Chapter 1 - IntroductionChapter 1 - Introduction
The Cornell University Health and Safety Policy 8.6 outlines safety responsibilities and training requirements to ensure individual and institutional compliance with relevant environmental health and safety laws, regulations, policies, and guidelines. This Laboratory Safety Manual supplements the University’s Chemical Hygiene Plan and recommendations for good laboratory practices to serve as a useful resource and to assist laboratories in designing their own site-specific laboratory safety procedures to meet these requirements.
The Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1450, "Occupational Exposure to Hazardous Chemicals in Laboratories”, mandates health and safety practices and procedures in laboratories that use hazardous chemicals. The Standard became effective May 1, 1990 and requires that a Chemical Hygiene Plan be developed for each laboratory workplace. The purpose of the Laboratory Standard is to protect laboratory employees from harm due to chemicals while they are working in a laboratory. This regulation applies to all employers engaged in the laboratory use of hazardous chemicals which OSHA defines as:
"Laboratory" means a facility where the "laboratory use of hazardous chemicals" occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.
"Laboratory scale" means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. "Laboratory scale" excludes those workplaces whose function is to produce commercial quantities of materials.
“Hazardous chemical” means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term “health hazard” includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems and agents which damage the lungs, skins, eyes, or mucous membranes. Appendix A and Appendix B of the Hazard Communication standard (29 CFR 1910.1200) provide further guidance in defining the scope of health hazards and determining whether or not a chemical is to be considered hazardous for the purposes of this standard.
A complete description of definitions applicable to laboratories can be found in the OSHA Laboratory Standard.
In all other areas that use chemicals, but do not fall under the OSHA definition of a “laboratory”, the OSHA regulation 29 CFR 1910.1200 – "Hazard Communication Standard” applies.
Most laboratories at Cornell using chemicals are subject to the requirements of the Laboratory Standard. In addition to employees who ordinarily work full-time within a laboratory space, other employees (such as office, custodial, maintenance and repair personnel) who regularly spend a significant amount of their time within a laboratory environment as part of their duties, also may fall under the requirements of the Laboratory Standard. OSHA considers graduate students who get paid for working in a lab as employees who are subject to the requirements of the Laboratory Standard.
The OSHA Laboratory Standard requires employers to develop a Chemical Hygiene Plan (CHP), designate a Chemical Hygiene Officer, and ensure laboratory employees are provided with the proper information and training, including knowing the location of the Chemical Hygiene Plan, and how to work safely in their labs. The main goals of the OSHA Laboratory Standard and the requirement to develop a Chemical Hygiene Plan are; to protect employees from health hazards associated with use of hazardous chemicals in the laboratory, and keep exposures below the permissible exposure limits as specified in 29 CFR Part 1910, subpart Z – Toxic and Hazardous Substances and other resources such as NIOSH and ACGIH. In addition to other requirements, the OSHA Lab Standard specifies the Chemical Hygiene Plan to include “criteria the employer will use to determine and implement control measures to reduce employee exposure to hazardous chemicals including engineering controls, the use of personal protective equipment and hygiene practices; particular attention shall be given to the selection of control measures for chemicals that are known to be extremely hazardous.”
Cornell EHS has taken responsibility for maintaining an institutional Chemical Hygiene Plan. Each college, center, department, or laboratory may adopt or modify this plan or write their own chemical hygiene plan as long as the requirements of the OSHA Laboratory Standard are met. It is assumed if a college, center, department, or laboratory has not developed their own chemical hygiene plan, then that unit or laboratory has adopted the Cornell University Chemical Hygiene Plan. The Cornell University CHP is maintained by the Department of Environmental Health and Safety (EHS). The campus CHP is designed to supplement department and laboratory specific safety manuals and procedures that already address chemical safety in laboratories.
