3
Guidelines for Establishing a Chemical Laboratory Safety and Security Program

Establishing a culture of safety requires sustained commitment to high standards at all levels—from top institutional leaders to laboratory personnel. As developing countries establish safety and security programs, it is important for them to consider the entire life cycle of chemicals—from planning, procurement, and security to ultimate use and final disposal. This chapter recommends a framework for systematically integrating safety and security into a research institution to anticipate and prevent circumstances that might result in injury, illness, or adverse environmental effects. The way the individual elements of the framework are applied will depend on the size of the institution, the nature of its activities, and the hazards and conditions specific to its operations. Chapter 4 provides further guidance in enhancing compliance with safety and security policies, programs, and rules.

WHOSE JOB IS IT? RESPONSIBILITY FOR CHEMICAL LABORATORY SAFETY AND SECURITY

Individuals in an institution have various roles and responsibilities for establishing and maintaining safe and secure practices. Setting a good example is the best way for people at all levels to demonstrate their commitment.



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3 Guidelines for Establishing a Chemical Laboratory Safety and Security Program Establishing a culture of safety requires sustained commitment to high stan- dards at all levels—from top institutional leaders to laboratory personnel. As developing countries establish safety and security programs, it is impor- tant for them to consider the entire life cycle of chemicals—from planning, procurement, and security to ultimate use and final disposal. This chapter recommends a framework for systematically integrating safety and security into a research institution to anticipate and prevent circumstances that might result in injury, illness, or adverse environmental effects. The way the individual elements of the framework are applied will depend on the size of the institution, the nature of its activities, and the hazards and conditions specific to its operations. Chapter 4 provides further guidance in enhancing compliance with safety and security policies, programs, and rules. WHOSE JOB IS IT? RESPONSIBILITY FOR CHEMICAL LABORATORY SAFETY AND SECuRITY Individuals in an institution have various roles and responsibilities for establishing and maintaining safe and secure practices. Setting a good example is the best way for people at all levels to demonstrate their commitment. 

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY Leaders Responsibility for safety and security rests ultimately with the head of the institution and its operating units. In some cases, there may be legal obligations and large personal fines or prison sentences if they do not pro- vide a secure and safe working environment. Leadership by those in charge ensures that an effective safety and security program is embraced by all; even a well-conceived program will be treated casually by workers if it is neglected by top management. Safety Officers To establish and support a unified effort for safety management and to provide guidance to people at all levels, each institution should have at least one designated safety officer. The safety officer should be equipped with the knowledge, responsibility, and authority to develop and enforce an effective safety and security management system. Environmental Health and Safety Office Some larger institutions also have an environmental health and safety office staffed by experts in chemical safety, engineering, occupational medi- cine, fire safety, toxicology, and other fields. Such an office assists in es- tablishing policies and promoting laboratory safety standards, and often handles hazardous waste issues, accident reviews, inspections and audits, compliance monitoring, training, recordkeeping, and emergency response. Chemical Laboratory Managers and Instructors Direct responsibility for the management of a chemical laboratory safety program typically rests with the chemical safety officer (CSO) and a laboratory manager. In coursework, laboratory instructors carry direct responsibility for actions taken by students. Instructors are responsible for promoting a culture of safety and for teaching the skills that students and other workers need if they are to handle chemicals safely. Students and Workers Although they are influenced by and depend on attitudes of and guid- ance by those in leadership or management positions, students and other laboratory workers who actually do the work are responsible for working safely.

