The University of Wisconsin–Madison is committed to protecting employees from the health and physical hazards associated with chemicals in university laboratories. Every effort is made to ensure that risks, including those from hazardous chemicals, are mitigated to an acceptable level through appropriate engineering controls, specific procedures, and policies instituted by the university. While the UW–Madison administration has provided significant resources to ensure that the vital research performed is done in full compliance with applicable federal, state, and local regulations, the responsibility for ensuring a safe workplace must truly be a shared responsibility between faculty, staff, students, and campus environment, health and safety professionals.
The UW–Madison Campus Chemical Hygiene Plan and Policy (Campus CHP) was developed to maintain compliance with the OSHA Laboratory Standard. In addition to OSHA regulations, this document also presents key information on the practices and procedures that must be implemented to maintain compliance with other key state, federal, and local regulations required for the use and storage of hazardous chemicals.
Class II. Liquids having a closed cup flash point at or above 100°F (38°C) and below 140°F (60°C).
Class IIIA. Liquids having a closed cup flash point at or above 140°F (60°C) and below 200°F (93°C).
Class IIIB. Liquids having a closed cup flash point at or above 200°F (93°C). The category of combustible liquids does not include compressed gases or cryogenic fluids.
Class IA. Liquids having a flash point below 73°F (23°C) and a boiling point below 100°F (38°C).
Class IB. Liquids having a flash point below 73°F (23°C) and a boiling point at or above 100°F (38°C).
Class IC. Liquids having a flash point at or above 73°F (23°C) and below 100°F (38°C).
This category of flammable liquids does not include compressed gases or cryogenic fluids.
Mixtures of these materials with ordinary materials, such as water, might not warrant classification as highly toxic. While this system is basically simple in application, any hazard evaluation that is required for the precise categorization of this type of material shall be performed by experienced, technically competent persons.
Class I. Those formulations that are capable of deflagration but not detonation.
Class II. Those formulations that burn very rapidly and that pose a moderate reactivity hazard.
Class III. Those formulations that burn rapidly and that pose a moderate reactivity hazard.
Class IV. Those formulations that burn in the same manner as ordinary combustibles and that pose a minimal reactivity hazard.
Class V. Those formulations that burn with less intensity than ordinary combustibles or do not sustain combustion and that pose no reactivity hazard.
Unclassified detonable. Organic peroxides that are capable of detonation. These peroxides pose an extremely high explosion hazard through rapid explosive decomposition.
Class 4. An oxidizer that can undergo an explosive reaction due to contamination or exposure to thermal or physical shock. Additionally, the oxidizer will enhance the burning rate and can cause spontaneous ignition of combustibles.
Class 3. An oxidizer that will cause a severe increase in the burning rate of combustible materials with which it comes in contact or that will undergo vigorous self-sustained decomposition due to contamination or exposure to heat.
Class 2. An oxidizer that will cause a moderate increase in the burning rate or that causes spontaneous ignition of combustible materials with which it comes in contact.
Class 1. An oxidizer whose primary hazard is that it slightly increases the burning rate but which does not cause spontaneous ignition when it comes in contact with combustible materials.
Class 4. Materials that in themselves are readily capable of detonation or explosive decomposition or explosive reaction at normal temperatures and pressures. This class includes materials that are sensitive to mechanical or localized thermal shock at normal temperatures and pressures.
Class 3. Materials that in themselves are capable of detonation or of explosive decomposition or explosive reaction but which require a strong initiating source or which must be heated under confinement before initiation. This class includes materials that are sensitive to thermal or mechanical shock at elevated temperatures and pressures.
Class 2. Materials that in themselves are normally unstable and readily undergo violent chemical change but do not detonate. This class includes materials that can undergo chemical change with rapid release of energy at normal temperatures and pressures, and that can undergo violent chemical change at elevated temperatures and pressures.
Class 1. Materials that in themselves are normally stable but which can become unstable at elevated temperatures and pressure.
Class 3. Materials that react explosively with water without requiring heat or confinement.
Class 2. Materials that may form potentially explosive mixtures with water.
Class 1. Materials that may react with water with some release of energy, but not violently, include bromine, chlorine and fluorine.
The Chemical Hygiene Plan (including the Campus CHP, Laboratory CHP and Laboratory Safety Guide) describes the necessary protection from risks posed by the laboratory use of hazardous chemicals and is limited to laboratory settings (where small amounts of hazardous chemicals are used on a laboratory-scale on a non-production basis). All campus laboratories must comply with the requirements outlined in this document. While certain organizations within or associated with the university have the option of adopting their own Chemical Hygiene Plans, those plans must, at a minimum, meet the elements outlined within this document and the laboratory-specific CHP template.
This plan does not specifically address protection needed against radiological, biological or other hazards (electrical, laser, mechanical, etc.), though elements of these may be covered in lab-specific SOPs. Questions on the applicability of this plan can be addressed to the Chemical Safety Office by calling 265-5700 or via email at chemsafety@fpm.wisc.edu. Information on chemical, biological, and radiological safety – as well as other safety topics – can also be found on the EH&S website.
I. Introduction
II. Roles and Responsibilities
III. General Laboratory Rules and Policies
IV. Hazardous Chemical Identification and Control
V. Hazard Communication
VI. Chemical Storage and Inventory
VII. Chemicals and Drugs Used to Elicit a Biological Response
VIII. Biological Toxins
IX. Drug Enforcement Agency (DEA) Scheduled Drugs
X. Surplus Chemicals and Hazardous Waste
XI. Employee Information and Training
XII. Emergency Response
XIII. Exposure Monitoring
XIV. Respiratory Protection
XV. Medical Consultations and Evaluations
XVI. Laboratory Visit Program
XVII. Incident/Accident Notification Investigation
XVIII. Transportation and Shipping of Hazardous Materials
XIX. Records
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
The University of Wisconsin–Madison is committed to protecting employees from the health and physical hazards associated with chemicals in university laboratories. Every effort is made to ensure that risks, including those from hazardous chemicals, are mitigated to an acceptable level through appropriate engineering controls, specific procedures, and policies instituted by the university. While the UW–Madison administration has provided significant resources to ensure that the vital research performed is done in full compliance with applicable federal, state, and local regulations, the responsibility for ensuring a safe workplace must truly be a shared responsibility between faculty, staff, students, and campus environment, health and safety professionals.
The UW–Madison Campus Chemical Hygiene Plan and Policy (Campus CHP) was developed to maintain compliance with the OSHA Laboratory Standard. In addition to OSHA regulations, this document also presents key information on the practices and procedures that must be implemented to maintain compliance with other key state, federal, and local regulations required for the use and storage of hazardous chemicals.
The Occupation Safety and Health Act of 1970 established the Occupational Safety and Health Administration (OSHA). The mission of OSHA is to save lives, prevent injuries, and protect the health of America's workers. Beginning in the early 1970s, a variety of groups and individuals representing laboratories contended that the existing OSHA standards were designed to protect workers from exposure conditions in industry and were inappropriate for the different exposure conditions in research laboratories. To correct this situation, OSHA developed a special regulatory section specific for laboratories. This standard, Occupational Exposure to Hazardous Chemicals in Laboratories, is often referred to as the OSHA Laboratory Standard (29 CFR 1910.1450). The Wisconsin Department of Safety and Professional Services has adopted the Laboratory Standard as part of its regulatory framework and therefore it applies to all state agencies and employees.
The requirements imposed by the OSHA Laboratory Standard include:
Other agencies, including the U.S. Environmental Protection Agency, the U.S. Department of Transportation, the Wisconsin Department of Natural Resources, the Wisconsin Department of Safety and Professional Services, and the Madison Fire Department, also impose obligations on users of hazardous chemicals, including:
This document, in and of itself, is not sufficient to maintain compliance with OSHA regulations. The complete Chemical Hygiene Plan for each laboratory consists of three elements:
This document outlines roles and responsibilities for key personnel, contains policies and practices applicable to the entire campus, and provides an understanding of the applicability of various regulations to operations in a campus laboratory.
The Chemical Safety Guide is prepared by the Chemical Safety Office within the Environment, Health & Safety Department (EH&S). This contains a wealth of information including specific practices and procedures for the safe use and disposal of chemicals. The Chemical Safety office also provides guidance documents on specific topics. The Chemical Safety Guide, along with the guidance documents, can be found at the EH&S website.
Each Principal Investigator must prepare a laboratory-specific Chemical Hygiene Plan that contains standard operating procedures (SOPs), personal protective equipment (PPE) requirements, engineering and administrative controls, and training prerequisites specific to their laboratory’s operations.
A template for a laboratory-specific CHP can be found on the EH&S website. The template includes directions on how to complete each section. This template provides an organizational framework for ensuring that Principal Investigators are compliant with OSHA laboratory safety regulations. The Laboratory CHP template contains the following sections:
The Chemical Hygiene Plan (including the Campus CHP, Laboratory CHP and Chemical Safety Guide) describes the necessary protection from risks posed by the laboratory use of hazardous chemicals and is limited to laboratory settings (where small amounts of hazardous chemicals are used on a laboratory-scale on a non-production basis). All campus laboratories must comply with the requirements outlined in this document. While certain organizations within or associated with the university have the option of adopting their own Chemical Hygiene Plans, those plans must, at a minimum, meet the elements outlined within this document and the laboratory-specific CHP template.
This plan does not specifically address protection needed against radiological, biological or other hazards (electrical, laser, mechanical, etc.), though elements of these may be covered in lab-specific SOPs. Questions on the applicability of this plan can be addressed to the Chemical Safety Office by calling 265-5700 or via email at chemsafety@fpm.wisc.edu. Information on chemical, biological, and radiological safety – as well as other safety topics – can also be found on the EH&S website.
The OSHA Laboratory Standard requires the designation of personnel responsible for implementation of the Chemical Hygiene Plan. Specifically, it calls for the assignment of a Chemical Hygiene Officer (CHO). The University of Wisconsin-Madison has assigned the role of Chemical Hygiene Officer to the head of the Chemical Safety Office, organizationally residing within EH&S. This individual has the responsibility for development and implementation of the Campus CHP and for ensuring overall compliance with all chemical safety regulations.
The CHO works with the UW–Madison Chemical Safety Committee (CSC) on the development of a campus-wide chemical safety and compliance program. The CSC approves this plan and aids in its implementation.
For laboratories on campus, the university designates the Principal Investigators as the individuals responsible for developing and implementing the Laboratory CHP for laboratories under their control. For some academic units that have developed departmental or organizational CHPs, the responsibility for developing and implementing a CHP has been designated as a departmental function and assigned to an individual or committee. Ultimate responsibility for compliance still resides with the Principal Investigator (or to an individual who has been assigned responsibility for a given laboratory). Academic units that have laboratories containing hazardous materials are encouraged to have their own safety officers to help implement their chemical hygiene plans.
All elements of the Chemical Hygiene Plan (including the Campus CHP, Laboratory CHP and Chemical Safety Guide) must be made readily available to employees or employee representatives.
The UW–Madison Chemical Hygiene Officer shall review and evaluate the effectiveness of the Campus CHP at least annually and update it as necessary. The university’s Chemical Safety Committee will review and approve all changes to the plan. Updates to the CHP will be posted on the Chemical Safety Office website.
For a Laboratory CHP to be useful it must reflect the work that is currently performed within the laboratory. The Principal Investigator must formally review the Laboratory CHP at minimum annually to ensure that its contents are appropriate and adequate for current operations. If changes are necessary before the review date, the Laboratory CHP must be amended and the changes approved by the respective Principal Investigator.
