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Chemical Hygiene Plan

Last Updated: February 14, 2024 10:24:30 AM PST
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See UC San Diego's Chemical Hygiene Plan for researchers.

This Web-based Chemical Hygiene Plan and Laboratory Safety Manual must be readily available to personnel in UC San Diego facilities where hazardous chemicals are present.

PDF Be Ready for the Inspector!

UC San Diego's Chemical Hygiene Plan (CHP) provides for and supports procedures, equipment, personal protective equipment, and work practices to protect personnel from the potential health and physical hazards of laboratory work with hazardous chemicals, and complies with California Occupational Safety and Health Administration (Cal/OSHA) Occupational Exposure to Hazardous Chemicals in Laboratories, CCR Title 8, §5191.

Never work alone when hazardous chemicals are involved.

Annual review

The Chemical Hygiene Officer shall review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary.

Plan last reviewed on December 18, 2023.

Hazardous chemical definition

Hazardous chemical definition
"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 toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes.
 
Appendices A and B of the Hazard Communication Standard (CCR Title 8, §5194) provide further guidance in defining the scope of health hazards and determining whether or not a chemical is to be considered hazardous for purposes of this regulation."
– CCR Title 8, §5191
  • See the "References" and "Policy and Regulations" sections below for more guidance on determining if a chemical is hazardous or highly toxic.

Regulatory background

The Laboratory Standard

In 1990, the federal Occupational Safety and Health Administration (OSHA) released a regulation entitled Occupational Exposure to Hazardous Chemicals in Laboratories, CCR Title 8, §5191, also known as the Laboratory Standard.

California's Occupational Safety and Health Administration (Cal/OSHA), responsible for enforcing California laws and regulations pertaining to workplace safety and health, issued the state Laboratory Standard (CCR Title 8, §5191) in 1991. The Laboratory Standard recognizes the unique differences between laboratories and other workplaces that handle chemicals.

The Laboratory Standard aims to protect workers from overexposure to hazardous chemicals by ensuring they are informed about the hazards of chemicals in their workplace and are protected from chemical exposures exceeding OSHA Permissible Exposure Limits. This goal is achieved by establishing safe work practices in laboratories through the implementation of a written Chemical Hygiene Plan which details how the facility will control exposures.

The key individual in the implementation of the CHP is a Chemical Hygiene Officer (CHO). The Chemical Hygiene Officer is designated by the employer, and is qualified by training or experience to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan.

Laboratory Safety Manual and Chemical Hygiene Plan (CHP)

UC San Diego maintains a web-based Laboratory Safety Manual, which includes the Chemical Hygiene Plan, available to all laboratories in compliance with the Laboratory Standard.

The Laboratory Safety Manual and CHP must be readily available to personnel where hazardous chemicals are used.

Scope of the CHP

The Chemical Hygiene Plan applies to all laboratories that use, store, or handle potentially hazardous chemicals and all personnel who work in these facilities.

The CHP does not apply to research involving exclusively radiological or biological materials.

Research involving more than one type of hazard must comply with all applicable regulatory requirements and follow guidance outlined in the relevant safety manuals.

Content of the CHP

The CHP is a written plan that establishes safety procedures and rules for handling chemicals in the laboratory. The CHP includes guidance and requirements for the use of laboratory equipment and personal protective equipment (PPE) such as gloves, lab coats, safety eyewear, and respirators.

The CHP must also establish safe work practices, known as standard operating procedures (SOPs), for the use of hazardous chemicals in the laboratory. Chemicals that are identified as "particularly hazardous substances" will often need special stringent procedures that include a discussion of workplace control methods such as fume hoods, glove boxes, and designated work areas. Particularly hazardous substances include select carcinogens, reproductive toxins, and chemicals with a high degree of acute toxicity.

Responsibilities

It is university policy that information concerning the particular hazards which may be posed, and the methods by which workers can use these materials in a safe and healthful manner, be available to all faculty, staff, and students who use hazardous chemicals in the workplace.

