**Research and Development Service**

**Written Chemical Hygiene Plan**

**I. General:**

This section of the policy describes the chemical hygiene plan for
Research and Development Service as required by OSHA's Occupational
Exposure to Hazardous Chemicals in Laboratories Standard, 29 CFR
1910.1450.

In order to comply with this standard, Research Service has established
a plan to ensure that employees are protected from health hazards
associated with hazardous chemicals in the laboratory, and capable of
keeping exposures below the permissible exposure limits specified in 29
CFR part 1910. subpart 2. Questions regarding this plan should be
directed to facility Safety Manager/Chemical Hygiene Officer, via pager
713-841-0933.

This plan shall be available through employee's supervisor and the
Research and Development Service Safety Subcommittee representatives.

A review and evaluation of the Chemical Hygiene Plan will be conducted
annually by the Medical Center Safety Manager.

The person responsible for implementation of this plan is the Chief,
Research and Development Service.

**II. Standard Operating Procedures:**

Research Service laboratory work, which involves the use of hazardous
chemicals, standard operating procedures have been addressed in order to
reduce potential safety and/or health hazards caused by such use. The
procedures include use of appropriate personal protective equipment and
engineering control measures such as room air changes/hour, negative air
work environment, biological, ionization and fume hoods, and maintenance
procedures for these engineering control measures including testing of
proper function of the maintenance of such equipment.

These specific procedures that Research Service has implemented are:

***A. General Rules for Safe Practices in Laboratories***

1\. *Accidents and spills:* Eye contact: Promptly flush eyes with water
for a prolonged period (15 minutes) and seek medical attention from the
Employee Health Clinic.

Ingestion: Encourage the victim to drink large amounts of water.

Skin Contact: Promptly flush the affected area with water and remove any
contaminated clothing. If symptoms persist after washing. Seek medical
attention from the Employee Health Clinic.

Spills: Call 911.

2\. *Avoidance of "routine" exposure:* Develop and encourage safe
habits; avoid unnecessary exposure to chemicals by any route.

Do not smell or taste chemicals. Vent apparatus that may discharge toxic
chemicals (vacuum pumps, distillation columns, etc.) into local exhaust
hoods.

Inspect gloves and test glove boxes before use.

Do not allow release of toxic substances in cold rooms and warm rooms,
since these have self contained recirulated atmospheres.

3.  *Choice of chemicals:* Use only those chemicals for which the
    quality of the available ventilation system is appropriate.

4\. *Eating, smoking, etc.:* Don't eat, drink, smoke, chew gum, or apply
cosmetics in areas where laboratory chemicals are present; wash hands
before conducting these activities.

Do not store, handle or consume food, ice, or beverages in storage
areas, refrigerators, glassware or utensils that are also used for
laboratory operations.

5\. *Equipment and glassware:* Handle and store laboratory glassware
with care to avoid damage; do not use damaged glassware. Use extra care
with Dewar flasks and other evacuated glass apparatus; shield or wrap
them to contain chemicals and fragments should implosion occur. Use
equipment only for its [designed]{.underline} purpose.

6\. *Exiting:* Wash areas of exposed skin well before leaving the
laboratory.

7\. *Horseplay:* Avoid practical jokes or other behavior, which might
confuse, startle or distract another worker.

8\. *Mouth suction:* Do not use mouth suction for pipeting or starting a
siphon.

9\. *Personal apparel:* Confine long hair and loose clothing. Wear
closed toe shoes at all times in the laboratory but do not wear sandals,
perforated shoes, sneakers, or shorts.

10\. *Personal housekeeping:* Keep the work area clean and uncluttered
with chemicals and equipment being properly labeled and stored; clean up
the area on completion of an operation or at the end of each day.

11\. *Person protection:* Assure that appropriate eye protection is worn
where a splash may occur by all persons, including visitors, where
chemicals are stored or handled.