In order to maintain an effective chemical safety program, it is important for all parties to clearly understand the responsibilities inherent in their roles. Below are assigned roles and responsibilities that are necessary to remain compliant with chemical safety regulations.
For the purpose of this document, a Principal Investigator is any individual who has primary responsibility for the operations of assigned laboratory space. In most instances, this will be a UW–Madison faculty member. In some instances, a facility director or department chair may assign the responsibilities outlined in this plan to a member of the academic staff (e.g., a supervisor of an instrumentation laboratory can be considered a Principal Investigator for the purposes of this plan).
The Assistant Vice Chancellor of EH&S will provide the necessary staffing and resources for maintaining an effective Chemical Safety Program.
The university Chemical Hygiene Officer (CHO) has the primary responsibility for ensuring implementation of the Campus CHP and overall compliance with chemical safety regulations. The CHO will:
Environment, Health & Safety Department staff have extensive expertise covering all areas of safety and compliance. EH&S personnel will:
The Principal Investigator has the primary responsibility for providing a safe work environment and for ensuring compliance with all elements of the Campus and Laboratory CHPs within their own assigned laboratory space. While the Principal Investigator can delegate health and safety responsibilities to a trained and knowledgeable individual (referred to as the Laboratory Chemical Hygiene Officer), the Principal Investigator must ultimately assure that the duties are performed. The Principal Investigator must:
The individuals working under the supervision of the Principal Investigator must:
The UW–Madison Chemical Safety Committee is comprised of university faculty and staff drawn from many organizations and departments. The Chemical Safety Committee will:
The UW–Madison Chemical Safety Committee has the ability to develop, review, and approve campus policies on issues related to the purchase, use, storage, and disposal of chemicals. All university personnel are subject to these policies in addition to federal state, and local regulations and codes.
Each Principal Investigator has the right to set polices for laboratories under their control as long as these are, at a minimum, compliant with regulations and campus-wide policies. Laboratory specific policies should be included in the Laboratory CHP.
The following general policies apply for all laboratory operations involving hazardous chemicals:
It is university policy that appropriate PPE must be worn at all times. At a minimum, close-toed shoes and safety glasses must be worn whenever hazardous chemicals are present in the laboratory.
It is university policy that no eating and drinking is allowed in laboratories where hazardous chemicals are present.
It is university policy that unnecessary exposure to hazardous chemicals via any route will be avoided through proper use of engineering controls, personal protective equipment, and administrative controls.
It is university policy that the use of audio headphones (over-ear and in-ear) is prohibited when performing chemical procedures and highly hazardous operations.
It is university policy that good housekeeping practices be upheld in all laboratories and that all passageways, exits, utility controls, and emergency equipment remain accessible at all times.
It is university policy that any procedure or operation identified by laboratory or EH&S staff as imminently dangerous (i.e., the operation puts individuals at immediate serious risk of death or serious physical harm) must be immediately stopped until corrective action is taken.
Additional specific policies for use of high-hazard compressed gases and for the use of cryogenic liquids are found in Appendix A of this plan. The Chemical Safety Guide also provides general laboratory safety rules as well as recommendations for safe work practices. Additional university policies are outlined in subsequent sections of this plan.
Many chemicals can cause immediate health problems as well as long-term health effects. Examples include carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Hazardous chemicals (such as flammable and combustible liquids, compressed gases, and unstable and water-reactive materials) can also pose inherent physical dangers. The University of Wisconsin is committed to minimizing worker exposure to the hazards imparted by use of hazardous chemicals and takes a risk-based approach in determining means of mitigating risk taking into account the characteristics of the chemical, the amounts used, the method in which a chemical is used, and the location.
The university requires that each Principal Investigator review all operations involving laboratory use of hazardous chemicals. Whenever possible the hazard should be eliminated or substitution of a hazardous chemical or procedure with a substance or process with lower inherent risk should be undertaken. Additionally, control measures commensurate with the risk must be implemented. Control measures include engineering controls (such as fume hoods, glove boxes, or intrinsically), administrative controls (such as policies against working alone), and personal protective equipment (gloves, eye protection, respirators, etc.). EH&S provides tools to perform this risk assessment, including the Laboratory Safety Guide and other guidance documents. Additionally, EH&S staff can provide consultation services if there are any questions on this process.
It is the responsibility of the Principal Investigator to insure that laboratory staff members have knowledge of the exposure limits applicable to the chemicals that are used within the lab. OSHA has the regulatory authority to set specific air exposure limits for chemicals. These Permissible Exposure Limits (PELs) are listed in 29 CFR 1910.1000 TABLE Z-1. States have the right to impose more stringent requirements and the State of Wisconsin has done so for public employees as outlined in Chapter SPS 332 “Public Employee Safety and Health.” In lieu of 29 CFR 1910.1000, July 1, 2003 edition, an employee’s exposure to air contaminants is regulated by the July 1, 1992 edition of 29 CFR 1910.1000. This earlier version is more stringent since it sets PELs for substances not in the later version and includes Short Term Exposure Limits (STEL) to complement 8-hour time weighted average (TWA) limits, establishes skin designations, and adds ceiling limits as appropriate. (Note: The 1992 edition of 29 CFR 1910.1000 was struck down by the courts and is not enforceable by federal OSHA.)
For substances that do not have an exposure limit specified in the OSHA standards, SPS 332 states that it will accept the recommendations of the American Conference of Governmental Industrial Hygienists (ACGIH) for Threshold Limit Values (TLVs).
While the published PELs and TLVs are enforceable, they were not created with a university laboratory setting in mind. The published ACGIH exposure limits, like the PELs, are levels to which it is believed nearly all workers may be exposed during a 40- hour workweek over a working lifetime without harmful effects. Most laboratory workers perform non-routine operations over a short time span. In these instances short- term exposure limits are often more appropriate. Many chemicals do not have any published exposure limits. It is the university’s policy, therefore, that all prudent steps will be taken to reduce exposures beyond what is legally required or, when there is no legal requirement, to minimize exposure by reasonable actions. See Appendix B for information on finding and interpreting OSHA PELs and ACGIH TLVs.
As stated above, a primary goal of chemical safety efforts is to minimize the potential for exposures. A direct way of reducing exposure can be accomplished by isolating the source or removing contaminants through various ventilation methods. Engineering controls should be implemented within the laboratory whenever practical to minimize exposure to hazardous chemicals.
By far the most commonly used engineering control used in laboratories is the chemical fume hood. Fume hoods are especially effective when handling gases, vapors, or powders. Laboratory workers rely heavily on these, often while performing the most hazardous tasks. The Chemical Safety Guide provides information on the proper us of fume hoods.
Due to the importance placed on fume hoods some key requirements are emphasized below:
Other ventilation methods, including general room ventilation, point-source (such as snorkels), and gas cabinets also provide protection to workers. Glove boxes, glove bags, pressure relief valves, automatic shut-offs, and air monitors are also routinely used on campus.
Due to the reliance placed on these engineering controls, laboratory personnel need to incorporate regular inspections and/or testing of the controls into their standard operating procedures to ensure proper operation. This may be as simple as testing that air is flowing or gauges are working. Some controls are more complicated and may require routine maintenance or calibration by outside vendors.
Administrative controls consist of policies and procedures developed to improve the safety of laboratory operations. Typical examples include night-time work hour limitations and experimental scale-up restrictions. Since administrative controls require lab personnel to follow appropriate procedures these are generally not as reliable as engineering controls. While the University of Wisconsin–Madison Chemical Safety Committee sets broad campus policy, as outlined in this document, it does not set specific administrative controls for use of hazardous chemicals. These controls must be set by individual PIs or Departments. If not already documented in departmental safety plans, administrative controls should be documented in the policy section of the laboratory-specific CHP or within an SOP for procedure-specific controls. All laboratory staff needs to be informed of these controls.
Engineering and administrative controls are the primary lines of defense within the hierarchy of hazard minimization. When these methods are not adequate then exposure to hazardous chemicals can normally be minimized, if not eliminated, through proper selection of PPE. Typical examples of PPE include safety goggles, safety glasses, lab coat, gloves, and respirators. The Principal Investigator has the primary responsibility to determine the appropriate PPE and ensure that the PPE is made available. Details are important. If respirators are required, specific types of respirators must be indicated. The same is true for gloves – chemical compatibility plays a major role in determining the type of glove (e.g., latex, nitrile, vinyl). The Chemical Safety Guide provides guidance on PPE choices. Additional information can be found on Safety Data Sheets, which often provide information on the proper choice. The Chemical Safety Office can provide assistance on proper choice for PPE. The Environmental & Occupational Health office should be contacted at eoh@uhs.wisc.edu to assist in the proper selection, training, and use of respirators.
While close-toed shoes and safety glasses are the minimum PPE requirements for all laboratories containing hazardous chemicals, the PPE required for specific procedures and tasks should be reflected in the Laboratory CHP. The Standard Operating Procedure (SOP) templates available on the EH&S Chemical Safety Office website provide a means to document the requirements.
University Health Services (UHS) provides prescription safety glasses if required to perform your work. The safety glasses provide frontal protection only from such hazards as flying particles encountered in woodworking, machine metalwork, general warehouse, stock clerk, dock work, brush cleaning, etc. Side shields, which are necessary for side protection from flying particles, are available with the glasses. These do not provide adequate eye and face protection from chemical splashes or fumes. Contact UHS at 890-1051 if you need additional information on this service. Information can also be obtained at their website.
Safety showers and eyewashes are essential protective elements for laboratories. Wis. Admin. Code SPS § 332.30 states, “Whenever the eyes or body of any person may be exposed to materials that are corrosive or can cause irreversible eye or bodily injury, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.” The Wisconsin code also notes that it will accept facilities that comply with American National Standards Institute (ANSI) standard Z358.1, Emergency Eyewash and Shower Equipment.
The ANSI Z358.1 has some specific requirements for safety showers and eyewashes. According to this standard emergency eyewashes and showers:
Employees must be instructed in the location and proper use of the equipment. Personal eyewash equipment such as a drench hoses may support but not replace approved eyewashes and showers.
Safety showers and eyewashes are inspected annually by Environment, Health & Safety. Contact Environment, Health & Safety at 265-5000 if your safety shower, eyewash or drench hose has not been inspected or if you any questions concerning the requirements for eyewashes and safety showers.
EH&S Fire Safety section manages over 12,000 extinguishers on the University of Wisconsin campus. This group provides, installs, and inspects all necessary fire extinguishers. It also provides training on proper use of extinguishers. While the fire extinguishers provided work for most situations, specific laboratory operations (e.g., those involving flammable metals) may require special extinguishers. The EH&S Fire Safety website has additional information.
OSHA regulations require that provisions for additional employee protection be made for work with particularly hazardous substances (PHSs). These include carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity. As part of the required risk assessment for any work involving hazardous materials, all PHSs must be identified by the Principal Investigator or laboratory worker designing the experiment or procedure. (Note: see Appendix C for more information on PHSs). Use of any PHS requires:
The room or area where work with PHS is performed must be posted with a Designated Area sign; sign samples in MS Word and PDF formats can be found on the EH&S Chemical Safety website. The posting of an established “designated area” identifies areas of higher health risk. In many laboratories, it is appropriate to establish the entire room as a “designated area” whereas in other laboratories a workbench or fume hood is more appropriate.
The controls used to minimize exposures to PHSs must be documented in the Laboratory CHP. The Standard Operating Procedure (SOP) templates found in the Laboratory CHP template provide a means to document the controls.
The nature of the work performed in laboratories on campus varies widely. Principal Investigators must ensure that a risk assessment is performed for all activities involving hazardous substances. Certain procedures may be considered hazardous enough that these should only be performed with prior approval of the Principal Investigator. While typically these may involve work with PHSs, other procedures, such as those involving pyrophoric, highly reactive or flammable compounds, may appropriately fall within this category.
