Tuesday, November 5, 2013

8 Elements of a Chemical Hygiene Plan

OSHA's Laboratory Standard requires a written Chemical Hygiene Plan (CHP). And that plan must contain these eight elements.

The CHP must:
  • Describe standard operating procedures.
  • Define criteria for implementation of control measures (i.e. engineering controls, administrative controls, and PPE).
  • Define (and document) procedures to maintain proper functioning of chemical fume hoods and protective equipment. This includes procedures such as checking the flow rate of hoods and verifying that equipment is working properly.
  • Provide employee information and training.
  • Provide criteria for "prior approval." Where you have processes or procedures where employees have to get prior approval (e.g., working alone) criteria allow you to make arrangements for protection.
  • Provide criteria for medical consultation and examination.
  • Designate personnel responsible for implementation of the CHP. Employers must designate responsibilities to a variety of people both in and out of lab, including the Chemical Hygiene Officer and others. The highest up person should sign the plan, saying that he/she has authorized the plan.
  • Provide employee protection from particularly hazardous substances. Inventory chemicals and decide which fall into this category—for example, carcinogens and extremely reactive materials.
  • The Chemical Hygiene Plan must be easily accessible and designed to protect employees from health hazards associated with the specific hazardous chemicals in their laboratories. The plan can be maintained and available electronically as long as employees know how to access it.

Make Sure You're in Compliance

Since 1990, OSHA has required facilities engaged in the use of chemicals in a laboratory to develop and implement a written chemical hygiene plan (CHP).
This standard mandates that companies set forth procedures, equipment, PPE, work practices, training, and policies to help protect employees from the health hazards presented by hazardous chemicals used in their workplace.

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