Wear appropriate gloves per Safety Manager guidance when the potential
for contact with toxic materials exists; inspect the gloves before each
use, wash them before removal, and replace them periodically.

Use appropriate respiratory equipment per Safety Manager guidance when
air contaminant concentrations are not sufficiently restricted by
engineering controls. Inspect the respirator before use.

Use any other protective and emergency apparel and equipment as directed
by Safety Manager.

Do not use contact lenses in the laboratory.

Remove laboratory coats when contaminated.

12\. *Planning:* Seek information and advice about hazards per Safety
Manager guidance, plan appropriate protection procedures, and plan
positioning of equipment before beginning any new operation.

13\. *Unattended operations:* Notify Safety Manager during
administrative hours, via pager 0730, of any unattended laboratory
operations; then leave lights on, place and appropriate sign on the
door, and provide for containment of toxic substances in the event of
failure of a utility service (such as cooling water) to an unattended
operation.

14\. *Use of hoods:* Use the hood for operations which [might
result]{.underline} in release of toxic chemical vapors or dust.

As a rule of thumb, use a hood or other local ventilation device when
working with any appreciable volatile substance with a TLV of 100 ppm or
less.

Confirm adequate hood performance before use; keep hood closed at all
times except when work within the hood is conducted; keep material in
hoods to an absolute minimum and do not allow material to block vents or
air flow.

Leave the hood "on" when it is not in active use if toxic substances are
stored in it or if it is uncertain whether adequate general laboratory
ventilation will be maintained when it is "off".

15\. *Vigilance:* Be alert to unsafe conditions and see that they are
reported to Principal Investigator when detected.

16\. *Waste disposal:* The plan for each laboratory operation includes
procedures and training for waste disposal:

Deposit chemical waste per Safety Manager guidance in appropriately
labeled receptacles and follow all other waste disposal procedures per
Safety Manager guidance.

Do not discharge to the sewer concentrated acids or bases; highly toxic,
malodorous, or lachrymatory substances; or any substances which might
interfere with the biological activity of waste water treatment plants,
create fire or explosion hazards, cause structural damage or obstruct
flow.

17\. *Working alone:* Do not work alone in a building; do not work alone
in a laboratory if the procedures being conducted could result in
employee injury or illness.

In addition laboratory personnel will utilize NFPA 491M, Hazardous
Chemical Reactions to correctly identify and avoid preventable hazardous
chemical reactions. Call pager 713-841-0933 for assistance.

**III. Employee Exposure:**

The facility Safety Manager provides an initial determination of
employee's exposure during annual Walk Through inspection and/or upon
request from the supervisor for any substance regulated by a standard
(29 CFR 1910.001 through 29 CFR 1910.1101) which requires monitoring if
there is reason to believe that exposure levels for that substance
routinely exceed the action level or in the absence of an action level,
the permissible exposure level or PEL. If this initial monitoring
discloses employee exposure over the action level or PEL, exposure
monitoring is done in accordance with the relevant standard. This
monitoring may be terminated in accordance with the relevant standard
when permissible.

Where the use of respirators is determined to be necessary to maintain
exposure below permissible limits, appropriate respiratory protection
per Safety Manager evaluation will be provided at no cost to employees.
Respirators are selected and used in accordance with the requirements of
29 CFR 1910.134.

The Safety Manager will notify the effected employee of these monitoring
results in writing via Service Chief or by posting at worksite within 15
working days after the receipt of any test results.

**IV. Employee Information and Training:**

Research Service supervisor/principal investigators will provide
employees with initial and annual refresher information and training on
hazardous chemicals used in their work area at the time of initial
assignment, and prior to assignments involving new laboratory procedures
or new exposure.