The University of Wisconsin–Madison allows the Principal Investigator to make the determination if a procedure needs prior approval. The Standard Operating Procedure (SOP) templates available on the EH&S website provide a means to document whether a specific procedure requires prior approval. Additionally, within the Laboratory CHP a section has been devoted to documentation of approvals.
One of the key requirements in OSHA chemical safety regulations is the communication of the potential hazards to which a worker may be exposed. This section describes UW–Madison policies for meeting these requirements.
OSHA regulations require the development of a Chemical Hygiene Plan which sets forth procedures, equipment, personal protective equipment and work practices that are capable of protecting employees from the health and physical hazards presented by hazardous chemicals used in that particular workplace. The Campus CHP and Chemical Safety Guide meet many of the requirements. However, work practices are laboratory specific and the university requires that Principal Investigators prepare the Laboratory CHP in order to be in full compliance. Additionally, the entire CHP (including the Campus CHP, the Laboratory CHP, and the Chemical Safety Guide) must be readily available to laboratory workers and worker representatives. These documents should be placed in a location that readily accessible to all workers or made available electronically (such as on a network drive).
A Safety Data Sheet (SDS) is prepared by manufacturers and summarizes the physical and chemical characteristics, health and safety information, handling, and emergency response recommendations related to their products. An SDS should be reviewed before beginning work with a chemical in order to determine proper use and safety precautions. OSHA regulations require that once a chemical is present in the laboratory the SDS must be made available, either electronically or as a hardcopy. Personnel must have ready access for reference in the case of emergencies. The International Fire Code (IFC), which has been adopted by the Madison Fire Department (MFD), also states that SDSs shall be readily available on the premises.
SDSs alone may not provide sufficient information on the hazards of a chemical. Laboratory personnel should review other sources of information on the chemical, such as the chemical literature or references on safe handling of chemicals such as National Research Council’s Prudent Practices in the Laboratory. These resources should be made available to laboratory staff.
In certain instances UW EH&S or the Environmental & Occupational Health Program at University Health Services may measure laboratory worker exposure to a chemical regulated by a standard. The Principal Investigator must, within 15 working days after the receipt of any monitoring results, notify the laboratory staff of these results in writing either individually or by posting results in an appropriate location that is accessible to employees. A section of the Laboratory CHP has also been delegated to the documentation of these results. Additional information on exposure monitoring is provided in Section XIII.0.
Chemicals received from outside vendors are, by law, required to have labels indicating the chemical identity and common name, manufacturer name, address and phone number, pictograms, signal words, hazards statements, and precautionary statement. Manufacturers’ labels on chemical containers shall not be removed or defaced.
Frequently, chemicals are dispensed from the original shipping container to a smaller container or chemical mixtures are prepared for subsequent use. All secondary containers must be labeled with the following information:
The primary hazards can be presented either in the form of GHS pictograms, GHS hazard statements, the NFPA 704 Standard (“Standard System for the Identification of the Hazards of Materials for Emergency Response”, commonly referred to as the NFPA fire diamond), or other similar hazard identification system. All lab personnel must be trained in the hazard communication method that is employed.
It is acceptable to use one label for a rack containing individual vials of similar chemicals.
It is not only necessary to provide workers with awareness of the hazardous chemicals present in a laboratory, but this information must also be provided to first responders in the event of an emergency. The Madison Fire Department (MFD) relies on the Laboratory Emergency Information Cards (i.e., the yellow “door cards”) to provide valuable information and these cards are required by fire code. Emergency responders need to know the hazards before entering a laboratory. EH&S requires that the cards be, at a minimum, reviewed annually and updated in the event of any change in the information. Door cards can be obtained by contacting EH&S at 265-5000. Additional information can be obtained online.
Use and storage of hazardous chemicals is regulated by federal, state, and local regulations. These regulations include OSHA worker protection standards, emergency response and planning regulations and local building and fire codes. Each of these place limitations on how much materials can be used, where they can be used or stored, or require information on inventory to be available for emergency planning and response.
The university must meet the requirements outlined in International Fire Code (IFC), by virtue of its adoption by the Madison Fire Department (MFD) – subject to modification as described in the City of Madison Fire Prevention Code. MFD also enforces sections of the National Fire Protection Association (NFPA) standards since these have been adopted by IFC reference. Finally, OSHA 29 CFR 1910.106 “Flammable and Combustible Liquids” is also enforceable. Together, these place limitations on use and storage of compressed gases, cryogenic fluids, highly toxic and toxic materials, flammable and combustible liquids, and water reactive solids, to name a few. The Madison Fire Department performs routine inspections of buildings and has the authority to cite any situation that they deem in violation of the relevant codes.
The allowable quantities (both in use and in storage) per 2015 IFC are presented in tables found in Appendix D. Allowable quantities are based on control areas, defined as “spaces within a building which are enclosed and bounded by exterior walls, fire walls, fire separation assemblies and roofs, or a combination thereof, where quantities of hazardous materials not exceeding the exempt amounts are stored, dispensed, used or handled.” Although the code limits appear straightforward, application of the code can be more complicated due to the following:
Due to the complexities of the standards and the university’s need to remain compliant with these regulations it is the university’s policy that every effort be made to minimize the quantity of hazardous chemicals within the campus laboratories.
In addition to the IFC limits, other limitations to storage and use apply. Below are some of the key policies and code requirements for storage of chemicals at UW–Madison. This list is not comprehensive and does not include many of the prudent safety practices included in Chemical Safety Guide or the guidance documents found on the Chemical Safety Office website.
In addition to the IFC code requirements, the following university limits have been set (in instances in which the building limits are more stringent, those limits will apply):
Below are a few general requirements for gas cylinder usage. Additional requirements for safe handling of gas cylinders can be found on the Chemical Safety Office website. Due to the hazards posed by highly toxic, corrosive, and pyrophoric gases all procedures involving these gases must be reviewed by EH&S staff prior to use (see Appendix A for details concerning the campus compressed gas policy). In order to ensure safe use and storage, all gas cylinders must be:
More comprehensive guidance can be found in the Chemical Safety Guide and other documents on the Chemical Safety website or by contacting the Chemical Safety Office at 265-5700.
In addition to chemical storage limitations imposed by regulations and codes, the Principal Investigator is responsible for following prudent storage practices of chemicals. This includes separating incompatible chemicals and disposing of unstable compounds (such as peroxide formers) after their indicated expiration date. Chemicals must be grouped according to their hazard category (i.e. strong acids, strong bases, oxidizers, flammables, pyrophorics, self-reactives, etc.). The Chemical Safety Guide outlines the principles that need to be followed.
As stated throughout this document, the university is subject to numerous regulations above and beyond the OSHA Laboratory Standard. Below are some of the codes and regulations requiring that laboratory staff have knowledge of their chemical inventories:
Emergency Planning and Community Right-to Know Act (EPCRA)
EPCRA is a federal statute that requires all entities that store, use or process hazardous chemicals to report this information to the State Emergency Response Commission and Local Emergency Planning Committees and in some cases the local fire department. EPCRA has four major provisions which are largely independent of each other and involve different chemical lists with different threshold reporting quantities.
Department of Homeland Security (DHS) Chemicals of Interest
The DHS has issued regulations related to security of high risk chemical facilities. These regulations, released in 2007, require facilities to determine if they have specific chemicals above screening threshold quantities. 300 chemicals (and respective thresholds) were identified. While most of the thresholds were set at thousands of pounds, some of the threshold amounts were significantly lower. The university completed the initial security screening but must report any change to DHS.
Madison Fire Codes
The Madison Fire Department requires entities that use hazardous materials to maintain inventories and to provide them upon request.
While maintaining a complete inventory of chemicals is highly recommended (it prevents unnecessary purchases and reduces inventory), at a minimum, Principal Investigators must maintain an up-to-date chemical inventory for the following:
Appendices B and C have information that would be useful in determining whether a chemical would fall under the inventory requirement. NFPA fire diamond information commonly available can also help. Liquids with a flammability rating of 3 are considered Class IB and IC liquids while those with a flammability rating of 4 are Class IA. If in doubt whether a chemical would fall under one of the above categories, then maintain it on your inventory. Inventories must be made available to the Chemical Safety Office upon request.
Use of FDA-approved drugs or experimental drugs in a clinical setting is outside the purview of this document. However, the safe handling and use of drugs in a laboratory setting must be described in the lab-specific CHP if the drug has the characteristics of a hazardous chemical or is a carcinogen and is in a form that has the potential to lead to an exposure. More broadly, usage of any hazardous chemical for the purpose of eliciting a biological response must be covered by the Laboratory CHP.
For animal experiments involving hazardous chemicals, it is the responsibility of the Principal Investigator to provide hazard communication information to animal care staff. This information will include, at a minimum:
The Public Health Security and Bioterrorism Preparedness and Response Act of 2002, Subtitle A of Public Law 107–188 requires the Department of Health and Human Services (HHS) to establish and regulate a list of biological toxins (and biological agents) that have the potential to pose a severe threat to public health and safety. The biological toxins, listed in the table below, are regulated if inventory levels exceed – at any time – the amounts indicated. Users that anticipate exceeding the listed thresholds must register with the university’s Select Agent Program. Users who maintain quantities below the listed threshold are still required to maintain inventory logs containing the date of access, name of individual accessing the toxin, the quantity used, the purpose of use and the amount remaining. The toxins must be kept in a locked area with access limited to those who need it. The biological inventory logs must be sent on a quarterly basis to the Select Agent Program Manager. Unregistered individuals exceeding these limits face severe federal penalties. Use of biological toxins must also be included in biosafety protocols.
| HHS Toxins [§73.3(d)(3)] | Amount |
|---|---|
| Abrin | 100 mg |
| Botulinum neurotoxins | 0.5 mg |
| Short, paralytic alpha conotoxins | 100 mg |
| Diacetoxyscirpenol (DAS) | 1000 mg |
| Ricin | 100 mg |
| Saxitoxin | 100 mg |
| Staphylococcal Enterotoxins (Subtypes A, B, C, D, and E) | 5 mg |
| T-2 toxin | 1000 mg |
| Tetrodotoxin | 100 mg |
Questions concerning biological toxins should be directed to the Select Agent Responsible Official.
The Congress of the United States enacted into law the Controlled Substances Act (CSA) as Title II of the Comprehensive Drug Abuse Prevention and Control Act of 1970. Use of controlled substances in animal research is common in animal research where pain medication is required.
Use of controlled substances for research requires obtaining both federal (DEA) and state (WI Controlled Substances Board Special Use Authorization) registration. Penalties for using such drugs without proper registration can be severe. The regulations strictly limit who can handle or administer the drugs and imposes both physical security requirements as well as inventory requirements. Some key points concerning the regulations:
EH&S has no role in the permitting process, though it can provide limited guidance upon request. Sewer disposal of any DEA drug is no longer an acceptable option. Contact the Chemical Safety Office for questions concerning disposal.
The University of Wisconsin Systems has very good guidance on the use of controlled substances. This can be found on their website.
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, is the principal Federal law in the United States governing the disposal of hazardous waste. RCRA is administered by the U.S. Environmental Protection Agency (EPA). In Wisconsin the hazardous waste regulations are found in Chapter NR 662 “Hazardous Waste Generator Standards.”
The university strives to maintain compliance with all regulations regarding hazardous wastes while at the same time minimizing waste by a number of programs. Our waste minimization efforts include chemical redistribution and inventory reduction programs.
