**CHEMICAL SAFETY**

**1.0 Objective**

The objective of this surveillance is to ensure that practices for
handling, storing, and using chemicals provides effective protection for
the health and safety of employees. The surveillance includes evaluation
of compliance with chemical safety standards and requirements applicable
to operations at DOE facilities.

**2.0 References**

DOE 5480.4, *Environmental Protection, Safety and Health Protection
Standards*

DOE O 440.1A, *Worker Protection Management for DOE Federal and
Contractor Employees*

DOE G 440.1-1, *Worker Protection Management for DOE Federal and
Contractor Employees Guide*

DOE G 440.1-3, *Occupational Exposure Assessment Implementing Guide*

DOE-HDBK-1100-96, *Chemical Hazard Analysis*

DOE-HDBK-1101-96, *Process Safety Management for Highly Hazardous
Chemicals*

29 CFR 1910.106, *Flammable and Combustible Liquids*

29 CFR 1910.119, *Process Safety Management of Highly Hazardous
Chemicals*

29 CFR 1910.1200, *Hazard Communication*

29 CFR 1910.1450, *Occupational Exposures to Hazardous Chemicals in
Laboratories*

29 CFR 1910.132, Personal Protective Equipment, *General Requirements*

48 CFR 970.5204-2*, Integration of Environment, Safety, and Health Into
Work Planning and Execution*

10 CFR 830.120, *Quality Assurance*

National Fire Protection Association, Standard 45, *Fire Protection for
Laboratories Using Chemicals*

American Conference of Governmental Industrial Hygienists, *Threshold
Limit Values for Chemical Substances and Physical Agents and Biological
Exposure Indices*

For PHMC facilities the following additional references could be used:

HNF-PRO-587, *Laboratory Safety*

HNF-PRO-368, *Laboratories*

HNF-PRO-578, *Hazard Communication*

HNF-PRO-699, *Receiving, Storing, and Handling Chemicals*

HNF-PRO-2258, *Chemical Management*

HNF-PRO-580, *Process Safety Management*

HNF-PRO-360, *Fire Protection/Prevention for Construction, General
Occupancy, and Demolition Activities*

HNF-PRO-079, *Job Hazard Analysis*

**3.0 Requirements Implemented**

This surveillance is conducted to implement the requirements of the RL
Functions, Responsibilities, and Authorities Manual (FRAM), number 1561,
and DOE O 440.1A and DOE 5480.4

**4.0 Surveillance Activities**

This surveillance involves separate activities relating to the hazard
communication program, storage of chemicals, and evaluation of field
work.

Activity 1 - Evaluate the general hazard communication program,
including documentation and training, MSDS availability, worker exposure
control, etc.

Activity 2 - Observe chemical storage locations and storage practices.

Activity 3 - Observe work activities involving handling or use of
chemicals.

**Surveillance Guideline**

**CHEMICAL SAFETY**

Surveillance No.:

Facility:

Date Completed:

**Activity 1: Evaluate the general hazard communication program,
including documentation and training, MSDS availability, worker exposure
control, etc.**

[Yes]{.underline} [No]{.underline} [N/A]{.underline}

\_\_\_ \_\_\_ \_\_\_ 1. Is there a written hazard communication program
which addresses labeling and other forms of warning, material data
safety sheets (MSDS), and employee information and training? 29 CFR
1910.1200(e)(1)

\_\_\_ \_\_\_ \_\_\_ 2. Is there a list of hazardous chemicals known to
be present that also provides a reference to appropriate MSDSs? 29 CFR
1910.1200(e)(1)(i); 29 CFR 1910.1200(h)(2)(iii)

\_\_\_ \_\_\_ \_\_\_ 3. Is the hazard communication program available to
all employees? 29 CFR 1910.1200(e)(4)

\_\_\_ \_\_\_ \_\_\_ 4. Are MSDSs readily available during each work
shift to employees in their workplace for each hazardous chemical? 29
CFR 1910.1200(g)(1); 29 CFR 1910.1200(e)(8); 29 CFR 1910.1450(h)(1)(ii)

\_\_\_ \_\_\_ \_\_\_ 5. Do employees receive effective information and
training on hazardous chemicals in their work area or with which they
work? 29 CFR 1910.1200(h)(1); 29 CFR 1910.1450(f)(1)

-   Does the training include the physical and health hazards of the
    chemicals including exposure limits? 29 CFR 1910.1200(h)(3)(ii); 29
    CFR 1910.1450(f)(3)(iii); 29 CFR 1910.1450(f)(4)(i)(B)

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-   Does the training include measures employees can take to protect
    themselves from the chemical hazards (procedures, work practices,
    and PPE)? 29 CFR 1910.1200(h)(3)(iii); 29 CFR 1910.1450(f)(4)(i)(C)