The following information is conveyed to employees:

a\. The contents of the Occupational Exposure to Hazardous Chemicals in
Laboratories Standard 29 CFR 1910.1450 its appendices and Hazardous
Communication Standard 29 CFR 1910.1200.

b\. The location and availability of Service Chemical Hygiene Plan.

c\. The permissible exposure limits for OSHA regulated substances or
recommended exposure limits for other hazardous chemicals where there is
no available OSHA standard.

d\. The signs and symptoms associated with exposure to hazardous
chemicals used in the laboratory and,

e\. The location and availability of known reference material on the
hazards, safe handling, storage and disposal of hazardous chemicals
found in the laboratory including but not limited to Material Safety
Data Sheets received from the chemical supplier. - See paragraph IX of
this section.

In addition to the above information, employees are trained on the
following:

a\. Methods and observations that may be used to detect the presence or
release of a hazardous chemical in the work area.

b\. The physical and health hazards of chemicals in the work area.

c\. The measures employees can take to protect themselves from these
hazards, including specific procedures that have been implemented to
protect employees from exposure to hazardous chemicals, such as
appropriate work practices, emergency procedures, and personal
protective equipment to be used, and

After attending the class, each employee will sign a form (appendix A)
given by the supervisor/lead technician stating that they reviewed the
training outlined above and had the opportunity to ask questions about
any uncertainty remaining. This documentation is then forwarded to the
Program Support Assistant, located in Bldg. 110, Room 318, where it will
be entered into the hospital computer as training completed and filed in
a three ring binder to be kept for review.

**V. Medical Program:**

VAMC provides all employees who work with hazardous chemicals the right
to receive medical attention, including any follow-up examination, which
the examining physician determines to be necessary, for the following
circumstances:

A. Whenever an employee develops signs or symptoms associated with a
hazardous chemical to which the employee may have been exposed in the
laboratory, the employee is provided an opportunity to receive an
appropriate medical examination.

B. Where exposure monitoring reveals an exposure routinely above the
action level (or in the absence of an action level, the PEL) for an OSHA
regulated substance for which there are exposure monitoring and medical
surveillance requirements, medical surveillance is established for the
effected employee as prescribed by the particular standard.

C. Whenever an event takes place in the work area such as a spill, leak,
explosion, or occurrence resulting in the likelihood of a hazardous
exposure, the affected employee is provided an opportunity for a medical
consultation. This consultation is for the purpose of determining the
need for a medical examination. Employee Health Physician as necessary
will provide an appropriate medical examination.

Medical examinations and consultations are performed by or under direct
supervision of a licensed physician, are provided at no cost to
employees without loss of pay, and at a reasonable time and place. The
examining physician is provided:

A. The identity of hazardous chemical(s) to which employee may have been
exposed to;

B. A description of conditions under which the exposure occurred
including quantitative exposure data, if available; and

C. A description of the signs and symptoms of exposure that the employee
is experiencing if any.

A written report from the examining physician based on an examination or
consultation is provided to the employee. This report includes:

A. Any recommendation of further medical follow-up;

B. The results of the medical examination and any associated tests;

C. Any medical condition that may be revealed in the course of the
examination which may place the employee at increased risk as a result
of exposure to a hazardous chemical found in; the workplace; and

D. A statement that the employee has been informed by the physician of
the results of the consultation or medical examination and any medical
condition that may require further examination or treatment.

This written opinion will not include any specific findings of diagnoses
that are unrelated to occupation exposure.

**VI. Special Procedures/Provisions**:

Research Service has certain procedures or activities that require prior
approval from facility Radiation Safety Officer, Safety Manager,
Chairperson Laser Safety Committee, Chairperson Biohazard Subcommittee,
or Chairperson Infection Control Committee before implementation. These
procedures are as follows:

Work with Nuclear Regulatory Commission, Environmental Protection
agency, Occupation Safety and Health Administration, Texas Department of
Health or Texas Water Commission regulated substances/ material and
those work procedures included in Communicable Disease Center prudent
practice recommendations.

There are special provisions for additional employee protection for work
with particularly hazardous substances used. These substances include
"select" carcinogens", reproductive toxins, and substances which have a
high degree of acute toxicity.

