls can provide), as required by existing regulations or upon review of the hazards by EHS, relevant oversight committees, or other institutional entities

Reproductive toxins are defined as chemicals that affect the reproductive capabilities including adverse effects on sexual function and fertility in adult males and females, as well as adverse effects on the development of the offspring. Chemicals classified as reproductive toxins in accordance with Appendix A — Health Hazard Criteria (Mandatory) of the Hazard Communication Standard (§1910.1200) shall be considered reproductive toxins for purposes of this section.

Select carcinogen means any substance which meets one of the following criteria:

(i) It is regulated by OSHA as a carcinogen; or

(ii) It is listed under the category, “known to be carcinogens,” in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or

(iii) It is listed under Group 1 (“carcinogenic to humans”) by the International Agency for Research on Cancer Monographs (IARC) (latest editions); or

(iv) It is listed in either Group 2A or 2B by IARC or under the category, “reasonably anticipated to be carcinogens” by NTP, and causes statistically significant tumor incidence in experimental animals in accordance with any of the following criteria:

(A) After inhalation exposure of 6-7 hours per day, 5 days per week, for a significant portion of a lifetime to dosages of less than 10 mg/m3;

(B) After repeated skin application of less than 300 (mg/kg of body weight) per week; or

(C) After oral dosages of less than 50 mg/kg of body weight per day.

General Principles

To promote the safe handling of chemicals, the below principles apply:

Minimization of Chemical Exposure and Risks: Work should be conducted under conditions that minimize risks from known and unknown hazardous substances, including:

• Identification of chemicals to be used, how they will be used, and their quantities; 
• Evaluation of the hazards associated with the chemicals to be used and consideration of laboratory conditions that could increase these hazards. The evaluation should include toxic, physical, reactive, flammable, explosive, radiation, and biological hazards as well as other potential hazards; 
• Consultation of resources, including the SDS and seeking guidance from EHS personnel and experienced personnel to ensure the risk assessment is informed; 
• Selection of appropriate controls (engineering, administrative, and personal protective equipment) to minimize risk and protect laboratory personnel from hazards. Controls must ensure that PELs are not exceeded. 
• Ensuring that procedures are in place to safely respond to accidents and emergencies

Avoidance of the Underestimation of Risk: Even for substances with no known significant hazards, exposure should be minimized. Unless otherwise known, it should be assumed that any mixture will be more toxic than its most toxic component. All substances of unknown toxicity should be considered toxic.

Provision of Adequate Ventilation: The best way to prevent exposure to airborne substances is to prevent their escape into the working environment by using chemical fume hoods and other appropriate ventilation devices.

Assumption of Personal Responsibility: Follow the CHP and seek guidance as needed. Individuals who work with chemicals are responsible for their own safety, the safety of colleagues, and of the general public.

Observation of Permissible Exposure Limits and Threshold Limit Values: OSHA’s PELs cannot be exceeded. The American Conference of Governmental Industrial Hygienists Threshold Limit Values should also not be exceeded. When a regulatory standard does not exist, recommended exposure limits should be followed.

1.0 Roles and Responsibilities

The chief element in this section is the designation of authority and responsibility for implementation of the CHP. The following parties are responsible for implementing the requirements of the CHP:

Laboratory Safety Committee (LSC)

The LSC serves as BU’s Chemical Hygiene Committee.

The scope of BU’s LSC extends to all laboratories affiliated with, served by, owned or controlled by Boston University and the research laboratories at BMC. The LSC is comprised of faculty members and representatives from administrative departments that have laboratories working with or storing hazardous chemicals. The committee also includes members of EHS, Office of the Provost, Research Occupational Health Program (ROHP), Campus Planning and Operations (CPO), and other University departments that support laboratories at the University.

The committee meets on a quarterly basis. The duties of the committee include, but are not limited to:

• Annual review of the CHP;
• In collaboration with the CHO and EHS, implementation of the CHP;
• Support general chemical safety efforts for laboratory workers covered under the CHP and students in teaching laboratories;
• In collaboration with EHS, define highly hazardous chemicals used in research and teaching laboratories at BU;
• Review HHC SOPs, as necessary;
• Review of written guidelines and training programs, as necessary;
• Discuss laboratory safety issues and incidents; and
• Recommend, develop, and/or review policies and practices regarding laboratory safety issues, in collaboration with EHS.

