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Environment, Health and Safety Department, 30 East Campus Mall, Madison, WI 53715-1227
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Frequently Asked SAFETY Questions (FAQs) of the Environment, Health & Safety Department's Chemical & Environmental Safety Program (as well as some not so frequently asked questions) This is one of two active, building lists (DISPOSAL and SAFETY) of questions that we receive from students, faculty, and staff on campus that are not necessarily addressed in the Chemical Safety & Disposal Guide. CHEMICAL SAFETY QUESTIONS IN ALPHABETICAL ORDER When is a CHEMICAL HYGIENE PLAN required? Writing a CHEMICAL HYGIENE PLAN seems like a lot of work. How can I find time to write one? Can more than one lab use the same CHEMICAL HYGIENE PLAN? What about rooms that are shared, such as stockrooms, coldrooms, and instrument rooms? Do I need an EYEWASH and EMERGENCY SHOWER in my room? Is chemical safety information available on the INTERNET? Are SAFETY GLASSES required for everyone who works in a lab? We love to wear SHORTS in our lab in the summertime. Does OSHA forbid shorts in labs? Where can I learn more about chemical safety? (TRAINING)
Q: When is a CHEMICAL HYGIENE PLAN required? A: A Chemical Hygiene Plan (CHP) is required for all laboratories in which chemicals are used where:
If it looks like a lab, walks like a lab, and quacks like a lab, then it probably is a lab. Laboratory stockrooms, preparatory rooms and cold rooms can be treated like a lab (and would therefore require a CHP if someone worked in them. Building shops would not be a lab; neither would any computer or art lab. Most of the Physical Sciences Laboratory in Stoughton is not a lab in this sense. Some OSHA or EPA law covers every workplace in which hazardous materials are used. Greenhouses are covered by EPA's worker protection standard. Other non-labs need to comply with OSHA's hazard communication standard. In general, each law requires that MSDSs be kept and accessible to workers and anyone who uses hazardous materials must be trained (and the training must be documented). Whereas the OSHA Lab Standard is flexible, it also requires a written CHP. (12/19/94 PR) Q: Does a CHEMICAL HYGIENE PLAN actually improve lab safety, or is it just another ineffective onerous government regulation? A: Chemical Hygiene Plans (CHP) can reduce chemical risks to you and your colleagues. Basically, a CHP is nothing more than written safety procedures. If safety procedures aren't documented in some way, how can you ensure that new people learn what they need to other than by documenting your safety procedures...everyone is following the same procedures...and no one is jeopardizing the safety of a coworker. (2/24/95 PR) Q: Writing a CHEMICAL HYGIENE PLAN seems like a lot of work. How can I find time to write one? A: An easy way to complete your Chemical Hygiene Plan (CHP) is to use a group meeting to discuss your ...don't try to be perfect or comprehensive the first time...I don't think dedicating one meeting a year to safety is asking too much. (2/24/95 PR) Q: Can more than one lab use the same CHEMICAL HYGIENE PLAN? A: Yes. Every lab needs a chemical hygiene plan, but one plan may be sufficient for all the labs under control of a) one Principal Investigator (PI) or b) Department or c) Building. Make sure all the safety procedures used in each lab are included. Some PIs with several labs have two CHPs: one for their high-risk lab and the other for the rest of their labs. (12/19/94 PR) Q: What about rooms that are shared, such as stockrooms, coldrooms, and instrument rooms? A. (1/23/95 PR) Q: If my lab follows the chemical safety procedures in Part D of the Guide, do we need to add details to sections I, II and III (SOPs, Criteria, PPE) of the CHEMICAL HYGIENE PLAN template in the Guide? A: No. If your lab follows all of the safety procedures given in Part D, you do not have to add information to the Appendix C template. However, Part D should be a complete safety procedure for your lab, so that even new people can learn what they need to know from reading it. If there are additional safety procedures, or criteria to implement exposure control measures, or personal protective equipment used in your lab that is not listed in Part D, you'll have to add information. (12/19/94 PR) Q: I want a safe lab that complies with the OSHA laboratory standard. What should be the scope of our CHEMICAL HYGIENE PLAN? A: The OSHA lab standard (OLS) only pertains to chemicals, not infectious agents or other biohazards, or radioactive materials. Further, the OLS focuses on controlling exposures to toxic chemicals. Except where it pertains to minimizing risks to health, your Chemical Hygiene Plan (CHP) need not to address in detail safe storage or the reactive, flammability hazards of chemicals, for example. Some labs use minute quantities of chemicals, such as