Highly Hazardous Chemicals Program

Environmental Health & Safety (EHS), in conjunction with the Boston University Laboratory Safety Committee (LSC), has identified certain chemicals as Highly Hazardous Chemicals (HHCs). A chemical is considered “highly hazardous” if it has any health, physical or environmental hazards that require additional safety and/or environmental practices beyond those of a typical laboratory setting, as required by existing regulations or upon review of the hazards by EHS, relevant oversight committees, or other institutional entities. The highly hazardous chemical program is based on a risk-based safety assessment.

Highly Hazardous Chemical List | Highly Hazardous Chemicals Program Guidance Document

Chemical Use Safety Assessment

Laboratories that use highly hazardous chemicals are identified during periodic reviews of the chemical inventories on BioRAFT, from alerts to EHS from Purchasing for identified chemicals ordered by PIs or authorized laboratory members, during other committee reviews of research, or during EHS’s Research Safety Inspections. When a laboratory is identified as using a highly hazardous chemical, the Chemical Safety Officer (CSO) will reach out to the lab to provide any appropriate Institutional SOPs for the chemicals and to assess PPE and other safety needs. Information regarding HHC use and activities at BU/BMC is reviewed by the LSC to determine if additional steps are required to manage the laboratory hazard as described in the program.

Reproductive Toxicants

Reproductive toxicants include chemical, biologic, and physical agents that can impair the reproductive process in men and/or women.  These reproductive hazards have the potential to interfere with fertility, embryo, fetal, infant and/or childhood development.  If you have concerns related to working with reproductive toxicants from preconception to delivery, please reach out to the Research Occupational Health Program (ROHP) for a consultation.

Institutional HHC Standard Operating Procedures (SOPs)

The majority of chemicals in the highly hazardous chemical program have standard safety requirements that are universal regardless of the application of the chemical. HHC Standard Operating Procedures (SOPs) are developed by EHS supported for researchers working with the HHCs, and reviewed by the LSC.

The Highly Hazardous Chemicals Program Guidance Document provides general information for working with HHCs in research and teaching laboratories. The chemical-specific SOPs are specific to a highly hazardous chemical or group of chemicals and provides specific information on the hazardous properties, the training and administrative requirements, information about locations where the chemical may be used or stored, the appropriate personal protective equipment (PPE), the steps to take to dispose of the chemical, and procedures to follow in the event of an emergency. The SOPs will be posted on this website as they are developed. The PI/designee and researchers may adapt the SOP templates and include the laboratory-specific information to develop the laboratory-specific written standard operating procedures.

Submission and Review of SOPs

While the Chemical Hygiene Plan (CHP) is available to provide guidance on the general use of chemicals, an additional level of guidance is necessary to ensure the safe use of chemicals considered to be highly hazardous. Before beginning work with these chemicals review the SOP templates for HHC classes located below. These templates include specific information on the hazards, handling procedures, storage, emergency procedures and reporting, and disposal requirements. In addition, an updated list of HHCs is located here.

There are two types of SOPs that the PI, RCD or Instructor/Lecturer may need to complete:

Adopted SOP: Adopt an SOP by adding laboratory information to the template, and submitting the SOP to the CSO at dmhengl@bu.edu  Adopted SOPs are reviewed by the appropriate EHS staff for any required feedback.

Lab-Specific SOP: Revise an SOP template with deviations from the recommended laboratory practices, add their laboratory information and submit the SOP to the CSO at dmhengl@bu.edu via email. The email should contain a rationale for the changes. SOPs will deviations (lab-specific changes) will be sent to EHS.

When SOPs with deviations are received, a primary reviewer with relevant expertise is assigned by the CSO. The primary reviewer’s suggested edits, comments, or questions will be returned to the PI, RCD or Instructor/Lecturer. Once all edits, questions and concerns have been addressed, the CSO will inform the laboratory that the SOP has been approved after providing the submitted SOP to the LSC for any additional suggestions.

The laboratory is responsible for ensuring that their HHC SOP has been approved prior to the use and storage of HHC and uploaded to the laboratory’s BioRAFT profile by the PI, RCD or Lecturer/Instructor.

PLEASE NOTE: If an appropriate template is not available, the PI, RCD or Instructor/Lecturer should contact Environmental Health & Safety for assistance with SOPs or when developing a new SOP.

If you have any questions regarding the Highly Hazardous Chemical Program, contact your departmental safety advisor or Environmental Health & Safety.