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3 GUIDELINES 10 STEPS TO ESTABLISH AN EFFECTIvE CHEMICAL LABORATORY SAFETY AND SECuRITY PROgRAM The most critical aspect of establishing a strong safety and security pro- gram is the commitment and support it should have from the top leaders in the institution. If the leaders facilitate the establishment of this program and hold their managers responsible and accountable, a culture of compliance can be achieved. 1. Establish an institutional safety and security oversight committee and designate a chemical safety officer. The top institutional leader (such as the president or chancellor of a university or the director of a research center or agency) should establish a committee to provide oversight for chemical safety and security. The committee should report directly to the top leaders and receive the necessary financial and administrative support. The institution should also define CSO responsibilities and authority and appoint at least one CSO. Each CSO should be part of the Safety and Se- curity Oversight Committee. For a CSO to be effective, he or she will need to be given dedicated time, resources, and the necessary authority to carry out his or her respon- sibilities. CSOs should have direct access, when necessary, to the senior authorities who are ultimately accountable to the public. 2. Develop a chemical safety and security policy. Institutional leaders should implement a formal policy to define, document, and endorse the program, and the policy should integrate safety and security into the entire life cycle of all laboratory chemicals. A formal policy statement establishes expectations and communicates the institution’s intent. The policy should state how the institution will • prevent or mitigate human and economic losses arising from ac- cidents, adverse occupational exposures, and environmental events; • build safety and security considerations into all phases of operations; • achieve and maintain compliance with laws and regulations; and • improve performance continually. The policy statement should be communicated and made readily ac- cessible to all employees and should be reviewed and revised by top man- agement as often as necessary. An example of a policy statement can be found in Appendix E. In developing a chemical safety and security policy, laboratory management should establish a credible and strong compliance program, complete with accountability and consequences for noncompli-

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY ance (see Chapter 4). Management should also communicate a commitment to safety and security to all laboratory personnel regularly. 3. Implement administrative controls and processes for performance measurement. Administrative controls are an institution’s specific rules and procedures for safe and secure practices, and they establish the responsibili- ties of the personnel involved. CSOs should develop general safety rules, laboratory housekeeping pro- cedures, manuals for use of materials and equipment, and other documents to communicate rules and expectations to all laboratory personnel. Those documents should clearly define the individual responsibilities of students and other laboratory workers, laboratory managers, institutional leaders, contractors, emergency service providers, and visitors to the laboratory. The business of conducting experiments changes continually: attri- tion in staff members and students, change in regulations, and evolution of technologies. As a result, evaluating the safety and security aspects of chemistry laboratory operations should be part of everyday activities, in ad- dition to and separate from regular formal performance measurements and reviews. For example, beginning all department and group meetings with a safety moment is one way to highlight the importance of safety. Adminis- trative controls should provide mechanisms for managing and responding to change, such as new procedures, technologies, legal requirements, staff, and institutional changes. In addition to performance measurements by those working in the laboratory, periodic audits by knowledgeable people independent of the location or activity should be arranged to enable a deeper and more critical appraisal. Top management should review the management system and its formal policy regularly. 4. Identify and address particularly hazardous situations. Manag- ers, principal investigators, lead researchers, team leaders, and supervisors should take active roles in managing the safety and security of their labora- tories. An initial status review to assess the scope, adequacy, and implemen- tation of safety procedures will provide a foundation on which to build a robust safety and security program and will help in setting priorities among efforts to improve safety and security. A risk-based evaluation should be performed to determine the adequacy of existing control measures, to set priorities among needs, and to incorporate corrective actions according to importance and available resources. To begin the process of ensuring effective management of chemicals, laboratory management should establish a list of all the chemicals in the laboratory, especially the chemicals of concern (COCs). COCs are highly hazardous chemicals or chemicals that are potential precursors of highly

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 GUIDELINES hazardous materials. Typically, the list would include chemicals listed by the Chemical Weapons Convention, chemicals that have potential for mass destruction, explosives and precursors of improvised explosive devices, and chemicals of high acute toxicity (rated as Category 1 in the Globally Har- monized System of Classification and Labeling of Chemicals). Examples of COCs are provided in Appendix D. 5. Evaluate facilities and address weaknesses. The role of physical ac- cess control in improving security of chemicals, equipment, and occupants of buildings in which chemicals are stored and used should be addressed specifically. This will require development of a comprehensive security vul- nerability assessment and policy setting (see “Guidelines for Facility Access and Use” later in this chapter). 6. Establish procedures for chemical handling and management. Chemical management is a critical component of a laboratory program. Safety and security should be integrated into the entire life cycle of a chemi- cal, including procurement, storage and inventory, use and handling, and transport and disposal. The overall process is described in more detail later in this chapter (see “Procedures for Managing and Working with Chemicals of Concern”). It should include procedures for screening of COCs as part of the normal procurement process. An inventory process to track use of a chemical until it is completely consumed or finally disposed of should be established. For example, when chemicals are received, their identities and quantities are entered into the inventory system. The inventory and record- keeping system can be important in order to • ensure the security of chemicals through accountability of chemical usage; • provide a resource to consult for possible sharing of chemicals; • provide information that allows managers to know when to reor- der chemicals; • provide the location of hazards in the laboratories for emergency responders; • determine future needs and uses of chemicals; and • minimize excess inventory and chemical waste. An important part of any process is accountability for chemical use and adherence to procedures. Managers should consider ways to recognize and reward those who follow best practices while handling and working with chemicals. Alternatively, managers may need to consider tools for enforce- ment of the practices when investigators bypass the system.