Designation of responsibility for implementing UC San Diego's Chemical Hygiene Plan:

  • The Chemical Safety & Surveillance Committee (CSSC) oversees use of chemical agents in facilities. CSSC activities are guided by university policy, national guidelines, industry standards, and federal, state, and county regulations.
  • Principal investigators (PIs) /lab supervisors are responsible for implementing the health, safety, and environmental management policies and practices described in the online Chemical Hygiene Plan and Laboratory Safety Manual, and within the Administrative Responsibilities Handbook, as the program relates to operations under their control.

    The online Hazard Control Plan Application (HCP) provides PIs with a documented method for managing and training employees to work safely with hazardous chemicals and processes.
  • The Director of Environment, Health & Safety (EH&S) is the cognizant administrator of health, safety, and environmental protection programs.
  • Individuals working with hazardous chemicals are responsible and accountable for ensuring activities are performed safely and in accordance with current policies and guidelines.

Safety training

Laboratory personnel are to receive chemical safety information and training, both general and laboratory-specific, at these times:

  • During new employee orientation Before beginning work involving hazardous chemicals and/or hazardous operations
  • NOTE: New employees must complete two safety training courses before beginning work in a university laboratory: 
    • 1) UC Laboratory Safety Fundamentals
    • 2) Annual Laboratory Hazards Training
  • When major aspects of the job change or new materials or procedures are introduced
Related links:

Exposure control practices

Traditional hierarchy of exposure control practices, NIOSHLimiting exposure at the source is the preferred way to protect workers from chemical hazards. Performing a risk assessment prior to the use of any hazardous material is essential to ensure the safe and effective use of hazardous chemicals.

The risk assessment strategy described below manages risk in a logical manner. It is the same strategy used by the National Institute for Occupational Safety and Health (NIOSH) to manage workplace risk.

Initial management focuses on removing the risk by changing the process through elimination, substitution, modification, containment, engineering controls, work practices, and then — as a last resort — personal protective equipment when nothing else can be done to manage the risk.

Use this strategy for all chemical hazards.

The traditional hierarchy of exposure control practices used to minimize exposures include:

  • Administrative controls – Administrative controls are changes in work procedures with the goal of reducing the duration, frequency, and severity of exposure. Examples of administrative controls are:
    • Elimination – Eliminate the hazard whenever possible to eliminate the risk.
    • Substitution – Use less dangerous, more stable chemicals when possible.
    • Modification – Before conducting the actual procedure, always perform a dry run to identify and resolve possible safety hazards. Modify the process to reduce risk.
    • Work practices – Follow standard operating procedures established for the materials and processes used in your lab. Never work alone.
    • Segregation – Establish a designated, restricted access work area.
  • Engineering controls – Engineering controls remove a hazard or place a barrier between the employee and the hazard.
    • Building ventilation – Building ventilation provides laboratories with at least 6 air changes per hour (ACH) of fresh (outside) air. This airflow reduces employee exposure to airborne contaminants and removes excess heat. It also directs the airflow from areas of lower hazard to areas of higher hazard, helping to keep odors and hazardous gases, dusts, and vapors out of hallways and other public areas.
    • Chemical fume hoods – When used properly, chemical fume hoods are one of the most reliable engineering controls in the laboratory.
    • Biosafety cabinets – Biosafety cabinets (BSC) use HEPA filters to protect lab workers and the environment from aerosols or droplets that could spread biohazardous material. BSCs look similar to chemical fume hoods and "clean benches." If you work with biohazard materials, make sure you're using a biosafety cabinet.
    • Other containment – Glove boxes, gas cabinets, and other containment devices isolate the source of exposure.
  • Work practices – Decontaminate area and/or equipment after each use.
  • Additional protections – PIs/lab supervisors are responsible for providing additional protection to lab personnel for work with particularly hazardous substances (i.e., carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity).