- OSHA Lab Standard
- OSHA Lab Standard Appendix A
- Environment, Health and Safety Policy 8.6
- University Policy 8.3 - Emergency Planning
- OSHA Hazcom Standard
- OSHA Lab Standard Appendix B
- OSHA Toxic and Hazardous Substance Standard
- Department Safety Representative (DSR) Program
1.1 Chemical Hygiene Plan Accessibility1.1 Chemical Hygiene Plan Accessibility
The OSHA Laboratory Standard requires the Chemical Hygiene Plan (CHP) to be readily available to employees, employee representatives and, upon request, to the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. This means laboratory employees working with hazardous chemicals in a laboratory must know the location of the CHP, be familiar with the contents, and be able to produce the CHP for any state or federal regulatory inspectors upon request. While EHS recommends a hard copy be kept in the laboratory, electronic access is acceptable and encouraged.
It is the responsibility of Principal Investigators and laboratory supervisors to ensure that personnel working in laboratories under their control are familiar with the contents and location of the Chemical Hygiene Plan, including any lab specific standard operating procedures and any department or college level laboratory safety manuals, policies, and procedures.
1.2 Laboratory Safety Responsibilities1.2 Laboratory Safety Responsibilities
The ultimate responsibility for health and safety within laboratories lies with each individual who works in the laboratory; however, it is the responsibility of the Principal Investigator, Faculty, and laboratory supervisor to ensure that employees (including visiting scientists, fellows, volunteers, temporary employees, and student employees) have received all appropriate training, and have been provided with all the necessary information to work safely in laboratories under their control. Principal investigators, Faculty, and Lab Supervisors have numerous resources at their disposal for helping to ensure a safe and healthy laboratory that is compliant with state and federal regulations. A listing of EHS staff, responsibilities, and services available to campus personnel can be found on the EHS Subject Matter Experts.
1.2.1 Environment, Health and Safety1.2.1 Environment, Health and Safety
Environment, Health and Safety (EHS) will provide technical information and program support to assist in compliance with the OSHA Laboratory Standard. This includes developing policies, recommendations and guidelines (as found in this Laboratory Safety Manual), developing and providing training programs designed to meet regulatory requirements, and serving as consultants in providing health and safety information to laboratory personnel. EHS will maintain the campus Chemical Hygiene Plan and the institutional Chemical Hygiene Officer responsibilities.
1.2.2 Chemical Hygiene Officer1.2.2 Chemical Hygiene Officer
The role of the Chemical Hygiene Officer (CHO) is to facilitate the implementation of the campus Chemical Hygiene Plan and this Laboratory Safety Manual in laboratories across campus and outlying facilities, and to serve as a technical resource to the campus laboratory community. The Associate CHO will act in the absence of the CHO. The names of the current CHO and the Associate CHO can be found in EHS Subject Matter Experts. The major duties of the Chemical Hygiene Officer are:
- Work with campus stakeholders to evaluate, implement, review annually, and make updates as needed to the Chemical Hygiene Plan and Laboratory Safety Manual.
- Provide technical expertise to the laboratory community in the area of laboratory safety and health, and serve as a point of contact to direct inquiries to other appropriate resources.
- Ensure that guidelines are in place and communicated for particularly hazardous substances regarding proper labeling, handling, use, and storage, selection of proper personal protective equipment, and facilitating the development of standard operating procedures for laboratories using these substances.
- Serve as a resource to review academic research protocols and standard operating procedures developed by Principal Investigators and department personnel for the use, disposal, spill cleanup, and decontamination of hazardous chemicals, and the proper selection and use of personal protective equipment.
- Coordinate the acquisition, testing and maintenance of fume hoods and emergency safety showers and eyewashes in all laboratories where hazardous chemicals are used.
- Conduct laboratory safety training sessions for laboratory personnel and upon request, assist laboratory supervisors in developing and conducting hands-on training sessions with employees.
- Review reports for laboratory incidents, accidents, chemical spills, and near misses and recommend follow up actions where appropriate.