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY 7. use personal protective equipment and engineering controls. En- gineering measures, such as a laboratory hood, local exhaust ventilation, and a glove box are the primary methods for controlling hazards in the chemical laboratory. Personal protective equipment (PPE) such as safety glasses, goggles, and face shields are used to supplement engineering con- trols. Laboratory management should not allow an experiment to proceed if inadequate hazard control measures (engineering or PPE) are unavailable. More detailed guidance on procedures for chemical handling and manage- ment are provided in the section “Special Concerns” later in this chapter. 8. Plan for emergencies. Laboratories, like all other workplaces, ex- perience unplanned incidents and emergencies. Laboratories should make plans to handle emergencies and implement the plans by purchasing and maintaining emergency equipment and supplies, such as fire extinguishers, eye washes, safety showers, and spill kits. The use of a COC may warrant development of special plans, such as antidotes for unintentional exposures (for example, atropine for organophosphorous agents). Some COCs may be pyrophoric (ignite spontaneously) and require special fire-extinguishing methods. Emergency response preparedness should involve local emergency response organizations, such as fire departments, to ensure that they have the equipment to assist in the event of an emergency. Prudent Practices in the Laboratory1 or other safety manual should be referred to for more information. 9. Identify and address barriers to safety compliance. Compliance with good safety and security practices involves having people act in accor- dance with established institutional policies and procedures. Each country faces challenges in implementing effective safety and security practices and complying with them. Local culture often presents barriers to compliance, and efforts are needed to address and overcome the barriers, as discussed in detail in Chapter 4. 10. Train, communicate, mentor. A comprehensive process that man- ages the entire life cycle of a chemical in the laboratory would result in responsible management of the safety and security aspects of that chemical. The CSO is responsible for ensuring that proper processes are established and communicated to all, but it takes a strong commitment by top lead- ers in the institution to create the best safety and security systems and to establish a culture that ensures the well-being of personnel and the public. 1 National Research Council. Prudent Practices in the Laboratory: Handling and Manage- ment of Chemical Hazards, Reised Edition. Washington, D.C.: The National Academies Press, in press.

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 GUIDELINES Accordingly, top leaders are ultimately accountable for chemical safety and security. See the section on “Guidance on Assigning Responsibility and Ac- countability” for more information. SPECIAL CONCERNS Security of Chemicals Chemists and other scientists collectively use thousands of chemicals in their laboratory work, but COCs pose a particular risk to the general public if they are acquired by people who wish to inflict harm. Some COCs can be used as precursors to make potentially deadly chemical agents or illicit drugs. Other chemicals have hazardous properties that can pose risks to laboratory personnel, especially if they are unaware of the properties. The United Nations has developed a system, the Globally Harmonized System for Classification and Labeling of Chemicals, for classifying chemicals ac- cording to their hazardous properties. In that system the most hazardous chemicals make up Hazard Class 1; these COCs should be kept secure from theft or diversion, and there are laboratory security measures that can help to prevent such diversions. Security begins with the individual, and prudent security practices for laboratories should include a system that limits access to authorized personnel who have a need to work in the laboratory. Authorized person- nel should be approved to work in a particular area and have access and authority to use COCs by someone in the institution. Authorized personnel should be given access through keys or card keys and may have identifi- cation badges. The issuance of keys or card keys should be subject to an established process in which laboratory personnel sign for keys and turn them in when they leave the program. Keys should be of a type that is not readily duplicated. In the academic community, security measures can pose a challenge. Teaching laboratories generally have few types and small amounts of chemi- cals, and the chemicals are not likely to be COCs; however, many teaching laboratories might have a wide range of solvents, some of which are COCs. In general, more hazardous chemicals are used in advanced laboratories, especially research laboratories, and there should be greater attention to limiting access to those laboratories. Separating advanced research labora- tories from other laboratories will make security much easier. In commer- cial and government institutions in some countries, it is common to conduct background checks of personnel who will work in research laboratories and have access to COCs. It is not as common in academic institutions, particularly for students. It takes vigilance on the part of those who work