General chemical safety guidelines

Maintain an organized and orderly facility

  • Work area:
    • Keep the work area clean and uncluttered.
    • Never play practical jokes or engage in horseplay.
    • Always use adequate safety measures and never leave the following unattended:
      • Ongoing chemical reactions in laboratories
      • Exposed sharps (needles, razor blades, etc.)
      • Energized electrical, mechanical, or heating equipment
  • Chemical storage and inventory:
    • Follow chemical storage and compatibility guidelines.
    • Maintain lean, well-managed chemical inventories to avoid fire code violations and subsequent inventory reduction measures.
  • Corridors:

Communicate hazards to everyone in the facility

  • Post:
    • Warning signs near any dangerous equipment, reactions, or conditions
    • A list of chemical abbreviations (PDF) (Word) used on chemical container labels (including hazardous waste) near the lab entrance
    • Personal protective equipment requirements for entering the facility, if applicable
  • Label all containers.
  • Keep containers closed except when in use, including hazardous waste containers.

Follow basic safety procedures

  • Evaluate the hazards:
    • Read the Safety Data Sheet (formerly called Material Safety Data Sheets) before beginning work with a chemical.
    • Follow hazard control plans for extremely hazardous materials.
  • Never underestimate risk.
    • Do not pipette by mouth.
    • Never smell chemicals to identify them.
    • Assume that:
      • Any mixture will be more hazardous than its most toxic component
      • All substances of unknown toxicity are highly toxic
  • Be aware of electrical hazards.
    • Keep electrical panels clearly visible and unobstructed.
    • Know how your circuits are labeled so equipment can be de-energized quickly in an emergency.
    • Never use extension cords as permanent wiring. Unplug them at the end of the workday.
    • Mount multi-plug adaptors a few inches off the floor to avoid possible water damage.
    • Never use multi-plug adaptors in series.
    • Replace any damaged or frayed electrical cords immediately.
  • Do not eat, drink, store food, smoke, or apply cosmetics in areas where chemicals are in use except in clearly marked Clean Areas. Wash your hands frequently and before eating.
  • Keep loose hair tied back.

Use engineering controls

Building vacuum system alert

Vacuum Trapping

When using a vacuum source, it is important to place a trap between the experimental apparatus and the vacuum source. The vacuum trap

  • protects the pump and the piping from the potentially damaging effects of the material
  • protects people who must work on the vacuum lines or system, and
  • prevents vapors and related odors from being emitted back into the laboratory or system exhaust.

There have been incidents at UC San Diego where improper trapping caused serious failure of the building (central) vacuum pump system and in one case in 2009 the explosion was so severe that the pump was completely destroyed leaving the vacuum system in disrepair for months. Luckily no one was injured.  

Proper Trapping Techniques 
To prevent contamination, all lines leading from the experimental apparatus to the vacuum source should be equipped with filtration or other trapping as appropriate: 

  • For particulates, use filtration capable of efficiently trapping the particles in the size range being generated
  • For most aqueous or non-volatile liquids, a filter flask at room temperature is adequate to prevent liquids from getting to the vacuum source.
  • For solvents and other volatile liquids, use a cold trap of sufficient size and cold enough to condense vapors generated, followed by a filter flask capable of collecting fluid that could be aspirated out of the cold trap.
  • For highly reactive, corrosive or toxic gases, use a sorbent canister or scrubbing device capable of trapping the gas. Do not use the building (central) vacuum pump system for these chemicals. Use a dedicated self-contained lab vacuum pump for this purpose.

Filters must be replaced as needed—at a minimum, every 90 days and when there is any evidence of deficiencies (e.g., filter blockage, failure, wetness). When changing out filters, dispose of them as hazardous chemical waste.

Cold Traps 
For most volatile liquids, a cold trap using a slush of dry ice and either isopropanol or ethanol is sufficient (to -78 deg. C). Avoid using acetone. Ethanol and isopropanol are cheaper and less likely to foam.