- Stay informed of plans for renovations or new laboratory construction projects and serve as a resource in providing code citations and internal standards to assist with the design and construction process.
- Keep the senior administration informed on the progress of continued implementation of the Chemical Hygiene Plan and Laboratory Safety Manual and bring campus-wide issues affecting laboratory safety to their attention.
1.2.3 Deans, Directors, and Department Chairpersons1.2.3 Deans, Directors, and Department Chairpersons
The Deans, Directors, and Department Chairpersons are responsible for laboratory safety within their department(s) and must know and understand the Environment, Health and Safety Policy 8.6 and know and understand the guidelines and requirements of the Laboratory Safety Manual. In addition to the responsibilities outlined within the University Health & Safety Policy, the laboratory safety responsibilities of Deans, Directors, and Department Chairpersons - which can be delegated to other authorized personnel within the department such as a Department Safety Representative (DSR) - are:
- Be familiar with and implement the University Health & Safety Policy within units under their control or designate a person in the department (such as the DSR) with the authority to carry out these requirements.
- Communicate and implement the University Health and Safety Policy and its requirements to faculty, staff (including temporary employees), visiting scholars, volunteers, and students working in laboratories within their units.
- Assist the Chemical Hygiene Officer with implementation of the Chemical Hygiene Plan and Laboratory Safety Manual.
- Ensure laboratory personnel develop and adhere to proper health and safety protocols.
- Direct individuals under their supervision, including but not limited to - Principal Investigators, supervisors, regular and temporary employees, visiting professors, and students employees - to obtain any required safety and health training before working with hazardous chemicals, biohazardous agents, radiation, and/or other physical/mechanical hazards found within their working or learning environments.
- Determine and ensure that safety needs and equipment for units/departments are met (e.g., engineering controls, training, protective equipment) and ensure corrective measures for noncompliance items identified in safety audits are corrected promptly.
- Encourage the formation of a college and/or department safety committee(s).
- Keep the DSR, Building Coordinator, and Chemical Hygiene Officer informed of plans for renovations or new laboratory construction projects.
- Ensure college and departmental procedures are established and communicated to identify and respond to potential accidents and emergency situations.
- Notify EHS before a faculty member retires or leaves the University so proper laboratory decommissioning occurs. For more information, see the Lab Decommissioning Process and Checklist in Appendix E.
- Establish college and departmental priorities, objectives, and targets for laboratory safety and health performance. Obtain assistance and guidance from EHS when necessary.
- Ensure college and departmental laboratory participation in EHS Research Area Inspections as a means to regularly check performance against regulatory requirements and identify opportunities for improvement.
- Ensure that research areas within their departments and units are registered using HASP in a timely manner upon notification by EHS and updated annually.
1.2.4 Principal Investigators, Faculty, and Laboratory Supervisors1.2.4 Principal Investigators, Faculty, and Laboratory Supervisors
Principal Investigators, faculty, and laboratory supervisors are responsible for laboratory safety in their research or teaching laboratories. In addition to the responsibilities outlined within the Environment, Health and Safety Policy 8.6, the laboratory safety duties of Principal Investigators, faculty, and laboratory supervisors (which can also be delegated to other authorized personnel within the laboratory) are:
- Implement and communicate the Environment, Health and Safety Policy 8.6 and all other University safety practices and programs, including the guidelines and procedures found within the Laboratory Safety Manual, in laboratories under your supervision or control.
- Establish laboratory priorities, objectives and targets for laboratory safety, health and environmental performance.
- Communicate roles and responsibilities of individuals within the laboratory relative to environmental, health, and safety according to this Laboratory Safety Manual.
- Conduct hazard evaluations for procedures conducted in the laboratory and maintain a file of standard operating procedures documenting those hazards.
- Ensure that specific operating procedures for handling and disposing of hazardous substances used in their laboratories are written, communicated, and followed and ensure laboratory personnel have been trained in these operating procedures and use proper control measures.