in a laser or photolysis laboratory. Consequently, the lab's CHP can be quite simple -- not much different than the template CHP in Appendix C. If your laboratory's hazards are primarily physical (such as the use of chemicals in high pressure or cryogenic procedures) a Chemical Hygiene Plan is still required. You will probably need only to address chemical exposures minimally. Also, the Guide may not be an adequate reference for safety procedures; ACS's Safety in Academic Chemistry Laboratories may be a better reference for these areas. Also, remember that OSHA will determine your compliance according to what you say you will do in your plan, so it may be best to leave additional safety procedures separate from your CHP. Be certain that you do what say. If you write that you'll all wear brown shoes on Tuesday (an improbable example), OSHA can cite you for wearing black shoes on Tuesday even if it has little to do with chemical safety. Q: The template CHP in Appendix C refers to safety procedures in Part D. What is some of the procedures in Part D aren't appropriate or necessary for our lab? A. Note in your Plan any modifications to referenced procedures. If you use the Appendix C template, it is a good idea to Review Part D carefully. For example... (1/23/95 PR) Q: Do I need an EYEWASH and EMERGENCY SHOWER in my room? A: State and Federal law (29 CFR 1910.151) requires the following: "Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for the quick drenching of the eyes and body shall be provided within the work area for immediate emergency use." Note that corrosives and oxidizers are particularly injurious to eyes, and that seconds count when seeking treatment. Eyewashes should be close and plentiful. Also, patients who have chemicals on them usually need to be showered prior to being taken to the hospital. You should know where your closest shower is, and understand how to work both devices. (1/18/95 PR, WD) Q: Is chemical safety information available on the INTERNET? A: Yes! Start with WiscInfo. Under the picks "General Campus and Community Information," then "Chemical and Environmental Safety" there is:
Also, the U.S. Occupational Health and Safety Administration has their own home page (http://www.osha.gov/) and a list of other safety resources on the internet (WWW servers) can be found at http://www.ccohs.ca/Resources/www.htm. (1/19/95 PR) Q: Do I need a MATERIAL SAFETY DATA SHEET (MSDS) for every chemical I have in my lab or work area? If so, how can I get them? A: With few exceptions, you need access to an MSDS for every chemical in your work area. The following chemicals do not need an MSDS per se, but must be addressed in your training program and in your lab's Chemical Hygiene Plan:
There are several ways to obtain an MSDS:
Q: We use a number of assaying kits in our lab that come with booklets but no MATERIAL SAFETY DATA SHEETS. The kits often include chemicals that the manufacturer considers to be a trade secret and are not identified. Is it enough to have the booklet that comes with the kit, or should we call the supplier and request any safety information necessary for the included reagents? A: You should call the supplier for the kit's MSDS. If a kit contains chemicals that can possibly pose a physical or health hazard, you need an MSDS. First, take a close look at the booklet; it may include an MSDS. At a minimum, you need to know the chemicals' characteristics, hazards, signs and symptoms of exposure, precautions, etc. Let the Environment, Health & Safety Department know if you have trouble obtaining your MSDS. We may have copies of some kit MSDSs. The manufacturer is allowed to withhold certain information as a trade secret, but they are still required to supply an MSDS with all hazardous chemicals or products that contain hazardous chemicals. (Reference: 29 CFR 1910.1200(i)) In general, you need to obtain a MSDS for any chemical that may pose a physical or health hazard to employees. There are a few exemptions for consumer products that come with warnings required by other Federal laws, articles that pose no risk to users, food and other items. (Reference: 29 CFR 1910.1200(b)) (1/17/95 PR) Q: Do we need a MATERIAL SAFETY DATA SHEET (MSDS) for a gift or sample chemical from another lab? Our lab has a number of chemicals, antibodies, etc., which were loaned or given to us by other labs and collaborators. Some of the antibodies were made in other labs rather than a commercial source. Obviously, we are in debt to them for their generosity and do not want to make them reluctant to aid us in the future. Do we need to request an MSDS for these gifts from our collaborators? A: This law became effective at the UW in 1991, so you do not need an MSDS for samples from other labs prior to 1991. From now on, however, labs that supply chemicals to other labs are required to provide an MSDS. OSHA has a blank MSDS form (No. 174), and a similar MSDS can be