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Chemical Hygiene Plan, Chapter 1 : Introduction, Purpose, Scope, Regulatory Requirements, Rights and Responsibilities

Purpose

UCLA strives to provide a healthy and safe working environment for the campus community, free from recognized hazards in accordance with UCLA Policy 811. The Chemical Hygiene Plan (CHP) establishes a formal written program for protecting laboratory personnel against adverse health and safety hazards associated with exposure to potentially hazardous chemicals and is available to all employees working with hazardous chemicals. The CHP describes the proper use and handling practices and procedures to be followed by faculty, staff, students, visiting scholars, volunteers, and all other personnel working with potentially hazardous chemicals in laboratory settings. This plan is based on best practices identified in, among others sources, “Prudent Practices for Handling Hazardous Chemicals in Laboratories ,” published by the National Research Council and the American Chemical Society’s “Safety in Academic Chemistry Laboratories.” 

Scope

The CHP applies to all laboratories that use, store or handle potentially hazardous chemicals and all personnel who work in these facilities.  It does not apply to research involving exclusively radiological or biological materials, which are covered by safety procedures and outlined in the Radiation Safety Manual and the Institutional Biosafety Plan, respectively.  Research involving more than one type of hazard must comply with all applicable regulatory requirements and follow guidance outlined in the relevant safety manuals. Additional oversight may be required based on the work being done.

The information presented in the CHP represents best practices and provides a broad overview of the information necessary for the safe operation of laboratories that utilize potentially hazardous chemicals. It is not intended to be all inclusive.  Departments, divisions or other work units engaged in work with hazardous chemicals that have unusual characteristics not explicitly covered in this CHP, must customize the document by adding additional sections addressing the hazards and how to mitigate their risks, as appropriate. Such customizations must receive prior approval from the PI/Laboratory Supervisor and/or the UCLA Office of Environment, Health and Safety (EH&S). See Policy 907 – Safe Handling of Particularly Hazardous Substances or additional information on substances that may trigger these additions.  For information on specific chemical safety topics not covered in the CHP, please contact EH&S at 310-206-3661 or laboratorysafety@ehs.ucla.edu.
 

Regulatory Requirements

Implementation of the necessary work practices, procedures, and policies outlined in this CHP is required by the following:  

These regulations require that the CHP be readily available wherever potentially hazardous chemicals are used, handled, or stored.  EH&S will review and evaluate the effectiveness of this Plan at least annually and update it as necessary.
 

Rights and Responsibilities

Employees and other personnel who work in laboratories have the right to be informed about the potential hazards of the chemicals in their work areas and to be properly trained to work safely with these substances.  This includes custodial staff and other personnel who work to clean and maintain laboratories.  Employees have the right to file a complaint with Cal/OSHA if they feel they are being exposed to unsafe or unhealthy work conditions and cannot be discharged, suspended, or otherwise disciplined by their employer for filing a complaint or exercising these rights. All personnel working with potentially hazardous chemicals are encouraged to report (anonymously, if preferred) any concerns about unsafe work conditions to the EH&S Hotline at 310-825-9797.

Responsibility for the health and safety of the campus community extends to all levels of UCLA.  The Chancellor and Vice Chancellors are responsible for the implementation of UCLA’s Environmental Health and Safety Policy (811) at all facilities and properties under campus control.  The Chemical and Physical Safety Committee (CPSC) is a faculty led committee that advises the Vice Chancellor of Research and Creative Activities regarding compliance with safety related policies. Deans and Department Heads are responsible for establishing and maintaining programs in their areas and for providing a safe and healthy work environment.

While the Chancellor, Vice Chancellors, Deans and Department Heads are responsible for the broad implementation and enforcement of Policy 811, the day-to-day responsibility for the management of laboratory safety and adherence to safe laboratory practices rests with the PI/Laboratory Supervisor within individual laboratory units and associated departments.  

All personnel, including PIs/Laboratory Supervisors, employees, and students, have a duty to fulfill their obligations with respect to maintaining a safe work environment.  

All employees and other personnel working with potentially hazardous chemicals have the responsibility to conscientiously participate in training seminars on general laboratory safety, review and be familiar with the contents of the CHP and other policies and procedures relevant to their workplace. Those working with chemicals are responsible for staying informed about the chemicals in their work areas, safe work practices and proper personal protective equipment (PPE) required for the safe performance of their job.  Failure to comply with these requirements will result in progressive disciplinary action in accordance with University policy (see Chapter 7), and may result in temporary suspension of laboratory activities until corrective action is implemented.   
 

