Overview
Written safety plans are lacking or incomplete (e.g., Virtual Manual/Chemical Hygiene Plan, Biosafety Manual, etc.) or employees do not know how or where to access plans and protocols.
Conformance with this checklist item is primarily established through an interview with laboratory workers. Notice there are two distinct parts to this question:
- Is there a safety manual for the laboratory?
- Do employees know how to access it?
Your survey needs to assess both. Ask laboratory workers if they have a manual. Then ask them how they access it. Search for a
profile under the PI’s email address. If you find a virtual manual (VM) but the laboratory workers that you interviewed did not know about it, then we have a problem with the second half of the question.
If the lab worker responded that they don’t have a safety manual, and you are not able to locate a virtual manual record for the PI (this should noted in the “Conditions” tab of the Chemical permit AND in a Virtual Manual User List is located on the common drive under "Safety & Compliance Survey Resources" ), then we have a problem with the first half of the question. Either way, this checklist item will be cited in these situations.
In a bio-lab, these same things are also assessed, but there is an additional requirement to assess these materials in the context of a biosafety manual. All bio labs must have a biosafety manual in addition to a general safety manual.
This item is based on numerous federal regulations and covers a variety of items that may trigger a citation.
Citations and Related Resources
Citations
29 CFR 1910.1450 (e)(1): Where hazardous chemicals as defined by this standard are used in the workplace, the employer shall develop and carry out the provisions of a written Chemical Hygiene Plan.
…(f)(3) Employees shall be informed of (ii) The location and availability of the employer's Chemical Hygiene Plan.
1910.1450(e)(3) The chemical hygiene plan shall include each of the following elements and shall indicate specific measure that the employer will take to ensure laboratory employee protection: (i) Standard Operating procedures relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals; (iv) Provisions for employee information and training as prescribed in paragraph (f) of this section; (v) The circumstances under which a particular laboratory operation, procedure or activity shall require prior approval from the employer or the employer's designee before implementation.
Prudent Practices 6.C.2 The preferred methods for reducing chemical exposures are, in order of preference, (1) substitution of less hazardous materials or processes, (2) engineering controls, (3) administrative controls (see Chapter 2), (4) personal protective equipment (PPE).
NFPA 45, 11.2.1 – 11.2.1.1 Before laboratory tests or chemical reactions are begun, evaluations shall be made for hazards that can be encountered or generated during the course of the work. 11.2.1.2 Evaluations shall include the hazards associated with the properties and the reactivity of the materials used and any intermediate and end products that can be formed, hazards associated with the operation of the equipment at the operating conditions, and hazardous associated with the proposed reactions- for example, oxidation and polymerization. 11.2.1.3 Regular reviews of laboratory operations and procedures shall be conducted with special attention given to any change in materials, operations, or personnel. 11.2.1.4 Where reactions are being performed to synthesize materials, the hazard characteristics of which have not yet been determined by test, precautions shall be employed to control the highest possible hazard based on a known hazard of similar material. 11.2.1.5 Where use of a new material or the premixing of flammable and oxidizing materials might present a severe explosion potential, initial experiments or tests shall be conducted in an enclosure that is designed to protect people and property from potential explosion damage.