Chemical Hygiene Plan
- Scope and Application
- Roles and Responsibilities
- Chemical and Hazard Identification
- Standard Operating Procedures
- Controlling Chemical Exposure
- Fume Hood Performance Evaluation
- Information and Training
- Prior Approval for Laboratory Procedures
- Medical Examinations and Consultations
- Particularly Hazardous Substances
- Laboratory Inspections and Audits
- Electrical Engineering Department Facility Systems
- For More Information
This Chemical Hygiene Plan was developed in response to the federal Occupational Health and Safety Administration (OSHA) regulation, Occupational Exposures to Hazardous Chemicals in the Laboratory (29 CFR 1910.1450), commonly referred to as the "Laboratory Standard".
The purpose of the Chemical Hygiene Plan is to provide guidelines for prudent work practices and procedures for the laboratory use of chemicals, and to protect laboratory workers from the potential health hazards of the chemicals they encounter in the workplace.
All laboratory workers must be made aware of this plan. New employees should review the plan and receive safety training before beginning work with hazardous chemicals. The plan is available to all laboratory workers at all times.
The Laboratory Standard covers employees who work with hazardous chemicals in laboratories. At Princeton University, this program applies to all individuals working with hazardous chemicals in science and engineering laboratories. Work with hazardous chemicals outside of laboratories is covered by the Hazard Communication Standard (29 CFR 1910.1200). See Hazard Communication for more information.
Department Chemical Hygiene Officer
Conrad Silvestre is the Chemical Hygiene Officer for the Electrical Engineering Department and is responsible for developing and implementing this Chemical Hygiene Plan. The Chemical Hygiene Officer is also responsible for the following:
- Review and update the Chemical Hygiene Plan at least annually.
- Investigate accidents and chemical exposures within the department.
- Act as a liaison between the EE Department and the Environmental Health and Safety Office (EHS) for laboratory safety issues.
- Maintain records of training, exposure monitoring and medical examinations.
- Ensure laboratory workers receive chemical and procedure-specific training.
- Approve laboratory workers return to work following a chemical exposure requiring medical consultation.
- Review and approve use of particularly hazardous substances.
- Ensure laboratory workers attend general lab safety training given by EHS.
- Ensure laboratory workers understand how to work with chemicals safely. Provide chemical and procedure-specific training, as needed.
- Provide laboratory workers with appropriate engineering controls and personal protective equipment needed to work safely with hazardous materials. Ensure such equipment is used correctly.
- Ensure laboratory workers complete and submit Particularly Hazardous Substance Use Approval forms and submit them for approval before using any particularly hazardous substance.
- Review and approve work with particularly hazardous substances.
Safety Records Coordinator
Sania Sadhvani is the Safety Records Coordinator.
- Maintain records of training, exposure monitoring and medical examinations. Maintainence of these records is assisted by the Departmental Safety Manager. Both also track departmental personnel getting required training.
Environmental Health and Safety (EHS)
- Provide consultation for safe work practices for hazardous chemicals
- Provide general training.
- Provide safe working guidelines for laboratory workers through the EHS web page.
- Inspect fume hoods annually
- Develop and maintain the EHS Website.
- Conduct exposure monitoring, as needed.
- Audit the departmental program periodically.
- Review the model Chemical Hygiene Plan at least annually
- Conduct limited laboratory safety inspections annually
- Attend laboratory safety training.
- Review the Chemical Hygiene Plan.
- Follow procedures and laboratory practices outlined in the Chemical Hygiene Plan and the EHS website.
- Adhere to all University and departmental safety policies and procedures and comply with safety directives issued by supervisors and principal investigators.
- Use engineering controls and personal protective equipment, as appropriate.
- Report all incidents, accidents and potential chemical exposures to the principal investigator and the Chemical Hygiene Officer.
- Document specific operating procedures for work with particularly hazardous substances, including carcinogens, reproductive toxins and chemicals with high acute toxicity.
Chemical and Hazard Identification
Chemical manufacturers or distributors perform an assessment of the physical and health hazards of each chemical they produce. This information is included in a safety data sheet (SDS) and, in part, on container labels.
The manufacturer's label should be kept intact. When a chemical is transferred to another container for storage, the new containers should be labeled with the name of the product, the chemical constituents and hazard warnings.
Safety data sheets received with chemical shipments must be maintained and readily accessible to laboratory workers. SDSs for stockroom chemicals withdrawn from the Molecular Biology Department or Chemistry Department stockrooms are available from the stockroom attendants.
SDSs for most laboratory chemicals may be found through various manufacturer websites and other online resources. Please see the SDS link on the EHS Website for more information.
Additional chemical safety resources are available through the EHS Chemical Safety web page.