The PI/Laboratory Supervisor has responsibility for the health and safety of all personnel using their laboratory who may be exposed to hazardous chemicals. The PI/Laboratory Supervisor may delegate safety duties, but remains responsible for ensuring that delegated safety duties are performed. The PI/Laboratory Supervisor is responsible for: 

1. Knowing all applicable health and safety rules and regulations, training and reporting requirements and standard operating procedures associated  with chemical safety for regulated substances.

2. Identifying hazardous conditions or operations in the laboratory or other facility containing hazardous chemicals and determining safe procedures and controls, and implementing and enforcing standard safety procedures.

3. Ensuring that standard safety operating procedures (general and protocol specific) are implemented.

4. Providing prior-approval for the use of hazardous chemicals in the PI’s laboratory or other facility with hazardous chemicals.

5. Consulting with EH&S and/or Departmental Safety Committee on use of higher risk materials, such as use of particularly hazardous substances, as defined by UCLA Policy 907  or conducting higher risk experimental procedures, so that, special safety precautions are taken.

6. Identifying whether anyone participating in research in their laboratory is an undergraduate researcher, as defined by UCLA Policy 906, and ensuring that their research complies with all applicable safety requirements and prohibitions.

7. Identifying whether anyone participating in research in their laboratory is a minor, and ensuring that their research activities comply with the UC Policy on Minors in Laboratories and Shops.

8. Maintaining an up-to-date and accurate chemical and compressed gas inventory for the laboratory or facility in RSS Chemicals.

9. Ensuring laboratory or other personnel under their supervision have access to and are familiar with the appropriate Safety Manual(s).

10. Training all laboratory supervisees to work safely with hazardous materials and maintaining written records of laboratory-specific or other specialized training in the appropriate Safety Manual(s). Electronic records of training are encouraged. Training must include information of the location and availability of hazard information (see Chapter 2).

11. Ensuring lab members have a way to contact emergency services and know how to do so.

12. Promptly notifying EH&S (310-825-9797) and/or Facilities Trouble Call (310-825-9236) upon becoming aware that workplace engineering controls (e.g., fume hoods, snorkel hoods) and safety equipment (e.g., emergency showers/eyewashes, fire extinguishers, etc.) are non-operational.

13. Ensuring all appropriate personal protective equipment (PPE) (e.g., laboratory coats, gloves, eye protection, etc.) is available in the laboratory, is used appropriately by researchers, and is maintained in good condition.

14. Conducting periodic self-inspections of laboratory or facility and maintaining records of inspections, as required.

15. Promptly reporting accidents and injuries to EH&S. All explosions, unintended fires, or uses of a fire extinguisher must be reported by calling 911. Serious injuries must be reported to EH&S (310-825-9797) immediately to allow for compliance with CAL/OSHA’s requirement for reporting injuries to it within 8-hours. Refer to 123 Poster for guidance on what types of injuries trigger this obligation. Any doubt as to whether an injury is serious should be resolved by reporting it.

16. Providing funding for medical surveillance and/or medical consultation and examination for laboratory and other personnel, as required.

17. Informing facilities personnel, other non-laboratory personnel, and any outside contractors of potential laboratory-related hazards when they are required to work in the laboratory environment.

18. Identifying and minimizing potential risks to provide a safe environment for repairs and renovations.

All personnel in research or teaching laboratories that use or store potentially hazardous chemicals are responsible for:

1. Reviewing and following the CHP and all appropriate safety manuals and policies.

2. Following all verbal and written laboratory safety rules, regulations, and standard operating procedures required for the tasks assigned.

3. Developing good personal chemical hygiene habits, including but not limited to, keeping the work areas safe and uncluttered (i.e., good housekeeping practices).

4. Planning, reviewing and understanding the hazards of materials and processes in their experiments, laboratory research setting or other work procedures prior to conducting work.

5. Utilizing appropriate measures to control identified hazards, including consistent and proper use of administrative controls, engineering controls and personal protective equipment.

6. Understanding the capabilities and limitations of PPE issued to them. 

7. Gaining prior approval from the PI/Laboratory Supervisor for the use of restricted chemicals and other materials.

8. Consulting with PI/Laboratory Supervisor before using particularly hazardous substances (PHS), pyrophorics, explosives and other highly hazardous materials or conducting certain higher risk experimental procedures.

9. Properly identifying/labeling, handling, storing and disposing of hazardous waste (see Chapter 5).

10. Immediately reporting all unsafe acts, unsafe conditions and lab accidents to the lab manager and PI/Laboratory Supervisor.

11. Completing all required health, safety and environmental training and providing written documentation to their PI/Supervisor.

