To maintain an effective chemical safety program, it is important for all parties to clearly understand the responsibilities inherent in their roles. Persons responsible for chemical hygiene include, but are not limited to, the following:
- Assistant Vice Chancellor of Environment, Health & Safety (EH&S)
- Provide the necessary staffing and resources for maintaining an effective Chemical Safety Program
- Review and approve campus policies on issues related to the purchase, use, storage, and disposal of chemicals including the UW–Madison Campus Chemical Hygiene Plan
- University Chemical Hygiene Officer (CHO)
- Develop, establish, maintain, and revise the Campus Chemical Hygiene Plan and policies related to chemical use
- Facilitate the campus community’s understanding of, and compliance with, required chemical health and safety regulations
- Provide technical resources to Principal Investigators on the development and implementation of Laboratory-specific Chemical Hygiene Plans (CHPs)
- Provide guidance for the safe handling, storage, and disposal of chemicals used on campus
- Facilitate implementation of processes that support campus sustainability efforts
- Review compliance with this policy and develop methods to promote compliance
- Environment, Health & Safety Department Staff
EH&S Department Staff have extensive expertise covering all areas of safety and compliance. EH&S Department Staff will:
- Develop, implement, and manage a comprehensive safety program for the university
- Develop and prepare safety training specific to laboratory operations
- Develop technical guidance materials and documents for the safe handling, storage, and disposal of chemicals used on campus
- Perform laboratory risk assessments upon request
- Survey laboratory facilities, identify hazards, identify issues of non-compliance, and offer recommendations for improved practices
- Inspect campus fire extinguishers annually to ensure their proper operation
- Maintain records of all relevant inspections
- Coordinate campus chemical emergency response with the Madison Fire Department's Hazardous Incident Response Team
- Maintain EH&S website containing easily accessible information, guidance, forms, and other information related to the CHP
- Principal Investigator (PI)
The PI may delegate these health and safety responsibilities to a trained and knowledgeable individual (e.g., the Laboratory Chemical Hygiene Officer). However, the PI maintains the responsibility of ensuring that the duties are appropriately performed.
- Responsible for chemical hygiene in the laboratory
- Develop and implement the laboratory-specific CHP
- Perform a risk assessment on chemical-related activities within their laboratories
- Assess individual roles of their staff and hazards associated with those roles
- Approve Standard Operating Protocols (SOPs), ensuring that Personal Protective Equipment (PPE), engineering controls, and administrative controls provide adequate protection to staff
- Determine (and document within the SOP) what procedures must only be performed with the explicit approval of the Principal Investigator
- Ensure that laboratory personnel understand and follow the chemical safety policies, practices, and regulations related to their laboratory’s operation
- Provide access to manufacturers’ Safety Data Sheets (SDSs), campus and laboratory CHPs, and other safety-related information for laboratory personnel
- Ensure that PPE and required safety equipment is available, in working order, and that laboratory personnel are trained in PPE use
- Ensure all laboratory personnel receive the necessary information and training to understand the hazards of the chemicals present in their work area. Including the following as applicable:
- The contents of 29 C.F.R. § 1910.1450 Occupational Exposure to Hazardous Chemicals in Laboratories (OSHA Laboratory Standard)
- The location and availability of this policy
- The permissible exposure limits (listed in 29 C.F.R. § 1910.1000 Air Contaminants) for OSHA-regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard
- Signs and symptoms associated with exposures to hazardous chemicals used in the laboratory
- The location and availability of known reference materials on the hazards, safe handling, storage, and disposal of hazardous chemicals found in the laboratory including SDS received from the chemical supplier
- The specific physical and health hazards (e.g., corrosive, carcinogenic, flammable, water-reactive chemicals), as defined in 29 C.F.R. § 1910.1200, Appendix A: Health Hazard Criteria (Mandatory), associated with any hazardous chemicals in the laboratory
- Methods (e.g., engineering controls, administrative controls, PPE) used to control and minimize exposure to hazardous chemicals in the laboratory
- Any laboratory-specific emergency procedures and the location and proper use of safety equipment (e.g., fume hood, fire extinguisher, emergency eyewash, shower)
- Methods and observations used to detect the presence or release of a hazardous chemical (e.g., monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released)
- Personnel who generate waste or work in Satellite Accumulation Areas need to be Training in waste handling, waste management, and emergency procedures for laboratory personnel working with Satellite Accumulation Areas
- Ensure that appropriate storage practices of chemicals are maintained
- Complete and keep the Laboratory Emergency Information (Door) Card up to date up to date
- Conduct regular chemical hygiene and housekeeping inspections, including inspection of emergency equipment
- Correct any unsafe conditions identified through self-inspections or inspections by EH&S or other authorized safety professionals
- Determine and ensure appropriate transportation of hazardous chemicals according to Department of Transportation (DOT) and International Air Transportation Association (IATA) regulations, see Transporting and Shipping of Hazardous Materials section of this policy
- Ensure proper disposal of hazardous materials according to university procedures
- Maintain all records associated with the laboratory. These records include:
- Copies of Laboratory CHPs
- Training records for laboratory personnel
- Records of any internal audits or inspections
- Results of any exposure monitoring
- Report any injuries or incidents as outlined in the Chemical Safety and Compliance Requirements section within 24 hours of occurrence
- Help in investigations of laboratory incidents
- Maintain compliance with federal, state, and local regulations related to the use of hazardous chemicals in their laboratory
- Laboratory Personnel
Individuals working in a campus lab using chemicals must:
- Follow campus and laboratory practices, policies, and SOPs as outlined in the Campus and Laboratory-specific CHPs
- Attend all safety training as required by the PI
- Only perform procedures and operate equipment that they have been authorized and trained to use safely
- Review relevant information (e.g., SDS, EHS guidance documents, related articles found during a thorough literature search) on chemical reactivity, physical properties, and toxicological properties of hazardous materials prior to use of the material
- Have knowledge of emergency procedures prior to working with hazardous chemicals
- Incorporate safety in the planning of all experiments and procedures
- Use personal protective equipment and hazard control devices provided for the task
- Routinely check that engineering controls are functioning
- Inspect and maintain equipment (e.g., glassware, electrical wiring, mechanical systems, tubing and fittings, high energy sources) for safety and appropriate functionality
- Understand the inherent risk of any laboratory procedure
- Report any unsafe condition immediately to the PI or other safety personnel
- Report incidents involving chemical spills, exposures, work-related injuries, or illnesses to the PI
- Keep work areas clean and orderly
- Avoid behavior which could lead to injury
- Dispose of hazardous waste according to university policy and procedures
- Consult with the PI or with EH&S staff on any safety concerns or questions
- EH&S Hazardous Waste Management Group
- Maintain compliance with all regulations regarding hazardous waste
- Maintain the On-Site Hazardous Materials Management (OSHMM) program which:
- Removes unwanted hazardous materials directly from laboratories
- Transports hazardous materials, when required, between campus buildings
- Maintains a chemical redistribution system to reduce hazardous waste disposal
- Maintains a laboratory request system for hazardous materials pickup, lab cleanouts, and lab moves
- Facilities Planning & Management (FP&M) Physical Plant
For buildings owned and/or contractually maintained by UW-Madison, FP&M Physical Plant has responsibilities to:
- Ensure proper function of fume hoods
- Perform annual inspections of campus fume hoods
- All fume hoods that pass inspection must have a dated certification sticker placed on the hood
- All fume hoods that fail inspection must immediately removed from service
- Repair and maintain fume hoods and associated infrastructure
- Inspect campus safety showers and eyewash stations annually to ensure their proper operation
- Maintain general building infrastructure