Even if you use only a small amount of chemicals in your laboratory it’s important that you store them properly. Not only is it common sense for your safety and for the safety of those working in your lab, but many labs are required to meet federal guidelines for their chemical storage. Failing to meet these guidelines could have serious repercussions for your organization regarding certifications, inspections, or legal liability if a chemical related injury should occur.
- Relevant Codes
The applicable code regarding chemical storage is the U.S. Office of Safety & Health Administration (OSHA) Standards -29 CFR 1910.1450 Subpart Z. This standard is most commonly referred to as “The Laboratory Standard.” The following information in this article will highlight many of the items in the standard but if you want the complete text you can consult the Code of Federal Regulations. The information concerning laboratory chemical storage is found in Part 1910 of Title 29 (cited as 29CFR 1910) section 1450 of subpart Z, “Occupational Exposure to Hazardous Chemicals in Laboratories.”
Who does the code apply to?
The OSHA Lab Standard does not apply to all laboratories, but where it does apply, it must be implemented. If your laboratory meets any of the following four criteria you are subject to the laboratory standard.
- Chemical manipulations are carried out on a laboratory scale. That is, the work with chemicals is in containers of a size that could easily and safely be manipulated by one person.
- Multiple chemical procedures or chemicals are used.
- Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
- The procedures involved are not part of a production process whose function is t produce commercial quantities of materials, not do the procedures in any way simulate a production process.
The fourth criterion would normally exclude quality control laboratories in industrial operations because they “are usually adjuncts of production operations that typically perform repetitive procedures for the purpose of monitoring a product or process.”
This criterion also would normally exclude pilot plant operations, which are typically closely connected with production processes. However, if pilot plant operations are an integral part of a research function for the purpose of evaluating a particular effect (for example “the operations do not proceed to production but remain part of the research activity”) then that pilot plant operation may be subject to the standard.
The Chemical Hygiene Plan
If your lab is subject to the standard, the first requirement is for your organization to develop a chemical hygiene plan. This plan is more than just a procedure for chemical storage. In fact, chemical storage is just one part of the plan. The Chemical Hygiene Plan is actually a safety manual based on OSHA requirements for laboratories. Fortunately, the safety manual/plan you’re currently using probably already incorporates most of what OSHA requires. You can compare the items listed below with your existing procedures to see they match. If they do then you’re well on your way to creating your required Chemical Hygiene Plan. If not, incorporating the items listed below will bring you closer to compliance.
It’s a good idea to put the plan into manual form. This way you can easily refer to it as well as use it for instructing new personnel. It also makes it easier to copy and distribute to other people in the lab.
Since The Chemical Hygiene Plan is the first step in proper chemical storage, the remainder of this article will highlight the basic items that should be included. More specific chemical storage information is covered in Introduction to Laboratory Chemical Storage Part 2.
Components of the Chemical Hygiene Plan
- Basic Rules and Procedures (See 29CFR 1910.1450 for full listing.)
- Avoidance of “routine” exposure: Develop and encourage safe habits; avoid unnecessary exposure to chemicals by any route.
- Do not smell or taste chemicals. Vent apparatus which may discharge toxic chemicals into local exhaust devices.
- Eating, smoking, etc.: Avoid eating, drinking, smoking, gum chewing, or application of cosmetics in areas where laboratory chemicals are present; wash hands before conducting these activities.
- Use of hood: use the hood for operations which might result in release of toxic chemical vapors or dust.
- Confirm adequate hood performance before use; keep hood closed at all items except when adjustments within the hood are being made; keep materials store din hoods to a minimum and do not allow them to block vents or air flow.
- Leave the hood “on” when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is “off”.
- Always use a hood previously evaluated to confirm adequate performance with a face velocity of at least 100 linear feet per minute.
- Chemical Procurement, Distribution, and Storage
- Procurement. Before a substance is received, information on proper handling, storage, and disposal should be known to those who will be involved. No container should be accepted without an adequate identifying label. Preferably, all substances should be received in a central location.
- Stockroom/storerooms. Toxic substances should be segregated in a well identified area under local exhaust ventilation. Chemicals which are highly toxic or other chemicals whose containers have been opened should be in unbreakable secondary containers. Stored chemicals should be examined periodically (at least annually) for replacement, deterioration, and container integrity. Stockroom/storerooms should not be used as preparation or repackaging areas. They should only be open during normal working hours and should be controlled by one person.
- Distribution. When chemicals are hand carried, the container should be placed in an outside container or bucket. Freight only elevators should be used if possible.
