Chemical Hygiene Plan
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Approved Oct 15, 2025
Introduction – 1
1.1 Purpose
Boston University (BU) is committed to a Culture of Safety and Responsibility, which includes the safe and compliant use of chemicals in the laboratory. The Chemical Hygiene Plan (CHP) sets forth the policies, procedures and guidelines 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 the following:
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.
- Provisions for additional employee protection for work with select carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity.
1.2 Scope and Applicability
This CHP applies to every laboratory or related research 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) but 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 Principal Investigator (PI), Research Core Director (RCD), Instructor/Lecturer, Laboratory Safety Coordinator, LSC, and/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 or any state, local, or federal regulations. 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.
- The signs and symptoms associated with exposure to the hazardous chemicals used in the laboratory.
- The location and availability of reference material, including access to Safety Data Sheets (SDS) on hazards, safe handling, storage, and disposal.
1.3 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. Please refer to BU Laboratory Reproductive Health Hazards Guidance Document for additional details.
Select carcinogen means any substance which meets the criteria listed below; please refer to the BU Highly Hazardous Chemical Program for additional details:
(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.
1.4 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 workers 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, published recommended exposure limits, as promulgated by NIOSH, should be followed.
Roles and Responsibilities – 2
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:
2.1 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 voting members of the LSC are comprised of faculty members and representatives from administrative departments that have laboratories working with or storing hazardous chemicals and members of EHS. The non-voting members of the committee also includes members of EHS, 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.
- Recommend, develop, and/or review policies and practices regarding laboratory safety issues, in collaboration with EHSEnvironmental Health & Safety
2.2 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.
- Periodically review Maximum Allowable Quantities (MAQ) regulating the total quantity of hazardous chemicals that can be stored in each control area.
- Manage the hazardous waste program.
2.3 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 Chemical Safety Officer 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.
2.4 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.
2.5 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 SciSure (formerly SciShield).
- 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 the following:
- safe work practices.
- are trained on specific SOPs for use of highly hazardous chemicals as appropriate.
- proper use of PPE.
- spill clean-up.
- 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 SciSure and appropriate safety logbooks in a designated Safety Center within the laboratory.
- Comply with the Boston University’s Policy on Minors in Laboratories.
2.6 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 and 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.
- Maintain relevant safety information for the laboratory in the SciSure and appropriate safety logbooks in a designated Safety Center within the laboratory.
2.7 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.
- Request information and training when unsure of how to handle a hazardous chemical or procedure
2.8 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.
Training – 3
All individuals who work in laboratories must be apprised of the hazards associated with chemicals present in their work area. This information must be provided by the PI/ RCD/ Instructor/Lecturer before initial assignment and before new potential exposure situations. It is the shared responsibility of the PI/RCD/Instructor/Lecturer and EHS to ensure that all laboratory workers have been properly trained. EHS verifies training compliance as part of their routine inspection process, detailed in Section 9.11, Comprehensive Risk-Based Laboratory Inspection Program.
The training program for all laboratory workers consists of training administered by EHS, and site-specific training conducted by the PI/RCD/Instructor/Lecturer or their designee.
EHS maintains training records for those individuals who complete this training in SciSure. The PI or their designee is responsible for the ensuring trainings are complete and can verify the training records in SciSure. These trainings are focused on the following laboratory safety topics:
- The University’s CHP
- Emergency Procedures
- Medical Consultations and Examinations
- OSHA’s Laboratory Standard
- Hazard Waste Management, Storage, and Disposal
- Hazard Recognition
- Safety Data Sheets (SDS)
- Safety Equipment
- Engineering Controls
- Chemical Management, Inventory, Labeling and Storage
- Highly Hazardous Chemical Program
- Chemical Agent specific training, such as 6-OHDA Training or MPTP
- PPE
- Nanotechnology
The PI is responsible for oversight of laboratory procedures. The PI and EHS will continually assess the need for any site-specific training before a laboratory worker uses a new hazardous chemical or conducts a new potentially hazardous procedure.
Signs and Symptoms of Chemical Exposure – 4
It is critically important that laboratory workers are aware of and recognize the signs and symptoms of chemical exposure. Prior to work, the chemical’s SDS should be reviewed for associated signs and symptoms.
If a lab-related exposure, injury or incident is suspected or is known to have occurred, it must be reported to ROHP and Environmental Health and Safety. See Appendix B: Emergency Procedures and Reporting for more information.
EMPLOYEES: In the event of an exposure incident, the researcher should immediately call ROHP. After reporting an incident to ROHP, the researchers should contact Stratacare an injury/incident intake service available 24/7. Employees should also notify their supervisor as soon as possible.
Signs and symptoms of chemical exposure may include the following symptoms (however, please note that these symptoms may also be associated with conditions other than 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.