The Chemical Safety Office operates the university’s On-Site Hazardous Materials Management (OSHMM) program. Through the OSHMM program, Chemical Safety Office staff will come directly to laboratories to remove those items that can be redistributed, require a more complex disposal procedure, or require disposal at a commercial hazardous waste treatment, storage and disposal facility. Most materials picked up through OSHMM are considered to be surplus chemicals and are not designated as waste until EH&S Waste Management staff has made this determination. The main exceptions are the materials placed in the waste solvent carboys as well as used silica gel (commonly used for chromatography). These materials are considered hazardous waste at the time of generation.
The Chemical Safety website provides detailed information on how to request a chemical pick-up, the documentation that needs to be completed prior to the pick-up, and how materials should be packaged for pick-up. The Chemical Safety Office highly recommends that laboratory staff periodically review their inventories and that requests for pick-up of unwanted chemicals be made on a frequent basis.
As part of the chemical disposal process, Principal Investigators and laboratory staff are allowed to perform In-Lab Chemical Management of their inventories. In-Lab Chemical Management includes simple disposal and treatment methods that can be done in a lab, such as solvent commingling, flushing down the sanitary sewer (for non-hazardous chemicals), and neutralization. Approved disposal procedures are described in detail in UW Chemical Safety Guide. The UW Chemical Safety Office gives advice regarding the disposal of specific chemicals and wastes and, in some cases, can demonstrate treatment and neutralization procedures. Follow the chemical disposal procedures in the Chemical Safety Guide, and on the Chemical Disposal website.
The EPA does not allow the University of Wisconsin to sewer hazardous waste. Hazardous waste is usually classified as belonging to one of two groups: (1) characteristic hazardous waste (ignitable, corrosive, reactive or toxic) or (2) listed hazardous waste (K, F, P, U are the four lists published by EPA). However, the university is able to perform elementary neutralizations and dispose of the product in the sanitary sewer and sewer disposal of non-hazardous chemicals by complying with the Madison Metropolitan Sewerage District’s (MMSD) and the university’s agreed criteria for the environmentally sound disposal of laboratory chemicals.
It is essential that materials being sewered are water soluble and completely dissolved before going into the sink drain. Madison Metro Sewerage District ordinances emphasize that materials that damage the pipes (corrosive), create an unsafe atmosphere (ignitable or toxic) in the line access points, block flow or interfere with the treatment process are prohibited. The Chemical Safety Guide provides information on sewer disposal of materials. Contact the Chemical Safety Office for specific questions.
Federal regulations allow a waste generator to accumulate as much as 55 gallons of non- acute hazardous waste or one quart of acutely hazardous waste in containers at or near any point of generation and under the control of the operator. These storage locations are referred to as “Satellite Accumulation Areas” or SAAs and each laboratory is allowed one SAA. Requirements for laboratories maintaining SAAs include the following:
The Chemical Safety Office distributes 5-gallon carboys for organic solvent waste free of charge and picks these up once filled or no longer needed. Non-halogenated solvent waste must be collected separately from halogenated waste. While 55 gallons are allowed per SAA other regulations, such as the fire codes, may impose further limits on the number of carboys that can be stored in the laboratory.
The Chemical Safety Waste Management group will perform laboratory cleanouts and departmental clean sweeps upon request. Clean sweeps provide opportunities for old and expired chemicals that may pose unnecessary risk to be removed. Information on cleanouts and moves can be obtained on the EH&S website.
For moves: https://ehs.wisc.edu/laboratory-move-guidelines/
For cleanouts: https://ehs.wisc.edu/lab-clean-outs/
The UW–Madison Chemical Redistribution Program tries to reduce the volume of unused chemicals being disposed as waste. The Chemical Safety Office will deliver these surplus chemicals to your laboratory for free. After surplus chemicals are collected a chemist examines them to determine that they are not degraded and are still useful for research. If so, the Chemical Safety Office will redistribute such chemicals to another campus laboratory upon request. All redistributed chemicals are in their original manufacturer's container. In many cases, these surplus chemicals still have the manufacturer's seals. Principal Investigators should review their inventory regularly and have their surplus chemicals picked up by EH&S so that these can be made available for use by other laboratories.
There are several ways to obtain surplus chemicals. The Chemical Safety Office provides an updated list of redistributable chemicals on the EH&S website.
The same site can be used to submit an electronic request. Orders will be delivered directly to your facility.
The OSHA Laboratory Standard is clear on the requirement that all laboratory personnel receive the necessary information and training so that they understand the hazards of the chemicals present in their work area. The primary responsibility for ensuring this rests with the Principal Investigator, though EH&S provides various courses and classes to meet these needs. Chemical Safety Office staff can also help by providing guidance on common techniques and the use of common chemicals. However, the lab-specific training must be provided by the Principal Investigator (personally or by a designated staff member or outside source). The Principal Investigator must ensure that the information and training is presented before laboratory workers are allowed to use or handle chemicals in their laboratory.
Laboratory personnel must be informed of:
The Chemical Safety Staff offers regularly scheduled training on general laboratory safety. This covers details of the OSHA Laboratory Standard as well as campus safety policies (including the Campus CHP), resources, and services. Contact the Chemical Safety Office or visit the EH&S website for additional information.
Laboratory staff must also receive training on the laboratory-specific operations. This must include:
Typically this training is provided by the Principal Investigator or other experienced laboratory staff member. Training must be communicated in a manner readily understood to those being trained. This may require written as well as oral transmission of information. The frequency of refresher training and information can be determined by the Principal Investigator. Refer to the Laboratory CHP template for information on documentation requirements.
Each Principal Investigator must ensure that laboratory staff is knowledgeable and trained on emergency procedures. Many of the procedures are covered in other campus plans, including a building’s Occupant Emergency Plan (OEP). The OEP is an all-hazard plan designed around a building’s unique layout and function. The primary purpose of the OEP is to provide guidance to building occupants in the event of an emergency, such as a tornado, active shooter, gas leak or bomb threat. Contact your building manager or department chair for location of this document.
Assess the hazards present in your workspace and tailor your emergency equipment and response plans accordingly. Emergency response plans should be developed covering lab-specific procedures, including:
In case of an emergency, be prepared to follow the planned emergency procedures for your workplace and building. Before an emergency strikes, there are several things that can be done to improve preparedness.
UW Police: 911
UW Hospital ER: 262-2398
UW Hospital Poison Control: 262-3702
Dialing 911 on a landline phone will go directly to UW Police dispatch. Calling 911 from a cell phone will connect you to the Dane County dispatch. When calling from a cell phone either ask to be put through to UW dispatch or make clear that you are calling from a campus facility.
The State of Wisconsin regulations require exposure monitoring where exposure may occur at or above a published exposure value of OSHA or ACGIH (American Conference of Governmental Industrial Hygienists). Examples of such values could include the action level, permissible exposure level, threshold limit value, short-term exposure limit or ceiling limit. If you believe that you are being exposed to levels above the permissible limits, contact EH&S. The Environmental and Occupational Health (EOH) unit will, if deemed appropriate, ensure the necessary exposure monitoring is performed. The affected university staff will be notified by EOH staff of the results within 15 days of receipt of the results (see Section V.3).
As stated in Section IV.1, it is the policy of the university to take all prudent steps to minimize exposures to hazardous chemicals. This is primarily achieved by prudent experimental design and engineering controls. Examples include eliminating the hazard by substituting for a less hazardous alternative or containing the hazard through ventilation or other controls. If no alternatives can be found, then respiratory protection may be required.
Respirators include filtering face pieces (N95), cartridge respirators, powered airpurifying respirators (PAPR) or self-contained breathing apparatus to prevent or limit exposure to airborne hazards. It is essential to evaluate the type and amount of the exposure to assure proper use and protection. There are a number of regulatory requirements associated with the use of respirators, including the development of a Respiratory Protection Program (RPP), conducting a medical evaluation and respiratory fit testing, and receiving training on the proper use of respirators. Environment Health & Safety can provide all necessary services and assist in the development of the RPP. Contact the Environmental and Occupational Health Program at 608-890-1992 or go to their website for additional information
The university offers access to medical evaluation and associated services under the following circumstances:
In addition to the circumstances listed above, there may be other occasions when consultation with either your personal physician or a university-affiliated Occupational Health physician may be warranted. Examples of such conditions may include pregnancy, desire to conceive or existence of a health condition which may put you at greater risk. To arrange for or discuss medical consultations and evaluations, contact the Occupational Medicine Program at 265-5610.
In the event of a possible exposure, the affected individual (or other laboratory staff present) must be prepared to supply the following information:
The Laboratory Visitation Program is an ongoing program that provides assistance and consultation to help create a safe work environment. As part of the visit, EH&S Chemical Safety Office staff will help ensure all university and governmental regulations are being complied with in the laboratories. The EH&S Laboratory Visitation Team performs a review of all safety documentation and physical hazards which include fire safety, chemical safety, engineering controls, and safety training. Upon completion of the laboratory visit, a report is issued to each laboratory manager. This report outlines areas that need improvement as well as any necessary guidance documents. EH&S staff are available to assist in making improvements.
The Chemical Safety Office visits laboratories by departments on a rotating basis. However, the Chemical Safety Office staff is available to visit any laboratory upon request. To schedule a laboratory visitation, contact the Chemical Safety Office of EH&S at 265-5700.
For additional information on the Laboratory Visit Program, visit the EH&S website.
Principal Investigators and supervisors must report any incident involving personal injury, exposure or illnesses, unintended fire, property damage or incidents involving an environmental release of hazardous materials directly to EH&S (call 265-5700) or through the EH&S website.
A primary tool to identify and recognize the areas responsible for accidents is a properly conducted accident investigation. Accident investigations shall be conducted by the EH&S staff with the primary focus of understanding why the accident or near-miss occurred and what actions can be taken to prevent recurrence.
Procedures for investigating workplace accidents and hazardous materials exposures include:
The investigation will be recorded in writing and will adequately identify the cause(s) of the accident or near-miss occurrence. Documentation of the investigation and all followups will be prepared and maintained by a member of the EH&S staff performing the investigation.
In order to protect the public at large, the US Department of Transportation (DOT) regulates the shipping and transportation of hazardous materials in commerce on roadways and airways. A hazardous material is defined as any substance or material that could adversely affect the safety of the public, handlers or carriers during transportation. All DOT hazardous materials are listed in the DOT's Hazardous Materials Table.
The regulations for shipping hazardous materials apply to all individuals involved in the shipping process, including individuals who:
Non-compliance with these standards is subject to civil penalties up to $50,000 per violation and up to $100,000 if death, serious illness, severe injury to any person or substantial destruction of property. Criminal penalties may result in penalties up to 10 years imprisonment. The requirements can be found in 49 CFR Parts 171-178 and cover the documentation, packing, marking, and labeling of hazardous materials as well as the training of shippers, carriers, and handlers. International Air Transport Association (IATA) regulations also apply when shipping hazardous chemicals by common air carriers such as FedEx since these carriers require that IATA rules are met.
In addition to proper packaging and labeling, the regulations require that the individual receive training that must be refreshed at minimum of every three years or when there is a significant change in the regulations. EH&S offers shipping training to individuals on campus, with separate courses geared toward chemical, biological, and radiological materials.
Important Note: With very few exceptions no hazards materials can be carried on or transported in checked luggage on any commercial airline flight. It is the responsibility of the PI to know which substances are hazardous, which are not, and to communicate this information to laboratory members
Contact EH&S at 265-5000 for information on training or other shipping concerns or go the EH&S website.