Environmental Health and Safety (EHS)

EHS responsibilities include, but are not limited to, the following:

• Design safety training programs;
• Development of SOPs;
• Conduct safety training programs that are not site-specific;
• Conduct site or topic specific trainings, as requested or required;
• Conduct laboratory safety inspections on a routine basis and by request;
• Conduct periodic and requested inspections of engineering controls;
• Make recommendations for corrective actions in cases of noncompliance;
• Oversee the hazard assessment and development of lab-specific SOPs, in consultation with the LSC as necessary;
• Investigate cases of suspected or reported exposure or exposure due to accident;
• Provide chemical spill response as needed;
• Maintain laboratory safety training records and ensure, in collaboration with the PI, that all laboratory workers complete the annual Laboratory Safety Training;
• Assist the PI and laboratory workers with compliance with all aspects of this Plan;
• Communicate to each PI, Research Core Director, Instructor/Lecturer any relevant safety information or concerns pertaining to their laboratory;
• Maintain incident reports; and
• Manage the hazardous waste program.

Chemical Hygiene Officer (CHO)

The CHO is a staff member of EHS, as well as a member of the LSC. Responsibilities of the CHO include, but are not limited to:

• Ensure that the CHP is readily accessible to all employees, either as a paper copy, as an electronic copy online, or other readily available means;
• Establishes exposure monitoring programs including initial and periodic monitoring;
• Assists the CSO, with monitoring, procurement, use, storage, and disposal of chemicals;
• The Chemical Hygiene Officer provides technical guidance in the development and implementation of the Chemical Hygiene Plan;
• Develop and implement appropriate laboratory safety policies, practices and procedures in collaboration or consultation with the PI, Research Core Director (RCD), Instructor/Lecturer with final recommendation or approval by the LSC;
• Assists laboratory supervisors in developing appropriate engineering controls for new and/or existing facilities;
• Seeks ways to improve the Chemical Hygiene Program.

Chemical Safety Officer (CSO)

The CSO is a staff member of EHS. Responsibilities of the CSO include, but are not limited to:

• Lead or participate with the development, implementation, maintenance, and management of chemical safety programs to promote a healthy and safe work and educational environment for the university and its research and teaching community;
• Work with the Chemical Hygiene Officer develop chemical safety standards, policies, and procedures that are compliant with applicable regulations and followed by laboratories;
• Manage and provide technical guidance, develop trainings, and conduct risk analysis of laboratory processes that involve Highly Hazardous Chemicals (HHC), hazardous gasses, and other hazardous chemicals, including the screening and approval of chemical purchases by labs; development, and updates of SOPs for HHC chemicals identified;
• Review and approve submitted HHC SOPs in consultation with faculty reviewers;
• Consult and provide technical assistance to technical safety committees and laboratories;
• Conduct risk assessments of chemical processes and provide guidance for working with hazardous chemicals including recommend appropriate PPE, procedures, and safety equipment;
• Implement and manage the hazardous gas program;
• Manage and maintain the University’s adherence with the Homeland Securities CFATS requirements for Chemicals of Interest (COI).

Principal Investigator (PI), Research Core Director (RCD), Instructor/Lecturer

The responsibility for ensuring that all laboratory work is safe and compliant rests with the PI/RCD/Instructor/Lecturer and EHS. In Research Core Facilities, the RCD is the PI equivalent and has equivalent responsibilities under this CHP. In teaching laboratories, the Instructor/Lecturer is the PI equivalent and has equivalent responsibilities under this CHP. When a PI uses a Core Facility, both the PI and RCD are responsible for facilitating a shared understanding of the chemicals being used and procedures utilized.

The PI is responsible for work being conducted by their laboratory workers in Core Facilities, and the RCD is responsible for the work being performed by the Facility workers. When an Instructor/Lecturer is using a shared laboratory space such as a Core Facility or teaching laboratory, they are responsible for work being conducted by their laboratory workers or instructional staff.

The PI designation refers to the faculty member responsible for work in a specific laboratory facility. This person, in collaboration with EHS, must develop laboratory-specific SOPs to be followed in his/her/their laboratory. When a laboratory space is used by more than one PI, all PIs utilizing that space are responsible for ensuring that work is safe and compliant. The PI can assign duties to a Laboratory Supervisor, but the PI is ultimately responsible for the safe and compliant conduct of work in his or her laboratory.