Medical Services and Surveillance – 5
Laboratory personnel working with hazardous chemicals may receive medical attention if needed. Medical attention, including any follow-up examination and treatment recommended by the examining health care provider, must be offered as described below:
Research Occupational Health Program (ROHP) serves BU and Boston Medical Center (BMC) laboratory researchers and those who support those research laboratories. Its client population includes faculty, staff, students, and sometimes visitors. Certain chemical and biological agents and other materials used in research labs have distinct hazards and/or special occupational health requirements. Confidential reproductive health counseling is available for researchers as it relates to their work environment. Researchers working with chemicals should read BU’s Laboratory Reproductive Health Hazards Guidance document prior to working with chemicals. A medical consultation to determine the need for a medical examination must be offered to any employee who is present in the work area when a spill, leak, explosion, or other accident occurs that results in a potential significant exposure to a hazardous chemical.
A medical examination must be provided to any employee who exhibits signs or experiences symptoms associated with exposure to a hazardous chemical used in the laboratory.
Medical surveillance will be performed by ROHP as directed by the relevant OSHA standard of the relevant hazardous agent whenever exposure of that particular agent exceeds its action level or PEL as indicated by exposure monitoring by EHS. Please refer to Section 6: Exposure Monitoring for more information.
5.2 Respiratory Protection Program
Additionally, the provisions of BU’s Respiratory Protection Program require that any employee required to wear a tight-fitting respirator in performance of his or her duties must first undergo a medical evaluation in addition to a respiratory fit-test. Medical evaluations are completed by ROHP; medical evaluations must be completed prior to the employee being fit tested or being required to use a respirator in the workplace. In the event that there is a change in one’s medical status that may affect one’s ability to use a respirator, or a change in your work environment, or any other reason that contributes to difficulty tolerating the use of a respirator, which may result in a substantial increase in physiological burden, please reach out to rohp@bu.edu to request reevaluation.
ROHP provides medical services and surveillance at no charge to university employees. ROHP can be reached at 617-358-7647.
Respirator fit-testing is performed by EHS. Fit testing shall be repeated or if changes in the person’s physical condition could affect the fit of the respirator. Examples of these changes include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight.
5.3 Medical Services Reporting
If the events triggering the request for medical services and/or surveillance involve a potential chemical exposure, the impacted individual must also contact EHS to investigate the extent of the exposure. ROHP uses the information gathered in the EHS investigation to appropriately scale their response. Any required records will be kept by ROHP and EHS, as necessary; medical records kept by ROHP will be maintained as confidential.
Exposure Monitoring – 6
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.
6.1 Initial monitoring
Initial monitoring will be completed by EHS to determine 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-3 Mineral Dusts – 1910.1000
6.2 Periodic monitoring
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 additional information.
Under recently promulgated EPA rules under the Toxic Substances Control Act, there are additional exposure monitoring requirements associated with certain chemicals, including, but not limited to, methylene chloride (DCM), Trichloroethylene (TCE) and Perchloroethylene (PCE). EHS will complete the periodic monitoring detailed in each EPA regulation, based on the results of the initial monitoring.
6.3 Notification of Results
Within fifteen (15) working days after the receipt of any monitoring results, the worker will be notified by EHS of these results in writing.
Request for Monitoring
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.
Record keeping – 7
- 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.
Laboratory Design and Engineering Controls – 8
Engineering controls should be implemented within the laboratory to minimize exposure to hazardous chemicals. Engineering controls may include, but are not limited to the following: general laboratory ventilation, chemical fume hoods, point-source or local exhaust ventilation, filtered enclosures, product substitution, secondary containment, gas monitoring, gas cabinets, 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, redesigned, or reassigned. 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. 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.
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 617-358-4144. NEIDL specific calls should be directed to the NEIDL Control Center at 617-358-9090
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 9.9: Laboratory Safety Equipment. Other common engineering controls are gas cabinets and gas monitoring systems. Details on these systems, including maintenance and annual calibration/testing can be found in Section 9.9.
Standard Operating Procedures (SOPs) – 9
9.1 Safe Work Practices
All staff handling chemicals in the laboratory will complete the following:
- 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.
- Ensure PI/RDC/Instructor/Lecturer and all other lab occupants are informed 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:
- Posted emergency instructions
- Eyewash and safety showers
- Fire extinguishers
- Fire blankets, if applicable
- Fire alarm pull stations
- Emergency exits
- Chemical spill equipment
- Gas shutoff valve
- Laser shutoff switch, if applicable
- Gas monitors and strobes
- 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 full chemical name(s). Abbreviations, chemical formulas, structures, etc. are insufficient for clear identification. Labels must include the concentration and any hazards of the substance. For chemical containers too small to support complete labeling (i.e., small vials, multi-well plates, etc.), external reference documents may be kept nearby.
- Promptly discard chemicals that have degraded, whose containers are in poor condition or that have gross contamination, that have exceeded their expiration date, and/or are no longer useful.
- Laboratory equipment must be decontaminated prior to moving or disposal. Please refer to BU’s Laboratory Decontamination and Decommissioning Green “decon” stickers can 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.