Under the current regulations, UW–Madison is considered a government agency; therefore, university employees transporting hazardous materials are not technically placing the materials “in commerce.” As a result, university employees transporting hazardous materials between campus buildings on public roadways are exempt from the DOT Hazardous Material Regulations (i.e. the normal packaging, labeling, placarding, and documentation do not apply). However, individuals who move hazardous chemicals on campus are still subject to the following university requirements:
See the EH&S Chemical Safety website for additional guidance on transportation of chemicals between campus buildings. Arrangements can be made with the Chemical Safety Office for transportation of large quantities of chemicals between buildings.
Hazardous waste is regulated by the US Environmental Protection Agency (EPA) in 40 CFR 260-265. The transportation of waste requires special marking, training, and documentation. Hazardous waste can only be transported by UW EH&S employees and approved contractors.
Principal Investigators are required to maintain all worker records associated with their laboratories. These records include:
Records of inspection results performed by EH&S staff will be maintained by EH&S. While training records for all lab-specific training must be maintained by the Principal Investigator, documentation of training performed by other organizations on campus is often maintained by those organizations. Consult with the training organization to ensure that they maintain these records.
See: Policy for the Purchase and Initial Use of High-Hazard Gas Cylinders
See: Policy for the Use and Storage of Inert Cryogenic Liquids
Laboratories as workplaces pose unique hazards. There is the potential for exposure to a large number of chemicals; but exposures, if they do occur, tend to be of short duration. All prudent steps should be taken to minimize exposure, but the steps should be risk based. Occupational exposure limits have been set by various organizations. Some of the limits are enforceable by law while others are recommendations only, with no legal bases. These limits still perform a needed function in aiding an informed risk assessment process. Below is a brief description of the major occupational exposure limits.
OSHA sets enforceable permissible exposure limits (PELs) to protect workers against the health effects of exposure to hazardous substances. PELs are regulatory limits on the amount or concentration of a substance in the air. They may also contain a skin designation that serves as a warning of potential cutaneous absorption that should be prevented in order to avoid exceeding the absorbed dose received by inhalation at the permissible exposure level (PEL). Most OSHA PELs are based on an 8-hour work shift of a 40-hour work week time weighted average (TWA) exposure that an employee may be exposed to for a working lifetime without adverse effects. Some of the PELs are listed as ceiling values – concentrations above which a worker should never be exposed, or short-term exposure limits (STELs) – average concentrations which should not be exceeded over a 15 minute time period. To locate PELs on specific chemicals see OSHA Annotated Table Z-1.
Threshold Limit Value (TLV) are occupational exposure limit set by the American Conference of Governmental Industrial Hygienists (ACGIH). The time-weighted average TLV (TWA-TLV) is an airborne concentration of a gas or particle to which most workers can be exposed on a daily basis for a working lifetime without adverse effect (assuming an average exposure on the basis of a 8h/day, 40h/week work schedule). In addition ACGIH defines:
TLVs are regulatory limits in the State of Wisconsin if OSHA does not designate a PEL for that specific gas or particulate. In many laboratories the TLV-STEL or TLV-C of a chemical are more appropriate values unless the individual routinely works with the chemical. Unfortunately values for TLVs are not available on the ACGIH website. Contact EH&S for assistance with TLVs.
Recommended Exposure Limits (RELs) were developed the National Institute for Occupational Safety and Health (NIOSH). NIOSH is the principal federal agency engaged in research, education, and training related to occupational safety and health. The REL is a level that NIOSH believes would be protective of worker safety and health over a working lifetime if used in combination with engineering and work practice controls, exposure and medical monitoring, posting and labeling of hazards, worker training and personal protective equipment. RELs are not legally enforceable.
NIOSH is well known for its NIOSH Pocket Guide to Chemical Hazards. In addition to containing RELs, it also has information on incompatibilities and reactivities, exposure routes, symptoms of exposure, target organs, potential cancer site, PPE, and first aid. A searchable version of the guide can be found online. The pocket guide can also be downloaded from this site.
NIOSH also provides concentrations for chemicals that it considers immediately dangerous to life or health (IDLH). NIOSH defines an IDLH condition as a situation "that poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment." IDLH values can be found in the NIOSH Pocket Guide to Chemical Hazards (see link above). The purpose for establishing this IDLH value was to determine a concentration from which a worker could escape without injury or without irreversible health effects. In determining IDLH values, the ability of a worker to escape without loss of life or irreversible health effects was considered along with severe eye or respiratory irritation and other effects (e.g., disorientation or incoordination) that could prevent escape. As a safety margin IDLH values were based on the effects that might occur as a consequence of a 30-minute exposure.
The American Industrial Hygiene Association (AIHA) develops worker exposure levels for health-based chemicals. Since most of the other worker protection limits are for commonly used industrial chemicals AIHA began developing Workplace Environmental Exposure Levels to meet a specific need. WEELs are air concentration guide values for agents in a healthy worker’s breathing zone. WEELs are not enforceable but provide a good guideline when no other guidance exists. The latest WEELs can be found online here.
When working with hazardous materials, laboratory personnel need to understand the risks associated with the chemicals. Once the hazards are known then steps can be taken to minimize the risk associated with the hazard. Such steps include appropriate PPE and engineering controls, such as fume hoods. OSHA requires that special provisions be taken when working with Particularly Hazardous Substances (PHSs) since these substances potentially pose a higher health risk. PHSs are, according to OSHA, “select carcinogens”, reproductive toxins, or substances that have a high degree of acute toxicity.
The OSHA requirements for working with PHSs are more a matter of degree than a clear-cut differentiation from other substances. Risk assessments must always be done. The Laboratory Standard simply requires that higher risk materials be identified and mandates that extra precautions be used, if appropriate.
Laboratory personnel must do their due diligence when planning an experiment or procedure to determine hazards. This appendix provides some information and links to resources that help you identify PHSs. It is impossible to provide a master list of all PHSs so the information below should not be considered as comprehensive. This is especially true at a research institution where exotic materials are used for which there is no toxicological information. Also, toxicity is often related to the chemical’s form and how it is used. For example, compounds which are not considered highly dangerous may pose a much greater risk in the form of a nanoparticle. It is for this reason that prudent practices should always be taken to minimize exposures.
“Select carcinogens” are any substances that meet one of the following criteria:
The National Toxicology Program has a website that provides the most recent list of materials known or reasonably anticipated to be carcinogenic. The website also provides a profile for each of the chemicals summarizing the carcinogenicity, properties, uses, and exposure routes for the substance. The website can be accessed online here.
A list of all the materials for which the IARC has issued reports can be found at the following website.
This site also indicates the category the material falls under, with Group 1, 2A, and 2B being the chemicals of greatest concern.
Reproductive toxins, according to OSHA, are chemicals that affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis). The Environmental Health and Safety Office at Iowa State University has compiled a list of carcinogens, reproductive toxins and teratogens on their website. This can be found here.
OSHA defines substances that have a high degree of acute toxicity as substances that are “fatal or cause damage to target organs as a result of a single exposure or exposures of short duration”. Due to the recent changes in the OSHA Hazard Communication Standard and pending further guidance from OSHA, UW–Madison will continue to use the term “highly toxic” per the previous OSHA definition. According to OSHA, a chemical falling within any of the following categories is considered to be highly toxic:
A complete list of all highly toxic compounds is impossible to compile. The compounds listed below were obtained from Penn State University. This list is provided as an aid. Laboratory personnel must still do their due diligence when performing a risk assessment. Consult other sources whenever possible. The SDS should also be consulted as it often has NFPA or HMIS health ratings for the compounds.
| COMPOUND | CAS # |
|---|---|
| ACETONE CYANOHYDRIN (DOT) | 75-86-5 |
| ACETONYLBENZYL)-4-HYDROXYCOUMARIN, 3- | 81-81-2 |
| ACROLEIN, INHIBITED (DOT) | 107-02-8 |
| ACTIDIONE | 66-81-9 |
| ACTINOMYCIN D | 50-76-0 |
| AFLATOXINS | 1402-68-2 |