used as an example. Call the Environment, Health & Safety Department for help completing it, or have your source lab call if they have questions. Note that this has been Federal law since January 1990. (Reference: 29 CFR 1910.1450(h)(2)(iii)) (1/17/95 PR) MSDSs help people in your lab learn about chemical hazards and the precautions that they should take. Even if toxicological information is not available, this knowledge helps users understand the risks that these materials may pose. Q: In Appendix D of the Chemical Safety and Disposal Guide, MINERAL OIL is listed as a carcinogen. Is this a mistake? A: It should read, "unrefined mineral oil.” The National Toxicology Program's 1994 Annual Report on Carcinogens summarizes toxicological and epidemiological studies that have long shown some soot extracts, coal tars and unrefined mineral oils to be carcinogenic. Most mineral oils used in laboratories are refined, and the Report notes that "There is inadequate evidence for the carcinogenicity of soots and highly refined mineral oils in experimental animals.” Further, mineral oil has very low volatility at room temperature. Studies indicate that you are only at risk if you have skin contact with unrefined mineral oils, which is rare in a laboratory situation. Q: We have a cartridge mask (RESPIRATOR) in our spill kit, and occasionally we use a dust mask for weighing out acrylamide. But Part D (p. 11D) and Appendix B (p. 6ApxB) of the Guide discourage respirator use. Should I throw them away? A: Cartridge masks, dust masks and air tanks (SCBA packs) are all types of respirators. To make sure that respirators are used properly and users are fit, OSHA requires respirator users to be trained and have a medical examination. Because this is rarely done and because better control measures exist (e.g., fume hoods), the Environment, Health & Safety Department discourages the use of respirators in most cases. However, the Environment, Health & Safety Department does not forbid the use of respirators in labs, or take them away. We supply the information above so that you can prudently make your own decisions. (12/19/94 PR) Q: Are SAFETY GLASSES required for everyone who works in a lab? A: Yes, or some other type of eye protection. [Citation] (12/19/94 PR) Q: We love to wear SHORTS in our lab in the summertime. Does OSHA forbid shorts in labs? A: No. You can wear shorts in a lab as long as you can show, in your Chemical Hygiene Plan (CHP), that other control measures or procedures adequately protect personnel from chemical exposures. For example, in section II of the CHP (Criteria to Implement Exposure Control Measures) you can require anyone who uses a liquid corrosive to wear full-length pants and an apron. Note that page 11D Part D of the Guide requires long pants, so you'll need to note this difference if you use Appendix C as your template CHP. The Environment, Health & Safety Department discourages wearing shorts in labs because of the risk of exposure and injury. (12/19/94 PR) Q: Where can I learn more about chemical safety? (TRAINING) A: If you use chemicals, you are required by law to receive safety training. Courses vary by the type of chemicals you use and where you use them. If you use hazardous chemicals in a laboratory, you must receive safety training and information. See the Chemical Safety and Disposal Guide for your many options, including attending a laboratory safety seminar (pages 3D and 3-4ApxB, and Appendix G). People who use pesticides are also required to receive safety training. Programs are available for greenhouse workers and people who work on a UW Agricultural Research Station. For others who use hazardous chemicals (not pesticides or in labs), hazard communication training is provided by the work unit. (Hazard communication refers to the dissemination of information about hazardous chemicals.) UW Hospital and Facilities, Planning and Management both offer "Haz Com" courses for their employees. If your campus work unit doesn't give a course and your coworkers use hazardous chemicals, the Environment, Health & Safety Department can arrange a program for your unit's designated trainer. Call the Environment, Health & Safety Department if you want information on any of these courses. (1/18/95 PR) Q: What bureaucratic hoops do I have to jump through to be able to use DEA controlled substances in my research? A: Use of DEA controlled substances requires authorization by both the Federal Department of Justice and the State Department of Health and Social Services. The feds permit can be obtained by writing: U.S. Department of Justice The State permit can be obtained by contacting: State of Wisconsin
All applications, permits, authorizations MUST be obtained prior to ordering of materials. Suppliers of the various classes of controlled substances are of little help in obtaining other than the federal permits.
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