Liquid nitrogen may only be used with sealed or evacuated equipment, and then only with extreme caution. If the system is opened while the cooling bath is still in contact with the trap, oxygen may condense from the atmosphere and react vigorously with any organic material present.

Use PPE as needed or required

Learn how to use Hazard Control Plans (HCPs)

Hazard Control Plans (HCPs) are required for work with hazardous chemicals. UC San Diego requires investigators to log in to create Hazard Control Plans for work with hazardous chemicals and processes. At UC San Diego, an HCP is a standard operating procedure.

Prepare for accidents and emergencies

Follow basic emergency preparedness best practices:

Emergency override button

Emergency override buttons (EOBs)

Some laboratories have emergency override buttons (see image at right) installed to provide maximum room ventilation in the event of a chemical emergency that impacts laboratory air.

Activate this button only if you feel laboratory air has been impacted by a chemical emergency.

To activate:

  • Open the clear cover and push where it says PUSH HERE. Once activated, room air supply and exhaust will be ramped up to maximum capacity to ventilate the space.
  • Evacuate all personnel from the space immediately. Stay out until the room is cleared for reentry.

When the button is pushed, Police and Environment, Health & Safety (EH&S) will be contacted to investigate. To ensure rapid response:

  • Contact Police after activating the EOB: Call 9-1-1 from campus phones.
  • Provide the police with any useful information.

When the issue has been resolved, the EOB will be deactivated by authorized personnel and the space will be declared safe for reentry.

First aid kits and Emergency Guides

First-aid kits and Emergency Guides are provided by EH&S in work areas using hazardous materials or generating hazardous waste.

  • The department representative, typically your Area Safety Coordinator, is responsible for monitoring first aid supplies and expiration dates.
  • Contact EH&S, if they are missing, damaged, or to request replacement supplies for EH&S-provided first aid kits.

Dispose of chemical waste according to guidelines

Read these articles to help you identify and dispose of hazardous waste:

Standard operating procedure (SOP) / Hazard Control Plan (HCP)

Requirements

The Laboratory Standard, under the provisions of the Chemical Hygiene Plan, requires standard operating procedures (SOPs) be established for work with hazardous chemicals:

"Standard operating procedures relevant to safety and health considerations must be followed when laboratory work involves the use of hazardous chemicals.”

PI Responsibility

Principal investigators/lab supervisors are responsible for establishing standard operating procedures relevant to health and safety for laboratory activities involving hazardous materials under their direction.

Hazard Control Plans

UC San Diego requires investigators who work with hazardous chemicals must create Hazard Control Plans (HCPs). At UC San Diego, a Hazard Control Plan is a standard operating procedure.

This web-based tool is provisioned with Hazard Control Plans approved by the Chemical & Safety Surveillance Committee (CSSC) for work with hazardous chemicals.

At UC San Diego, a Hazard Control Plan (HCP) is a standard operating procedure and can be found within the MyReseachSafety HCP app. Paper copies of in-house SOPs are acceptable IF they meet the same standard of an HCP. This is a Web-based tool provisioned with Hazard Control Plans approved by the Chemical & Safety Surveillance Committee (CSSC) for work with hazardous chemicals. Hazard Control Plans (HCPs) are written instructions that detail the requirements for working with hazardous chemicals and/or processes. HCPs come in two groups:

  • CSSC approved Hazard Control Plan – Required for high hazard chemicals.
    • Chemical agents identified as high-hazard or inordinate risk by the CSSC are listed here.
  • EH&S reviewed Hazard Control Plan – Use for all other hazardous chemicals. These are standard Hazard Control Plans for chemicals grouped by hazard classification such as carcinogens or pyrophorics.

HCPs must be developed, reviewed, approved, and confirmed before using chemicals. At a minimum, an HCP must be developed for any substance that is identified by the Chemical Evaluator tool in the MyReseachSafety HCP app.