| ALDRIN (DOT) | 309-00-2 |
| ALLYL BROMIDE (DOT) | 106-95-6 |
| ALLYL ISOTHIOCYANATE | 57-06-7 |
| ALLYLIDENE DIACETATE | 869-29-4 |
| ALUMINUM PHOSPHIDE (DOT) | 20859-73-8 |
| AMINO PYRIDINE, 2- | 504-29-0 |
| AMINOPTERIN | 54-62-6 |
| AMINOPYRIDINE, 4- | 504-24-5 |
| ANTU (NAPHTHYLTHIOUREA, ALPHA-) | 86-88-4 |
| ARSENIC ACID, SODIUM SALT (SODIUM ARSENATE) | 7631-89-2 |
| ARSENIC ACID, SOLUTION | 7778-39-4 |
| ARSENIC IODIDE | 7784-45-4 |
| ARSENIC PENTASULFIDE | 1303-34-0 |
| ARSENIC PENTOXIDE (DOT) | 1303-28-2 |
| ARSENIC TRICHLORIDE | 7784-34-1 |
| ARSENIC TRIOXIDE | 1327-53-3 |
| ARSENIC TRISULFIDE | 1303-33-9 |
| ARSENIOUS ACID (ARSENIC TRIOXIDE, SOLID) | 1327-53-3 |
| ARSENIOUS OXIDE (ARSENIC TRIOXIDE, SOLID) | 1327-53-3 |
| ARSINE | 7784-42-1 |
| AZINPHOS-METHYL | 86-50-0 |
| AZIRIDINE | 151-56-4 |
| BAY 25141 | 115-90-2 |
| BENZEDRINE | 300-62-9 |
| BENZENETHIOL (PHENYL MERCAPTAN) (DOT) | 108-98-5 |
| BIDRIN | 141-66-2 |
| BORON TRIFLUORIDE | 7637-07-2 |
| BUSULFAN | 55-98-1 |
| BUTANEDIOL DIMETHYLSULFONATE, 1,4- | 55-98-1 |
| BUTYL-4,6-DINITROPHENOL, 2-SEC- | 88-85-7 |
| CALCIUM ARSENATE, SOLID | 7778-44-1 |
| CALCIUM CYANIDE | 592-01-8 |
| CARBON OXYFLUORIDE | 353-50-4 |
| CARBONYL CHLORIDE | 75-44-5 |
| CARBONYL FLUORIDE | 353-50-4 |
| CARBONYL SULFIDE | 463-58-1 |
| CHLORINATED DIPHENYL OXIDE | 31242-93-0 |
| CHLORINE (DOT) | 7782-50-5 |
| CHLORINE PENTAFLUORIDE | 13637-63-3 |
| CHLORINE TRIFLUORIDE | 7790-91-2 |
| CISPLATIN | 15663-27-1 |
| CYANOGEN | 460-19-5 |
| CYANOGEN CHLORIDE | 506-77-4 |
| CYCLOHEXIMIDE | 66-81-9 |
| CYCLOPHOSPHAMIDE | 50-18-0 |
| DASANIT | 115-90-2 |
| DAUNOMYCIN | 20830-81-3 |
| DDVP (DICHLORVOS) | 62-73-7 |
| DEMETON, MIXED ISOMERS | 8065-48-3 |
| DICHLORO-N-METHYLDIETHYLAMINE, 2,2'- | 51-75-2 |
| DICHLORVOS | 62-73-7 |
| DICROTOPHOS | 141-66-2 |
| DIELDRIN (DOT) | 60-57-1 |
| DIETHYL S-[2-(ETHYLTHIO)ETHYL]PHOSPHORODITHIOATE, O- | 298-04-4 |
| DIETHYLHYDRAZINE, 1,2- | 1615-80-1 |
| DIISOPROPLY FLUOROPHOSPHATE | 55-91-4 |
| DIMETHYL MERCURY | 593-74-8 |
| DINITRO-O-CRESOL, 4,6- | 534-52-1 |
| DINITROPHENOL, 2, 4- | 51-28-5 |
| DINOSEB | 88-85-7 |
| DIOXATHION | 78-34-2 |
| DISULFOTON | 298-04-4 |
| DNBP | 88-85-7 |
| ENDOSULFAN | 115-29-7 |
| ENDRIN | 72-20-8 |
| EPN | 2104-64-5 |
| ETHION | 563-12-2 |
| ETHYLENEIMINE (DOT) | 151-56-4 |
| FENAMIPHOS | 22224-92-6 |
| FENSULFOTHION | 115-90-2 |
| FLUOROACETIC ACID, SODIUM SALT | 62-74-8 |
| FONOFOS | 944-22-9 |
| GLYCOLONITRILE | 107-16-4 |
| GUTHION | 86-50-0 |
| HEPTACHLOR | 76-44-8 |
| HEPTACHLOR EPOXIDE | 1024-57-3 |
| HYDROCYANIC ACID, LIQUIFIED | 74-90-8 |
| HYDROGEN CHLORIDE GAS | 7647-01-0 |
| HYDROGEN CYANIDE | 74-90-8 |
| HYDROGEN FLUORIDE GAS | 7664-39-3 |
| HYDROXY-3(3-OXO-1-PHENYLBUTYL)-2H-1-BENZOPYRAN-2-ONE | 81-81-2 |
| IRON PENTACARBONYL | 13463-40-6 |
| LANNATE | 16752-77-5 |
| MELPHALAN | 148-82-3 |
| MERCURIC CHLORIDE | 7439-97-6 |
| METHYL CYCLOPENTADIENYL MANGANESE TRICARBONYL, 2- | 12108-13-3 |
| METHYL HYDRAZINE | 60-34-4 |
| METHYL IODIDE | 74-88-4 |
| METHYL MERCURY | 593-74-8 |
| METHYL PARATHION, LIQUID | 298-00-0 |
| METHYL VINYL KETONE, INHIBITED (DOT) | 78-94-4 |
| METHYL-BIS(2-CHLOROETHYL) AMINE (NITROGEN MUSTARD), N- | 51-75-2 |
| METHYL-N-NITROSO-METHANAMINE,N- | 62-75-9 |
| METHYLAZIRIDINE, 2- (PROPYLENEIMINE, INHIBITED) | 75-55-8 |
| METHYLHYDRAZINE (DOT) | 60-34-4 |
| METHYLPROPYL)-4,6-DINITRO-PHENOL,2-(1- | 88-85-7 |
| MEVINPHOS | 7786-34-7 |
| MITOMYCIN C | 50-07-7 |
| MONOCROTOPHOS | 6923-22-4 |
| MYLERAN | 55-98-1 |
| NAPHTHYLTHIOUREA, ALPHA- | 86-88-4 |
| NITROGEN MUSTARD | 51-75-2 |
| NITROSODIMETHYLAMINE, N- | 62-75-9 |
| PARAQUAT, RESPIRABLE FRACTION | 2074-50-2 |
| PERFLUOROISOBUTYLENE | 382-21-8 |
| PHENYL MERCAPTAN (DOT) | 108-98-5 |
| PHENYLPHOSPHINE | 638-21-1 |
| PHORATE | 298-02-2 |
| PHOSDRIN (MEVINPHOS) | 7786-34-7 |
| PHOSGENE | 75-44-5 |
| PHOSHONOTHIOIC ACID, O-ETHYL O-(P-NITROPHENYL)ESTER, | 2104-64-5 |
| PHOSPHINE | 7803-51-2 |
| PHOSPHORUS PENTAFLUORIDE | 7641-19-0 |
| POTASSIUM CYANIDE, SOLID (DOT) | 151-50-8 |
| PREMERGE | 88-85-7 |
| PROPANENITRILE | 107-12-0 |
| PROPIONITRILE | 107-12-0 |
| PROPYLENEIMINE, INHIBITED (DOT) | 75-55-8 |
| SODIUM AZIDE | 26628-22-8 |
| SODIUM CYANIDE, SOLID (DOT) | 143-33-9 |
| STRYCHNINE, SOLID (DOT) | 57-24-9 |
| SULFOTEP | 3689-24-5 |
| SYSTOX | 8065-48-3 |
| TETRACHLORODIBENZO-P-DIOXIN, 2,3,7,8- (TCDD) | 1746-01-6 |
| TETRAETHYL DITHIOPYROPHOSPHATE (TEDP) | 3689-24-5 |
| TETRAETHYL LEAD, LIQUID | 78-00-2 |
| TETRAETHYLPYROPHOSPHATE, LIQUID | 107-49-3 |
| THIODAN (ENDOSULFAN) | 115-29-7 |
| THIOPHENOL (PHENYL MERCAPTAN) (DOT) | 108-98-5 |
| TRIETHYLENETHIOPHORAMIDE, N,N',N''- | 52-24-4 |
| TRIMETHYLENETRINITRAMINE | 121-82-4 |
| URACIL MUSTARD | 66-75-1 |
| VANADIUM PENTOXIDE | 1314-62-1 |
| VAPATONE (TETRAETHYLPYROPHOSPHATE, LIQUID) | 107-49-3 |
| WARFARIN | 81-81-2 |
The university is subject to the International Fire Code (IFC), by virtue of it being adopted by the Madison Fire Department (MFD), as well as the International Building Code since the State of Wisconsin has adopted the 2015 version. MFD also enforces sections of the National Fire Protection Association (NFPA) standards since these have been adopted by IFC reference.
The tables in this section attempt to portray the limits that are imposed by the codes mentioned above. The maximum allowable quantities (MAQs) listed below are per control area. As discussed in Section 6.1 of this document a laboratory is not necessarily a control area – it may consist of more than one laboratory. These limits are therefore guidelines since it is beyond the scope of this document to provide information on each campus building. Most laboratories are unlikely to exceed the MAQs. In instances where the MAQs are approached, it is often possible to reduce the inventory on-hand by making minimal changes to procedures. Contact the Chemical Safety Office if you have any questions concerning the limits. Note: Only a few facilities have been specifically constructed to allow quantities in excess of the MAQs.
This table provides a list of MAQs based on the class of material. The MAQs are defined below for the ground floor level (floor 1). Higher level floors and below grade floors decrease the MAQ as indicated in Table D2. The table includes storage limits and limits for usage in an open or closed system. IFC defines “open” and “closed” systems as the following:
OPEN SYSTEM. The use of a solid or liquid hazardous material involving a vessel or system that is continuously open to the atmosphere during normal operations and where vapors are liberated, or the product is exposed to the atmosphere during normal operations. Examples of open systems for solids and liquids include dispensing from or into open beakers or containers, dip tank and plating tank operations.
CLOSED SYSTEM. The use of a solid or liquid hazardous material involving a closed vessel or system that remains closed during normal operations where vapors emitted by the product are not liberated outside of the vessel or system and the product is not exposed to the atmosphere during normal operations; and all uses of compressed gases. Examples of closed systems for solids and liquids include product conveyed through a piping system into a closed vessel, system or piece of equipment.
Additional definitions are supplied at the end of this Appendix. When viewing Table D1 note the footnotes below the Tables. These indicate building or containment features that may increase the MAQs or, in some instances, are required. Also, the aggregate quantity in use and storage cannot exceed the quantity listed for storage. Table D1 assumes the laboratory is on the ground floor.
| Hazardous Material | Class | Storage | Use (closed system) | Use (open system) |
|---|---|---|---|---|
| Flammable Liquid (gallons) |
IA IB or IC |
301,2 1201,2 |
301 1201 |
101 301 |
| Combustible liquids (gallons) |
II IIIA |
1201,2 3301,2 |
1201 3301 |
301 801 |
| Flammable gas, gaseous (cubic feet) | 10001,2 | 10001,2 | NA | |
| Flammable gas, liquefied (pounds) | 1501,2 | 1501,2 | NA | |
| Flammable solid (pounds) | 1251,2 | 1251 | 251 | |
| Cryogenics, flammable (pounds) | 451 | 451 | 101 | |
| Cryogenics, oxidizing (pounds) | 451 | 451 | 101 | |
| Organic peroxides (pounds) |
UD I II III |
12,4 51,2 501,2 1251,2 |
0.254 11 501 1251 |
0.254 11 101 251 |
| Highly Toxic gases, gaseous (cubic feet) | 201 | 201,3 | NA | |
| Highly Toxic gases, liquefied (pounds) | 41,3 | 41,3 | NA | |
| Highly Toxic liquids or solids (pounds) | 101,2 | 101 | 31 | |
| Toxic gases, gaseous (cubic feet) | 8101,2 | 8101,2 | NA | |
| Toxic gases, liquefied (pounds) | 1501,2 | 1501,2 | NA | |
| Toxic liquids or solids (pounds) | 5001,2 | 5001 | 1251 | |
| Oxidizing gas, gaseous (cubic feet) | 15001,2 | 15001,2 | ||
| Oxidizing gas, liquefied (pounds) | 1501,2 | 1501,2 | ||
| Pyrophoric solids or liquids (pounds) | 42,4 | 14 | 0 | |
| Pyrophoric gases (cubic feet) | 502,4 | 102,4 | 0 | |
| Unstable (reactive) solids or liquids (pounds) |
4 3 2 |
12,4 51,2 501,2 |
0.254 11 501 |
0.254 11 501 |
| Unstable (reactive) Gases (cubic feet) |
4 3 2 |
102,4 501,2 2501,2 |
22,4 101,2 2501,2 |
|
| Water reactive (pounds) |
3 2 |
51,2 501,2 |
51 501 |
11 101 |
| Corrosive, solids (pounds) | 50001,2 | 50001 | 10001 | |
| Corrosive, liquids (gallons) | 5001,2 | 5001 | 1001 | |
| Corrosive, gases (cubic feet) | 8101 | 8101 | ||
| Corrosive, liquified gas (pounds) | 1501 | 1501 |
NA = Not applicable; a cubic foot = 0.0283 m3; 1 pound = 0.454 kg.; 1 gallon = 3.785 L.
1 Maximum quantities shall be increased 100% (Table D1) for buildings equipped throughout with an automatic sprinkler. Where note 2 also applies the increase for both notes are to be applied accumulatively.
2 Maximum allowable quantities are to be increased up to 100% when stored in approved storage cabinets, gas cabinets, exhausted enclosures or safety cans as specified in IFC. Where note 1 also applies the increase for both notes are to be applied accumulatively.
3 Allowed only when stored in approved exhausted gas cabinets or exhausted enclosures as specified in the International Fire Code.