The EHS website provides general principles for working safely with hazardous chemicals. Principal investigators, laboratory managers and laboratory workers are encouraged to develop and implement more detailed guidelines for specific operations and chemicals in their laboratories.
The following criteria are used to determine and implement control measures to reduce exposures to hazardous chemicals.
Exposure monitoring is conducted by EHS upon request if there is reason to believe that exposure levels for a particular substance may routinely exceed either the action level or the permissible exposure limit set forth by OSHA, NIOSH, or ACGIH. Individuals may contact EHS directly at 609-258-5294 or notify the Chemical Hygiene Officer, Conrad Silvestre.
Results of the monitoring will be made available by EHS to the individual(s) monitored, their supervisors, and the Chemical Hygiene Officer within 15 working days of the receipt of analytical results.
Based on the monitoring results, periodic monitoring may be scheduled at the discretion of EHS, in accordance with applicable federal, state and local regulations.
Engineering controls are the primary means of control for exposure to hazardous chemicals. Local ventilation, including fume hoods, ducted biosafety cabinets, glove boxes, vented storage cabinets, and vented canopies are the most common types of engineering controls. Upon request, EHS provides assistance in determining the appropriate type of engineering controls for specific operations.
Protective equipment, including gloves, face shields, safety glasses, safety goggles, lab coats and aprons, are used when engineering controls are not sufficient to adequately control exposure. Specifically, this equipment is used to prevent exposure to the skin or eyes. Personal protective equipment is carefully selected to ensure that it is compatible with the chemicals used. Information about selection of appropriate protective equipment is available on the EHS Website.
When feasible engineering controls are not adequate to reduce inhalation exposure to acceptable levels, a respirator may be used to minimize exposure to airborne contaminants. Use of a respirator is subject to approval by EHS and must be in accordance with the University Respiratory Protection Policy. See Respirator Use for more information.
It may be necessary to supplement engineering controls and protective equipment with administrative controls, such as restricting access to an area, restricting use of particular chemicals to a limited group of people, or limiting the length of exposure.
Fume Hood Performance Evaluation
Laboratory fume hoods are evaluated at least annually by EHS technical staff. An inspection sticker is affixed to each hood to document the evaluation and to provide information to the hood user regarding the measured performance of the hood. Each fume hood is equipped with at least one type of continuous monitoring device designed to provide the user with current information on the operational status of the hood. The Fume Hoods section of the EHS Website has more information about the safe operation of laboratory hoods and the hood survey program.
In the event that a hood does not appear to be operating properly, hood users may contact EHS at 609-258-5294 for a performance evaluation. Routine maintenance and repairs of fume hoods are conducted by Special Facilities.
Hood users may route requests for hood repair directly to Special Facilities at 609-258-4565. EHS does not initiate maintenance or ensure that it is completed. Upon request, EHS will re-inspect the fume hood following maintenance or repairs.
All laboratory workers must receive laboratory safety training when they are first assigned to a work area where hazardous chemicals are present and before assignments involving new exposure situations. General laboratory safety training is provided by EHS. More specific training for particular materials or operations in a particular work area is provided by the Principal Investigators, laboratory staff, and teaching assistants.
EHS Laboratory Safety Training
EHS provides Laboratory Safety Training sessions each semester and by request. Contact EHS at 609-258-5294 to request a training session.
The general training offered by EHS covers the following topics:
- An overview of the OSHA Laboratory Standard. Full text of the standard is available on the web at OSHA Laboratory Standard.
- The content and availability of the Chemical Hygiene Plan and Laboratory Safety web pages.
- The availability of material safety data sheets and how to use them.
- An explanation of permissible exposure limits for chemicals
- An overview of methods to recognize hazards, how to evaluate hazards, and common methods to prevent and control exposure
- The use, function and selection of personal protective equipment
- Emergency procedures for fire, injury, chemical exposure, and chemical spill situations
- Chemical waste disposal procedures at Princeton University.
Departmental Information and Training
Each laboratory worker must be made aware of the following information:
- Location of the Chemical Hygiene Plan: The Chemical Hygiene Plan for the Department of Electrical Engineering is kept on the safety shelf J402, in the individual laboratories, and on the EHS web page.
- Nature and potential health and safety risks of specific hazardous substances used by the laboratory worker. Each Principal Investigator ensures that each individual working in his or her laboratory understands the hazards of and how to properly handle the materials in the laboratory. The PI maintains relevant files in the laboratory.
- Proper handling, under all circumstances, of hazardous substances used in the laboratory.
- Location and availability of reference materials, including safety data sheets (SDSs) for hazardous chemicals used or stored in the laboratory.