PI duties also include, but are not limited to, oversight and maintenance of the following:

• Identify and designate work areas where chemicals will be used;
• Ensure that an up-to-date inventory of chemicals is maintained and provided to EHS through BioRAFT;
• Assist EHS and the CHO in defining all hazardous operations, alerting employees to hazards, and establishing safe procedures for these operations by identifying suitable engineering controls and PPE;
• Ensure, in collaboration with EHS, that all new laboratory workers complete training requirements before working unsupervised in the laboratory/facility and that all workers complete this training annually thereafter;
• Ensure that all laboratory workers receive instruction in: safe work practices; are trained on specific SOPs for use of highly hazardous chemicals as appropriate; proper use of PPE; spill clean-up; and emergency procedures;
• Ensure that all laboratory workers have read and are familiar with the CHP and know how to access it;
• Designate a Laboratory Safety Coordinator for the laboratory/facility, as appropriate;
• Provide access to safety information and specific training to laboratory workers for the hazardous chemicals with which they work (which may include training when the worker’s exposure changes or when new workers start in the laboratory/facility);
• Develop and establish SOPs for safe handling and operations applicable to the hazardous chemicals as needed;
• Provide, in collaboration with EHS, all appropriate and required PPE to laboratory workers;
• Assist the CHO or EHS personnel in fulfillment of their duties with respect to his or her laboratory/facility;
• Correct deficiencies identified during inspections, as appropriate;
• Report all accidents and near misses (which are unplanned events that did not result in injury, illness, or damage but had the potential to do so) that occur in their laboratory/facility and take corrective measures to prevent recurrence;
• Ensure proper disposal of all laboratory waste, including hazardous waste, biological waste, and sharps waste from his or her laboratory/facility;
• Inform visitors, vendors and non-laboratory personnel of hazards before accessing the laboratory/facility;
• Ensure that the laboratory provides access to SDS for hazardous chemicals used in the laboratory/facility;
• Maintain relevant safety information for the laboratory/facility in BioRAFT and appropriate safety logbooks in a designated Safety Center within the laboratory; and
• Comply with the Boston University’s Policy on Minors in Laboratories.

Laboratory Safety Coordinators

The Laboratory Safety Coordinator is assigned by the PI/RCD/Instructor/Lecturer to assist with safety and compliance efforts in the laboratory, as appropriate. When designated by the PI/RCD/Instructor/Lecturer, the Laboratory Safety Coordinator is authorized to represent the PI/RCD/Instructor/Lecturer in matters related to the implementation of safe laboratory work practices however, ultimate responsibility resides with the PI/RCD/Instructor/Lecturer. The duties of the Laboratory Safety Coordinator include, but are not limited to:

• Participate in specialized Laboratory Safety Coordinator training and discussions sponsored by EHS;
• Assist PI/RCD/Instructor/Lecturer efforts to maintain and promote laboratory compliance;
• Serve as the primary laboratory contact with EHS for issues related to safety (i.e., biological, chemical, fire & general safety, controlled substances, etc.);
• Take positive actions to help reduce the potential for accidents and incidents associated with laboratory operations;
• Inform laboratory workers of the safety hazards associated with their work and instruct laboratory workers in safe work practices;
• Assist other laboratory workers with reporting all accidents, near misses, or safety concerns to the PI/RCD/Instructor/Lecturer and EHS;
• Work with EHS to determine safe work practices and procedures;
• Work with EHS to ensure that laboratory workers complete all required safety trainings in a timely manner;
• Ensure that all deficiencies identified by EHS or outside regulatory inspectors are addressed and corrected per a schedule for correction;
• Participate in the incident review process;
• Stop operations that are in clear violation of the safety requirements, approved SOPs, or that may potentially result in injuries or potential exposures; and
• Maintain relevant safety information for the laboratory in the BioRAFT and appropriate safety logbooks in a designated Safety Center within the laboratory.

Laboratory Workers

Individuals who work in laboratories, including visiting scholars, where hazardous chemicals are used or stored are responsible for performing their work in accordance with the CHP. Responsibilities of laboratory workers include, but are not limited to:

• Follow all University, Federal, State, and local health and safety standards, rules and regulations, as they apply to the laboratory;
• Maintain up-to-date training;
• Report all hazardous conditions to their PI/RCD/Instructor/Lecturer and EHS;
• Review the SDS prior to work with hazardous chemicals;
• Consult with the PI or appropriate designee before conducting any changes in protocol or using any new chemicals, particularly if highly hazardous or highly reactive;
• Inform the PI/RCD/Instructor/Lecturer or appropriate designee of any unapproved changes in protocol or the unapproved use of new chemicals in the laboratory;
• Wear and use prescribed PPE;
• Follow all appropriate SOPs necessary for the safe operation of laboratory work, and if no such SOP currently exists, contact and work with EHS and the LSC to develop the necessary SOP and obtain approval from the LSC;
• Report any suspected job-related injuries, exposures or illnesses to the immediate supervisor and ROHP and seek treatment immediately;
• Do not operate equipment or instruments that may pose a hazard without the proper instruction, training and authorization;
• Remain aware of chemical hazards in the laboratory; and
• Request information and training when unsure of how to handle a hazardous chemical or procedure.