4 Permitted only in buildings equipped throughout with an automatic sprinkler system.
Additional Notes:
The MAQs defined in Table D1 are defined for first floor occupancies. Other floors (both above and below grade) have lower MAQs based on a percentage of the 1st floor MAQ. Table D2 provide these percentages as well as the number of allowable control areas per floor.
| Floor Level | % of MAQ per Control Area | No. of Control Areas |
|---|---|---|
| 1 | 100 | 4 |
| 2 | 75 | 3 |
| 3 | 50 | 2 |
| 4 through 6 | 12.5 | 2 |
| 7 through 9 | 5 | 2 |
| 10 and above | 5 | 1 |
| Below Grade Level 1 | 75 | 1 |
| Below Grade Level 2 | 50 | 1 |
NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals sets limits on the quantities of flammable and combustible liquids that can be stored in any one container based on the construction of the container. Aggregate quantities must still be below the amounts indicated by Tables D1 and D2.
| Container Type | Flammable Liquids | Combustible Liquids | |||
|---|---|---|---|---|---|
| Class IA | Class IB | Class IC | Class II | Class III | |
| Glass or approved plastic | 1 pt. | 1 qt. | 1 gal. | 1 gal. | 1 gal. |
| Metal (other than DOT drums) | 1 gal. | 5 gal. | 5 gal. | 5 gal. | 5 gal. |
| Safety cans | 2 gal. | 5 gal. | 5 gal. | 5 gal. | 5 gal. |
| Metal drums (DOT specifications) | 60 gal. | 60 gal. | 60 gal. | 60 gal. | 60 gal. |
| Approved portable tanks | 660 gal. | 660 gal. | 660 gal. | 660 gal. | 660 gal. |
The following chart lists the maximum volume of flammables and combustibles that can be stored in a single flammable storage cabinet. Again, quantities in a given control area cannot exceed MAQs listed above.
| MAXIMUM STORAGE QUANTITIES FOR CABINETS | |
|---|---|
| Liquid Class | Maximum Storage Capacity |
| Flammable/Class I | 60 Gal. |
| Combustible/Class II | 60 Gal. |
| Combustible/Class III | 120 Gal. |
| Combination of classes | 120 Gal. |
Not more than 60 gallons may be Class I and Class II liquids. No more than 120 gallons of Class III liquids may be stored in a storage cabinet, according to OSHA 29 CFR 1910.106(d)(3) and NFPA 30 Section 4-3.1.
The IFC limits the quantities of flammable liquids that can be stored in a control area. The MAQs are based on the classification of the flammable liquids. The following table provides NFPA classification information for some common solvents. The NFPA fire diamond information is often found on containers or in SDSs. Liquids with a flammability rating of 3 are considered Class IB and IC liquids while those with a flammability rating of 4 are Class IA. Note that Class IA, IB, and IC are flammable liquids. Class II liquids are combustible.
| Chemical | Flash Point (℉/ ℃) | Boiling Point (℉/ ℃) | IFC Classification |
|---|---|---|---|
| Acetic acid | 103/39 | 245/118 | II |
| Acetone | -4/-20 | 133/56 | 1B |
| Acetaldehyde | -38/-39 | 70/21 | IA |
| Acetonitrile | 42/6 | 179/82 | IB |
| Acrylonitrile | 32/0 | 171/77 | IB |
| Benzene | 12/-11 | 176/80 | IB |
| t-Butyl Alcohol | 52/11 | 181/83 | IB |
| Cyclohexene | 20/-7 | 181/83 | IB |
| Dioxane | 54/12 | 214/101 | IB |
| Ethyl Acetate | 24/-4 | 171/77 | IB |
| Ethyl Alcohol | 55/13 | 173/78 | IB |
| Ethyl Ether | -49/-45 | 95/35 | IA |
| Gasoline | -45/-43 | 100-400/38-204 | IB |
| Hexane | -7/-22 | 156/69 | IB |
| Isopropanol | 53/12 | 183/83 | IB |
| Methanol | 52/11 | 174/64 | IB |
| Methylene Chloride | none | 104/40 | - |
| Methyl Ethyl Ketone | 16/-9 | 176/80 | IB |
| Pentane | -40/ | 97/36 | IA |
| Petroleum Ether | 0/-18 | 95-140/35-60 | IA-IB |
| Propyl Alcohol | 74/23 | 207/97 | IC |
| n-Propyl Ether | 70/21 | 194/90 | IB |
| Pyridine | 68/20 | 239/115 | IB |
| Tetrahydrofuran | 6/-14 | 151/66 | IB |
| Toluene | 40/4 | 230/111 | IB |
| Triethylamine | 16/-7 | 193/89 | IB |
| m-Xylene | 77/25 | 282/138 | IC |
The following table provides information on the hazards associated with common gases. This will aid risk assessments and also help determine MAQs. Since gases can fall into multiple categories (such as flammable and highly toxic) the most restrictive MAQ applies.
| Gas | Asphyxiant | Flammable | Oxidizer | Corrosive | Toxic | Highly Toxic | Pyrophoric | LC50/PEL (ppm) |
|---|---|---|---|---|---|---|---|---|
| Ammonia (NH3) | X | X | 4000/50 | |||||
| Arsine (AsH3) | X | X | 20/0.05 | |||||
| Boron Tribromide (BBr3) | X | X | 380/1 | |||||
| Boron Trichloride (BCl3) | X | X | 2541/5 | |||||
| Bromine (Br2) | X | X | X | 113/0.1 | ||||
| Chlorine (Cl2) | X | X | X | 293/1 | ||||
| Chlorine Dioxide (ClO2) | X | X | 250/0.1 | |||||
| Chlorine Trifluoride (ClF3) | X | X | 299/0.1 | |||||
| Diborane (B2H6) | X | X | X | 80/0.1 | ||||
| Dichlorosilane (SiH2Cl2) | X | X | X | 314/5 | ||||
| Ethylene Oxide (C2H4O) | X | X | 4350/1 | |||||
| Fluorine (F2) | X | X | X | 185/0.1 | ||||
| Germane (GeH4) | X | X | 622/0.2 | |||||
| Hydrogen (H2) | X | X | ||||||
| Hydrogen Bromide (HBr) | X | 2860/3 | ||||||
| Hydrogen Chloride (HCl) | X | 2810/5 | ||||||
| Hydrogen Cyanide (HCN) | X | X | 40/10 | |||||
| Hydrogen Fluoride (HF) | X | X | 1300/3 | |||||
| Methyl Bromide (CH3Br) | X | X | 1007/20 | |||||
| Nickel Carbonyl [Ni (CO)4] | X | X | 18/0.001 | |||||
| Nitrogen Dioxide (NO2) | X | X | 115/5 | |||||
| Oxygen (O2) | X | |||||||
| Phosgene (COCl2) | X | 5/0.1 | ||||||
| Phosphine (PH3) | X | X | 20/0.3 | |||||
| Silane (SiH4) | X | X | X | 9600/5 | ||||
| Sulfur Dioxide (SO2) | X | 2520/5 |
Note: Argon, carbon dioxide, helium and nitrogen are asphyxiating gases.
PEL: Permissible exposure limit.
LC50: For inhalation experiments, the concentration of the chemical in air that kills 50% of the test animals in a given time (usually four hours) is the LC50 value.
The University of Wisconsin-Madison is subject to two key regulations which require it to have knowledge of chemical inventories. The Emergency Planning and Community Right-to Know Act (EPCRA) requires the university to report quantities above specified thresholds for listed chemicals to state and local emergency planners. The Department of Homeland Security (DHS) also has created a list of Chemicals of Interest (COI) based on threat criteria such as sabotage, theft, and release. All chemical facilities in the U.S. must report any COIs maintained above the screening threshold quantities (STQs). In order to remain compliant the university requires that laboratory inventories of the specific chemicals (listed in the tables below) be maintained. Since most laboratories work with low quantities of material the lists have been truncated to include only those chemicals which have a low reporting threshold. Chemical spills involving chemicals on the EPCRA list should be reported to UW–Madison Chemical Safety Office since specific reporting requirements may apply.
Laboratory staff should consult the complete EPA List of Lists and the complete DHS COI list when working with unusually large amounts of a hazardous chemical to determine whether the chemical should be included on their inventory. Contact the Chemical Safety Office for any questions on inventory requirements. The TPQs and STQs have been included for information purposes only.
Below is listed a subset of the EPCRA extremely hazardous substances list which have low threshold planning quantities (TPQs).
| Chemical | CAS # | Density (lbs/gal)1 | Threshold Planning Quantity (lbs) | Reportable Volume (gal) | Reportable Volume (L) |
|---|---|---|---|---|---|
| Nickel carbonyl | 13463-39-3 | 11.01 | 1 | 0.1 | 0.3 |
| 2-Chloro-N-(2-chloroethyl)-N-methylethanamine/ Mechlorethamine / Nitrogen mustard | 51-75-2 | 9.31 | 10 | 1.1 | 4.1 |
| Carbonic dichloride / Phosgene | 75-44-5 | 11.43 | 10 | 0.9 | 3.3 |
| Ethylene fluorohydrin | 371-62-0 | 9.20 | 10 | 1.1 | 4.1 |
| Fluoroacetyl chloride | 359-06-8 | 11.27 | 10 | 0.9 | 3.4 |
| Hydrogen selenide | 7783-07-5 | Gas | 10 | ||
| Lewisite | 541-25-3 | 15.73 | 10 | 0.6 | 2.4 |
| Methyl vinyl ketone | 78-94-4 | 7.19 | 10 | 1.4 | 5.3 |
| Phorate | 298-02-2 | 9.63 | 10 | 1.0 | 3.9 |
| Propargyl bromide | 106-96-7 | 13.15 | 10 | 0.8 | 2.9 |
| Sarin | 107-44-8 | 9.07 | 10 | 1.1 | 4.2 |
| Tabun | 77-81-6 | 8.94 | 10 | 1.1 | 4.2 |
| 2-Propenoyl chloride / Acrylyl chloride | 814-68-6 | 9.28 | 100 | 10.8 | 40.8 |
| Arsine | 7784-42-1 | Gas | 100 | ||
| Benzene, 1,3-diisocyanato-2-methyl- / Toluene-2,6-diisocyanate | 91-08-7 | 10.16 | 100 | 9.8 | 37.2 |
| Benzoic trichloride / Benzotrichloride | 98-07-7 | 11.46 | 100 | 8.7 | 33.0 |
| Bis(chloromethyl) ether / Chloromethyl ether / Dichloromethyl ether / Methane, oxybis[chloro- | 542-88-1 | 11.02 | 100 | 9.1 | 34.3 |
| Chlorine | 7782-50-5 | Gas | 100 | ||
| Chloromethyl methyl ether / Methane, chloromethoxy- | 107-30-2 | 8.83 | 100 | 11.3 | 42.9 |