For help in drafting your Hazard Control Plans, please review the Hazard Control Plan Resources page.

An HCP is considered complete ONLY after the following has been done:

  • The ‘Summary’ section and ‘Lab Specific Instructions’ sections have been completed.
  • All lab personnel have been assigned to all HCPs relevant to their activities in the laboratory before they can work with the materials or process that involves that material.
  • The Supervisor / Principal Investigator (PI) must approve (submit) the HCP before beginning work with any chemicals, and whenever hazards change. Only the PI can submit an HCP.
  • Laboratory Personnel must confirm their assignment to an HCP before beginning work with any chemicals.
  • HCPs have been updated as processes/procedures change. They must be current, and reflect laboratory practices.

Particularly hazardous substances

Particularly hazardous substances include (but is not limited to) select carcinogens, reproductive toxins, and substances which have a high degree of acute toxicity.

Provisions for additional employee protection are required for work with particularly hazardous substances.

Important – For all work with particularly hazardous substances, the PI / lab supervisor must log in to the Hazard Control Plan (HCP) to complete an appropriate Hazard Control Plan, including:

Provisions for additional employee protection for work with particularly hazardous substances. These include "select carcinogens," reproductive toxins and substances which have a high degree of acute toxicity. Specific consideration shall be given to the following provisions which shall be included where appropriate; 

  1. Establishment of a designated area;
  2. Use of containment devices such as fume hoods or glove boxes;
  3. Procedures for safe removal of contaminated waste; and
  4. Decontamination procedures."

Resources for developing SOPs and Hazard Control Plans:

"Tag out" chemicals that are not in use

Tag out chemicals to keep them in inventory for future use without having to write an SOP/Hazard Control Plan by attaching an SOP Required sticker to the container.

The SOP Required sticker signifies the chemical is "tagged out" and may not be used by anyone until these conditions are met:

  1. An SOP/Hazard Control Plan has been generated
  2. Research staff have been assigned to the SOP/Hazard Control Plan
  3. All individuals comply with and sign off on all aspects of the SOP/Hazard Control Plan prior to its use
  4. The PI approves and signs the SOP/Hazard Control Plan

Contact the Research Assistance Program specialist assigned to your area to request a supply of "SOP Required" stickers.

Prior approval and consultation

Circumstances requiring prior approval from the PI

Whenever there is a significant change in chemical amounts, chemical functionality, the introduction of new equipment, new chemicals, a new procedure, or a new workspace, PI approval must be given prior to startup to determine that conditions now exist to protect the worker.

Prior approval is an important aspect to the overall safety of the lab that:

  • Allows for thorough communication between the PI and research staff
  • Ensures safety precautions are reviewed and upgraded where appropriate
  • Accounts for and addresses possible changes

Safety considerations

Include in your safety considerations the inherent hazards of experimental design, equipment design, materials, scaling up quantities, workspace, development of Hazard Control Plans/SOPs, and worker preparedness and experience.

Be alert for any project involving:

  • Particularly hazardous substances (see below)
  • Unattended operations
  • High-risk activities
  • Scaling up the amounts
  • Unique chemical properties

Work with particularly hazardous substances

Particularly hazardous substances include (but are not limited to) select carcinogens, reproductive toxins, and substances which have a high degree of acute toxicity.

For all work with particularly hazardous substances, PIs must complete the appropriate Hazard Control Plan.

  • Carcinogens
  • Reproductive hazards
  • Acutely toxic materials
Related links:

Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

GHS-compliant labels that include a harmonized signal word, pictogram, and hazard and precaution statements for each hazard class and category will begin to appear in our chemical inventories soon.