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-   Does the training include the details of the hazard communication
    program, including an explanation of the labeling system, MSDSs, and
    how employees can obtain and use hazard information? 29 CFR
    1910.1200(h)(3)(iv); 29 CFR 1910.1450(f)(3)(v)

\_\_\_ \_\_\_ \_\_\_ 6. Have the employees been informed of the location
and availability of the written hazard communication program, the
required list of chemicals, and the location of MSDSs? 29 CFR
1910.1200(e)(1)

\_\_\_ \_\_\_ \_\_\_ 7. Do employers ensure that employees do not exceed
OSHA Permissible Exposure Levels (PEL) or American Conference of
Governmental Industrial Hygienist Threshold Limit Values (TLV),
whichever is more restrictive? 29 CFR 1910.1450(c); DOE O 440.1A,
Section 4.l; DOE O 440.1A, Attachment 2, Section 12.g

\_\_\_ \_\_\_ \_\_\_ 8. Do employers measure employee exposure to
chemicals if it is believed that action levels or PELs may have been
exceeded? 29 CFR 1910.1450(d)(1); 29 CFR 1910.1450(d)(2)

\_\_\_ \_\_\_ \_\_\_ 9. Do employers notify employees of monitoring
results within 15 workdays of receipt of such information? 29 CFR
1910.1450(d)(4)

\_\_\_ \_\_\_ \_\_\_ 10. Do employers have a Chemical Hygiene Plan for
laboratory use of chemicals (laboratory use - laboratory scale, multiple
chemicals/procedures, non-production chemical use, standard laboratory
protective practices)? 29 CFR 1910.1450(e)(1)

-   Is the Chemical Hygiene Plan capable of protecting employees from
    health hazards associated with hazardous chemicals? 29 CFR
    1910.1450(e)(1)(i)

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-   Does the Chemical Hygiene Plan provide provision for keeping
    exposures below limits? 29 CFR 1910.1450(e)(1)(ii)

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-   Is the Chemical Hygiene Plan readily available to employees? 29 CFR
    1910.1450(e)(2)

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-   Does the Chemical Hygiene Plan identify standard operating
    procedures relevant to safety and health considerations for handling
    chemicals? 29 CFR 1910.1450(e)(3)(i)

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-   Does the Chemical Hygiene Plan provide criteria used to determine
    and implement control measures to reduce employee exposure the
    hazardous chemicals? 29 CFR 1910.1450(e)(3)(ii)

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-   Does the Chemical Hygiene Plan provide requirements that fume hoods
    and other protective equipment function properly? 29 CFR
    1910.1450(e)(3)(iii)

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-   Does the Chemical Hygiene Plan contain provisions for employee
    information and training relative to chemical hazards? 29 CFR
    1910.1450(e)(3)(iv)

\_\_\_ \_\_\_ \_\_\_ 13. Do training records substantiate that workers
have received required training on hazard recognition and control
related to chemical safety? 29 CFR 1910.1200(h)(3)(i); 29 CFR
1910.1450(f)(1)

**Activity 2: Observe chemical storage locations and storage
practices.**

[Yes]{.underline} [No]{.underline} [N/A]{.underline}

\_\_\_ \_\_\_ \_\_\_ 14. Is each container containing a hazardous
chemical labeled, tagged or marked with the identity of the chemical,
and appropriate hazard warnings? (Labels are not required on portable
containers into which chemicals are transferred from labeled containers
and which are intended only for the immediate use of the employee who
made the transfer.) 29 CFR 1910.1200(f)(5); 29 CFR 1910.1200(f)(7); 29
CFR 1910.1450(h) (1)(i)

\_\_\_ \_\_\_ \_\_\_15. Are the labels on containers legible and
prominently displayed? 29 CFR 1910.1200(f)(9); 29 CFR 1910.1450(h)(1)(i)

\_\_\_ \_\_\_ \_\_\_ 16. Do containers and portable tanks containing
flammable and combustible liquids meet 29 CFR 1910.106(d), Table H-12
size requirements? 29 CFR 1910.106(d)(2)(iii)

\_\_\_ \_\_\_ \_\_\_ 17. Is each portable tank containing
flammable/combustible liquid provided with a means of venting to limit
internal pressure to less than 10 psig? 29 CFR 1910.106(d)(2)(ii)

\_\_\_ \_\_\_ \_\_\_ 18. Do flammable storage cabinets contain less than
60 gallons of Class I or Class II liquids, or less than 120 gallons of
Class III liquids? 29 CFR 1910.106(d)(3)(i)

\_\_\_ \_\_\_ \_\_\_ 19. Are flammable storage cabinets conspicuously
labeled \"Flammable Keep Fire Away\"? 29 CFR 1910.106(d)(3)(ii)

\_\_\_ \_\_\_ \_\_\_ 20. Does the flammable storage cabinet meet the
design requirements of 29 CFR 1910.106(d)(3)(ii)(a)?