- When transporting chemicals and biologicals outside of laboratory spaces, do not touch non-lab surfaces, including door handles and elevator buttons, with gloves.
- Discard, decontaminate, clean, or sanitize PPE on a regular basis.
- Always wash hands immediately after removing gloves and before leaving the laboratory.
- Door placarding is further discussed in Section 9.7, Laboratory Door Labeling.
Working alone with hazardous materials, chemicals, equipment, or working under conditions that may create the risk of serious injury should be avoided (and in some cases may be prohibited). Associated risks and steps taken to minimize these risks must be discussed with the PI/RDC/Instructor/Lecturer prior to working alone.
If the PI/RCD/Instructor/Lecturer determines that the risk cannot be minimized to a safe level, then the individual should only conduct work when others are present. Undergraduate students are not permitted to work alone without prior written approval from the immediate PI/RCD/Instructor/Lecturer, following a risk assessment:
- 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 617-358-4444 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.
OSHA requires that SDS are available to employees working with hazardous chemicals. The SDS summarize information about the material including chemical components, hazard identification, first aid, spill, and firefighting procedures, incompatibilities, safe handling and storage requirements, and disposal guidelines. The Laboratory Supervisor, PI, and EHS are responsible for providing workers with access to SDS.
- 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. HHC SDS and SOPs must be stored in a designated and demarcated location. 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 are 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.
The purchasing of chemicals must be authorized by the PI or PI designee before submitting to Sourcing and Procurement. Best practices include:
- Purchase chemicals through Sourcing and Procurement (Ariba);
- Prior to increasing the volume of chemicals in the laboratory, the PI or PI designee can submit a Pre-Purchase MAQ Analysis request to EHS, in order to determine if the laboratory’s control area can accommodate the additional volume of chemicals to be added.
- Order the minimum amount of the chemical needed to perform the work;
- Review current chemical stocks in laboratory before ordering;
- New chemicals must be immediately stored according to the chemical storage guidelines in Section 9.6, General Chemical Safety Guidelines.
- Limit purchases of duplicate chemicals. Use up or discard old chemicals prior to re-ordering.
Please note that EHS will routinely monitor MAQ compliance in all laboratories and control areas. Refer to Sections 9.11 Comprehensive Risk Based Laboratory Inspection Program and 9.12 Laboratory Non-Compliance for additional details
Individuals who will be receiving and using the chemical must be adequately informed and trained on proper handling, storage, and disposal. Proper PPE and plans for safe storage and handling should be in place prior to receipt. EHS is available as a resource and should be consulted as needed.
9.5 Safe handling and storage of chemicalsThe PI is responsible for maintaining a complete and accurate inventory of all chemicals and gases in their laboratory on SciSure ChemTracker. A step by step tutorial on updating your chemical inventory with Chemtracker is available online.
Inventory management shall include:
- Chemicals and gases must be added to ChemTracker upon receipt and deleted from ChemTracker when used up or discarded.
- When adding chemicals to ChemTracker, ensure that the chemical is added using the name/ID information that SciSure recognizes to prevent unlinked chemicals in the database that lead to undercounting chemicals when calculating Maximum Allowable Quantities (MAQs) for fire code compliance.
- The laboratory will complete an annual chemical inventory update in ChemTracker. The ChemTracker update shall consist of either a Bulk Upload, Bulk Edit, or Chemical Reconciliation in SciSure.
- If selected, the reconciliation process entails the following:
- Examining each chemical container for usefulness, expiration date, and degradation. Discard chemicals and update ChemTracker accordingly.
- Using SciSure ChemTracker’s Reconciliation feature to verify that chemical name (and concentration, if applicable), CAS number, location (building and room number), physical state, amount, units, container ID/barcode (if applicable), specific location, and expiration date are correct.
- Additional information regarding chemical inventory reconciliation through SciSure is available online.
- Ensure that all chemicals are properly segregated by hazard class. See section 9.6, General Chemical Safety.
By following the guidelines below, the risks associated with the storage and handling of chemicals in the laboratory can be considerably reduced:
• 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.
• Label secondary containers that may be used for storing hazardous chemicals with full chemical name and appropriate hazard warnings.
• Follow storage requirements as prescribed in the SDS and use appropriate PPE (See Section 9.8: Personal Protective Equipment).
• The chemical storage guidelines should be used for work with specific chemical hazards; see Section 9.6: 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.
• New chemicals must be promptly removed from their shipping containers and stored according to their chemical hazards.
• Chemicals must not be stored in hoods overnight.
• Chemicals connected to instruments permanently installed in a hood or part of an overnight process/reaction must be clearly labeled.
• 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.
• Avoid storing larger (>500g) or glass chemical containers above eye level. Do not store chemicals or large lab equipment more than 8-feet off the floor. Do not store chemicals within 18-inches of the sprinklers and/or ceiling.
• Instrument/equipment pump and/or waste bottles must have commercially available caps designed with the correct number of tightly fitting tubing access septa/ports – home drilled caps are not acceptable.