- Attend required health and safety training.
- Require all staff members and students under their direction to obtain and maintain required health and safety training commensurate with their duties and/or department requirements.
- Participate in EHS Research Area Inspections with their laboratory employees or designate someone in the laboratory to conduct these inspections.
- Ensure that all items identified during annual EHS research area inspections are corrected in a timely manner.
- Ensure that all appropriate engineering controls including chemical fume hoods and safety equipment are available and in good working order in their laboratories. This includes notifying EHS when significant changes in chemical use may require a re-evaluation of the laboratory ventilation.
- Ensure procedures are established and communicated to identify the potential for, and the appropriate response to accidents and emergency situations.
- Ensure that all incidents and near misses occurring in their laboratories are reported to their Director or Department Chairperson and/or Department Safety Representative and that a written Injury/Illness Report is filed with EHS for each injured person.
- Ensure laboratory personnel under your supervision know and follow the guidelines and requirements contained within the Laboratory Safety Manual.
- Follow the guidelines identified within this manual as Principal Investigator and laboratory supervisor responsibilities. A compiled version of these responsibilities can be found in the Appendix C.
- Notify EHS before retiring or leaves the University and ensure proper laboratory decommissioning occurs. For more information, see the Lab Decommissioning Process and Checklist in Appendix E.
- Keep EHS, the Department Safety Representative, Department Chairperson informed of plans for renovations or new laboratory construction projects.
- Ensure that research areas under their supervision are registered using HASP in a timely manner upon notification by EHS and updated annually.
1.2.5 Laboratory Employees1.2.5 Laboratory Employees
Laboratory employees are those personnel who conduct their work in a laboratory and are at risk of possible exposure to hazardous chemicals on a regular or periodic basis. These personnel include laboratory technicians, instructors, researchers, visiting researchers, administrative assistants, graduate assistants, student aides, student employees, and part time and temporary employees.
In addition to the responsibilities outlined within the Environment, Health and Safety Policy 8.6, the laboratory safety duties of laboratory employees are:
- Comply with the Environment, Health and Safety Policy 8.6 and all other health and safety practices and programs by maintaining class, work, and laboratory areas safe and free from hazards.
- Know the location of the Chemical Hygiene Plan and how to access safety data sheets (SDS).
- Attend health and safety training as designated by your supervisor.
- Inform your supervisor or instructor of any safety hazards in the workplace, classroom, or laboratory, including reporting any unsafe working conditions, faulty fume hoods, or other emergency safety equipment to the laboratory supervisor.
- Ensure an SDS is present for all new chemicals you purchase (either sent with the original shipment or available online. Review the SDSs for chemicals you are working with and check with your laboratory supervisor or principal investigator if you ever have any questions.
- Conduct hazard evaluations with your supervisor for procedures conducted in the laboratory and maintain a file of standard operating procedures documenting those hazards.
- Be familiar with what to do in the event of an emergency situation.
- Participate in laboratory self inspections and annual EHS Research Area Inspections.
- Follow the standard operating procedures for your laboratory and incorporate the guidelines and requirements outlined in this Laboratory Safety Manual into everyday practice.
1.2.6 Building Coordinators1.2.6 Building Coordinators
Building Coordinators serve as an important conduit for information with regard to building wide issues. This information includes reporting and coordinating routine maintenance issues, scheduling building shutdowns, and communicating building wide maintenance and repairs and building system shutdowns to all occupants.
Laboratory safety responsibilities of Building Coordinators include:
- Comply with the Environment, Health and Safety policy 8.6 and all other University health and safety practices and programs by maintaining common building areas safe and free from hazards.
- Attend health and safety training as designated by your supervisor.
- Keep the DSR, Department Chairperson, and EHS informed of plans for renovations or new laboratory construction projects, and the laboratory needs of new faculty and staff.
- Notify EHS of faculty retiring or leaving the University so appropriate laboratory decommissioning occurs. For more information, see the Lab Decommissioning Process and Checklist in Appendix E.
