Synergist - October 2011

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 effective CHP.

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 of employment.

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, discipline.

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 used.

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 their participation.

Good luck with your CHP!

Jim Kaufman is president and CEO of the Laboratory Safety Institute in Natick, Mass. He can be reached at jim@labsafetyinstitute.org or (508) 647-1900.