Specific considerations for these particular hazardous substance(s)
classified as potentially carcinogenic by the International Agency for
Research on Cancer, the National Toxicology Program, the National
Institute for Occupational Safety and Health, the Occupational Safety
and Health Administration or the American Conference of Governmental
Industrial Hygienists include use, storage and disposed in accordance
with the Chemsyn Science Laboratory handbook entitled "Handling Chemical
Carcinogens, a Safety Guide for the Laboratory".

***A. Working with Allergens and Embryotoxins***

1\. *Allergens:* (examples: diazomethane, isocyanates, bichromates):
Wear suitable gloves to prevent hand contact with allergens or
substances of unknown allergenic activity.

2\. *Embryotoxins:* (examples: organomercurials, lead compounds,
formamide): If you are a woman of childbearing age, handle these
substances only in a hood whose satisfactory performance has been
confirmed, using appropriate protective apparel (especially gloves) to
prevent skin contact.

Review each use of these materials with the research supervisor and
review continuing uses annually or whenever a procedural change is made.

Store these substances, properly labeled, in an adequately ventilated
area. In and unbreakable secondary container.

Notify supervisor of all incidents of exposure or spills and consult
Employee Health Physician.

***B. Work with Chemicals of Moderate Chronic or High Acute Toxicity***

EXAMPLES: disopropyiflurophosphate, hydrofluoric acid, hydrogen cyanide.

Supplemental rules to be followed in addition to those mentioned above:

1\. *Aim:* To minimize exposure to these toxic substances by any route
using all reasonable precautions.

2\. *Applicability:* These precautions are appropriate for substances
with moderate chronic or high acute toxicity.

3\. *Location:* Use and store these substances only in areas of
restricted access with special warning signs.

Always use a hood (previously evaluated to confirm adequate performance.

4\. *Personal protection:* Always avoid skin contact by use of gloves
and long sleeves (and other protective apparel as appropriate per Safety
Manager guidance). Always wash hands and arms immediately after working
with these materials.

5\. *Records:* Supervisors maintain records for employee health of the
amounts of materials on hand, amounts used, and the names of the workers
involved.

6\. *Prevention of spills and accidents:* Be prepared for accidents and
spills.

Assure that at least 2 people are present at all times if a compound in
use is highly toxic or of unknown toxicity.

Store breakable containers of these substances in chemically resistant
trays; also work and mount apparatus above such trays or cover work and
storage surfaces with removable, absorbent, plastic backed paper.

7\. *Waste:* Contact Safety Manager via pager 713-841-0933 for moderate,
high, or chronic toxicity waste pick up.

Store contaminated waste in closed, suitably labeled, impervious
containers (for liquids, in glass or plastic bottles half-filled with
vermiculite).

***C. Work with Chemicals of High Chronic Toxicity***

(Examples: dimethyimercury and nickel carbonyl, benzo-a-pyrene,
N-nitrosodiethylamine, other human carcinogens or substances with high
carcinogenic potency in animals.

Further supplemental rules to be followed in addition to all these
mentioned above, for work with substances of known high chronic
toxicity.

1\. *Access:* Conduct all transfers and work with these substances to a
"controlled area": a restricted hood, glove box, or portion of a lab,
designated for ruse of highly toxic substances, for which all people
with access are aware of the substances being used and necessary
precautions.

2\. *Approvals:* Prepare a written plan for use and disposal of these
materials and obtain the approval of the Safety Manager.

3\. *Non-contamination/Decontamination:* Protect vacuum pumps against
contamination by scrubbers or HEPA filters and vent them into the hood.
Decontaminate vacuum pumps or other contaminated equipment. Including
glassware in the hood before removing them from the controlled area.

Decontaminate the controlled area per manufacturer instructions before
normal work is resumed there.

4\. *Exiting:* On leaving a controlled area, remove any protective
apparel (placing it in an appropriate, labeled container) and thoroughly
wash hands, forearms, face, and neck.