• Do not store food or beverages in the laboratory refrigerator or cold room.
• Handle hazardous chemicals with appropriate engineering controls (e.g. chemical fume hood) and appropriate PPE.
• Do not dispense solvents/chemicals inside a flammable storage cabinet.
• Workers should not use hazardous chemicals or equipment if they have not been trained to do so.
• Highly hazardous chemicals should be stored in well-ventilated and secure areas designated for that purpose.
• Highly hazardous chemicals need to be individually segregated by chemical. (Multiple bottles of the same HHC may be stored in the secondary container).
• Maintain existing labels on incoming containers of chemicals.
• Laboratory doors should remain closed at all times.
• Work surfaces and laboratory furniture should be impervious to chemical spills.
9.6.1 Corrosives
- Store corrosive materials below eye level.
- Segregate acids from bases and bases from acids in different secondary containers or cabinets. BFD strongly prefers segregation in separate 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 stored container if it should break.
- Use appropriate bottle carriers or a cart when transporting any hazardous chemicals.
- Store flammable corrosives in flammable cabinets not corrosive cabinets. Flammability trumps corrosivity when determining storage locations for chemicals with multiple hazards, i.e., acetic acid.
- Do not store anything directly on top of free-standing corrosive cabinets.
- 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, i.e., hydrochloric, sulfuric, nitric, from organic acids, i.e., acetic, in separate cabinets.;
- All lab-workers must know where spill-control supplies and acid neutralizers are stored, to be prepared 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.
- All laboratories with Hydrofluoric Acid (HF) must keep unexpired 2.5% calcium gluconate in a location that is known by all laboratory staff.
- 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.
- Segregate inorganic bases, i.e., sodium hydroxide, ammonium hydroxide, from organic bases, i.e., amines.
- Store solutions of inorganic hydroxides in polyethylene containers.
- Know where spill-control supplies and caustic neutralizers are stored to be prepared for caustic spills. Do not use acids to neutralize base spills.
- Flammable chemicals must be stored in a spark-free environment and in approved flammable-liquid containers and storage cabinets.
- Store spray and squirt bottles of flammables (i.e., 70% ethanol for disinfection), in a flammable cabinet when not in use/overnight.
- Grounding and bonding should be used to prevent static charge buildups when dispensing solvents.
- Flammable liquids shall be stored in a specially equipped, explosion-proof or flammable-safe flammable storage cabinet.
- If cool storage is required, only laboratory-grade, flammable-rated refrigerators and freezers shall be used to store sealed chemical containers of flammable liquids.
- 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 within each control area. Consult EHS’s fire safety group for guidance.
- Flammables must be dispensed in a chemical fume hood.
- Do NOT dispense flammables inside the flammable cabinet. Avoid ordering flammables, including alcohol, in containers with spigots. Remove dispensing pumps from bottles and kegs before storage.
- No cardboard inside flammables cabinets.
- Flammable solvents connected to instruments must have commercially available caps designed with the correct number of tightly fitting tubing access septa/ports. Home drilled caps are not acceptable.
- Small flammable gases, i.e., blow-torch propane, needs to be stored in a dedicated flammable cabinet with the torch head removed.
- Do not store anything, including empty Styrofoam and cardboard boxes, directly on top of free-standing flammables cabinets.
- Flammable corrosives, i.e., acetic acid or triethylamine, must stored in a flammable cabinet in plastic secondary containment.
- Examples of oxidizers include, not are not limited to Perchlorates, Nitrates, Permanganates
- Oxidizers can intensify and increase the flammable range for chemicals so they can ignite more readily.
- Store oxidizers in a cool, dry area.
- Do not store oxidizers in the same flammable storage cabinet as flammable chemicals
- Store oxidizers away from flammable and combustible materials, such as paper, wood, etc.
- Do not store nitric acid with acetic acid.
- Oxidizers, reducing agents, and fuels should be stored separately to prevent contact in the event of an accident.
- Examples of peroxide forming chemicals include, but are not limited to, Isopropyl alcohol, Diethyl Ether and Tetrahydrofuran
- 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.
- Refer to EHS Management and Safety of Peroxide Forming Chemicals for additional details.
- EHS must be informed prior to purchase, storage and use of hazardous (pyrophoric, toxic, oxidizing, (including oxygen), 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 in each control area. Consult EHS’s fire safety group for guidance.
- Gases in the laboratory must be stored in a 1:1 ratio of active cylinder to back-up cylinder.
- “Active” cylinders are considered attached to regulator, manifold, or equipment.
- Monitor compressed gas inventories and dispose of or return gases for which there is no immediate need. Maintain compressed gas inventory in SciSure.
- Order the smallest quantity possible in a returnable cylinder. Empty or unused gas cylinders should be returned to the supplier on a regular basis. Note that when ordering “lecture” bottles, that empty cylinders are not returnable to the gas supplier and must be disposed of as hazardous waste.
