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lab safety audit info 5 01.1

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Laboratory Environmental Safety Audit;Issues and InformationYour Guide to Managing a Safe Laboratory at UVMEnvironmental Safety Facility - http://esf.uvm.edu656-5400Your laboratory was audited by staff from the Environmental Safety Facility, according to Procedure9 of the Environmental Management Plan (EMP). Please respond to the issues identified with theEnvironmental Safety Audit Response form within 4 weeks. Issues that you may have questionsabout are addressed in the Environmental Management Plan, the Chemical Hygiene Plan, and Pru-dent Practices in the Laboratory. These plans can be found on the web at http://esf.uvm.edu. PrudentPractices is available from the Environmental Safety Facility at 656-5400, at campus libraries andonline (http://books.nap.edu/books/0309052297/html/index.html). This guide follows the layout ofthe audit form.1. Housekeeping Issuesa. Contamination: Any visible stain or spill is considered to be a chemical hazard in theenvironment. All surfaces should be cleaned of contamination immediately, including spills ofnonhazardous chemicals.b. Sharps: Any unprotected sharps are a danger to anyone in the lab. Place them in a punc-ture proof container so that someone unaware of their presence is not accidentally injured.c. Food: OSHA 29CFR1910.141(g) and UVM procedures prohibit the storage, preparation orconsumption of food or drink in a location in which hazardous materials are present. Remove food,food refrigerators, coffee ...
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Laboratory Environmental Safety Audit;
Issues and Information
Your Guide to Managing a Safe Laboratory at UVM
Environmental Safety Facility - http://esf.uvm.edu
656-5400
Your laboratory was audited by staff from the Environmental Safety Facility, according to Procedure
9 of the Environmental Management Plan (EMP). Please respond to the issues identified with the
Environmental Safety Audit Response form within 4 weeks. Issues that you may have questions
about are addressed in the Environmental Management Plan, the Chemical Hygiene Plan, and Pru-
dent Practices in the Laboratory. These plans can be found on the web at http://esf.uvm.edu. Prudent
Practices is available from the Environmental Safety Facility at 656-5400, at campus libraries and
online (http://books.nap.edu/books/0309052297/html/index.html). This guide follows the layout of
the audit form.
1. Housekeeping Issues
a. Contamination: Any visible stain or spill is considered to be a chemical hazard in the
environment. All surfaces should be cleaned of contamination immediately, including spills of
nonhazardous chemicals.
b. Sharps: Any unprotected sharps are a danger to anyone in the lab. Place them in a punc-
ture proof container so that someone unaware of their presence is not accidentally injured.
c. Food: OSHA 29CFR1910.141(g) and UVM procedures prohibit the storage, preparation or
consumption of food or drink in a location in which hazardous materials are present. Remove food,
food refrigerators, coffee makers, tea bags, coffee cups, water bottles, candy wrappers, etc. from the
lab including from trash containers. Any sign that food or drink is or was present in the lab, even if
not consumed there, is prohibited.
d. Bench top or Fume hood cluttered: Upon entering a lab a government inspector immedi-
ately gets a visual impression. Stacked or unused equipment and supplies in disarray are signs of lax
lab practices and the inspectors assume the same holds true for labeling, proper storage locations and
compatibility of chemicals. Based on their first impression, they will look harder and spend more
time in these labs. Remember: Daily use quantities and properly labeled squeeze bottles of alcohol
or disinfectant for cleaning [as in 2(f) below] are the only chemical containers allowed to be stored
on the bench top.
e. Room cluttered/dirty: Avoid clutter, overflowing trash containers and storage of materials
outside of cabinets and shelves. The same concerns apply as in 1d above.
2. Chemicals and Waste Storage
a. (1) Floor: All chemicals and waste containers are required to be stored in cabinets, in
appliances, or on shelves. Exceptions: Properly labeled 5-gallon pails of nonflammable waste can be
stored on the floor; if the waste is liquid it requires chemically compatible secondary containment.
Fiber drums containing solid, nonhazardous salts can also be stored on the floor. Storage of larger
containers of waste in the lab requires prior approval from the ESF.
(2) Hood: Fume hoods are designed as a work environment and are not to be used for
chemical or waste storage. Excess storage clutters the hood work space and inhibits the air flow
needed for proper containment.
b. Liquids above eye level: All hazardous liquids must be stored below eye level (generally
4 ft high) and require chemically compatible secondary containment. This minimizes the chance of
Page 1
(Rev.7/19/01)chemicals being dropped and decreases the risk to eyes and face.
c. Household appliances: Flammable liquids can only be stored in appliances designed for
flammable liquid storage. Extremely violent and potentially fatal explosions can and have resulted
when flammables are stored in household refrigerators or freezers.
d. Food/Chemicals stored together: See 1c above.
e. Waste quantities: Laboratory waste containers must be tagged for disposal when they are
full or otherwise ready for disposal. No more than 30 gallons of waste or no more than 1 quart of
acutely hazardous waste may accumulate before being tagged for disposal. See EMP Procedure 5.
f. More than daily use quantities: All chemicals are required to be in proper storage loca-
tions and closed at all times except when transferring a portion of the chemical to be used into
another container or using a chemical in a process. Once the transfer or process has been completed
immediately placed back into storage. The presence ofthe original container(s) are required to be
any container(s) unattended on a bench top other than listed below is a violation of the regulations.