5\. *Housekeeping:* Laboratory personnel will use a wet mop or a vacuum
cleaner equipped with a HEPA filter instead of dry sweeping if the toxic
substance was a dry powder.

6\. *Records:* Supervisors maintain records for employee health of the
amounts of materials on hand, amounts used, and the names of the workers
involved.

7\. *Signs and labels:* Assure that the controlled area is conspicuously
marked with warning and restricted access signs and that all containers
of these substances are appropriately labeled with identity and warning
labels.

8\. *Spills:* Call 911.

9\. *Storage:* Store containers of these chemicals only in a ventilated
limited access area. In appropriately labeled unbreakable, chemically
resistant, secondary containers.

10\. *Glove boxes:* Trap the exit gases or filter them through a HEPA
filter and then release them through a HEPA filter and then release them
into the hood.

11\. *Waste:* Contact Safety Manager via pager 713-841-0933 for
moderate, high or chronic toxicity wastes pick up.

Store contaminated waste in closed, suitably labeled, impervious
containers (for liquids, in glass or plastic bottles half-filled with
vermiculite).

***D. Animal Work with Chemicals of High Chronic Toxicity***

1\. *Access:* For large scale studies, special facilities with
restricted assess are preferable.

2\. *Administration of the toxic substances:* When possible, administer
the substance by injection or gavage instead of in the diet, use a
caging system under negative pressure or under laminar air flow directed
toward HEPA filters.

3\. *Aerosol suppression:* Devise procedures which minimize formation
and disposal of contaminated aerosols, including those from food, urine,
and feces (e.g., use HEPA filtered vacuum equipment for cleaning,
moisten contaminated bedding before removal from the cage, mix diets in
closed containers in a hood).

4\. *Personal protection:* When working in the animal room, wear plastic
or rubber gloves, fully buttoned laboratory coat or jumpsuit and, if
needed because of incomplete suppression of aerosols, other apparel and
equipment (shoe and head coverings, respirator).

5\. *Waste:* Contact Safety Manager via pager 713-841-0933 for moderate,
high or chronic toxicity wastes pick up.

Store contaminated waste in closed, suitably labeled, impervious
containers (for liquids, in glass or plastic bottles half-filled with
vermiculite).

**VII. Hazard Identification:**

Research Service will assure labels on incoming containers of hazardous
chemicals are not removed or defaced; and material safety data sheets
that are received with incoming shipments of hazardous chemicals are
maintained and readily accessible to laboratory employees.

For chemical substances developed in the laboratory, the following
procedures have been implemented:

A. For known composition for chemicals substances produced exclusively
for the laboratory use, which are determined by the supervisor to be
hazardous, the appropriate training and labeling will be provided;

B. No unknown composition of chemicals produced as a by product, is
permitted and;

C. For chemical substances produced for another user outside of the
laboratory, Research Service complies with the Hazard Communication
Standard 29 CFR 1910.1200, including the requirements of preparation of
material safety data sheets and labeling.

**VIII. Record Keeping:**

VAMC establishes and maintains for each employee an accurate record of
any measurements taken to monitor employee exposure and any medical
consultation and examinations including tests or written opinions as
required by the Standard. These records are kept, transferred, and made
available in accordance with 29 CFR 1910.20, Access to Employee and
Medical Records. Contact facility Safety Manager; via pager 713-841-0933
or Employee Health Physician, extension 7003 for employee access
information.

**IX. Reference Material**

The below listed reference material, identified in this Chemical Hygiene
Plan may be obtained from facility Safety Manager, via pager
713-841-0933.

NFPA 491M, Manual of Hazardous Chemical Reactions.

Handling Chemical Carcinogens: a Safety Guide for the Laboratory.

Prudent Practices for Handling Hazardous Chemicals in Laboratories.

OSHA 1910.1450, Occupational Exposure to Hazardous Chemicals in
Laboratories.

OSHA 1910.20, Access to Employee Exposure and Medical Records.

OSHA 1910.1200, Hazard Communication Standard.