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY in the laboratories to look for suspicious activity or unexplained missing COCs or to detect security breaches. Physical security is an important part of any security program. When given proper instructions and training, security guards can play a key role in preventing access to areas where COCs are used or stored. Door locks, of either the normal key type or the more expensive electronic type, are necessary where COCs are being used or stored. Other physical security measures include locked cabinets, locked storage areas, locked drawers, and perhaps alarm systems. Any extraordinary laboratory security measures should be commensurate with the potential risks and should be imposed in a manner that does not hamper research or safety unreasonably. The effectiveness of a security program is closely related to the expecta- tions established by management. All laboratory personnel should be en- couraged to question the presence of unfamiliar people in laboratories and to report suspicious activity immediately. Locking laboratory doors when laboratories are unoccupied should become routine. COCs that are not be- ing used should be secured. Laboratory managers should establish a policy that prohibits all unauthorized use of laboratory materials and facilities, and that violations will be subject to a penalty. A training program in laboratory security should set out the expecta- tions of management and the need to maintain a safe and secure laboratory environment. Training should be conducted periodically and especially for new personnel. Laboratories should be inspected routinely for compliance with security measures. Personnel working in laboratories should follow all established security procedures, and there should be a protocol for report- ing security breaches or security concerns. guIDELINES FOR FACILITY ACCESS AND uSE Conducting a security vulnerability assessment (SVA) and develop- ing and writing a site security plan as described below are meant to be in conjunction with establishing an effective safety and security program (see Step 5 above).2 2 Many of the ideas for this section are based on the National Institute of Justice document A Method to Assess the Vulnerability of U.S. Chemical Facilities (November 2002). Other documents that were useful are the state of South Carolina’s Best Practices: Workplace Se- curity (February 2003), the Occupational Safety and Health Agency’s Compliance Policy for Emergency Action Plans and Fire Preention Plans (July 2002), the National Institute for Occupational Safety and Health’s Guidance for Protecting Building Enironments from Air- borne Chemical, Biological, or Radiological Attacks (May 2002), and the U.S. Department of Justice’s Using Crime Preention Through Enironmental Design in Problem-Soling, by Di- ane Zahm (August 2007). Organizations identified in Chapter 2 may offer further resources.

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 GUIDELINES Developing a Comprehensive Security vulnerability Assessment An SVA may include an entire campus or specific facilities on a campus and it involves a series of comprehensive investigations and an integrated analysis. The purpose of an SVA is to catalog potential security risks to a laboratory, determine the magnitude of the risks, and assess the adequacy of systems that are in place. An SVA helps in determining the security plan- ning needs of a facility. An SVA should include an asset evaluation, threat assessment, site survey and analysis, and physical vulnerability survey. Asset Evaluation This investigation identifies and quantifies valuable assets—such as equip- ment, instruments, libraries, and documents—that should be protected from accidental loss or damage and from theft or destruction by persons who intend to do harm or by natural disasters. Information should be included about sources of replacement and alternative resources on campus or elsewhere that could permit continuity of operations. Threat Assessment This identifies possible types of threats to the institution and specific facilities from the generic to site-specific threats, from natural disasters to terrorist attacks. To the extent possible, a threat assessment should describe the adversarial groups or individuals, their ideological and economic mo- tivations, members and supporters, leadership and organizational charac- teristics, record of illegal or disruptive activities, preferred mode of action, and potential capabilities to attack a target, what they typically want to communicate to the public, and how they prefer to do it. Institutions must to be careful to adhere to laws that protect personal privacy within their country. Possibilities of attack or action against the institution and its facili- ties should be detailed. The consequences of natural disasters—including wind, water, fire, earthquake, and multifocal events such as those that occur during cyclones, hurricanes, tornados, earthquakes, tsunamis, and volcanic eruptions—should be estimated. Scenarios (best case and worst case) should be generated to derive a measure of the potential severity of an event, natu- ral or malicious. Chapter 4 of Prudent Practices in the Laboratory and the American Chemical Society’s SVA provide more complete explanations of this process.

