OSHA has once again published its list of its most-cited standards. This time, they discuss the 2019 heavy-hitters, and once again, chemical management issues top the list. Year after year organizations are fined for incomplete management of their chemical hygiene program. Labs have it even harder- they have to adhere to two sets of standards, Hazard Communication and the Laboratory Standard. That means a great number of regulations must be followed closely, but it can be done well with good oversight.

First, make sure the lab has a designated Chemical Hygiene Officer. OSHA requires this, and the CHO should be someone with knowledge and experience to adequately manage a chemical program in the lab. Ensure policies and procedures are in place which outline proper safety procedures as well as handling and storage requirements for the chemicals used in the department. A written Chemical Hygiene Plan (CHP) should include details about engineering controls, PPE, and practices put in place to protect employees from chemical hazards on the job.

OSHA also requires that the effectiveness of this Chemical Hygiene Plan is evaluated every year. This evaluation should be documented, and any deficiencies noted should be used to update the overall plan. This evaluation can be done using a review of many aspects of chemical safety.

First, review any chemical spills that may have occurred in the past year. How many were there? What type were they? Was there anything in common with these spills, and what was follow-up for each one? Take a look at spill drill records. Were drills performed? Was there improvement in the response? These records can easily show issues with the important training aspects of chemical safety.

Check to see that the current CHP is up to date and that it is available to all staff. Next, review the management of Safety Data Sheets (SDS). Staff should have access to them at all times (whether they are in electronic or paper format), and you should check to see that employees know how to access them and under what circumstances a SDS might be needed quickly.

The chemical inventory should be updated on a regular basis as well. The inventory should include a total chemical risk assessment for every chemical used in the department. All chemicals need to be evaluated to determine if they are a carcinogen, an acutely toxic substance, or a reproductive toxin. All of these assessments can be documented on the chemical inventory form and updated as necessary.

Chemical storage should also be reviewed as part of the CHP annual evaluation of effectiveness. Perform a visual inspection and ensure that incompatible chemicals are not stored together. See that chemicals are stored below shoulder level and that adequate spill kits are located nearby. Acids and bases should be stored near the floor, and bottle carriers should be in use if these corrosive chemicals are transported for long distances in the department.

A review of proper flammable storage is also necessary. Make sure flammable chemicals are not stored near heat sources and that working supplies are limited such that most are kept inside flammable storage cabinets. Flammable cabinets should have self-closing doors. All lab refrigerators and freezers must be labeled as to their capacity to store flammable liquids.

Review exposure monitoring records as well. If employees are exposed to formaldehyde or xylene, there should be an ongoing monitoring process in place. Make sure vapor badge readings are within safe limits and that employees have been notified of results in a timely manner. If readings are elevated, check to see that appropriate actions were taken such as repeat testing and needed process changes.

Once these aspects of the chemical management program have been evaluated, you can now make a reasonable determination about the overall effectiveness of the program. If the majority of the elements are in place, and if spills and exposures were kept to a minimum in the lats year, you could label your program as effective. If not, note the issues and create an action plan to make improvements which include a focus on problem areas. Document this evaluation and report on it every year during safety committee meetings.

The management of a laboratory’s entire chemical hygiene program is no small job, and there are several guiding standards and regulations. However, finding those rules and even locating example CHP templates is not difficult. Use the OSHA website (www.osha.gov) and checklists from lab accrediting organizations (like CAP, for example). The Chemical Hygiene Officer has a big role, but by following these tips each year, a solid safety program that protects staff from chemical hazards can be easily realized.