The chemical hygiene plan (CHP) is the cen- terpiece of the OSHA laboratory standard
29CFR1910.1450, Occupational Exposure to Hazardous Chemicals in
Laboratories. According to the
standard, the CHP must be “capable
of protecting employees from the
health hazards presented by hazardous chemicals used in that particular workplace.” Among the
stipulations for CHPs is the appointment of a Chemical Hygiene
Officer (CHO), who is responsible
for implementing the CHP. Here are
some suggestions for creating an
Enforce the policies. If you don’t enforce your chemical safety policies, you
don’t have policies; you have lip service.
Working safely needs to be a condition
Describe everyone’s responsibilities.
Start at the top of the organization and
work your way through all the major
levels of management. The CHO’s responsibilities belong here as well. Remember, the sled can’t go any faster
than the lead dog.
Don’t forget to include your students.
You can’t adequately protect your faculty and staff when you have 20–30 students following a lower standard of care.
If faculty and staff need to observe
OSHA PELs, ACGIH® TLV®s and NIOSH
RELs, how can we justify exposing students to higher levels?
Serve as an advisor. The CHO is not a
cop. Enforcement belongs to the supervisor, not the CHO. Supervisors give praise,
bonuses and promotions to their employees; faculty give praise and grades to
their students for their work and behavior. They are the ones who need to enforce the rules and, if necessary,
Create a rotating CHP review team. The
CHP is supposed to be reviewed at least
annually and revised as needed. Every
year, appoint a new team of four to ten
employees (depending on the size of
your organization) to review the CHP.
Ideally, everyone who is covered under
the plan will participate in the review
once every five to ten years.
Making the review everyone’s responsibility is much better than having the
same people do it over and over. Include
some students on the review team to enrich their education and make them
more valuable (as well as safer and
healthier) future employees.
Invite all team members to a CHP review
luncheon to discuss their ideas. Ask a
senior manager or administrator to send
everyone on the team a thank-you note.
Create a lab safety bulletin board.
Every month, post a brief summary (in a
large font) of a section of your CHP.
Why wait for the refresher training?
Make the bulletin board a passive learning center. Include accident stories, off-the-job safety information, the
emergency procedure of the month and
the MSDS of the month.
Pay your CHO. This is not a volunteer
position. It is a federal or state requirement. Provide time off, reduced teaching
load, and appropriate overtime or additional compensation.
Define the CHO’s time commitment.
The CHO and his or her supervisor need
to know how much time he or she is expected to spend on CHO responsibilities.
Misunderstandings lead to problems.
Once management has decided how
much time to allocate to this position,
you’ll have a better understanding of
what can be accomplished. You can then
define the tasks that can be reasonably
completed in the available time and
fairly evaluate the CHO.
Any compliance tasks that cannot be
completed are management’s responsibility, not the CHO’s. Management is responsible for making business decisions
about how to allocate resources and how
much compliance it wishes to have.
Summarize prior approvals. OSHA requires CHPs to describe the circumstances that require prior approval. Some
plans list them all in one section; others
include them throughout the document.
If your CHP discusses prior approvals
throughout the document, include a separate section that briefly lists all prior
approval circumstances and refers readers to the appropriate section for more
According to Plan | FEATURE
information. If your plan is electronic,
make these references hyperlinks.
Require prior approval for new particularly hazardous substances (PHS). The
standard asks the employer to describe
the additional precautions that should be
taken when working with PHS. Obtain
prior approval for both purchasing new
PHS (those that aren’t currently in the
inventory) and using ones not previously
Review eye and face protection language. Make sure that the CHP clarifies
which types of eye protection should be
used. Only ANSI Z-87.1-compliant indirect vent (or nonventilated) cover goggles
are appropriate for protection against
chemical splashes. Face shields, which
protect the face and throat, are used only
in addition to, and not instead of, eye
protection. Neither safety glasses nor
safety goggles are primary eye protection.
Distinguish between “must” and
“should.” The plan needs to clearly indi-
cate the policies and practices over
which users have no discretion. They
must do it that way. Other policies and
practices may offer the user some discre-
tion about how to proceed. These latter
policies contain the word “should.”
Separate policy from instruction. The
CHP should focus readers’ attention on
what they need to do. Place all instruc-
tional information and explanations of
lab procedures in a separate document. If
your plan is electronic, link to the expla-
nations and instructions.
Identify your occupational medicine
provider. The employer should have its
own occupational medicine provider/
clinic where employees can be seen by
professionals who understand chemical
exposure. Their name, address and phone
number should be in the plan.
Develop the CHP together. Employee/
faculty/staff acceptance of the CHP will
be greatly enhanced by their involvement in the creation of the plan. Invite
Good luck with your CHP!
Jim Kaufman is president and CEO of the Laboratory
Safety Institute in Natick, Mass. He can be reached
at firstname.lastname@example.org or (508) 647-1900.
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