Background

The Globally Harmonized System of Classification and Labeling of Chemicals, or GHS, is an international system of chemical classification, labeling, and hazard communication adopted by the United Nations in 2003. The United States participated in the development of the GHS and U.S. regulatory agencies are adopting the system. It is a logical and comprehensive approach to:

  • Defining health, physical, and environmental hazards of chemicals;
  • Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
  • Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels, and Safety Data Sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities. This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United States, there are requirements for the classification and labeling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration.

The GHS itself is not a regulation or a standard. The United Nations GHS Document is intended to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate.

Regulatory authorities in countries adopting the GHS (including the U.S.) will take the agreed criteria and provisions and implement them through their own regulatory process and procedures rather than simply incorporating the text of the GHS into their national requirements. The GHS Document thus provides countries with the regulatory building blocks to develop or modify existing national programs that address the classification of hazards and transmittal of information about those hazards and associated protective measures. This helps to ensure the safe use of chemicals as they move through the product life cycle from "cradle to grave."

Related links:
  • HAZCOM 2012 (Video), Yale Environmental Health & Safety Online Training

Safety Data Sheets (SDS)

A Safety Data Sheet (formerly called Material Safety Data Sheet) is a detailed informational document prepared by the manufacturer or importer of a hazardous chemical. It describes the physical and chemical properties of the product. SDS’s contain useful information such as toxicity, flash point, procedures for spills and leaks, storage guidelines, and exposure control.

SDS resources:

Related links:

Hazardous chemical inventory

University laboratories, departments, and shops are required to maintain an inventory of hazardous substances present in their areas.

Principal investigators, authorized lab contacts, and Department Safety Officers (DSOs) may use the My Research Safety Web portal to view and export inventory data for chemicals, radioisotopes, and controlled substances in areas under their responsibility.

Related links:

Medical consultation, surveillance, and exams

Employees who work with hazardous chemicals have an opportunity to receive medical attention under the following circumstances:

  • When an employee develops signs or symptoms that may be related to the use of hazardous chemicals
  • Where exposure monitoring reveals exposures above an action level or permissible exposure limit for an OSHA regulated substance for which exposure monitoring and medical surveillance is required
  • Whenever an event takes place in the work area resulting in the likelihood of hazardous exposure, a consultation determines the need for a medical exam

How to get a medical consultation

All medical exams and consultations must be performed under the direct supervision of a licensed physician and provided at no cost to the employee, without loss of pay, and at a reasonable time and place.

The employer must provide this information to the physician:

  • Identity of the material with which the employee may have been exposed
  • Description of the conditions under which the exposure occurred
  • Description of the signs and symptoms

The employee must obtain a written opinion from the physician including the following:

  1. Recommendations for follow up
  2. Results of the exam and associated tests
  3. Any medical condition revealed which may place the employee at increased risk as a result of the exposure
  4. A statement that the employee has been informed by the physician of the results
    • Note: The written opinion must not reveal specifics of diagnoses unrelated to the exposure.
Related links:

Emergency procedures

Report work-related injuries and illness

Report work-related injury or illness immediately.

Important – Chemistry / Biochemistry personnel must:

  • Report serious incidents immediately: Call 9-1-1
  • Immediately secure any incident scene from all access and preserve all evidence for no less than 24 hours.
Related links:

Resources

Flash chromatography

UC San Diego researchers using flash chromatography should use the Flash Chromatography Hazard Control Plan (HCP). This HCP must be preapproved by the principal investigator prior to beginning any work with flash chromatography.

Solvent Purification Systems

 UC San Diego researchers using solvent purification systems should use the Solvent Purification Systems Hazard Control Plan (HCP). This HCP must be preapproved by the principal investigator prior to beginning any work with solvent purification systems.

 Spill response

Waste streams

References

UC Los Angeles Chemical Hygiene Plan

Policy and regulations

State of California

Federal

University of California

County of San Diego

Questions? Contact the EH&S Chemical Hygiene Officer.
Note: This page has a friendly link that's easy to remember: http://blink.ucsd.edu/go/chp