Creating Your Chemical Hygiene Plan
A chemical hygiene plan (CHP) is a written program stating the policies, procedures, and responsibilities that serve to protect employees from the health hazards associated with the hazardous chemicals used in that particular workplace.
- OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Title 29, Code of Federal Regulations, Part 1910.1450, specifies the mandatory requirements of a CHP to protect persons from harm due to hazardous chemicals). The Standard can be viewed on the OSHA Web site at www.osha.gov.
- It applies to school employees who work in laboratory settings (i.e., science teachers and lab assistants); indirectly it may serve to protect students.
- The school superintendent, science department chairperson, and/or chemistry teacher(s) are typically responsible for developing the CHP for the school.
- Appendix A of 29 Code of Federal Regulations 1910.1450 provides non-mandatory recommendations to assist in the development of a CHP.
Chemical Hygiene Plan Required Elements
- Defined standard operating procedures relevant to safety and health considerations for each activity involving the use of hazardous chemicals.
- Criteria to use to determine and implement control measures to reduce exposure to hazardous materials (i.e., engineering controls, the use of personal protective equipment, administrative controls, and hygiene practices) with particular attention given to the selection of control measures for extremely hazardous materials.
- A requirement to ensure laboratory chemical hoods and other protective equipment are installed and functioning properly. Information for persons working with hazardous substances specifying the hazards of the chemicals in the work area, the location of the CHP, signs and symptoms associated with hazardous chemical exposures, the permissible or recommended exposure limits of the chemicals, and the location and availability of information on the hazards, safe handling, storage, and disposal of hazardous chemicals [not limited to Safety Data Sheets (SDSs)].
- Training for persons working with hazardous substances that includes methods and observations to detect the presence or release of a hazardous chemical, the physical and health hazards of the chemicals used, the measures to be taken to protect against these hazards (i.e., personal protective equipment, appropriate work practices, emergency response actions), and applicable details of the CHP.
- The circumstances under which a particular laboratory operation or procedure requires prior approval from the appropriate administrator. Requirements for medical consultation and medical examination whenever (1) a person develops signs or symptoms associated with a hazardous chemical, (2) exposure monitoring reveals an exposure level routinely above the action level, or (3) an event takes place in the work area such as a spill, leak, explosion or other occurrence resulting in the likelihood of a hazardous exposure.
- Designation of personnel responsible for the implementation of the CHP, including the assignment of a Chemical Hygiene Officer.
- Requirements for additional protection when working with particularly hazardous substances including "select carcinogens," reproductive toxins, and substances with a high degree of acute toxicity.
- Provisions for yearly re-evaluation of the CHP.
Other Suggested Elements of a Chemical Hygiene Plan
- Hazard identification including proper labeling of containers of hazardous chemicals and maintaining SDSs in a readily accessible location.
- Requirements to establish and maintain accurate records monitoring employee exposures and any medical consultation and/or examinations, and to assure the confidentiality of these records.
For additional information on developing a CHP consult the following sources:
- Handbook of Chemical Health and Safety (ACS Handbooks) by Robert J Alaimo (2001)
- Prudent Practices in the Laboratory: Handling and Disposal of Chemicals by The National Research Council (1995)
This information is from the School Chemistry Laboratory Safety Guide created by the U.S. Consumer Safety Product Commission (CPSC), Department of Health and Human Services, Centers for Disease Control and Prevention (CDC), and the National Institute for Occupational Safety and Health (NIOSH).
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