- Store and use hazardous gases in a ventilated space such as a chemical fume hood and/or certified gas cabinet. Refer to Section 9.9.8, Gas Cabinets, for additional details.
- 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.
- Please refer to the Chemical Inventory Management and Gas Cylinder Safety Guidance sites for more information.
- 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.
The Boston Fire Department requires the National Fire Protection Association (NFPA) 704 Diamond be posted on all laboratory doors. In order to appropriate update the door signage, the laboratory must inform EHS when:
- The laboratory acquires new chemicals or gases
- There are significant changes to chemical inventory
- There are changes to biosafety levels and/or animal usage
- Installation or removal of lasers or radioactive materials
- There are changes to the lab groups occupying the space
- There are changes to lab staff contact information
9.8 Personal Protective Equipment (PPE)
There are many different types of PPE. The type of hazard, the design of available engineering controls, and the route of exposure should all be considered when determining what constitutes appropriate PPE.
At a minimum, in accordance with BU’s Personal Protection Equipment in Laboratories Policy, the following PPE is required: long pants or full length skirts, long sleeves, closed toe shoes, long sleeve lab coat, gloves, and eye protection. The type of lab coat, gloves, and eye protection used should be matched to the hazard.
The PI, Research Core Director, Instructor/Lecturer is responsible for selecting, in collaboration with EHS, and providing the appropriate PPE for the laboratory. Laboratory workers must wear PPE as directed, remove PPE upon exiting the laboratory or laboratory support area, and notify the PI if the PPE provided is damaged or inadequate.
EHS is available to assist in the selection of appropriate PPE and to train laboratory workers on the proper use of the PPE. EHS inspects laboratories for compliance to enforce appropriate PPE use.
If the use of a respirator is needed to maintain exposure below PELs, medical clearance must be obtained by ROHP, and a respirator fit testing must be conducted by EHS. Please refer to the BU Respiratory Protection website for more information.
9.9 Laboratory Safety Equipment
There may be many different types of safety equipment in laboratories at BU. The Laboratory Supervisor or PI/RCD/Instructor/Lecturer should ensure that laboratory workers are familiar with the location and proper operation of safety equipment available in the laboratory. Basic information on safety equipment is provided to researchers by EHS during Laboratory Safety Training. EHS or CPO verifies on an annual basis that safety equipment is in place and functioning properly. Common pieces of laboratory safety equipment include:
9.9.1 Emergency Eye Wash Station
- 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. Please consult with EHS when selecting eyewash signage.
- 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).
Eye wash stations are inspected semi-annually to ensure they meet appropriate standards and regulations. EHS oversees the semi-annual inspections on both the CRC and BUMC campuses. Repairs on both campuses are conducted by CPO.
In the event that an emergency eye wash station is activated and a floor drain is not present, PI/RCD/Instructor/Lecturer or designee will contact EHS to notify EHS of the event. Should a laboratory suspect that the emergency eye wash is not operational, the PI/RCD/Instructor/Lecturer or PI/RCD/Instructor/Lecturer designee will contact EHS.
The emergency safety shower delivers flushing fluid in sufficient volume to flush away gross chemical contamination from the body or to extinguish a fire on the body. Emergency safety showers should be clearly marked and kept free from obstructions.
- 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).
- Safety shower stations should be clearly marked and kept free from obstructions. Please consult with EHS when selecting eyewash signage
Emergency safety showers are inspected semi-annually to ensure they meet appropriate standards and regulations. EHS oversees the semi-annual inspections on both the CRC and BUMC. Repairs on both campuses are conducted by CPO.
In the event that an emergency safety shower is activated and a floor drain is not present, the PI/RCD/Instructor/Lecturer or PI/RCD/Instructor/Lecturer or designee will contact EHS to notify EHS of the event. Should a laboratory suspect that the emergency safety shower is not operational, the PI/RCD/Instructor/Lecturer or PI/RCD/Instructor/Lecturer or designee will contact EHS.
Some laboratories are equipped with fire blankets. Please note that fire blankets are not required. The laboratory is responsible for maintaining fire blankets and should have procedures in place for their use. EHS is available to assess the need for a fire blanket.
9.9.4 Fire Extinguishers
Fire extinguishers are provided to laboratories in the event a fire blocks a means of egress, and the laboratory worker must fight a fire to save his or her own life or to extinguish small fires if able and if the individual has been properly trained. Laboratories should have the appropriate class of extinguisher for the fire hazards in the laboratory. In general, a class BC or class ABC extinguisher is appropriate. In some instances, this extinguisher is supplemented with a class D fire extinguisher, as required. EHS can provide guidance on the selection of the appropriate fire extinguisher including its placement.
Laboratory workers are trained on basic fire extinguisher use in annual Laboratory Safety Training (see Section 3: Training). EHS will provide specific fire extinguisher training as requested.
Fire extinguishers are inspected annually by an outside vendor and replaced as needed. CPO inspects each fire extinguisher monthly and also manages the installation, inspection, and replacement of fire extinguishers. Laboratory personnel should report any issues with fire extinguishers to CPO. 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 617-358-4144.
