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9.5 Prior Approval

The OSHA Laboratory Standard requires Chemical Hygiene Plans to include information on “the circumstances under which a particular laboratory operation, procedure or activity shall require prior approval”, including “provisions for additional employee protection for work with particularly hazardous substances” such as "select carcinogens," reproductive toxins, and substances which have a high degree of acute toxicity.

Prior approval ensures that laboratory workers have received the proper training on the hazards of particularly hazardous substances or with new equipment, and that safety considerations have been taken into account BEFORE a new experiment begins.

While EHS can provide assistance in identifying circumstances when there should be prior approval before implementation of a particular laboratory operation, the ultimate responsibility of establishing prior approval procedures lies with the Principal Investigator or laboratory supervisor.

Principal Investigators or laboratory supervisors must identify operations or experiments that involve particularly hazardous substances (such as "select carcinogens," reproductive toxins, and substances which have a high degree of acute toxicity) and highly hazardous operations or equipment that require prior approval. They must establish the guidelines, procedures, and approval process that would be required. This information should be documented in the laboratory's or department's SOPs. Additionally, Principal Investigators and laboratory supervisors are strongly encouraged to have written documentation, such as “Prior Approval” forms that are completed and signed by the laboratory worker, and signed off by the Principal Investigator or laboratory supervisor and kept on file.

Examples where Principal Investigators or laboratory supervisors should consider requiring their laboratory workers to obtain prior approval include:

  • Experiments that require the use of particularly hazardous substances such as "select carcinogens," reproductive toxins, and substances that have a high degree of acute toxicity, highly toxic gases, cryogenic materials and other highly hazardous chemicals or experiments involving radioactive materials, high powered lasers, etc. 
  • Where a significant change is planned for the amount of chemicals to be used for a routine experiment such as an increase of 10% or greater in the quantity of chemicals normally used. 
  • When a new piece of equipment is brought into the lab that requires special training in addition to the normal training provided to laboratory workers. 
  • When a laboratory worker is planning on working alone on an experiment that involves highly hazardous chemicals or operations.