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0 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY Site Survey and Analysis This part of an SVA is specific to the physical facilities covered by the security and facility access policy. Up-to-date drawings of campus features, vehicular traffic, pedestrian circulation, site and terrain, and buildings are critical resources for this investigation. Walk-throughs of specific buildings that use or store chemicals, and a tour of the entire site or campus, should be conducted. These inspections should be documented with photographs or videos of specific conditions. Building enclosure integrity with regard to weather and physical intru- sion are important to investigate in all areas, on all sides, and on roof and subsurface extensions, including tunnels and utility routes and entry points into buildings. Locations of air intakes for mechanical and natural ventila- tion and locations and conditions of storage elements for chemicals and other hazardous materials are important to analyze. The site survey and analysis should include a vehicular traffic plan that highlights areas for material deliveries, truck routes, parking, and building entries and exits. The site analysis should address traffic patterns of vehicles and pedestrians over 24-hour periods on normal workdays and weekends, physical protection and security features, building uses, and which persons are allowed access. Such a comprehensive review is necessary to permit an accurate survey of physical vulnerability and to put into place operational procedures for detection, delay, and assessment systems to protect physical assets and to protect operations on the campus or in a facility that could be interrupted or sabotaged. Physical vulnerability Survey A vulnerability survey includes several kinds of investigation, within the limits of local legal frameworks. 1. Identifying potential targets and gaining access to those targets. 2. Identifying and rating potential threat(s) based on historical con- text; for example, threats that have previously been acted upon have more significance than potential threats without historical motive or intent. This pertains to both natural factors, such as the likelihood of flood, and mali- cious action. 3. Identifying personnel, contract employees, vendors, contractors, and visitors who may have personal problems or conflicts with the institu- tion and who may also be able to identify internal physical facility vulner- abilities and obtain access to facilities.

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 GUIDELINES Various data should be considered in a vulnerability survey. • Which potential targets are clearly recognizable with little or no knowledge. • Which potential facility targets store chemicals. • The quantities, concentrations, and hazards of the chemicals that could be involved in each potential target. • The potential for offsite release or illegal use of the chemicals. • Physical protection measures that are in place to mitigate the harm that could result from a chemical release or spill. A matrix or other analytical tool should be devised to estimate the severity of effects of each undesired event identified in the scenarios devel- oped in the threat analysis. The severity level will contribute to the overall risk analysis. Worst-case scenarios should be used for events (natural or malicious) for estimating • how many people would be affected; • what the monetary loss of property would be; • how much money and time would be needed to acquire replace- ment facilities; • what the loss of productivity and the period of shut-down and recovery would be; and • what value in public trust, support, and image would be lost. Develop a Site Security Plan A comprehensive site security plan integrates all the information gained in the analyses, surveys, and investigations mentioned above. It addresses workplace security guidelines and an emergency response plan that provides a physical protection strategy to detect, delay, and respond quickly and effectively to interrupt, neutralize, or mitigate malicious-intent threats and natural disasters. Methods in the public domain (such as Responsible Care, CEFIC, IUPAC, and ISO) outline many approaches to developing a plan that meets the goals of the security and access control policy. Tactics and a wide variety of technologies are well documented to provide in-depth pro- tection and to minimize consequences of failure of security components. Institutions may consider applying concepts of crime prevention through environmental design. Building location and properly placed en- tryways, windows, lighting, shrubbery, and other physical features can help deter criminal activity, and are cost-effective, systemic improvements that do not depend solely on technology. The security and access control policy should be the basis of the site security plan.