| Cyanuric fluoride | 675-14-9 | 13.33 | 100 | 7.5 | 28.4 |
| Diborane / Diborane(6) | 19287-45-7 | Gas | 100 | ||
| Dicrotophos | 141-66-2 | 10.13 | 100 | 9.9 | 37.4 |
| Diisopropylfluorophosphate / Isofluorphate | 55-91-4 | 8.79 | 100 | 11.4 | 43.1 |
| Diphosphoramide, octamethyl- / Schradan | 152-16-9 | 9.45 | 100 | 10.6 | 40.1 |
| Formothion | 2540-82-1 | 11.34 | 100 | 8.8 | 33.4 |
| Hexachlorocyclopentadiene | 77-47-4 | 14.18 | 100 | 7.1 | 26.7 |
| Hydrocyanic acid / Hydrogen cyanide | 74-90-8 | 5.72 / Gas | 100 | 17 | 66.2 |
| Hydrofluoric acid / Hydrofluoric acid (conc. 50% or greater) | 7664-39-3 | 8.35 | 100 | 12.0 | 45.4 |
| Hydrogen fluoride / Hydrogen fluoride (anhydrous) | 7664-39-3 | Gas | 100 | ||
| Iron carbonyl (Fe(CO)5), (TB-5-11)- / Iron, pentacarbonyl- | 13463-40-6 | 12.41 | 100 | 8.1 | 30.5 |
| Lithium hydride | 7580-67-8 | Solid | 100 | ||
| Manganese, tricarbonyl methylcyclopentadienyl | 12108-13-3 | 11.58 | 100 | 8.6 | 32.7 |
| Methacryloyl chloride | 920-46-7 | 9.06 | 100 | 11.0 | 41.8 |
| Methacryloyloxyethyl isocyanate | 30674-80-7 | 9.15 | 100 | 10.9 | 41.4 |
| Methyl phosphonic dichloride | 676-97-1 | 11.58 | 100 | 8.6 | 32.7 |
| Nicotine / Pyridine, 3-(1-methyl-2-pyrrolidinyl)-,(S)- | 54-11-5 | 8.41 | 100 | 11.9 | 45.0 |
| Nitric oxide / Nitrogen oxide (NO) | 10102-43-9 | Gas | 100 | ||
| Nitrogen dioxide | 10102-44-0 | 12.06 / Gas | 100 | 8.3 | 31.4 |
| Ozone | 10028-15-6 | Gas | 100 | ||
| Parathion / Phosphorothioic acid, O,O-diethyl-O-(4-nitrophenyl) ester | 56-38-2 | 10.50 | 100 | 9.5 | 36.7 |
| Phosphamidon | 13171-21-6 | 10.11 | 100 | 9.9 | 37.5 |
| Phosphonothioic acid, methyl-, S-(2-(bis(1-methylethyl)amino)ethyl) O-ethyl ester | 50782-69-9 | 8.40 | 100 | 11.9 | 45.1 |
| Phosphorus / Phosphorus (yellow or white) | 7723-14-0 | Solid | 100 | ||
| Plumbane, tetramethyl- / Tetramethyllead | 75-74-1 | 16.62 | 100 | 6.0 | 22.8 |
| Potassium cyanide | 151-50-8 | Solid | 100 | ||
| Sodium cyanide (Na(CN)) | 143-33-9 | Solid | 100 | ||
| Sulfur fluoride (SF4), (T-4)- / Sulfur tetrafluoride | 7783-60-0 | Gas | 100 | ||
| Sulfur trioxide | 7446-11-9 | Solid | 100 | ||
| Tellurium hexafluoride | 7783-80-4 | Gas | 100 | ||
| TEPP / Tetraethyl pyrophosphate | 107-49-3 | 9.87 | 100 | 10.1 | 38.3 |
| Terbufos | 13071-79-9 | 9.20 | 100 | 10.9 | 41.1 |
| Tetraethyl lead | 78-00-2 | 13.77 | 100 | 7.3 | 27.5 |
| Tetraethyltin | 597-64-8 | 9.99 | 100 | 10.0 | 37.9 |
| Titanium chloride (TiCl4) (T-4)- / Titanium tetrachloride | 7550-45-0 | 14.38 | 100 | 7.0 | 26.3 |
| Trichloro(chloromethyl)silane | 1558-25-4 | 12.30 | 100 | 8.1 | 30.8 |
| Tris(2-chloroethyl)amine | 555-77-1 | 10.29 | 100 | 9.7 | 36.8 |
| The Items with two threshold planning quantities listed (e.g., 1/10,000) are those where the lower TPQ number applies if the substance is present as a solid in powder form with particle size less than 100 microns, in solution or in molten form. Inventories must be maintained only when they are in the low TPQ form. | |||||
| Chromic chloride | 10025-73-7 | Solid | 1/10,000 | ||
| Emetine, dihydrochloride | 316-42-7 | Solid | 1/10,000 | ||
| 4,6-Dinitro-o-cresol | 534-52-1 | Solid | 10/10,000 | ||
| Azinphos-methyl / Guthion | 86-50-0 | Solid | 10/10,000 | ||
| Benzenearsonic acid | 98-05-5 | Solid | 10/10,000 | ||
| Bis(chloromethyl) ketone | 534-07-6 | Solid | 10/10,000 | ||
| Carbofuran | 1563-66-2 | Solid | 10/10,000 | ||
| Cobalt carbonyl | 10210-68-1 | Solid | 10/10,000 | ||
| Colchicine | 64-86-8 | Solid | 10/10,000 | ||
| Digoxin | 20830-75-5 | Solid | 10/10,000 | ||
| Dimethyl-p-phenylenediamine | 99-98-9 | Solid | 10/10,000 | ||
| Dinitrocresol | 534-52-1 | Solid | 10/10,000 | ||
| Diphacinone | 82-66-6 | Solid | 10/10,000 | ||
| Endosulfan | 115-29-7 | Solid | 10/10,000 | ||
| Fenamiphos | 22224-92-6 | Solid | 10/10,000 | ||
| Fluoroacetic acid | 144-49-0 | Solid | 10/10,000 | ||
| Fluoroacetic acid, sodium salt | 62-74-8 | Solid | 10/10,000 | ||
| Monocrotophos | 6923-22-4 | Solid | 10/10,000 | ||
| Organorhodium Complex (PMN-82-147) | 0 | Solid | 10/10,000 | ||
| Paraquat dichloride | 1910-42-5 | Solid | 10/10,000 | ||
| Paraquat methosulfate | 2074-50-2 | Solid | 10/10,000 | ||
| Sodium fluoroacetate | 62-74-8 | Solid | 10/10,000 | ||
1 Density (lb/gal) = specific gravity * 8.33
| Chemicals of Interest | Synonym | CAS Number | Min. Conc. (%) | STQs (in pounds unless otherwise noted) |
|---|---|---|---|---|
| Arsenic trichloride | Arsenous trichloride | 7784-34-1 | 30 | 2.2 |
| Arsine | 7784-42-1 | 0.67 | 15 | |
| 1,4-Bis(2-chloroethylthio)-nbutane | 142868-93-7 | NA | 100g | |
| Bis(2-chloroethylthio)methane | 63869-13-6 | NA | 100g | |
| Bis(2-chloroethylthiomethyl)ether | 63918-90-1 | NA | 100g | |
| 1,5-Bis(2-chloroethylthio)-npentane | 142868-94-8 | NA | 100g | |
| 1,3-Bis(2-chloroethylthio)-npropane | 63905-10-2 | NA | 100g | |
| 2-Chloroethylchloromethylsulfide | 2625-76-5 | NA | 100g | |
| Chlorosarin | o-Isopropyl methylphosphonochloridate | 1445-76-7 | NA | 100g |
| Chlorosoman | o-Pinacolyl methylphosphonochloridate | 7040-57-5 | NA | 100g |
| DF | Methyl phosphonyl difluoride | 676-99-3 | NA | 100g |
| N,N-(2-diethylamino)ethanethiol | 100-38-9 | 30 | 2.2 | |
| o,o-Diethyl S-[2-(diethylamino)ethyl] phosphorothiolate | 78-53-5 | 30 | 2.2 | |
| Diethyl methylphosphonite | 15715-41-0 | 30 | 2.2 | |
| N,N-Diethyl phosphoramidic dichloride | 1498-54-0 | 30 | 2.2 | |
| N,N-(2-diisopropylamino)ethanethiol N,N-diisopropyl-(beta)-aminoethane thiol | 5842-07-9 | 30 | 2.2 | |
| N,N-Diisopropyl phosphoramidic dichloride | 23306-80-1 | 30 | 2.2 | |
| N,N-(2-dimethylamino)ethanethiol | 108-02-1 | 30 | 2.2 | |
| N,N-Dimethyl phosphoramidic dichloride Dimethylphosphoramidodichloridate | 677-43-0 | 30 | 2.2 | |
| Dinitrogen tetroxide | 10544-72-6 | 3.8 | 15 | |
| N,N-(2-dipropylamino)ethanethiol | 5842-06-8 | 30 | 2.2 | |
| N,N-Dipropyl phosphoramidic dichloride | 40881-98-9 | 30 | 2.2 | |
| Fluorine | 7782-41-4 | 6.17 | 15 | |
| Germanium tetrafluoride | 7783-58-6 | 2.11 | 15 | |
| HN1 (nitrogen mustard-1) | Bis(2-chloroethyl)ethylamine | 538-07-8 | NA | 100g |
| HN2 (nitrogen mustard-2) | Bis(2-chloroethyl)methylamine | 51-75-2 | NA | 100g |
| HN3 (nitrogen mustard-3) | Tris(2-chloroethyl)amine | 555-77-1 | NA | CUM 100g |
| Hydrogen cyanide | Hydrocyanic acid | 74-90-8 | 4.67 | 15 |
| Hydrogen selenide | 7783-07-5 | 0.07 | 15 | |
| Isopropylphosphonothioic dichloride | 1498-60-8 | 30 | 2.2 | |
| Isopropylphosphonyl difluoride | 677-42-9 | NA | 100g | |
| Lewisite 1 | 2-Chlorovinyldichloroarsine | 541-25-3 | NA | 100g |
| Lewisite 2 | Bis(2-chlorovinyl)chloroarsine | 40334-69-8 | NA | 100g |
| Lewisite 3 | Tris(2-chlorovinyl)arsine | 40334-70-1 | NA | 100g |
| Methylphosphonothioic dichloride | 676-98-2 | 30 | 2.2 | |
| Sulfur mustard (Mustard gas(H)) | Bis(2-chloroethyl)sulfide | 505-60-2 | NA | 100g |
| O-Mustard (T) | Bis(2-chloroethylthioethyl)ether | 63918-89-8 | NA | 100g |
| Nitric oxide | Nitrogen oxide (NO) | 10102-43-9 | 3.83 | 15 |
| Nitrogen mustard hydrochloride | Bis(2-chloroethyl)methylamine hydrochloride | 55-86-7 | 30 | 2.2 |
| Nitrogen trioxide | 10544-73-7 | 3.83 | 15 | |
| Nitrosyl chloride | 2696-92-6 | 1.17 | 15 | |
| Oxygen difluoride | 7783-41-7 | 0.09 | 15 | |
| Phosgene | Carbonic dichloride;carbonyl dichloride | 75-44-5 | 0.17 | 15 |
| Phosphine | 7803-51-2 | 0.67 | 15 | |
| Propylphosphonothioic dichloride | 2524-01-8 | 30 | 2.2 | |
| Propylphosphonyl difluoride | 690-14-2 | 100g | ||
| Selenium hexafluoride | 7783-79-1 | 1.67 | 15 | |
| Sesquimustard | 1,2-Bis(2-chloroethylthio)ethane | 3563-36-8 | NA | 100g |
| Soman | o-Pinacolyl methylphosphonofluoridate | 96-64-0 | NA | 100g |
| Stibine | 7803-52-3 | 0.67 | 15 | |
| Sulfur tetrafluoride | Sulfur fluoride (SF4), (T-4)- | 7783-60-0 | 1.33 | 15 |
| Tabun | o-Ethyl-N,Ndimethylphosphoramido-cyanidate | 77-81-6 | NA | 100g |
| Tellurium hexafluoride | 7783-80-4 | 0.83 | 15 | |
| Thiodiglycol | Bis(2-hydroxyethyl)sulfide | 111-48-8 | 30 | 2.2 |
| VX | o-Ethyl-S-2-diisopropylaminoethyl methyl phosphonothiolate | 50782-69-9 | NA | 100g |
NIOSH Pocket Guide to Chemical Hazards
Prudent Practices in the Laboratory
Agents Classified by the IARC Monographs
ANSI standard Z358.1, Emergency Eyewash and Shower Equipment
Iowa State University: Carcinogens, Reproductive Toxins, and Teratogens
NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals
OSHA 29 CFR 1910.106 Flammable and Combustible Liquids
OSHA 29 CFR 1910.1000 Air contaminants
OSHA 29 CFR 1910.1000 TABLE Z-1 Limits for Air Contaminants
OSHA 29 CFR 1910.1450 Occupational exposure to hazardous chemicals in laboratories
Wis. Admin. Code SPS § 332 Public Employee Safety and Health
U.S. Department of Health and Human Services (HHS) 15th Report on Carcinogens.
08-01-2020
