No one plans to be exposed to hazardous chemicals. However, unforeseen emergencies, accidents, and spills can occur. To protect your employees from chemical hazards, you need to develop a written Chemical Hygiene Plan (CHP). Having a CHP in place before an emergency can make all the difference between a minor inconvenience and a life-threatening situation.
What is a CHP?
A CHP is a written program stating the policies, procedures, and responsibilities that protect workers from the health hazards associated with the chemicals used in a particular lab.
A CHP is required for all industries utilizing chemicals regulated by the Occupational Safety and Health Administration (OSHA). A CHP is required under many chemical hygiene laws (CHLs), and it applies to any lab with ten or more employees handling hazardous chemicals. Although developed by OSHA as a federal regulation, much of the content has been taken from general good practice guidelines developed by industry associations and professional organizations (e.g., American Conference of Governmental Industrial Hygienists).
ALL employees working with hazardous chemicals should receive training on the content of their employer's CHP before they begin work with these chemicals or equipment. This training must include training on each hazard covered by the plan and the procedures to follow if someone is exposed to hazards.
Why do you need a CHP?
A CHP is required whenever there is exposure to hazardous chemicals. This can include:
- Chemicals produced in the facility by manufacturing, processing, or otherwise;
- Chemicals purchased and brought into the facility;
- Chemicals transferred between containers within the facility; and
- Chemicals brought into a facility for use, storage, or disposal.
Exposure to hazardous chemicals can cause acute, sub-acute, or chronic health effects. Acute health effects occur suddenly and usually disappear soon after exposure. Sub-acute health effects can develop over days, weeks, or months of exposure and result in long-term damage or disease. Chronic health effects may occur after long-term (chronic) exposures, where damage to body organs or systems develops over several years.
Specific purposes of a CHP include:
- Preventing injury, illness, impairment, or death caused by chemical exposures in the workplace;
- Protecting workers from hazardous conditions resulting from emergencies caused by chemical exposures;
- Providing a means for employees to become knowledgeable about potential hazards associated with their work activities; and
- Ensuring compliance with all applicable state, federal and local regulations regarding employee protection against occupational hazards associated with chemical exposures.
How do you develop a CHP?
To develop an effective CHP for your lab, one should include the following:
- An assessment of each chemical used in the workplace. This should include its identity, physical and chemical characteristics, and health hazards.
- A description of each operation in which hazardous chemicals are present. This should include work practices and the equipment used to minimize exposure to hazardous chemicals.
- A list of all control measures implemented in the workplace to protect against exposure to hazardous chemicals, including engineering controls, administrative controls, personal protective equipment, and housekeeping practices.
- A program for worker training and education regarding the purpose, use, and potential hazards of each hazardous chemical used in their work area.
- The methods that will be used to ensure compliance with applicable regulations, standards, and company policies and procedures regarding the use of hazardous chemicals in this workplace, including the designation of a safety representative responsible for ensuring workers' compliance with all applicable requirements.
Tasks covered by the CHP include:
- Chemical inventory – A list of all chemicals in use at the workplace and their chemical name, concentration, container size, the maximum amount used each day, date received, and storage location.
- Storage – Rules for storing chemicals, including special storage requirements such as locked storage or special temperature controls.
- Emergency procedures – Written procedures to follow in case of spills, leaks, or other emergencies involving hazardous substances.
- Personal protective equipment (PPE) – Information on PPE, including where it is located, how often it must be replaced, who is required to wear it, and how it should be properly worn.
- Housekeeping – Rules for keeping the workplace clean and safe for employees to avoid tracking chemicals into the building or spreading them around during routine tasks like sweeping and mopping.
A CHP should be developed by a trained and knowledgeable person (such as the employer, a supervisor, or a competent person) who understands the nature of the hazardous chemicals handled at the site.
The plan should be reviewed and updated at least annually and whenever there is a change in production processes or the chemical inventory during the year. A copy of the current CHP must be provided to each employee using or handling hazardous chemicals and posted in a central location that is accessible to all employees.
Many types of chemical exposures can result in adverse health effects. Controls must be in place to ensure that workers are protected from these effects. The CHP serves as a working document for employers and workers when problems arise regarding the safe use and handling of hazardous chemicals.
The best approach is to make your CHP as comprehensive as possible. Ensure that your CHP includes all of the chemicals used in your workplace and includes procedures for handling them, including regular inspections and audits to ensure that everyone knows the safety measures to take. Be proactive about lab safety by issuing briefings and training sessions so that workers can address issues before they escalate into major problems.
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