Laboratory Visitors

Laboratory Visitors are individuals who do not normally work in a laboratory but may need to visit a laboratory to perform assigned work or accompany a laboratory worker as a guest (see Visitor Policy). This category includes Facilities maintenance and custodial staff, vendors, contractors, and any other person who enters a laboratory but does not meet the definition of laboratory worker. Responsibilities of laboratory visitors include, but are not limited to:

• Review the laboratory safety placard posted at the entrance to the laboratory and comply with all PPE and work practices listed;
• Do not disturb any laboratory equipment on benchtops or in chemical fume hoods or biological safety cabinets;
• Direct any questions to a person working in the laboratory if available;
• Report unsafe conditions to a person working in the laboratory, supervisor, or the emergency numbers listed on the laboratory safety placard.

2.0 Training

• The University’s CHP
• Emergency Procedures
• Medical Consultations and Examinations
• OSHA’s Laboratory Standard
• Hazard Recognition
• Safety Data Sheets (SDS)
• Safety Equipment
• Engineering Controls
• PPE
• Chemical Management, Inventory, Labeling and Storage
• Hazardous Waste Management, Storage and Disposal
• Highly Hazardous Chemical Program
• Nanotechnology

3.0 Signs and Symptoms of Chemical Exposure

• Skin that has become dried, whitened, reddened, swelled, blistered, and itchy or exhibits a rash;
• A chemical odor. Many chemicals can be smelled at concentrations below harmful levels. Harmful levels may also be present for some chemicals without a detectable odor. Consult the SDS;
• A chemical taste;
• Tearing or burning of the eyes;
• Burning sensations of the skin, nose or throat;
• Cough, headache or dizziness.

4.0 Medical Services and Surveillance

• NEIDLNational Emerging Infectious Diseases Laboratories The NE...
• Animal Science Center (ASC)
• Researchers at BU or BMC BSL 2, 3, or 4 research laboratories, and those listed on an IBC protocol
• Environmental Health & Safety staff

5.0 Exposure Monitoring

EHS is responsible for ensuring that a laboratory worker’s exposure to hazardous chemicals does not exceed the Permissible Exposure Limits (PELs) specified by OSHA (see below).

Worker exposure determinations will be made by EHS in accordance with paragraph (d) of 29 CFR 1910.1450 or applicable OSHA standard.

Initial monitoring will be done by EHS to measure worker exposure whenever 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 PEL). Initial monitoring should also be considered whenever a substance is first introduced for proposed use, or whenever laboratory practices change in ways that exposure levels of the substance could significantly increase.

The PELs for OSHA-regulated substances can be found in 29 CFR part 1910, subpart Z as indicated below:

TABLE Z-1 Limits for Air Contaminants. – 1910.1000

TABLE Z-2 – 1910.1000

TABLE Z-3 Mineral Dusts – 1910.1000

Periodic monitoring will be conducted by EHS if the initial monitoring performed discloses worker exposure over the action level (or, in the absence of an action level, the PEL). BU will immediately comply with the exposure monitoring provisions of the relevant standard. Please refer to Section 5: Medical Services and Surveillance for more information.

Within fifteen (15) working days after the receipt of any monitoring results, the worker will be notified by EHS of these results in writing.

Any BU employee with a reason to believe that exposure levels for a substance exceed the action level or, in the absence of an action level, the PEL, may request monitoring through the CHO or EHS office. Monitoring may be requested at any time. EHS is responsible for coordinating exposure monitoring requests. EHS is also responsible for determining when monitoring is no longer necessary and can be terminated.

6.0 Record keeping

• Records of any measurements taken to monitor worker exposure are maintained by EHS for at least 30 years per 29 CFR 1910.1450 in accordance with 29 CFR 1910.1020;
• Records of any medical consultation and examinations are maintained by ROHP for at least the duration of employment plus 30 years per 29 CFR 1910.1450 in accordance with 29 CFR 1910.1020;
• Training records are maintained by EHS;
• Fume hood evaluations are maintained by EHS for 3 years; and
• Records of laboratory inspections are maintained by EHS.

7.0 Laboratory Design and Engineering Controls

Engineering controls should be implemented within the laboratory to minimize exposure to hazardous chemicals. Engineering controls may include the following: general laboratory ventilation, chemical fume hoods, point-source ventilation, filtered enclosures, product substitution, secondary containment, and other physical systems used to minimize exposure.