12. Participating in the medical surveillance program, when required.

13. Informing the PI/Laboratory Supervisor of any work modifications ordered by a physician as a result of medical surveillance, occupational injury or exposure.

14. When working autonomously or performing independent research or work.

14.1. Reviewing the plan or scope of work for their proposed research with the PI/Laboratory Supervisor.

14.2. Notifying in writing and consulting with the PI/Laboratory Supervisor, in advance, if they intend to significantly deviate from previously reviewed procedures (Note: Significant change may include, but is not limited to, change in the objectives, change in PI, change in the duration, quantity, frequency, temperature or location, increase or change in PPE, and reduction or elimination of administrative controls and/or engineering controls.).

14.3. Preparing SOPs and/or Job Safety Analyses (JSAs) that are appropriate for their work.

14.4. Providing appropriate oversight, training and safety information to laboratory or other personnel they supervise or direct.

EH&S is responsible for administering and overseeing institutional implementation of the Chemical Safety
Program. EH&S assigns a Chemical Hygiene Officer (CHO) who has primary responsibility for ensuring the
implementation of all components of the CHP. In case of life safety matters or immediate danger to life or
health (IDLH conditions), the Assistant Vice Chancellor for Research or their designee has the authority to
order the immediate cessation of the activity until the hazardous condition is abated. EH&S provides
technical guidance to personnel at all levels of responsibility on matters pertaining to laboratory use of
hazardous materials. The CHO is a member of EH&S and, with support from other EH&S personnel, is
responsible for:

1. Informing PIs/Laboratory Supervisors of all health and safety requirements and assisting with the
selection of appropriate safety controls, including laboratory and other workplace practices,
personal protective equipment, engineering controls, training, etc.

2. Conducting periodic inspections and taking steps to abate hazards that may pose a risk to life or
safety upon discovery of such hazards.

3. Performing hazard assessments, upon request.

4. Obtaining and utilizing, when necessary, area and personal exposure monitoring records.

5. Helping to develop and implement appropriate chemical hygiene policies and practices.

6. Having working knowledge of current health and safety rules and regulations, training, reporting
requirements and standard operating procedures associated with regulated substances. Such
knowledge may be supplemented and developed through research and training materials.

7. Working with Departmental Safety Committees to review existing and developing new SOPs for
handling hazardous chemicals.

8. Providing technical guidance and investigation, as appropriate, for laboratory and other types of
accidents and injuries.

9. Reviewing plans for installation of engineering controls and new facility construction/renovation, as
requested.

10. Reviewing and evaluating the effectiveness of the CHP at least annually and updating it as
appropriate.

11. Providing assistance with environmental compliance, transport and disposal of hazardous waste.

The CPSC is established as the Chemical Hygiene Committee for UCLA. The CPSC is responsible for;

1. Developing, recommending, updating and maintaining policies and procedures applicable to
chemical and physical health and safety practices at UCLA in order to promote safe research
practices.

2. Advising the Vice Chancellor for Research regarding compliance with safety-related policies.

3. Receiving and reviewing summary reports from EH&S regarding laboratory safety inspections and
incidents related to chemical and physical hazards.

4. Reviewing findings of inspection and hazard surveillance programs carried out by authorized EH&S
personnel and State and Federal Regulatory authorities.

5. Receiving and reviewing reports from Departmental Health and Safety Committees as well as
receive input from individual Faculty and Researchers.

6. Establishing and reviewing strategies to ensure ongoing and adequate surveillance, hazard
identification, and risk evaluation of laboratory activities related to chemical and physical hazards.

7. Reviewing the campus CHP annually, advising the Vice Chancellor for Research and AVC for
EH&S regarding its effectiveness, and proposing improvements as necessary.

8. Reviewing requests for variances from established campus safety practices and making
recommendations to the Vice Chancellor for Research on accepting or not accepting these
requests.

Additional Resources

EH&S has published numerous factsheets and other resources to assist PIs and lab personnel. See our documents library for more information:

• PI/ Lab Supervisor’s Responsibilities
• Lab Hazard Assessment Tool (LHAT)
• EH&S Safety Training Matrix
• Site Specific Training form
• Site Safety Orientation Checklist
• EH&S Laboratory Safety Fact Sheets
 

University of California Policies

Effective October 31st, 2013, two UC-wide policies were enacted by the Office of the President. The first policy sets forth guidelines regarding the hazards minors are allowed to come in contact with in UC laboratories. The second policy concerns laboratory safety training.
•    UCOP Minors in Laboratories and Shops Policy 
•    UCOP Lab Safety Training Policy 
 

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