Required Personal Protective Equipment Use in Campus Research Laboratories

Responsible Executive: Pablo Debenedetti

Responsible Offices: Office of Environmental Health and Safety (EHS) and Dean for Research

Contacts: Please direct questions concerning this policy to EHS at [email protected]

Effective Date: 6/17/2020

I. Policy Statement

This policy establishes rules for the appropriate selection, use and maintenance of personal protective equipment (PPE) for use in campus research laboratories and other research facilities. It also establishes expectations for appropriate attire to be worn in research facilities when carrying out hazardous operations, such as working with or in close proximity to hazardous materials. The purpose of this policy is to prevent workplace injuries and illness for faculty, staff, students, and visitors conducting research at Princeton University and establish minimum levels of PPE that must be worn in the absence of a documented risk assessment showing it is appropriate to downgrade the minimum PPE levels established in this policy.

II. Who Is Affected by This Policy

This policy applies to all students, faculty, staff, and visitors who conduct or observe experimental techniques within campus research facilities.

III. Definitions

Personal Protective Equipment (PPE) – Equipment, as outlined in 29 CFR 1910 Subpart I – the Occupational Health and Safety Administration (OSHA) Personal Protective Equipment [1] regulations and worn or otherwise used by an individual for the purpose of minimizing/eliminating exposure to hazards, such as chemical, biological or physical agents/hazards. Examples of PPE include protective eyewear and face protection (e.g., goggles/glasses, face shield), hand protection (e.g., disposable or other gloves), body protection (e.g., lab coat or apron), foot protection, respiratory protection, and hearing protection.

Hazardous Operations - Any work or other operation involving radioactive material, x-ray/radiation producing equipment, hazardous chemicals, biological agents, energized equipment (electrical, high pressure/vacuum, etc.), or Class 3 or 4 lasers. Additional hazards include other sources of non-ionizing radiation (high intensity lights, ultraviolet light sources, welding, furnaces, etc.), or other physical hazards (impact, penetration, compression, heat/cold, etc.).

Hazardous Chemicals - Any chemical which is a "health hazard" or "physical hazard," including but not limited to: chemicals that are carcinogens, toxic agents, irritants, corrosives, combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive.

Biological Agents - Biological material capable of causing disease in humans. Biological agents include bacteria, viruses, fungi, other microorganisms and their associated toxins, that can adversely affect human health.

Administrative Controls - Controls that define the way a process or procedure is performed with the intent of mitigating risk to the hazards present, including timing of work, policies and other rules, and work practices such as standard operating procedures.

Engineering Controls - Controls that provide a physical means of protecting workers by mitigating hazardous conditions by actively removing hazardous substances from the workplace (commonly by mechanical ventilation) or by placing a barrier between the worker and the hazard.

Body Protection – A protective garment worn by researchers in the laboratory to protect the body from exposure to chemical, biological, or other physical hazards. A laboratory coat is a commonly used protective garment worn by researchers in the lab to protect personal clothing and the body from exposure to chemical, biological or other physical hazards.

Eye/Face Protection – Equipment worn to protect the eyes and/or face of the wearer against specific hazards to the eyes and face.

Gloves/Hand Protection – Protective gloves should be worn when handling hazardous materials, chemicals of unknown toxicity, corrosive materials, rough or sharp-edged objects, and very hot or very cold materials.

Foot Protection – additional personal protective equipment to either protect personal footwear from contamination (e.g., shoe covers, over-boots) or to provide additional protection not commonly present in personal footwear (steel toe/shank, anti-slip).

Respiratory Protection – A type of personal protective equipment used to eliminate airborne contaminants from the air when other controls do not adequately eliminate such contaminants.

Hearing Protection Equipment worn to reduce the effects of exposure to loud noises and promote hearing conservation.

Risk Assessment – A systematic process of evaluating the potential risks that may be involved in a projected activity or undertaking; e.g., RAMP - Recognize, Assess, Minimize, Prepare methodology.

IV. Policy

Personal protective equipment (PPE) is an essential, last line of defense, in protecting individuals from hazards (chemical, biological, radiological, and physical) within research facilities where the hazard is not fully controlled. PPE is to be used in combination with administrative and engineering controls to prevent exposure and injury. Princeton University requires all individuals who perform activities involving hazardous operations be provided and wear appropriate PPE to protect the individual from the hazards present.

Minimum Standard for PPE in Research Facilities

PPE must be selected by way of a deliberate risk assessment in partnership with Environmental Health and Safety (EHS) training, resources and/or consultation. The minimum requirements listed in this section may be downgraded, provided that the risk assessment clearly shows it appropriate. In this case the risk assessment must be documented, then reviewed and approved by the principal investigator or designated lab manager/senior researcher.

Princeton University has established the following minimum required PPE to be worn when conducting hazardous operations.

  • Lab Coat appropriately selected to be protective against the hazards encountered; e.g., flame retardant for use of flammable and pyrophoric materials.
  • Gloves appropriately selected with particular attention to material compatibility, chemical breakthrough.
  • Eye Protection, safety glasses or goggles

 Proper Research Attire

Proper Attire for Hazardous Operations (e.g., performing, or working near others performing hazardous operations)

  • Shirt – Intended to cover the torso and upper arms (minimally)
  • Long Pants or Other Garment – Intended to cover the entire leg to the ankle
  • Shoes – Intended to resist penetration by spilled liquids and cover the entire foot; i.e., ‘closed-toe’

AVOID synthetic clothing items which can melt or readily burn in the presence of open flame.

V. Policy Enforcement

  1. Students found to be in violation of this policy may be subject to discipline in accordance with Rules, Rights, and Responsibilities.
  2. Faculty and Staff found to be in violation of this policy may be subject to discipline in accordance with appropriate University policy.
  3. Campus visitors found to be in violation of this policy may be subject to University sanctions including being banned from campus.
     

VI. Roles and Responsibilities

Research Staff/Students

  • Wear PPE in accordance with instructions and training received.
  • Care for their PPE properly and guard aganst damage and gross contamination.
  • Ensure PPE is routinely laundered/cleaned as needed.
  • Report damaged PPE or other problems to supervisory personnel.

Science and Engineering Departments

  • Ensure that department/institute staff and students utilize PPE appropriately as required.
Environmental Health and Safety
  • Enforce any part of this policy.
  • Assist departments in conducting PPE Hazard Assessments.
  • Assist departments in determining appropriate PPE for specified hazards.

 

VII. Related Policies

  1. Rights, Rules, Responsibilities
  2. Workplace Health and Safety Policies and Responsibilities
     

VIII. Update Log

Endorsed by ESRM on June 17, 2020

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[1] Occupational Safety and Health Administration. "Regulation (Standard-29 CFR) 1910 Subpart I-Toxic and Hazardous Substances." (2019).