Chemical Hygiene Plan Procedures
The Occupational Safety and Health Administration (OSHA) requires laboratories using hazardous chemicals to develop and implement a written Chemical Hygiene Plan (CHP). This plan must include provisions for protecting employees from the health hazards associated with chemicals in the laboratory and maintaining employee exposure to chemicals below the Permissible Exposure Limits (PEL’s).
The basic elements of a Chemical Hygiene Plan are defined in the OSHA Lab Standard. Many of these elements are appropriately addressed by university-wide procedures. The Chemical Safety section of the Laboratory Safety Manual contains many general safety procedures for chemical laboratories.
However, because of the diverse nature of the teaching, research, and clinical programs at the University of Louisville, general procedures cannot address all potential chemical hazards. Customizing the plan to their individual laboratory activities, each laboratory unit is required to complete some additional elements of the Chemical Hygiene Plan. These lab-specific elements, combined with the Chemical Safety section of the Lab Safety Manual, comprise a comprehensive Chemical Hygiene Plan.
How to Complete the Chemical Hygiene Plan
A model template for lab-specific elements of the Chemical Hygiene Plan has been developed to simplify this process. After opening the template, do a "save as" to a desired location on your computer. After saving, you can customize the plan by completing the required lab-specific information. Save your customized plan electronically to make future updates easier. Keep an up-to-date printed copy readily accessible in the lab in case of OSHA or DEHS inspections.
The first time you customize your plan and complete your chemical inventory, send a copy to DEHS Lab Safety Coordinator. Electronic submission is preferred, but a printed copy is also acceptable.
Customization of this template for an individual laboratory unit is straightforward.
- Complete basic information about the location and responsible supervision of the laboratory unit on the front page of the Chemical Hygiene Plan. The lab unit covered by the plan may be a single lab or a group of labs that form a work unit. Also list all employees currently working in the laboratory along with the dates they received General Lab Safety Training and Lab-Specific Training. Add names as new employees are hired or transferred into the lab. Delete names of employees when they leave the lab.
- Describe responsibilities of lab personnel pertaining to health and safety under the section titled “Internal Lab Responsibilities”.
- Complete the section “Operations/Procedures Requiring Prior Approval”.
- Include the laboratory chemical inventory with the date compiled noted.
- Complete the section identifying the location and accessibility of the laboratory’s material safety data sheets.
- Inclusion of lab-specific safe operating procedures (SOP’s) relevant to safety and health considerations for highly hazardous chemicals used in the individual laboratory. Send copies of the SOP's to the DEHS Laboratory Safety Coordinator.
- If your work involves animals and hazardous drugs or chemicals, you may be required to complete a Special Animal Safety Protocol (SASP).
- Describe the specific procedures employees must follow when reporting an injury/chemical exposure.
- Ensure attendance at General Lab Safety Training provided by DEHS.
- Provide Lab-Specific Safety Training including the content of the Chemical Hygiene Plan and SOP's.
- Provide personal protective equipment (PPE) as described in the Lab PPE Hazard Assessment. Print out a copy of this assessment and post in the lab.
- Labs may include other safety/health related information at their discretion.
Requirements for Annual Review
The Faculty/Principal Investigator is in charge of assuring that the following items are reviewed at least annually.
- Chemical Hygiene Plan front page - Remove personnel no longer working in the lab, add any new personnel and list the appropriate training dates for each. Forward an updated copy, preferably electronically, to the DEHS Laboratory Safety Coordinator each year.
- Chemical Hygiene Plan - Review and update if necessary. Pay particular attention to the following sections: internal lab responsibilities, operations/procedures requiring prior approval, MSDS.
- Chemical Inventory - delete items that are no longer available in the lab, add new items to the inventory.
- Safe Operating Procedures (SOP's) for highly hazardous chemicals - assure that existing SOP's are up to date and that an SOP is available for each highly hazardous chemical in use.