It is the responsibility of the department and Campus Planning and Operations (CPO) to inform EHS when a laboratory is selected to be renovated or redesigned. EHS will meet with the PI/RCD/Instructor/Lecturer of the laboratory to understand the nature of the work being conducted, including which hazards may be present, and to recommend appropriate engineering controls for the new laboratory. PIs are encouraged to contact EHS at any time to request an evaluation or meeting to discuss engineering controls in their laboratory.

If ventilation engineering controls are not supporting safe operations in the laboratory, the laboratory worker must cease all work with volatile and aerosol producing substances immediately, secure all chemicals and contact CPO for repair. Please note: Any modifications to existing ventilation engineering controls must be installed by CPO or a licensed HVAC contractor following approval by EHS. On the CRC, CPO’s Emergency Control Desk can be contacted 24 hours per day at 617-353-2105. On BUMC, the Control Center is available 24 hours per day at 617-638-4144.

A common engineering control installed in laboratories is the chemical fume hood. Details of chemical fume hood use, maintenance, and annual testing can be found in Section 9: Standard Operating Procedures.

In addition to reviewing and approving engineering controls in new laboratory design projects, EHS is responsible for the review of laboratory design plans for compliance with applicable local, state, and federal environmental health and safety codes, regulations, and standards.

8.0 Standard Operating Procedures (SOPs)

• Read and become familiar with this CHP and any SOPs developed specifically for the laboratory prior to working in the laboratory.
• Notify supervisors and ROHP of chemical sensitivities or allergies.
• Always read the SDS and label before using a chemical.
• Make others aware of special hazards associated with your work.
• Use appropriate ventilation (e.g., fume hood or local exhaust ventilation) when working with hazardous chemicals.
• In a laboratory setting, long pants or full-length skirt and proper PPE are required, including closed-toe shoes (shoes should be water-resistant or water-repellant or shoe covers should be worn). See Section 9.8 Personal Protective Equipment.
• Become familiar with the location and use of emergency equipment and facilities, such as:
  • eyewash and safety showers;
  • fire extinguishers;
  • fire blankets, if applicable;
  • fire alarm pull stations;
  • emergency exits; and
  • chemical spill equipment.
• Never eat, drink, smoke, chew gum, apply cosmetics, or manipulate contact lenses in the laboratory. Contact lenses may be prohibited in certain chemical laboratories, as indicated in laboratory-specific SOPs.
• Food, beverages, cups, and other drinking and eating utensils should not be stored in areas where hazardous chemicals are used or stored.
• Pipetting should never be done by mouth.
• Never leave exposed sharps, micropipettes, or broken glass on the bench or in washing facilities.
• Keep chemical containers closed unless actively in use.
• Clearly label all containers of any stored substances with the name(s) of the chemical(s).  Abbreviations, chemical formulas, structures, etc. are insufficient for clear identification. If possible, include the concentration and any hazards of the substance. For small quantities of synthesized chemicals (i.e., in multi-well plates, etc.), external reference documents may be kept nearby.
• When disposing of or moving unwanted laboratory equipment, it must be decontaminated prior to disposal or removal from the laboratory. Please refer to BU’s Laboratory Decontamination and Decommissioning guidance. A green “decon” sticker can also be requested from EHS.
• Remove PPE (e.g., gloves, aprons, protective footwear, and headwear) before leaving the laboratory space. Do not wear PPE in non-laboratory support areas.
• Discard, decontaminate, clean, or sanitize PPE on a regular basis.
• Always wash hands immediately after removing gloves and before leaving the laboratory.

• Discuss and conduct a risk assessment with the PI/RCD/Instructor/Lecturer before conducting hazardous procedures.
• The worker should inform a co-worker, friend, family member or colleague that they will be in the laboratory alone and give them information on whom to contact in the event that the worker does not contact them when leaving the laboratory.
• On BUMC, the worker can notify Public Safety at 617-414-4444, and officers will include the laboratory on the building’s walk-through, if appropriate.
• On the CRC, the BU Police Department can be reached at 617-353-2121 if non-emergency assistance is needed or to request a walkthrough.

• Workers should review the SDS prior to working with a chemical. SDS should be readily available for quick response to any spills, medical emergencies, or other incidents involving a chemical.
• Hard copies of highly hazardous chemical SDS are required along with appropriate SOPs.  PIs are encouraged, however, to keep SDS hard copies of all chemicals in their laboratory inventory. Hard copies can be obtained in two ways:
  • Chemical manufacturers often ship an SDS with a chemical or mail it to the laboratory separately. When a hard copy of an SDS is received in the laboratory it should be saved for future reference. New copies should replace older versions.
  • SDS is also often available online. Laboratory workers can download and print copies of SDS from manufacturers’ websites and keep them in or near the laboratory.
• Digital copies of SDS are acceptable if there is immediate laboratory access either through a shared computer station and/or laboratory smart device.