9.9.5 Chemical Spill Containment Kits
All laboratories are required to have and maintain a Chemical Spill Containment Kit. EHS provides Chemical Spill Containment Kits in some common areas to provide laboratories with additional basic equipment to contain a chemical spill. These kits are stocked with material to help contain a large chemical spill. Appropriate PPE must be worn. All used chemical spill clean-up materials must be disposed of as hazardous waste.
The PI, Research Core Director, Instructor/Lecturer is responsible for determining whether additional spill containment or clean-up material (appropriate to the chemicals used in the laboratory) is required, and is responsible, along with EHS, for providing that material as needed. Laboratory workers should be trained in the proper use of chemical spill kits. All chemical spills, (whether involving medical exposure or a near-miss) should be reported to EHS (see Appendix B: Emergency Procedures and Reporting for more information).
9.9.6 Chemical Fume Hoods
Chemical fume hoods are the most common engineering control to protect against the inhalation of chemicals.
EHS conducts the annual inspection of chemical fume hoods to ensure they are functioning properly. A yellow pass sticker is affixed on the fume hood indicating pass along with the inspector’s initials, date, and face velocity at the sash opening. An orange fail sticker is affixed to the hood sash or other conspicuous location, if airflow testing indicates that the chemical fume hood is operating outside of testing criteria (refer to most recent edition of ANSI Z9.5 standard) EHS will submit a work order request to CPO for any fume hood that fails inspection. Laboratory workers are instructed not to use the fume hood with an orange sticker present until repairs are made, and proper performance has been verified by EHS.
CPO repairs chemical fume hoods that are not functioning. If a laboratory worker suspects that a chemical fume hood is not functioning properly, he/she/they should contact CPO at 617-353-2105 (CRC) or 617-638-4144 (BUMC).
When using a chemical fume hood, laboratory workers should follow these guidelines:
- 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.
- Permanent chemical and waste storage is not permitted inside a laboratory fume hood. All chemicals and waste containers must be removed at the end of the lab operations for the day or when not in use.
- Do not modify chemical fume hoods without prior approval from EHS and/or CPO.
Local exhaust ventilation (LEV) systems are an important engineering control technique for maintaining acceptable air quality in the work environment. Its major approaches are the capture, control or containment of airborne contaminants at or as close as possible to the point of contaminant generation.
Types of LEV systems included, but are not limited to, extraction arms (e.g. snorkels), down draft or grossing tables, acid wet benches, slot hoods, pivoting canopy hoods, spray booths, or other ventilation systems designed to draw contaminants away from the breathing zone of the user. These systems are functionally different from chemical fume hoods, as these are not enclosed.
EHS conducts the annual inspection of LEV systems to ensure they are functioning properly. A light blue pass sticker is affixed on the LEV in a conspicuous location, indicating pass along with the inspector’s initials, date, and face velocity at the opening. An orange fail sticker is affixed to conspicuous location, if airflow testing indicates that the LEV is operating outside of testing criteria (refer to most recent edition of ANSI Z9.2 standard). EHS will submit a work order request to CPO for any LEV that fails inspection. Laboratory workers are instructed not to use the LEV with an orange sticker until repairs are made, and proper performance has been verified by EHS.
CPO repairs LEV systems that are not functioning. If a laboratory worker suspects that a LEV is not functioning properly, he/she/they should contact CPO at 617-353-2105 (CRC) or 617-638-4144 (BUMC).
When using a LEV, laboratory workers should follow these guidelines:
- Check airflow prior to starting activities, using Kimwipe or other lightweight paper, to ensure inward air flow.
- Position the LEV or work, such that the work is completed as close to the opening as the work process will allow.
- Do not modify LEV systems without prior approval from EHS and/or CPO.
Exhausted enclosure ventilation or gas cabinets are required for specific types of gases, per the most recent version of NFPA 55 guidelines, which are incorporated into the MA Fire Code (527 CMR 1.00). These gases include but are not limited to, unstable reactive Class 3 or Class 4, or corrosive gases. For these types of exhausted enclosures, the MA Fire Code states that “the velocity at the face of access ports or windows, with the access port or window open, shall not be less than 200 ft/min (61 m/min) average, with not less than 150 ft/min (46 m/min) at any single point.”
Combustible, flammable and oxidizing gases may also be stored in exhausted enclosures, in order to increase the volume of gas that may be stored in the control area. These types of gas cabinets shall be negatively pressurized with respect to the surrounding area or will meet the specific CFM requirements, as designed by a licensed HVAC engineer (referred to design standard herein). Please refer to Hazardous Materials Inventory and Storage in Research Building for additional details on which gases should be stored in gas cabinets.