\_\_\_ \_\_\_ \_\_\_ 21. Do flammable storage rooms meet the
requirements of 29 CFR 1910.106.(d)(4) for room design, quantity of
liquid stored, ventilation, storage spacing requirements, electrical
wiring, etc.?

\_\_\_ \_\_\_ \_\_\_ 22. Are suitable fire control devices, such as fire
extinguishers, available at locations where flammable or combustible
liquids are stored? 29 CFR 1910.106(d)(7)(i)

\_\_\_ \_\_\_ \_\_\_ 23. Are incompatible chemicals/materials segregated
to prevent accidental contact with one another? NFPA Standard 45,
7-2.3.4

\_\_\_ \_\_\_ \_\_\_ 24. Is the minimum amount of hazardous chemical
necessary for work stored in the open in the laboratory work area? NFPA
Standard 45, 7-2.3.1

\_\_\_ \_\_\_ \_\_\_ 25. Are safety showers and/or an eyewash stations
provided within the work area for immediate emergency use? 29 CFR
1910.151(c)

**Activity 3: Observe work activities involving handling or use of
chemicals.**

[Yes]{.underline} [No]{.underline} [N/A]{.underline}

\_\_\_ \_\_\_ \_\_\_ 26. Are users of flammable/combustible liquids
familiar with the hazard classification of the liquid? 29 CFR
1910.1200(h)(3)(ii)

\_\_\_ \_\_\_ \_\_\_ 27. Is bonding used when transferring Class I
flammable liquids between two conductive containers of greater volume
than 1.1 gallon? 29 CFR 1910.106(e)(6)(ii); NFPA Standard 45, 7-2.2.8

\_\_\_ \_\_\_ \_\_\_ 28. Has the maintenance work package or work
activity been reviewed by representatives of the safety and/or
environmental organizations for appropriate safety and environmental
controls? 29 CFR 1910.132(d)(2); 48 CFR 970.5204-2(b)(5)

\_\_\_ \_\_\_ \_\_\_ 29. Was an appropriate job safety analysis
performed for the work activity, identifying the hazards and
implementing controls? 29 CFR 1910.132(d)(1); 48 CFR 970.5204-2(b)(5)

\_\_\_ \_\_\_ \_\_\_ 30. Do the work instructions address use of
specific personnel protective equipment such as safety glasses with side
shields, rubber gloves, aprons, etc.? 29 CFR 1910.132(d)(1)(i); 29 CFR
1910.1200(h)(3)(iii); 29 CFR 1910.1450(f)(4)(ii)

\_\_\_ \_\_\_ \_\_\_ 31. Do the work instructions include procedures in
sufficient detail to ensure the safety and health of the workers? 29 CFR
1910.1200(h)(3)(iii); 29 CFR 1910.1450(e)(3)(i); 48 CFR 970.5204-2(b)(6)

\_\_\_ \_\_\_ \_\_\_ 32. Were potential chemical hazards discussed with
workers during the pre-job brief? 29 CFR 1910.1200(h)(3)(ii)

\_\_\_ \_\_\_ \_\_\_ 33. Are workers using the personal protective
equipment specified in the work instructions or procedures while
performing the activity? 29 CFR 1910.132(a); 10CFR 830.120(c)(2)(i)

\_\_\_ \_\_\_ \_\_\_ 34. Do workers follow instructions/procedures
prescribed in the work package? 10CFR 830.120(c)(2)(i)

\_\_\_ \_\_\_ \_\_\_ 35. Can workers describe the chemical hazards
associated with the work they are performing? 29 CFR
1910.1200(h)(3)(ii); 29 CFR 1910.1450(f)(4)(i)(B)

\_\_\_ \_\_\_ \_\_\_ 36. Were workers provided the opportunity to review
and understand the MSDSs for chemicals associated with the activity? 29
CFR 1910.1200(h)(1); 29 CFR 1910.1200(h)(2)(iii)

\_\_\_ \_\_\_ \_\_\_ 37. Can workers describe the correct response to an
emergency involving chemical hazards? 29 CFR 1910.1200(h)(2)(iii); 29
CFR 1910.1450(f)(4)(i)(C)

**NOTE**

The Facility Representative should avoid interrupting maintenance
personnel performing work on systems containing hazardous chemicals. The
Facility Representative should wait for opportune times to conduct
business with Facility Operators.

OTHER:

NOTES/COMMENTS:

PERSONNEL CONTACTED:

PROCEDURES REVIEWED:

FINDINGS:

Finding No.:

Description:

OBSERVATIONS:

Observation No.:

Description:

FOLLOWUP ITEMS:

CONTRACTOR MANAGEMENT DEBRIEFED AND RESULTS:

Signature:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_/\_\_\_\_\_/\_\_\_\_\_

Facility Representative