• Purchasing chemicals through Sourcing and Procurement;
• Ordering the minimum amount of the chemical needed to perform the work;
• Reviewing current chemical stocks in laboratory before ordering;
• Chemicals need to be dated and added to the inventory upon receipt.

• A risk assessment should be conducted by the PI/RCD/Instructor/Lecturer or PI/RCD/Instructor/Lecturer designee prior to beginning work with any highly hazardous chemicals for the first time. EHS shall review any risk assessment completed for highly hazardous chemicals.
• Read SDS and label information before using a chemical for the first time.
• Consult the SDS and keep incompatible chemicals separate during transport, storage, use, and disposal.
• Follow storage requirements as prescribed in the SDS.
• The chemical storage guidelines should be used for work with specific chemical hazards; see Section 8.6: General Chemical Safety Guidelines.
• Chemicals should not be stored on the floor, in areas of egress, or in areas near heat or in direct sunlight.
• Open shelves used for chemical storage should be secured to the wall and contain ¾ inch lips. Secondary containment devices should be used as necessary.
• Do not store food or beverages in the laboratory refrigerator.
• Handle hazardous chemicals with appropriate engineering controls (e.g. chemical fume hood) and appropriate PPE.
• Workers should not use hazardous chemicals or equipment if they have not been trained to do so.
• Highly hazardous chemicals should be stored in a well-ventilated and secure areas designated for that purpose.
• Maintain existing labels on incoming containers of chemicals.
• Label secondary containers that may be used for storing hazardous chemicals with chemical identification and appropriate hazard warnings.
• Laboratory doors should remain closed at all times.
• Work surfaces and laboratory furniture should be impervious to chemical spills.

• Store corrosive materials below eye level.
• Segregate acids from bases and bases from acids indifferent secondary containers or cabinets.
• Store concentrated acids and bases in corrosive cabinets or secondary containers large enough to hold at least the contents of 110% of the largest container if it should break
• Use appropriate bottle carriers or a cart when transporting acid bottles.

• Store large bottles of acids in bins or trays on low shelves or in acid cabinets, or in a cabinet marked “Corrosives.”
• Segregate oxidizing acids (i.e., nitric acid) from organic acids (i.e., acetic or formic acids) and flammable and combustible materials.
• Segregate acids from active metals such as sodium, potassium, and magnesium, and other incompatible materials, including cyanides and hypochlorites.
• Segregate inorganic acids from organic acids.;
• Awareness of where spill-control pillows or acid neutralizers are available (in common areas) in the event of a spill. Do not use bases to neutralize acid spills.
• Highly hazardous hydrofluoric acid (HF) and perchloric acid (HClO4) need dedicated secondary containment.

• Store large bottles of liquid bases in bins or trays in a cabinet marked “Bases” or “Corrosives.”
• Segregate bases from acids and other incompatible materials (i.e., amines and ammonium hydroxide) from hypochlorites.
• Store solutions of inorganic hydroxides in polyethylene containers.
• Know where spill-control pillows or caustic neutralizers are available (in common areas) for caustic spills.  Do not use acids to neutralize base spills.

• Bulk storage of flammable chemicals should be stored in a spark-free environment and in approved flammable-liquid containers and storage cabinets. Grounding and bonding should be used to prevent static charge buildups when dispensing solvents.
• Only store flammable liquids in a specially equipped, explosion-proof or flammable-safe refrigerator or flammables cabinet.
• Laboratory-grade, flammable-rated refrigerators and freezers should be used to store sealed chemical containers of flammable liquids that require cool storage.
• Keep flammables away from sources of ignition.
• For flammable metals, have a Class-D fire extinguisher available.  See the “Fire Extinguishers” part under Section 7.8: Laboratory Safety Equipment for more information.
• MA fire code (527 CMR) regulates the total quantity of flammable materials that can be stored on each floor of each building. Consult EHS’s fire safety group for guidance.

• Oxidizers can intensify and increase the flammable range for chemicals so they can ignite more readily.
• Store oxidizers in a cool, dry area.
• Store oxidizers away from flammable and combustible materials, such as paper, wood, etc.
• Oxidizers, reducing agents, and fuels should be stored separately to prevent contact in the event of an accident.