EHS conducts the annual inspection of gas cabinets to ensure they are functioning properly. A light blue pass sticker is affixed on the gas cabinet in a conspicuous location, indicating pass along with the inspector’s initials, date, and face velocity at the opening. An orange fail sticker is affixed to conspicuous location, if airflow testing indicates that the gas cabinet is operating outside of testing criteria, based on the type of gas within the gas cabinets (e.g. either NFPA face velocity or design standard). EHS will submit a work order request to CPO for any gas cabinet that fails inspection. Laboratory workers are instructed to turn off gas within gas cabinet until repairs are made, and proper performance has been verified by EHS.
CPO repairs gas cabinet that are not functioning. If a laboratory worker suspects that a gas cabinet is not functioning properly, he/she/they should contact CPO at 617-353-2105 (CRC) or 617-638-4144 (BUMC).
Gas monitoring may be required when highly toxic, toxic, flammable, or pyrophoric gas cylinders are stored and planned for use. Under some conditions, oxygen monitoring is required in locations with compressed and liquefied inert gases or other simple asphyxiants AND where there is a potential to create an oxygen deficient environment).
- During new design and construction projects, the number, location, and type of gas alarms will be determined by the project design review team, including EHS.
- In existing laboratories and upon commissioning of a new compressed gas system, EHS will meet with the PI, Research Core Director, Instructor/Lecturer and/or LSC to determine if gas monitoring is required and what options are available.
Following commission of the gas alarm systems, EHS will coordinate as-needed calibration of the sensor(s) and will assist the laboratory with the placement of appropriate signage over displays and/or strobes. Replacement and maintenance of gas monitor sensors will be the responsibility of the laboratory and/or Department;
There are many different waste streams that could potentially be generated by laboratories. Please refer to the Laboratory Waste Disposal Overview site for more information on specific waste streams.
9.10.1 Solid, Non-contaminated Waste
Solid waste is waste that is not regulated for special disposal and therefore can be placed in a standard dumpster for disposal. Solid waste is removed from the laboratory by CPO staff. Examples of solid waste include, but are not limited to:
- Recyclable waste: clean, non-contaminated recyclable waste should be recycled when possible using designated receptacles. Refer to the BU Sustainability
- 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, promptly deface containers and dispose of as solid waste.
- Reference the Chemical Waste Management Guide for complete list of P-listed chemicals.
- Another sustainable use for empty solvent or non-hazardous chemical containers is to re-use them for liquid hazardous waste collection.
- 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 per SAA),
- Make sure there is secondary containment for each waste container. Secondary containment for all liquid waste containers must be large enough to contain 110% of the full volume of the largest container in the SAA,
- Segregate incompatible wastes into different secondary containers,
- Contact EHS to pick up full containers as soon as they become full.
- Do not store chemical waste in the hood overnight.
- Flammable waste must be stored in a flammable cabinet SAA or a red solvent waste can.
- Ignitable instrument waste, including HPLC and UHPLC, must be accumulated in a solvent can equipped with a tubing manifold provided by EHS. Laboratories must purchase compatible tubing that fits the EHS provided manifold and their specific instrument.
- Biological waste is collected in red bag-lined bio waste 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.
- Bio waste boxes in laboratories are sealed by the laboratory and labeled with the laboratory name. On the CRC, bio waste boxes are removed by request. On the Medical Campus, closed bio waste boxes are removed by custodial staff.
- Plastic serological pipettes should be disposed of in 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 in biological waste boxes, 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.
- Chemically contaminated biological waste must be disposed of as chemical waste.
- Visit the Biological Waste section of the EHS website for more information.
- Sharps waste, including, but not limited to, needles, syringes, serological pipettes, 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.
- 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.
- 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.
Laboratory Safety Inspections are scheduled in advance with the Laboratory Supervisor or PI/RCD/Instructor/Lecturer, or their delegate. EHS conducts laboratory safety inspections. Frequency is determined by performing a risk assessment for each laboratory and recording information pertaining to inventory, processes and procedures, personnel, and compliance history.
During the inspection the EHS inspector reviews a checklist to help identify areas for improvement within the laboratory. Following the inspection, the PI receives an inspection report through SciSure and may be asked to correct unsatisfactory conditions as appropriate. The PI/RCD/Instructor/Lecturer should contact EHS with any questions prior to, during, or following an inspection. Details on the Comprehensive Risk-Based Laboratory Inspection Program are available online.
For findings that are related to Immediately Dangerous to Life and Health (IDLH), EHS is authorized to shut down any activity that may be considered IDLH. If activities are stopped, EHS will immediately inform the PI, LSC or supervisor. A further risk assessment may be initiated. Work may not resume until all hazardous conditions have been corrected.
For findings are that are related to Maximum Allowable Quantities (MAQ) or Chemical Inventories non-compliance, EHS will notify the PI if (a) the laboratory’s chemical inventory has not been updated in one calendar year, or (b) the Maximum Allowable Quantity of hazardous materials is exceeded for the laboratory’s control area. As discussed above, the PI will be provided an expected completion date to resolve this finding. EHS will shut down any laboratory that does not correct non-compliance with their control areas MAQ within 14 calendar days of receipt. Laboratory operations may not resume until conditions have been corrected.