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY PROCEDuRES FOR MANAgINg AND WORKINg WITH CHEMICALS OF CONCERN Procuring Laboratory Chemicals Laboratory management should establish a system for authorizing pro- curement of a COC that considers all the acceptable ways that COCs may be obtained in laboratories—such as purchase order, credit card order, online purchase, donation, sharing, exchanging. The system should require that the CSO be notified of orders of COCs and, if necessary (for example, when there is an unusual supplier or material that has not been purchased previously), the CSO’s approval should be obtained. The CSO should be notified when the chemical is received, and the CSO or a designated alternate should check the order and enter the amount in an accountability log. The CSO or desig- nated alternate should maintain an inventory accountability log for COCs, from procurement to disposal. The log should be kept in a secure location where everyone can read it but only the CSO or a designated alternate can edit it. If a centralized log for the department is not adequate, each laboratory or group should keep its own log. The log could be an automated system, spreadsheet, or a manual list of all COCs in the laboratory. The important aspects are that it be diligently maintained and that compliance be enforced; otherwise the effort will be wasted. The log should identify each chemical to avoid ambiguity (for example, by using the Chemical Abstract Service registry number) and should indicate use and current inventory. The CSO or designated alternate should review the logs regularly, for example, monthly. An example of an inventory accountability log is provided in Appendix F. Storing Laboratory Chemicals Chemicals should be stored safely and securely on the basis of risks and hazards, as outlined in Prudent Practices in the Laboratory. Access to the storage area should be limited to persons approved by the laboratory man- ager or supervisor and the CSO. The list of authorized persons should be posted at the storage facility and communicated to all laboratory personnel. It is important to maintain an appropriate level of security (for example, door locks, lock boxes) for all chemicals, especially COCs (as discussed earlier). Laboratory managers should remind users that COCs should be secured when not in use. There should be a requirement that unwanted or unneeded chemicals are returned to the storage area at the end of a proj- ect or process. Experience indicates that the CSO needs to reinforce this requirement regularly.

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3 GUIDELINES BOX 3-1 Five Questions for Laboratory Safety and Security 1. What are the hazards? For example, health hazards, flammability, reactivity, and physical hazards. 2. What is the worst thing that could happen? For example, personal exposure, spills, fire, uncontrolled reaction, and electric shock. 3. What can be done to prevent this from happening? For example, substitution, guarding, change in environmental conditions, and modifica- tion of a procedure. 4. What can be done to protect from these hazards? For example, ventilation, gloves, eye and face protection, and protective clothing. 5. What should be done if something goes wrong? For example, spill control, fire extinguisher, safety shower, and eyewash. Safely using Laboratory Chemicals There are established ways to manage the safe use of COCs and other hazardous chemicals. The critical elements of safe work with COCs de- scribed below are known to most health and safety professionals. Box 3-1 provides a useful checklist for use of any hazardous chemical. It can be posted in the laboratory or given to laboratory workers. The first step in ensuring safety is to conduct hazard evaluations to understand the nature and severity of the risks being posed by the chemicals being used. Once the risks are determined, the best available measures to control and man- age them should be selected. Those measures include developing a specific safety plan or safe operating procedures (SOPs) for the particular intended use of the chemicals. It is critical to ensure that all who will handle chemi- cals are knowledgeable about the hazards and safe handling procedures, especially COCs. It is equally important to ensure that users follow estab- lished safety procedures during their work. Hence, communication of the safety procedures to all users is essential, and a suitable process for that should be developed. Users of extremely hazardous chemicals may require additional training. Unexpected incidents or events during handling of COCs or other hazardous materials are almost inevitable, so a system that requires and encourages the reporting of all incidents, concerns, or problems (even if minor) should be established. Such a system allows reviews and continuous improvement of the processes and systems that are in place.