Exceptions: (1) Properly labeled bottles filled with only “daily use quantities” may be kept on the
bench top (in secondary containment) and need not be dated since they are not used for storage. At
the end of each day these bottles will be empty. (2) Properly labeled squeeze bottles of “alcohol or
disinfectant for cleaning” are also allowed to be stored on the bench top.
g. Flammables: All flammable liquids are required to be stored in a designated flammable
storage cabinet when not being transferred or utilized. Exception: See above.
h. Cabinet labels: All chemical storage cabinets require labeling with the hazard of the
contents. The regulations are specific as to size and wording for these labels. Labels are available
through the Environmental Safety Facility. (Example: Flammable, corrosive, toxic, oxidizer)
i. Under sink storage: Cabinets under the sink are not for laboratory chemical storage due to
the degradation of containers and chemicals. Only cleaning chemicals may be stored in cabinets
under the sink. These chemicals are still hazardous and do require secondary containment.
j. Chemicals/Food stored together: See 1c above.
2a. Chemical Storage Compatibility
Chemicals must be stored according to chemical compatibility to avoid reactions and main-
tain chemical quality. It is only acceptable to store chemicals alphabetically within compatible
groups. Follow these guidelines for storage: Consult the UVM Hazardous Chemicals of Concern list
attached to the Chemical Use Planning Form (EMP Procedure 1) for the basic groups of chemicals.
A rule of thumb is that chemicals in the same group may be stored together; however, individual
chemicals within the groups may have additional hazards. To view the Howard Hughes Medical
Institute video on Chemical Storage Hazards call the ESF.
Use the following guidelines to understand compatibility issues and further segregate chemi-
cals for proper storage. If it is unclear where a chemical should be stored contact the ESF staff.
a. Flammables and Corrosives: Corrosives (acids and alkalines) must be stored in a sepa-
rate cabinet from flammables.
b. Liquids in secondary containment: All hazardous liquids stored in cabinets, on shelves,
in appliances, etc. require a chemically compatible secondary containment tray so that if the primary
container breaks the spill is contained within the larger, secondary container.
c. Oxidizers: All oxidizers (solids and liquids, ex.: nitrates, nitrites and compounds contain-
ing the prefix “per”, such as ammonium persulfate) need to be identified and stored separately or can
be placed on a shelf with other chemicals provided there is a means of physical separation, i.e.,
secondary containment tray.
d. Solids and Liquids: All solid chemicals may be stored either in cabinets or on shelves,
while hazardous liquids should be placed in cabinets. There must be a physical separation; however,
Page 2between solids and all liquids. They may be placed on the same shelf but separated by secondary
containment for hazardous liquids [see 2a (b)] and by physical distance if the liquid is nonhazardous.
e. Other:
*Acids and alkalines should be stored in separate cabinets, but can be stored in the same
cabinet if separated by secondary containment trays and the cabinet is labeled as corrosives. If
oxidizing acids are present in this cabinet then all organic material must be removed. Check monthly
for crystallization on the container and degradation of caps.
Example: If nitric, perchloric, or chromic acids, etc. are present in the corrosives cabinet then
all organic corrosives such as acetic acid, amines, etc. need to be moved to a separate (organic)
corrosives cabinet (or limited amounts may be stored in the flammables cabinet, separated in differ-
ent secondary containment).
*Inorganic and organic acids can be stored in the same cabinet providing they have separate
secondary containment trays.
*Even though a chemical may have been diluted it must still be categorized as that chemical
group and stored as such.
*It is preferred that all hazardous liquid chemicals be placed in cabinets and not on shelves.