• Peroxide forming chemicals shall be dated upon receipt and upon opening.
• Store these chemicals in airtight containers in a dark, cool, dry area. Store away from heat and light with tightfitting, nonmetal lids.
• Do not open, do not touch a bottle of liquid peroxide forming material if solid precipitates or crystals are seen in the bottle or along the bottle’s cap. Immediately contact EHS to arrange disposal.
• Test for peroxides before concentrating (i.e. distilling, rotovapping, recrystallizing) peroxidizable solvents using appropriate test strips.
• Dispose of peroxide forming chemicals on or before the expiration date.
• After expiration date or one year, peroxide generating reagents must either be disposed of or tested using indicator strips on a quarterly basis, including peroxide forming solvents in solvent purification systems.
• Indicator strips may be purchased from Millipore-Sigma, Fisher, or VWR.
• A positive test indicates that the reagent should be appropriately disposed of as hazardous waste; a negative test requires quarterly testing until peroxides are detected leading to its appropriate disposal.
• Quarterly peroxide testing results should be documented by recording the date and test result on a label affixed to the container.
• BU’s hazardous waste vendor will not ship peroxidizable materials with peroxides over 20ppm. If test strip indicates peroxides >20ppm, contact EHS to arrange for a high hazard stabilization.

• EHS must be informed prior to purchase, storage and use of hazardous (pyrophoric, toxic, corrosive and/or reactive) gases to ensure the appropriate storage conditions, ventilation, PPE and gas monitoring are in place.
• Fire code sets Maximum Allowable Quantities (MAQ) regulating the total quantity of hazardous gases that can be stored on each floor of each building. Consult EHS’s fire safety group for guidance.
• Monitor compressed gas inventories and dispose of or return gases for which there is no immediate need. Maintain compressed gas inventory in BioRAFT.
• Order the smallest quantity possible in a returnable cylinder.  Empty or unused gas cylinders should be returned to the supplier on a regular basis.  Avoid ordering lecture bottles as they are not returnable to the gas supplier.
• Store and use hazardous gases in a ventilated space such as a chemical fume hood or certified gas cabinet.
• Store compressed gases in a secure and upright position.  Secure cylinders individually with a chain or strap, 2/3 to 3/4 up the height of the cylinder from the floor.  A cylinder stand may be used to secure a small gas cylinder within a fume hood.
• Routinely inspect gas cylinder straps and chains for structural integrity.  Do not use damaged straps or chains.
• Indicate the status of the cylinder: “Full” or “In Use” or “Empty.”
• When not in use, replace the valve cap.
• Use commercially-prepared liquid leak detector (i.e., “Snoop”) to leak test pressure regulator and other gas system fittings when the regulator is replaced or removed or when performing maintenance or modifications to the gas system.
• Gas regulators must be pressure tested with an inert gas prior to use.
• Pressure regulators must be used in accordance with manufacturer’s specifications.  Always use the correct pressure regulator for the gas.
• Use only Compressed Gas Association (CGA) standard combinations of valves and fittings.  Do not use regulator adaptors.
• Do not build or modify gas regulators.
• Remove all manifolds and regulators, secure the valve cap, and chain or strap the cylinder to a cylinder cart before moving. Only transport gas cylinders that are capped and secured to a cylinder cart.

• Requires prior approval and strict record keeping and security measures for receipt, use, storage and disposal. Please refer to the Controlled Substances Program site for more information.

• Per ANSI z358.1-2014, laboratory workers must flush their eye wash stations weekly to ensure clean water is available in the event of an emergency.
• Laboratory workers shall maintain a written log to document the weekly eyewash flushing has been completed.
• Eye wash stations should be clearly marked and kept free from obstructions.
• In the event of eye contamination, the laboratory worker should hold their eye open and rinse for a minimum of 15 minutes; then, they should seek medical attention (see Appendix B: Emergency Procedures and Reporting).

• In the event of a fire on the body, implement the Rescue/Remove, Alert/Activate, Confine, Extinguish (RACE) fire plan, as appropriate. The laboratory worker should activate the safety shower and stand under the water flow until the contamination is removed; then, they should seek medical attention (see Appendix B: Emergency Procedures and Reporting).
• In the event of gross chemical contamination on the body, the laboratory worker should remove contaminated clothing, activate the safety shower, and stand under the water for a minimum of 15 minutes; then, they should seek medical attention (see Appendix B: Emergency Procedures and Reporting).

• On sashes that open vertically, keep the sash as low as possible. The sash should never exceed the maximum sash height indicated on the inspection sticker.
• On horizontal sliding sashes, the sliding sash shall be between the worker and any laboratory hazards.
• Keep only what is needed for the task in the hood.  Excess equipment in the hood can reduce the provided protection.
• Work as far back in the hood as possible, ideally at least 6″ from the opening.