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY Hazard Evaluation The risks posed by use of a chemical can depend on the quantity used. The larger the quantity of a COC being used, the more serious the hazard; reducing the quantity being used (or stored) reduces the hazard. The CSO or designated alternate should evaluate the hazards posed by the chemicals in the quantities procured and used. The hazard evalua- tion should consider the routes of potential exposure: eye contact, skin contact, inhalation, injection, and ingestion (can be substantially reduced by prohibiting eating and drinking in the laboratory). It should take into account physical hazards and health hazards. Physical hazards can include flammable or explosive chemicals, high-vacuum or high-pressure systems, hot equipment or devices, cryogenic materials, radioactive materials, and corrosive acids or bases. Combinations of chemicals that result in extreme exothermic (heat-releasing) reactions can result in explosions if not prop- erly controlled. Health hazards include acutely toxic chemicals, sensitizers (allergens), chemicals that cause chronic toxicity (such as carcinogens), and reproductive toxicants. Particular handling practices and procedures should be developed for laboratory hazards (see the hazard assessment checklist in Appendix F). Hazard Control and Management In all laboratory experiments and procedures, it is important that hazards be controlled or managed primarily by engineering measures, such as a laboratory hood, local exhaust ventilation, or a glove box. Ventilated enclosures can often be used for weighing chemicals. Best practices also include having a laboratory under negative pressure with respect to the adjacent hallway so that hazardous chemical vapors are kept in the labora- tory. In same cases, such as with the use of radioactive materials, personal hand, foot, or full-body monitors may be needed to control the spread of material into areas outside controlled laboratory facilities. Another method of controlling and managing hazardous chemical op- erations could be the use of smaller-scale experiments or procedures that use micro-scale or mini-scale laboratory equipment. That reduces the quan- tities of chemicals and thus reduces risk. Although the primary methods of control are engineering methods, personal protective equipment (PPE) should supplement them. Eye and face protection (safety glasses, goggles, and face shields) are essential in any laboratory in which chemicals are handled. Protective gloves are important if chemicals can come into contact with skin. Gloves should be selected for the particular chemicals being used, recognizing that no single kind of glove protects against all hazards. Laboratory coats and aprons provide addi-

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 GUIDELINES tional protection for the body from chemical exposure. Protective footwear may be needed in some laboratories. Respirators are a last resort for controlling a hazard and preventing exposure. They should not be used unless all other methods of control are inadequate. Respirators should be properly selected, should be correctly fitted to a person’s face, and a person using a respirator should be aware of its uses and limitations. It is essential that all respirator users receive train- ing in respiratory protection and that respirator users must work in teams of at least two workers.3 If the hazard control measures (engineering or PPE) are not adequate to prevent exposure and provide an acceptable level of safety, laboratory management should not permit the experiment or procedure in question, and should explore whether a safe substitute for COCs can be identified. Safety Plans for Chemical use Safety plans or SOPs should be developed to document the hazards posed by and controls for COCs. SOPs can have a variety of formats, in- cluding postings, documentation in laboratory notebooks, forms, binders, and digital collections of plans. The objective is to document hazards and control and disposal methods in a manner that ensures that those who have access to the materials will understand how to use them safely. An example of a form for a safety plan is provided in Appendix F. Incident Reporting A process for reporting and investigating incidents should be estab- lished. It should emphasize free exchange of information without penalty to the people who report an incident. The objective is to (1) maintain a culture in which people feel comfortable sharing information about prob- lems they have encountered and about their concerns and (2) promote the understanding that laboratory workers’ personal safety is paramount. Disposing of Laboratory Chemicals The end of the life cycle of a chemical is its consumption in a labora- tory procedure or its disposal. The CSO or designated alternate should develop a program to ensure safe and environmentally responsible disposal of chemicals, especially COCs. 3 For more information, see the OSHA Respiratory Protection Standard: http://www.osha. go/pls/oshaweb/owadisp.show_document?p_id=&p_table=standards (accessed January 26, 2010).

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY Before procuring chemicals, experimenters should ensure that disposal facilities that will manage them are available or that there is a laboratory SOP for rendering them safe for drain or solid-waste disposal. Procedures for handling waste from the time it is produced to its ultimate treatment or disposal need to be developed. Laboratory managers should ensure that laboratory workers know how to collect waste safely and the type of con- tainers to use. Laboratory workers should be given guidance on how, how much, and where to store waste in the laboratory as it is collected, including methods to prevent spills and accidental releases. Keeping containers sealed when they are not in use and using secondary containment, such as trays or bins, in the event of a spill, are best practices. Procedures for removing chemical waste from the laboratory for stor- age in a facility or area dedicated for that purpose or for removal by a qualified chemical waste vender need to be formulated. A process whereby laboratory managers notify the CSO or waste manager that they have chemical waste for removal should be established. Depending on the location of the facility, there may be regulations or guidance on recordkeeping for chemical waste. Records of disposal—in- cluding disposal date, quantity disposed of, and disposal method—should be maintained. The records should be kept indefinitely or as long as speci- fied in regulations. guidance on Assigning Responsibility and Accountability The following are examples of how responsibility and accountability for chemicals may be assigned. The needs and management style of an in- stitution should be considered in determining its appropriate management structure. Responsibilities of Chemical Safety and Security Oversight Committees The Chemical Safety and Security Oversight Committee, appointed by the top leader of the institution, is responsible for the following broad elements: • developing and maintaining safety and security policy initiatives; • adequately budgeting and allocating resources for the chemical safety and security program; • making inquiries as appropriate regarding incidents, accidents, and breaches of safety and security; • making recommendations to top leaders regarding recognition of best practices and disciplinary actions as appropriate; and • providing necessary support to the chemical safety officers (CSOs).