EHS maintains a database of attendance for training sessions given by EHS. The Electrical Engineering Department attendance records for EHS training sessions and in-house training are maintained by the Safety Records Coordinator. Records of laboratory-specific training provided by individual laboratories are maintained in the laboratories.
Prior Approval for Laboratory Procedures
Individuals planning to use Particularly Hazardous Substances, as described later in this document, must complete a Particularly Hazardous Substance Use Approval Form and have it approved by the Principal Investigator or supervisor and the departmental Chemical Hygiene Officer prior to their initial use of the substance. Forms are available from the department manager and can be dowloaded from the web.
Responsibility for determining whether a chemical is a Particularly Hazardous Substance rests jointly with the supervisor and the individual planning to use the substance.
Any laboratory worker who is concerned about safety considerations involving a particular apparatus, experiment, or chemical should contact Conrad Silvestre by e-mail at firstname.lastname@example.org. If necessary, the Chemical Hygiene Officer will coordinate a peer review.
Medical Examinations and Consultations
Medical Consultation Policy
Laboratory workers should seek medical attention from University Health Services at McCosh under the following conditions:
- If the individual experiences signs or symptoms associated with a hazardous chemical to which he or she may have been exposed in the laboratory
- Where exposure monitoring reveals an exposure level routinely above the OSHA action level or permissible exposure limit
- Whenever a spill, leak, explosion or other occurrence results in the likelihood of a hazardous exposure to a laboratory worker
All medical exams will be performed by or under the direction of University Health Services at McCosh staff and provided at no cost to the worker, without loss of pay.
In the event of any incident that results in a possible overexposure to a chemical, regardless of whether any signs or symptoms of exposure are noted, the labortory worker should report to University Health Services Immediately. The laboratory worker or delegate should report the incident to EHS immediately. If after hours, report the incident to Public Safety and EHS will be contacted.
Medical Consultation Procedure
In an emergency situation, the laboratory worker should immediately be taken to McCosh Health Center or Princeton Medical Center, as appropriate. Public Safety may be contacted at 911 for transportation. For a non-emergency exposure situation, the laboratory worker or supervisor should contact University Health Services at McCosh at 609-258-5035 to schedule an appointment.
The laboratory worker, supervisor, or Chemical Hygiene Officer must provide the physician with the identity of the hazardous chemicals encountered in the workplace and the conditions by which the worker was exposed. If available, the safety data sheet or other safety information resource should be provided to the physician.
The examining physician will submit a written opinion to the laboratory worker and the Chemical Hygiene Officer using the Medical Consultation Form. The opinion shall not reveal any specific findings or diagnoses unrelated to the occupational exposure. The opinion will include the following information:
- Recommendations for further medical follow-up;
- Results of the medical examination, and any test results;
- Any medical condition revealed during the examination that may place the worker at increased risk as a result of exposure to the hazardous chemical found in the workplace.
Based on the physician's opinion, the Chemical Hygiene Officer shall approve the individual's return to work.
Particularly Hazardous Substances
Particularly hazardous substances are defined to include select carcinogens, reproductive toxins and substances that have a high degree of acute toxicity (such as cyanides and dimethyl mercury).
Select carcinogens include any substance that is included on any of the following lists of carcinogens:
- OSHA Carcinogen List
- Annual Report on Carcinogens published by the National Toxicology Program (NTP), including all of the substances listed as "known to be carcinogens" and some substances listed as "reasonably anticipated to be carcinogens"
- International Agency for Research on Cancer (IARC), including all of Group 1 "carcinogen to humans" and some in Group 2A or 2B, "reasonably anticipated to be carcinogens"
Reproductive toxin includes any chemical that may affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis).
High acute toxicity includes any chemical that falls within any of the following categories:
- A chemical with a median lethal dose (LD50) of 50 mg or less per kg of body weight when administered orally to certain test populations
- A chemical with an LD50 of 200 mg or less per kg of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) to certain test populations
- A chemical with a median lethal concentration (LC50) in air of 200 parts per million (ppm) by volume or less of gas or vapor, or 2 mg per liter or less of mist, fume, or dust, when administered to certain test populations by continuous inhalation for one hour, provided such concentration and/or condition are likely to be encountered by humans when the chemical is used in any reasonably foreseeable manner.
A list of the more commonly used particularly hazardous substances is available at the partuclarly hazardous substances section of the EHS website, however, this list is not exhaustive. Consult the product MSDS or contact EHS for assistance in determining whether a substance is classified as particularly hazardous.
Before using a particularly hazardous substance, an individual must:
- Complete a Particularly Hazardous Substance Use Approval Form. This form can be downloaded here.
- Submit the completed form to their supervisor or Principal Investigator for approval.
- Submit the approved form to Conrad Silvestre for his approval.
- Post the area where the substance will be used with a Designated Area sign, available from the departmental Chemical Hygiene Officer or EHS or can be downloaded.
