Highly Hazardous Chemicals Program Policy

1.1

The purpose of this policy is to reduce the risk to research personnel and support staff working with highly hazardous chemicals and to comply with municipal, state and federal laws and regulations and prudent laboratory practices.

1.2

The chemicals covered under this policy include those chemicals or mixtures of chemicals that have the potential to cause a high health hazard, a high physical hazard, and/or a high hazard to the environment.

1.3

This policy applies to any individual who works with chemicals or chemically contaminated items in a laboratory or animal facility at Boston University or Boston Medical Center.

2.1. Regulations

2.1.1. 29 CFR 1910 Subpart H Hazardous Materials

2.1.2. 29 CFR 1910 Subpart Z Toxic and Hazardous Substances

2.1.3. 29 CFR 1910.1450 – OSHA Laboratory Safety Standard

2.1.4. 29 CFR 1910.1200 – OSHA Hazard Communication Standard

2.1.5. 40 CFR 261 Identification and Listing of Hazardous Waste

2.1.6. Boston Fire Prevention Code

2.1.7. 527 CMR MA Board of Fire Prevention Regulations

2.1.8. 780 CMR MA State Building Code

2.2. BU Policies

2.2.1. Boston University Chemical Hygiene Plan

2.2.2. Boston University Guidelines – Transporting Laboratory Materials Outside of the Laboratory

2.2.3. Boston University Chemical Inventory Program

2.2.4. Boston University Quarterly Research Safety Inspections Program

2.2.5. Boston University Door Placard Program

2.3. Supplementary Documents

2.3.1. NFPA 45 – National Fire Protection Administration Standard on Fire Protection for Laboratories Using Chemicals

2.3.2 NFPA Fire Protection Guide for Hazardous Materials

2.3.3 Handbook of Compressed Gases – Compressed Gas Association

2.3.4 IARC Group 1, 2A and 2B Lists – International Agency for Research on Cancer lists for known, probable and possible carcinogens

2.3.5 National Toxicology Program list of carcinogens

3.1 – 3.3

3.1 High Hazard Chemical – a chemical that has the potential to cause 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 Environmental Health and Safety (EHS), relevant oversight committees, or other institutional entity.

3.2 Health hazard – a hazard caused by chemicals that are considered corrosive, toxic, carcinogenic, teratogenic and mutagenic and that have potential to cause negative effects to human health.

3.3 Physical hazard – a hazard caused by chemicals that are oxidizers, unstable, reactive, flammable, explosive or pyrophoric.

3.4 – 3.6

3.4 Environmentally hazardous chemicals – chemicals listed in 40 CFR 261 Subpart D.

3.5 Chemical Information Sheet – a document created by EHS that gives specific guidelines for the use of a high hazard chemical or a class of high hazard chemicals that is applicable to typical laboratory operations.

3.6 High Hazard Chemical SOP – a standard operating procedure created by a laboratory or group of laboratories and EHS which describes the procedures and safety precautions for a specific process involving a high hazard chemical.

3.7 – 3.10

3.7 Chemical Use Authorization Site Assessment Visit – a visit to a laboratory and/or animal facility by EHS to determine the application of this program to the specific laboratory and/or animal facility.

3.8 Chemical Safety Logbook – a binder prepared by EHS and distributed to a principal investigator (PI) containing PI-specific information related to chemical safety in the laboratory.

3.9 MSDS – a material safety data sheet prepared for a chemical stating specific hazards and properties of that chemical.

3.10 RIMS – an information management system developed for tracking research compliance in laboratories and animal facilities at BU.

4.1. Principal Investigator

4.1.1. Evaluates the possibility of substitution of less hazardous chemicals and considers alternate processes and methods that do not require the usage of high hazard chemicals.

4.1.2. Updates chemical inventory in RIMS upon receipt of any high hazard chemicals per the Chemical Inventory Program.

4.1.3. Removes high hazard chemicals from the inventory that will no longer be used and updates information in RIMS per the Chemical Inventory Program.

4.1.4. Assists EHS in identifying the use of high hazard chemicals within the laboratory and/or animal facilities.

4.1.5. With assistance from EHS, develops new SOPs with the specific procedures used by the laboratory or animal facility as required by the Chemical Use Authorization Site Assessment Visit.

4.1.6. Ensures that all personnel review any applicable CIS, MSDS and High Hazard Chemical SOP and are appropriately trained prior to working with any high hazard chemical.

4.1.7. Ensures that laboratory personnel do not work alone with high hazard chemicals in the laboratory or leave unattended experiments overnight unless specifically permitted by a High Hazard Chemical SOP.

4.1.8. Maintains copies of any applicable CISs, manufacturer-specific MSDSs and High Hazard Chemical SOPs in the Chemical Safety Logbook.

4.1.9. Notifies EHS of any incidents involving a high hazard chemical and records incidents in the Chemical Safety Logbook.

4.1.10. Notifies EHS of any changes in the usage and location of any high hazard chemicals.

4.2. Environmental Health and Safety (EHS)

4.2.1. Develops Chemical Information Sheets for high hazard chemicals.

4.2.2. Visits the laboratory or animal facility and performs a Chemical Use Authorization Site Assessment Visit to determine the use of high hazard chemicals.