- Ensure that ticket requests for safety equipment (such as fume hoods and emergency eyewash/showers) and other laboratory equipment are processed in a timely manner.
- Ensure that requests from EHS related to building-wide laboratory safety issues are addressed.
- Be aware of building issues that could impact the health and safety of laboratory personnel and contact EHS at 607-255-8200 whenever building-wide health and safety issues occurs in laboratories.
- Be familiar with what to do in the event of an emergency situation.
- Assist emergency responders during emergencies by serving as a resource for control of building control systems (ventilation, turning off water main, etc.).
1.2.7 Department Safety Representatives1.2.7 Department Safety Representatives
The Department Safety Representative (DSR) serves a very important function in implementing the Chemical Hygiene Plan and Laboratory Safety Manual within the department. The role of the DSR is to assist the director, unit head, and/or department chairperson meet their responsibilities for safety and compliance as described in the Environment, Health and Safety Policy 8.6. A detailed description of DSR roles and responsibilities can be found in the separate document – Department Safety Representative Program.
Laboratory safety responsibilities of DSRs include:
- Comply with the Environment, Health and Safety policy 8.6 and all other University health and safety practices and programs.
- Request and coordinate assistance from EHS and other organizations that can provide guidance, training, and other services to assist laboratory personnel.
- Assist directors, unit heads, department chairpersons, supervisors, and individuals within the areas they represent to establish departmental, unit, or facility-wide safety programs, priorities, objectives and targets for safety, health, and environmental performance.
- Assist directors, unit heads, department chairpersons, supervisors, and individuals to identify (with assistance and guidance from EHS) if the safety needs for the areas they represent are met (e.g., training, protective equipment, acquisition of safety equipment, and corrective measures including noncompliance items identified in safety inspections).
- Encourage the formation of, and participate on college, unit, departmental, and/or facility-wide safety committee(s).
- Collaborate with unit Emergency Coordinator(s) on emergency planning efforts, response, and implementation of University Policy 8.3 - Emergency Planning.
- Work with EHS to stay knowledgeable about safety, health, and environmental services available, the University health and safety policies and procedures that apply to, and the health and safety issues that occur within the areas they represent.
- Communicate to individuals working within the areas they represent about health and safety policies and procedures, including this Laboratory Safety Manual, and the safety, health, and environmental services available to them.
- Conduct and/or facilitate routine inspections of work areas in the areas they represent using tools and resources provided by EHS, including participation in EHS Research Area Inspections. Facilitate corrective actions for any issues identified with the support and participation of EHS, including bringing issues of noncompliance to the attention of directors, unit heads and department chairpersons.
- Promote safety, health, and environmental training program and workshops (particularly EHS trainings) throughout the areas they represent by distributing fliers and EHS newsletters, and forwarding EHS training announcements and other announcements via email or hardcopy. Inform individuals working in areas they represent about the requirements to obtain necessary training as identified by their supervisor, department, college and EHS.
- Serve as a “conduit for information exchange” through facilitation and dissemination of safety, health and environmental information (particularly information sent out by EHS) to all personnel, including visiting faculty and researchers, and student employees, within the areas they represent.
- Communicate with supervisors in the areas they represent that all incidents and near misses should be reported and that a written Injury/Illness Report is completed.
- Attend EHS training programs (and other safety, health, and environmental training programs and workshops) to increase and maintain knowledge about safety, health, and environmental issues that are applicable to the areas they represent.
- Attend University DSR meetings and other college or unit level safety, health, and environmental related meetings and serve as the liaison for the areas they represent at these meetings.
- Be aware that changes in chemical use in a particular laboratory may require a re-evaluation of the laboratory ventilation.
- Notify EHS before a faculty member retires or leaves the University or laboratory groups move so proper laboratory decommissioning can occur. For more information, see the Lab Decommissioning Process and Checklist in Appendix E.