- Follow the procedures outlined in the approved form and the EHS website.
The Particularly Hazardous Substance Use Approval Form provides documentation of the specific standard operating procedure for use of the substance. These procedures include the use of containment devices and personal protective equipment, decontamination procedures and procedures for safe removal of contaminated waste.
Laboratory Inspections and Audits
EHS technicians conduct a limited laboratory inspection at the time of the fume hood performance evaluation. A summary of the inspection results are provided to the Chemical Hygiene Officer.
The Chemical Hygiene Officer, Associate Chemical Hygiene Officer, and Departmental Safety Manager conduct additional laboratory inspections at least annually.
Fire extinguisher are inspected monthly by Building Services personnel. Should a fire extinguisher be used, or if the inspection is out-of-date, e-mail or call Otto Meilick at 609-258-0556.
Safety Showers and Eyewash Fountains
Special Facilities staff inspect all safety showers and eyewash fountains every six months. Contact Special Facilities at email@example.com or 609-258-4565 if inspection is out-of-date or for any questions.
Self-Contained Breathing Apparatus
If self-contained breathing apparatus (SCBA) is used, contact EHS at 609-258-5294 immediately for decontamination and refilling. SEAS staff inspect SCBA monthly. Contact Joe Laskow at 609-258-4739 with any questions.
Electrical Engineering Department Facility Systems
There are several types of alarms in the Department of Electrical Engineering:
The fire alarm has a distinctive sound consisting of a loud, constant horn that sounds throughout the School of Engineering and Applied Sciences, regardless of the location of the alarm sensor or pull box station. The fire alarm is activated by smoke sensor or manual pull box stations. The system is monitored by Public Safety and serviced by the University Alarm Shop.
If the fire alarm sounds, immediately leave the building and report to the designated assembly area assigned to the laboratory. See the SEAS Emergency Action Plan for more details.
Fume Hood Alarms
Some fume hoods in Electrical Engineering are equipped with alarms. The alarm sounds are distinctively different from the fire alarm. Some alarms sound when the fume hood exhaust falls below a set percentage (e.g., 70% of the expected performance). Fume hoods in the J wing are of this type. In the event of this type of alarm, lower the sash and contact firstname.lastname@example.org for Special Facilities.
Some fume hoods alarm when the horizontal sash is above or below a fixed level. These are controlled in real time by the laboratory worker by moving the sash.
Toxic Gas Alarms
Several areas where toxic gases are stored or used are equipped with alarms warning of leaks. These alarms are distinctively different from both the fire alarm and the fume hood alarms, and sound only at the location of the work area. Do not enter the area if the alarm is activated. Alert individuals that work with the gases of the alarm, as well as Conrad Silvestre.
The central vacuum system serving the School of Engineering and Applied Sciences is located in the basement of the building, in a mechanical room. Their model numbers and operating instructions are recorded and maintained by the Special Facilities Maintenance group serving SEAS.
Protection from contamination is achieved by water trapping vacuum pump exhaust vapors at the basement location. However, since odors still occur at times in that location, users of the system are required to cold trap at the point of use. The vacuum systems provide vacuum in the range of 17-25 inches of water.
The fume hoods in Electrical Engineering are bypass hoods with a vertical sash, equipped with magnehelic gauges for continuous monitoring of air draw. Some are equipped with alarms. Some are equipped with velocity monitors. See the "fume hoods" for more information about these hoods.
Electrical Engineering Department personnel may obtain maintenance help in several ways:
- Contact email@example.com (609-258-4565) for immediate or planned maintenance.
- All emergencies involving facilities should be reported to Public Safety at 609-258-3134. The proctors will page the appropriate maintenance personnel, as necessary.
The EHS web page contains as myriad of safety information covering a number of topics including chemical safety, lasers, radioactive materials, electrical safety, and much more.
Electrical Engineering Department
- David Radcliff, Chemical Hygiene Officer, firstname.lastname@example.org, 609-258-6236, C402 E-Quad
- Cecilia York, Department Manager, email@example.com, 609-258-3059, B208 E-Quad
- Sania Sadhvani, Safety Records Coordinator, firstname.lastname@example.org, 609-258-6636, B210 E-Quad
- Robert Kennedy, Facilities Manager, email@example.com, 609-258-4552, ACE 22 E-Quad
- Steve Elwood, Health and Safety Specialist, firstname.lastname@example.org, 609-258-6271
- Kelly States, Senior Program Manager, Health and Safety, email@example.com, 609-258-2648
- Stanley Howell, Program Manager - Chemical Safety, firstname.lastname@example.org, 609-258-2711
For compliance with the OSHA Laboratory Standard
Revised April 2015