4.2.3. Provides any appropriate Chemical Information Sheets to the PI.

4.2.4. Maintains laboratory door placards to reflect the usage and/or storage of high hazard chemicals in the laboratory per the Laboratory Door Placard Program.

4.2.5. Provides appropriate signage for areas within the laboratory where any high hazard chemicals are used and/or stored.

4.2.6. Assists the Principal Investigator in identifying and creating standard operating procedures (SOPs) for the use of highly hazardous chemicals, if required by the Chemical Use Authorization Site Assessment Visit.

4.2.7. Provides any additional training as determined by the Chemical Use Authorization Site Assessment Visit.

4.2.8. Reviews storage and usage of high hazard chemicals during quarterly research safety inspections and verifies the accuracy of information on door placards, in RIMS and in the Chemical Safety Logbook.

4.2.9. Maintains lists of high hazard chemicals.

4.2.10. Periodically reviews chemical inventories in RIMS to determine if any new high hazard chemicals have been added to any laboratories.

4.2.11. Assist PIs with removal of unwanted high hazard chemicals from their laboratories.

4.3 BU Charles River and Medical Campus Laboratory Safety Committees

4.3.1 Acts as technical resources to EHS in the review of SOPs involving highly hazardous chemicals.

4.3.2 Reviews and approves Chemical Information Sheets.

4.4. The Institutional Biosafety Committee (IBC), Laboratory Animal Science Center (LASC), and the Institutional Animal Care and Use Committee (IACUC)

4.4.1 Evaluates and verifies that an approved SOP for the use of high hazard chemicals is in place as a part of the committee approval process.

4.5. Research Occupational Health Program

4.5.1 Assists EHS in its review of high hazard chemicals by providing medical and technical input.

5.1 Training

5.1.1. All persons working in or supervising a research laboratory at Boston University must attend Laboratory Safety Training for Researchers annually.

5.1.2. All persons working with high hazard chemicals must be trained on the hazards and safety precautions of the high hazard chemical and the information on the Chemical information Sheet by the Principal Investigator, Laboratory Safety Coordinator, or their designee.

5.1.3. Additional training may be required, based on the results of the Chemical Use Authorization Site Assessment Visit.

5.2. Monitoring Requirements

5.2.1. EHS will periodically review campus-wide chemical inventories to determine where high hazard chemicals are in use at the University.

5.2.2. Individual laboratory’s chemical inventories, door placards and Chemical Safety Logbooks will be reviewed by EHS as part of the Quarterly Research Safety Inspection program.

6.1

This program applies to any laboratory or animal facility containing chemicals at Boston University or Boston Medical Center.

7.1 – 7.3

7.1. EHS develops Chemical Information Sheets for high hazard chemicals.

7.2. Chemical Information Sheets are reviewed and approved by the Laboratory Safety Committees on each campus.

7.3. EHS reviews chemical inventories to identify laboratories using high hazard chemicals.

7.4 – 7.6

7.4. EHS meets with the PI and/or his or her designee and performs a Chemical Use Authorization Site Assessment Visit.

7.5. EHS provides the PI with any applicable Chemical Information Sheets regarding the high hazard chemical(s) in his or her laboratory or animal facility.

7.6. EHS updates the laboratory door placards and provides any signage inside the laboratory as required by any Chemical Information Sheets that are applicable to that laboratory.

7.7 – 7.9

7.7. Based on the results of the Site Assessment Visit, EHS and the PI may determine that a High Hazard Chemical SOP is required. EHS will assist the PI in creating that SOP.

7.8. EHS reviews, edits, and circulates the SOP to appropriate parties, which may include The Research Occupational Health Program, Laboratory Safety Committee (LSC), Laboratory Animal Science Center (LASC), Institutional Animal Care and Use Committee (IACUC) and others, as necessary.

7.9. EHS approves the SOP and provides the approved copy to the PI for inclusion in the Chemical Safety Logbook.

7.10 – 7.12

7.10.The PI reviews any Chemical Information Sheets and SOPs with the personnel that work in the laboratory or animal facility.

7.11.The PI notifies EHS if there are any changes in location, personnel, or procedures that need to be updated on the SOP.

7.12. EHS periodically audits the SOP to verify that procedures are in place.

7.13

7.13. EHS maintains records of the locations where highly hazardous chemicals are used, including monitoring records from exposure assessments.

8.1 – 8.3

8.1. Chemical Information Sheet template

8.2. Chemical Use Authorization Site Assessment Visit form

8.3. High Hazard Chemical Standard Operating Procedure template

9.1 – 9.3

9.1. Chemical Information Sheets will be posted on the EHS website.

9.2. Chemical Information Sheets applicable to the laboratory will be kept in the Chemical Safety Logbook.

9.3. The original copy of the High Hazard Chemical SOP will be kept at EHS.

9.4 – 9.6

9.4. A copy of the High Hazard Chemical SOP will be kept in all laboratories and/or animal facilities where the chemical is used or stored.

9.5. Records of the locations where high hazard chemicals are used will be kept in RIMS.

9.6. Monitoring records from exposure assessments will be kept at EHS.

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