2b. Chemical/Container Condition
a. Chemical container condition: All chemical containers must be clean, intact and free of
damage, corrosion, crystallization and contamination.
b. Chemical container caps: Chemical containers must be properly closed and sealed at all
times except when transferring from one container to another. A cracked lid does not contain vapors
that chemicals give off and does not protect the chemical from contamination. Intact lids last ap-
proximately 1 year.
c. Outdated chemicals: EPA considers chemicals to be “inherently waste like” and subject
to fine if:
* A liquid chemical shows signs of crystallization
* A solid chemical does not flow freely when rotated
* There is evidence of a change in color or discoloration of original chemical,
* A chemical container is dusty or shows other signs of not being used recently
* A chemical has no planned use within the next year
d. Containers not sealed: Every container of chemicals or waste must be sealed tightly at all
times except when contents are being added or removed. This prevents evaporation and vapor
release of chemicals into the environment. Containers with funnels left in them or topped with
parafilm are not considered to be properly sealed.
e. Securing gas cylinders: All compressed gas cylinders must be properly secured to a wall
or bench top, no more than one row deep, and capped when no longer in use. Call the distributor for
cylinder pickup. Lecture bottles are cylinders and must be stored on their side and in cabinets when
not in use.
2c. Chemical Waste Identification and Storage
a. Waste container labeling: Laboratory waste containers must be properly labeled using a
completely filled out Laboratory Waste Accumulation label or, when ready for removal by ESF staff,
a completed and attached Laboratory Waste tag. The label must describe all contents, hazards and
the date accumulation started. Make sure the waste is accumulated in a chemically compatible
container.
b. Waste container tagging for removal: Waste containers must be tagged for disposal
when any of the following conditions exists:
Page 3* They are full
* They are ready for disposal
* When 30 gallons of laboratory waste has accumulated in the laboratory
* When 1 quart of acutely hazardous laboratory waste has accumulated in the laboratory
c. Waste bottles in hood: Hoods are a work environment and not a chemical storage area.
Waste containers clutter the work space and inhibit the air flow needed for proper operation. The
same issues apply as in 1d.
d. Waste containers not sealed: See 2b(d) above.
e. Other: The outside of waste containers and surrounding areas that have contamination due
to the adding of waste must be cleaned immediately upon completion of transfer.
3. Chemical Labeling
a. Chemicals with no labeling: The chemical must be completely identifiable by the infor-
mation on the container. Chemical formulas, structures and abbreviations do not achieve this. All
chemical containers, including flasks, beakers, reaction vessels and process equipment require the
following information: contents, hazards, and dates as specified below.
b. Chemicals without full chemical name, hazard warning and dates: Any container used
for a solid, liquid or gas material is required to have a minimum amount of information that is
legible at all times:
* Full chemical name: No structures, formulas or abbreviations of hazardous materials. This
information must be written in English and legible at all times.
* Hazard or warning of the material: The hazard or warning must be written in English and
legible at all times. Example: Flammable, Corrosive, Toxic, etc. Note that the labels of chemicals
packaged commercially before 1986 most often do not meet these requirements and must be updated
to reflect all required information, including the hazard.
* Dates received or transferred: Write “received” on the label and place a date next to it when
the container is received from the manufacturer or when the lab takes responsibility for the chemical
from another laboratory. Write a date when the chemical is transferred to another container and
assure the legibility of the complete label at all times. Remember: When chemicals are transferred,
the new container needs to be labeled with all essential information and legible at all times.
Note: If no label is present the material is assumed to be hazardous. Nonhazardous chemicals
may be labeled with abbreviations provided a key to the abbreviations is posted in prominent loca-
tions in the lab. Make sure the word “nonhazardous” is included in the heading and then list the
abbreviations and associated full chemical names. For referencing the hazard place a unique colored
sticker on each container associated with the key and to the left of the word “nonhazardous” on the
key. Reference the date on each container as above.
* Labeling Experimental or Archival Materials: The following information is required to
accompany experimental or archival materials:
* Originator: Indicate the name and department of the person to contact for safe emergency
response or handling information.
* Identification: Include, as a minimum, the laboratory notebook reference and primary
components that are known to be hazardous.
* All the known or suspected potential hazards.
* Date that the material was placed in the container.
Note: Groups of experimental or archival chemicals in very small containers can be stored
together in a secondary container labeled as above providing the individual materials are chemically
compatible. Be aware that the inner containers are not properly identified and cannot be placed
unattended anywhere in the lab.
Page 4c. Chemical labels degrading: Replace deteriorating labels before information is lost or
obscured. See 3b above.
d. Other: The labels (including the name, hazards and warnings) of empty chemical con-
tainers must be defaced by removing them or heavily obliterating them with a thick marker. Empty
containers may be triple rinsed and put into recycling. Those that held highly toxic chemicals (i.e.,
teratogens, mutagens and carcinogens) should be tagged and picked up as chemical waste with the
label intact. If in doubt call the ESF for guidance.