BU laboratories often contain valuable equipment and materials, equipment and materials that may pose a danger to public safety, and equipment and materials that may pose a danger to an untrained visitor. Given this, it is important that the laboratory is secure at all times. Some laboratories may have special precautions in place given the nature of the materials stored in the laboratory. In general, all laboratories should follow these tips to help keep the laboratory secure:
- 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 617-358-4444.
- 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.
Per BU’s Visitor Policy (See Section 2.8), a laboratory visitor is any person who is not assigned to work in the laboratory space on a regular basis. To protect the visitor and reduce the risk to the University, the following guidelines for visitors to laboratories should be followed:
- 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.
Laboratory workers and PIs are permitted to transfer chemicals between laboratories and buildings on the same campus provided they do not transport the chemicals in a vehicle on a public roadway. High traffic areas should be avoided. The materials themselves must be in sealed containers, clearly labeled with the contents’ name and applicable hazard(s) classification.
The sealed materials should be placed in secondary containment prior to transport. The secondary container should be sealed, break-resistant, and leak-resistant. If the container is being transported on a cart, the cart should have a lip to prevent the container from sliding off.
It is against DOT regulations to transport hazardous chemicals by vehicle under any circumstance. If chemicals must be transported between campuses or to an off-campus location by motor vehicle or airplane then EHS must be contacted for assistance in complying with applicable transport regulations.
See BU Chemical Transport from Storage Room Guidance for further information.
9.16 Laboratory-Specific SOPs
As detailed in Section 3.2 Site Specific Training, it is the responsibility of the PI/RCD/Instructor/Lecturer to review procedures for all chemicals being used. If a laboratory’s procedures differ from those outlined in this CHP, or if more specific or stringent SOP’s are needed or required, the PI/RCD/Instructor/Lecturer and EHS are responsible for developing SOPs detailing laboratory-specific procedures, and EHS should be contacted. The process of developing laboratory-specific SOPs is intended to characterize various toxicological, regulatory, and physical criteria or to identify conditions that might require additional control measures, as well as to aid in the identification of those control measures.
A chemical is considered “highly hazardous” if it 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. Details on the Highly Hazardous Chemicals Program are available online.
OSHA classifies the following list of chemicals, meeting threshold levels, as highly hazardous 1910.119 App A. BU’s HHC includes the OSHA agents as well as those select carcinogens, substances with a high degree of acute toxicity, and substances that pose a high degree of physical hazard. As part of the Highly Hazardous Chemicals Program, BU’s list of highly hazardous chemicals (HHCs) is reviewed and revised annually to remove HHCs no longer in use and to add HHCs not previously used.
Additional employee protection is required by the Laboratory Standard and BU for work with particularly hazardous substances. Prior approval to use and order these chemicals must be sought by the PI/RCD/Instructor/Lecturer from the LSC. Procedures for obtaining approval for use, as well as PI/RCD/Instructor/Lecturer and laboratory worker responsibilities, are provided in the Highly Hazardous Chemicals Program.
The purpose of this program is to provide a designation of containment levels that outlines the requisite administrative controls, engineering controls and personal protective equipment necessary to protect researchers, BU Animal Science Center (ASC) staff, and the environment from potential exposures involving animals that have been treated with and exposed to potentially hazardous chemicals that are housed or handled in BUASC spaces. Information is available here.
Laboratory staff play a critical role in determining appropriate immediate actions to ensure their safety and the safety of others in the event of a chemical spill. These immediate actions are based on various factors including the nature of the spilled materials, the quantity of the spilled material, and the location of the spill.
Spill clean-up procedure:
- Restrict access to area, assess the extent of the spill and remove affected personnel
- If safe to do so, spill using materials from Laboratory Safety Kit. Be sure to block off drains if possible.
- If you have been exposed, call BUPD at 353-2121(CRC) or BUMC Control Desk at (617) 358-4444 for medical assistance. Also contact ROHP at 358-7647 following all lab related exposures.
- For assistance cleaning the spill contact Environmental Health and Safety at:
- CRC: (617) 353-4094 or after-hours Facilities at (617) 353-2105
- BUMC: (617) 358-6666
- If you feel comfortable, have been properly trained, and there is no immediate threat to your health, proceed to clean the spill. (If at any time you do not feel comfortable, leave the room and await assistance).
- When cleaning a spill:
- Be sure to wear appropriate PPE- gloves, goggles, lab coat.
- Collect contaminated material and place into a proper waste container
- Place hazardous waste label on the container and fill out completely.
- Store with your laboratory hazardous waste, in your Satellite Accumulation Area
- Request a hazardous waste pickup on SciSure’s waste tab.
9.20 Laboratory Decontamination and Decommissioning
PI/RCD/Instructor/Lecturer is responsible for ensuring that the outlined Laboratory Decontamination and Decommissioning procedures are followed whenever group ceases activity in laboratory space.