- Laboratory storage. Amounts permitted should be as small as practical. Storage on bench tops and in hoods is inadvisable. Exposure to heat or direct sunlight should be avoided. Periodic inventories should be conducted, with needed items being discarded or returned to the storeroom/stockroom.
- Environmental Monitoring
Regular instrumental monitoring of airborne concentrations is not usually justified or practical in laboratories but may be appropriate when testing or redesigning hoods or other ventilation devices or when a highly toxic substance is stored or used regularly.
- Housekeeping, Maintenance, and Inspections
- Cleaning. Floors should be cleaned regularly.
- Inspections. Formal housekeeping and chemical hygiene inspections should be held at least quarterly for units which have frequent personnel changes and semiannually for others; informal inspections should be continual.
- Maintenance. Each wash fountain should be inspected at intervals of not less than 3 months. Respirators for routing use should be inspected periodically by the laboratory supervisor. Other safety equipment should be inspected regularly (Every 3-6 months.)
- Passageways. Stairways and hallways should not be used as storage areas. Access to exits, emergency equipment, and utility controls should never be blocked.
- Medical Program
- Compliance with regulations. Regular medical surveillance should be established to the extent required by regulations.
- Routine surveillance. Anyone whose work involves regular and frequent handling of toxicologically significant quantities of a chemical should consult a qualified physician to determine on an individual basis whether a regular schedule or medical surveillance is desirable.
- First aid. Personnel trained in first aid should be available during working hours and an emergency room with medical personnel should be nearby.
- Protective Apparel and Equipment
These should be included in each laboratory:
- Protective apparel compatible with the required degree of protection for substances being handled.
- An easily accessible drench-type safety shower.
- An eyewash fountain.
- A fire extinguisher.
- Respiratory protection, fire alarm and telephone for emergency use should be available nearby; and other items designated by the laboratory supervisor.
- Accident records should be written and retained.
- Chemical hygiene plan records should document that the facilities and precautions were compatible with current knowledge and regulations.
- Medical records should be retained by the institution in accordance with the requirements of state and federal regulations.
- Signs and Labels
Prominent signs and labels of the following types should be posted.
- Emergency telephone number of emergency personnel/facilities, supervisors, and laboratory workers.
- Identify labels, showing contents of containers (including waste receptacles) and associated hazards.
- Location signs for safety showers, eyewash stations, other safety and first aid equipment, exits, areas where food and beverage consumption and storage are permitted.
- Warnings at areas or equipment where special or unusual hazards exist.
- Spills and Accidents
- A written emergency plan should be established and communicated to all personnel; it should include procedures for ventilation failure, evacuation, medical care, reporting and drills.
- There should be an alarm system to alert people in all parts of the facility including isolation areas such as cold rooms.
- A spill control policy should be developed and should include consideration of prevention, containment, cleanup and reporting.
- All accidents or near accidents should be carefully analyzed with the results distributed to all who might benefit.
- Information and Training Program
- Aim: to assure that all individual at risk are adequately informed about the work in the laboratory, its risks, and what to do if an accident occurs.
- Emergency and Personal Protection Training; every laboratory worker should know the location and proper use of available protective apparel and equipment.
- Waste Disposal Program
- Aim: To assure that minimal harm to people, other organisms, and the environment will result from the disposal of waste laboratory chemicals.
- Content: The waste disposal program should specify how waste is to be collected, segregated, stored, and transported and include considerations of what materials can be incinerated. Transport from the institution must be in accordance with DOT regulations.
- Discarding chemical stocks: Unlabeled containers of chemicals and solutions should undergo prompt disposal; if partially used, they should not be opened.
- Frequency of Disposal: Waste should be removed from the laboratories to a central waste area at least once per week and from the central waste storage area at regular intervals.
- Method of disposal: Incineration in an environmentally acceptable manner is the most practical disposal method of combustible laboratory waste. Indiscriminate disposal by pouring waste chemicals down the drain or adding them to mixed refuse for landfill burial is unacceptable. Disposal by recycling or chemical decontamination should be used when possible.
Many laboratories are required to meet OSHA standards for chemical storage. For those labs that must be compliant, the first step is to develop a chemical hygiene plan. Your lab’s chemical hygiene plan should address the following:
- Basic rules and procedures.
- Chemical procurement, distribution and storage.
- Environmental Monitoring.
- Housekeeping, Maintenance and Inspections.
- Medical Program.
- Protective Apparel and Equipment.
- Signs and Labels.
- Spills and Accidents.
- Information and Training Program.
- Waste Disposal Program.
If you have any questions feel free to give me, Bruce Ciloski, a call. You can reach me at 832.256.0014 or email me at firstname.lastname@example.org.