4. Worker Safety Training and Awareness
a. Inadequate safety or environmental awareness: It is the laboratory supervisor’s respon-
sibility to train all lab workers according to regulatory requirements. Government and UVM stan-
dards require that the contents and availability of the OSHA Laboratory Standard (and Appendi-
ces), the UVM Chemical Hygiene Plan (CHP), the UVM Environmental Management Plan
(EMP), the OSHA Bloodborne Pathogens Standard, and the UVM (Bloodborne Pathogens)
Exposure Control Plan be made available to employees. This training, along with general lab
safety and emergency response procedures, can be provided to lab workers by ESF staff in Labora-
tory Safety Trainings (which include Chemical Safety, Environmental Awareness and Bloodborne
Pathogens trainings). Other safety training is specific to the work of the laboratory and must be
delivered by the laboratory supervisor. If, through interviews of employees, inspectors determine
there is a lack of knowledge of these standards, or the individual has knowledge but does not have
access to the standards then it is considered a violation of government regulations.
* OSHA Laboratory Standard website: http://www.osha-slc.gov/OshStd_data/
1910_1450.html
* OSHA Bloodborne Pathogen Standard website: http://www.osha-slc.gov/SLTC/
bloodbornepathogens/index.html
* CHP and EMP and UVM Exposure Control Plan website: http://esf.uvm.edu
b. Inadequate training documentation: All training must be documented by the laboratory
supervisor, according to Procedure 8 of the EMP, using the Laboratory Supervision and Safety
Training Documentation form. These forms are available through the ESF. Keep a completed copy
for your laboratory training file and return the original document to the ESF. Update as needed,
following the same procedure. The lab supervisor may use this form for ESF and in-house trainings
(specifying the contents of the training) or may use a separate document for in-house trainings.
5. Chemical Safety Information Available
a. MSDS or other chemical information not available: Material Safety Data Sheets
(MSDS) must be available and the location of chemical safety information known to employees
whenever work is being accomplished in the laboratory. A folder with an MSDS collection or a
computer with a bookmarked website is acceptable. Two MSDS websites can be accessed at
http://esf.uvm.edu by clicking on “Working Safely at the University of Vermont”.
b. Chemical Use Planning Forms incomplete: Chemical Use Planning Forms must be
completed and signed by the laboratory supervisor and kept on file for access by lab workers, gov-
ernment inspectors and UVM laboratory auditors.
c. Workers unaware of information sources: During government inspections and labora-
tory audits lab workers are asked about a variety of information sources. Lab workers need to have
knowledge of and access to this information to work safely in the laboratory. This information is
listed in the Laboratory Supervisor’s Guide to Training available from the ESF. Also see 4a above.
d. UVM Laboratory Self-Inspection Forms: Procedure 7 of the EMP covers laboratory
Page 5self-inspections, which must be done at least once per month. Keep a file of these completed forms
for access by government regulators during EPA/OSHA inspections and UVM ESF staff during
routine lab safety audits. All lab workers need to know where these are located.
6. Emergency Preparedness
a. No emergency notification sign: The main entry door of each laboratory must be posted
with accurate emergency notification information. These signs are available through the ESF.
b. Emergency notification sign not complete/current: Emergency notification signs must
be updated to reflect current contacts and hazards present in the lab. Home phone numbers must also
be included for off hours. (Evenings and weekends)
c. Eye wash/safety showers not flushed or logged weekly: Eye washes, drench hoses and
safety showers need to be flushed weekly to assure their proper operation in an emergency and to
flush contaminants from the lines. Microbial growth in stagnant water in the lines can cause
infection that leads to blindness. This flushing is required to be documented using either a tag
attached to the unit (available from the ESF) or a form on the wall and government inspectors will
look for this documentation. They may look for physical evidence in spite of proper logging (dust on
the unit or dirty looking water) that flushing has not been done every week.
d. Chemical spill kits: All laboratories that have chemicals are required to have spill equip-
ment necessary for emergency response to small chemical spills (benchtop type spills). It must be
readily available and the location known by all workers. These kits are available from the ESF; if
any material is used call the ESF for replacement.
e. Eye wash station required: Any laboratory that uses chemicals is required to have an eye
wash (may be a drench hose) available within 10 seconds of any location within the lab. For guid-
ance on whether a unit is required contact the ESF or call Service Operations to schedule installa-
tion.
f. Eye wash station blocked: Eye washes, drench hoses and safety showers must be free of
obstruction and readily accessible at all times. No material may be placed on the benchtops obstruct-
ing a drench hose or on the floor under a safety shower or eye wash.
g. Other: All eye washes, drench hoses and safety showers must be boldly labeled for ease of
recognition in an emergency. The appropriate signs are available from the ESF.
Any exceptions to these policies must be documented by written memo and kept on
file in the laboratory. Describe the issue and the reasons (including any professional
references) for not complying with guidelines in this document. This documentation
does not relieve you of the responsibility to comply with government guidelines, but
may lessen the severity of the violation assessed. Be sure that the lab supervisor is
clearly identified and that person’s signature is included.
Page 6