• Recyclable waste: clean, non-contaminated recyclable waste should be recycled when possible using designated receptacles. Refer to the BU Sustainability guidelines.
• Office waste: papers, plastics, and other non-contaminated trash. Office waste can be placed in a general trash receptacle.
• Glass waste: non-contaminated broken or whole glass, non-contaminated glass or plastic pipettes, or pipette tips. Glass waste should be placed in a sturdy, cardboard box with a top that is lined with a plastic bag. The box should be clearly marked “Broken Glass — Trash”.
• Empty chemical containers: For non-P-listed chemicals, deface containers and dispose of as solid waste. Reference the Chemical Waste Management Guide for complete list of P-listed chemicals.

• Batteries: Batteries may be collected in the laboratory’s hazardous waste area.  Collect in a properly labeled plastic bag. Pickup can be arranged by selecting the “Waste Pickup” link on the EHS Chemical Waste website.
• Fluorescent lamps: Fluorescent lamps may be collected in the laboratory’s hazardous waste area.  Do not place fluorescent lamps in the broken glass box.  Collect in a properly labeled plastic bag or sturdy box.  Pickup can be arranged by selecting the “Waste Pickup” link on the EHS Chemical Waste website.

• Most chemical waste is regulated as hazardous waste and must be collected for disposal through EHS. For detailed information on chemical waste management visit the EHS Chemical Waste Management Guide website.
• Expired and extraneous chemicals must be disposed of as hazardous chemical waste.
• P-listed chemicals are acutely toxic, therefore EPA regulations (40 CFR 261.32) mandate that empty P-list chemical containers be disposed of as hazardous waste. Please consult the following link to determine if you have a P-list chemical.
• Collect chemical waste in the laboratory’s hazardous waste satellite accumulation area (SAA). Use the SAA signs posted at each location as a quick reference guide as a reminder to:
  • Keep containers tightly closed,
  • Make sure each container is appropriately labeled,
  • Don’t duplicate containers (one per waste stream),
  • Make sure there is secondary containment for each waste container,
  • Segregate incompatible wastes into different secondary containers,
  • Contact EHS to pick up full containers as soon as they become full.

• Red bag waste is collected in red bag-lined boxes by laboratory personnel, and includes solid, non-sharp wastes which are contaminated with:
  • Blood or blood products,
  • RG1 or RG2 infectious agents,
  • Recombinant or synthetic nucleic acid molecules or cells containing such molecules.
• Red bag waste containers in laboratories are sealed by the laboratory and labeled with the laboratory name. On the CRC, red bag waste is removed by request. On the Medical Campus, closed red bag boxes are removed by custodial staff.
• Plastic serological pipettes should be disposed of in red bags-lined boxes, or sharps containers
• Pathological/Animal Waste: Human tissues, animal carcasses, and animal bedding from studies where animals have been infected with biological agents or recombinant/synthetic nucleic acid molecules must be collected as red bag wastes, with the closed boxes also labeled with the yellow ‘incinerate only’ sticker prior to pick up.
• Liquid Biological Wastes: Must be completely inactivated, including destruction of recombinant/synthetic nucleic acid molecules, prior to disposal in a sink drain.
• Visit the Biological Waste section of the EHS website for more information.

• Sharps waste: needles, syringes, Pasteur pipettes, pipette tips, razor blades and other metal sharps, are disposed of in biological sharps containers regardless of whether they are contaminated with biohazardous materials. Sharps waste must be placed in approved sharps containers. On BUMC, sharps containers for the laboratory are available from CPO custodial staff. On BUMC, CPO staff removes full sharps containers from laboratories. On the CRC, sharps containers are provided and removed as requested through the Biological Waste Pickup Request Form.

• BU discourages the use of mercury in chemicals or equipment anywhere on campus unless absolutely required for a particular use. Replacement non-mercury thermometers, barometers, manometers, and other basic equipment are available free of charge from EHS. Contact EHS for more information.

• Question visitors. Do not hesitate to contact the authorities to report a suspicious person. On the CRC, contact BUPD at 617-353-2121. On BUMC, contact Public Safety at 617-414-4444.
• Laboratory workers should carry or wear their BU or BMC identification.
• Always keep doors between the laboratory and hallways or other common places closed.
• Always lock the doors between the laboratory and hallways or other common places when leaving the laboratory unattended.

• No person under the age of 18 should be allowed to work in a laboratory without the expressed, written permission of EHS. Contact EHS for more information.
• All visitors must be escorted and supervised by laboratory personnel at all times while the visitor is in the laboratory.
• Visitors to the laboratory are expected to follow the same requirements as the laboratory workers in regards to such items as PPE, proper dress, food and drink, etc.
• A student or other person regularly visiting the laboratory, even if just as a volunteer, should follow the requirements for a laboratory worker laid out in this plan, including the training requirements.