Laboratory Safety Audit Guidance
Inspection Items - Deficiencies
- University of Louisville Chemical Hygiene Plan not completed.
The Occupational Safety and Health Administration (OSHA) requires laboratories that use hazardous chemicals to develop and implement a written Chemical Hygiene Plan (CHP). Each Principal Investigator (Faculty or Staff in charge of supervising a lab/s). A model template for lab-specific elements of the Chemical Hygiene Plan has been developed to simplify this process.
- Chemical Inventory not completed. Each lab is required to complete a chemical inventory and keep the inventory current.
- Standard Operating Procedures not developed for the use of "highly hazardous chemicals."
The OSHA Lab Standard specifically lists three categories of chemicals as "particularly hazardous." They include select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity. Each laboratory is responsible for generating operation specific SOPs for routinely conducted procedures. Guidance on preparing SOPs.
- Material Safety Data Sheets (MSDSs) not accessible.
Manufacturers must provide a Material Safety Data Sheet (MSDS) for each hazardous chemical or compound that they sell. The MSDS summarizes important hazard information and must be readily available during all working hours to be used as a reference for lab personnel. In the event of an accident or incident, emergency responders will first consult the MSDSs so that safe and successful remedial actions may be planned and initiated. Laboratory supervisors are required to maintain their own MSDSs. All lab staff must be capable of retrieving an MSDS for any chemical in the lab. The MSDSs can be hard copies or accessed through bookmarked websites.
- Containers unlabeled or labeled improperly.
All chemical containers must be labeled with its contents including secondary containers (i.e., squirt bottles, storage vials. Even containers of water should be labeled so there is no confusion.
- Containers in poor condition.
All chemical containers must be in good condition.
- Containers stored above eye level or on the floor.
- Chemicals with inhalation hazards used outside the fume hood.
Chemicals that are toxic, flammable, or volatile should be manipulated inside a properly functioning fume hood.
- Expired or unneeded chemicals not disposed of.
- Chemicals not segregated by compatibility.
A suggested storage scheme would be separating by these classes:
- Acids are stored with flammables.
- Oxidizers stored with flammables.
- Flammable chemicals stored in household refrigerators or freezers.
Household refrigerators have many ignition sources inside the refrigerator such as lights, switches, compressors, and thermostats. Flammable material refrigerators and freezers are designed to prevent ignition of flammable vapors inside the storage compartment and should be used when a refrigerator is needed to store flammable liquid.
- Water-reactive chemicals stored near water.
Water reactive chemicals should be tightly sealed against exposure to water.
- Not dated upon receipt, opening, and expiration date.
Certain chemicals, such as ethyl ether, tetrahydrofuran, and dioxane can form dangerous peroxides with exposure to air and light upon aging. Peroxides may detonate with extreme violence when concentrated by evaporation or distillation, when combined with other compounds, or when disturbed by unusual heat, shock or friction. Always check the expiration date on the container before use. Formation of peroxides in ethers is accelerated in opened and partially emptied containers.
- Stored beyond expiration date.
Dispose of peroxide forming chemicals as Hazardous Waste when the expiration date is reached.
- Not labeled "Hazardous Waste."
Containers that are filled with hazardous waste must have the words "Hazardous Waste" affixed to the container. Use permanent markers, labels or some other secure fashion.
- Not labeled with contents.
In addition to the words "Hazardous Waste" the chemical(s) names must be listed on the label.
- Open containers of Hazardous Waste.
Containers holding hazardous waste must be closed at ALL TIMES. The only exception to this is when waste is being added to or removed from the container.
- Biohazardous waste container overfilled.
To avoid overfilling, dispose of the waste when the container is ¾ full.
- Glass waste container overfilled.
Do not overfill the container; try to keep it under 30 pounds.
- Glass waste box unlabeled.
Containers for glass waste must be labeled as glass waste.
- Cylinders not secured.
Compressed gas cylinders must be secured firmly at all times. There have been many cases in which damaged cylinders have become uncontrolled rockets or pinwheels and have caused severe injury and damage. This danger has happened when unsecured, uncapped cylinders were knocked over causing the cylinder valve to break and high pressure gas to escape rapidly.
- Valve caps not in place on cylinder when the cylinder is not in use.
- Main valve not closed when not in use.
The main cylinder valve should be closed as soon as it is no longer necessary that it be open (i.e., it should never be left open when the equipment is unattended or not operating).
- Fire extinguisher inaccessible.
- Emergency eyewash or shower obstructed.
- Combustible material within 18" of sprinkler heads.
A minimum of 18 inches clearance is required below all sprinkler heads.
- Sash above working height during use.
Keep the sash lowered to the yellow arrow label while using the fume hood. Close the sash when the hood is not in use. The sash is a shield to protect you from chemical splash, broken glass, etc.
- Excess storage in fume hood.
Store only the bare minimum of equipment and chemicals in your hood.
- Latex gloves used for chemical hazards.
Nitrile gloves, rather than latex, should be the standard glove used for most laboratory applications. Vinyl is also acceptable although nitrile is resistant to more chemicals. Latex gloves, especially thin, disposable exam gloves, offer little protection from commonly used chemicals. Latex gloves protect against blood or body fluid.
- Eye protection not in use.
ANSI-approved safety glasses with side shields at a minimum must be worn in a lab where chemicals are being manipulated. Other hazards to the eyes are handling glassware, UV radiation, vacuum or pressure work, lasers, etc.
- Unauthorized respirator use.
Use of respirators in laboratories is strongly discouraged. Respiratory use is only allowed where engineering controls, such as a fume hood, are not feasible. DEHS must pre-approve all respirator selection and use.
- Poor housekeeping.
- Food or drink in lab.
- Improper attire, i.e., open-toed shoes, shorts.
- Tripping or slipping hazards.
- No hand washing materials.
- Electrical panels blocked.
There should be at least 36 inches of clear space in front of a panel box so there is good access in the event of an emergency.
- Electrical cords are damaged.
All frayed cords must be completely replaced before the equipment is allowed back into use, or the equipment must be disposed of.
- Extension cord used for permanent operation.
Extension cords can be used for a short, temporary source of electricity. If additional outlets are needed for a permanent use they must be installed.