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 GUIDELINES Responsibilities of Chemical Safety Officers CSOs are responsible for the following broad elements: • developing and implementing an integrated safety and security program for the life cycle of the chemicals of concern (COCs) on the basis of the guidelines established in the present report and discussed in more detail in Prudent Practices in the Laboratory; • establishing a training program that ensures that laboratory man- agers, supervisors, and workers receive training appropriate for their duties and for the materials they will use regularly, reviewing and approving the content of the training, and maintaining training records and periodically auditing them to ensure that all who should be trained are being trained; • developing a laboratory inspection program that reviews laboratory facilities, SOPs, and worker preparedness; keeping records of the inspec- tions and sharing the results with laboratory managers and senior manage- ment; and tracking resolution of issues identified during inspections; • periodically auditing all aspects of the safety and security program and reporting findings to senior management, including recommendations for improvements; and • developing a program for managing incidents, including spills, injuries, and near misses. More specifically, CSOs or designated alternates are responsible for • executing the established policies regarding laboratory COCs and ensuring compliance with applicable regulations as required; • assisting in procurement, storage, use, and waste disposal at the laboratory level, including providing training for how to develop appropri- ate SOPs; • operating, if required, a waste management program for wastes to be disposed of outside the laboratory, including receipt of wastes, transpor- tation, and final disposal of material by commercial venders; • logging orders of COCs; • receiving and inventorying on purchase receipts; • disposing of laboratory COCs; • auditing inventory logs and cabinet security at least once a year; • investigating incidents involving COCs; • suspending authorizations to use laboratory COCs in cases of non- compliance; and • maintaining complete records of program operations in a form suitable for inspection that can readily be retrieved and distributed.

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 PROMOTING CHEMICAL LABORATORY SAFETY AND SECURITY Responsibilities of Laboratory Managers or Supervisors Each laboratory should designate a manager or supervisor. In many cases, the person may be the principal investigator. Laboratory managers and supervisors play an important role in the safety and security program and will be the key connection between the laboratory and the CSO. Re- sponsibilities include at least • ensuring that laboratory workers receive training in general chemi- cal safety and security; • ensuring that laboratory workers understand how to work with COCs safely and providing chemical-specific and procedure-specific train- ing as needed, including developing and reviewing SOPs; • providing laboratory workers with appropriate engineering con- trols and PPE needed to work safely with COCs; • ensuring that the laboratory has the appropriate level of security for COCs; • setting expectations for safety and security and including safety and security components in performance appraisals; and • reviewing and approving work with COCs. Responsibilities of Local Laboratory Safety Committees Local laboratory safety committees are composed of managers of labo- ratories, laboratory workers (or their selected representatives), CSOs, and perhaps security officers. Responsibilities include • reviewing and discussing current safety issues; • reviewing safety incidents; • planning safety training; • providing representation for laboratory workers; and • making recommendations for safety improvements. Responsibility of Laboratory Workers All the people who work in a laboratory—whether paid or unpaid, stu- dent or employee—are responsible for following all the safety and security protocols for their own protection and the protection of their fellow work- ers. All laboratory workers are responsible for at least the following: • attending laboratory safety training; • reviewing and following written procedures;

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 GUIDELINES • ensuring, before working with a chemical or procedure the first time, that all the hazards and procedures needed for safety and security are understood by either reviewing or developing and approving SOPs; • asking a supervisor or a CSO for help if unsure about the hazards; • using engineering controls and PPE, as appropriate; • reporting all incidents, security issues, and potential chemical ex- posures to a laboratory supervisor; and • documenting specific operating procedures for working with COCs and amending procedures as needed.

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