Environmental Health and Safety

1. Chemical Hygiene Plan

a. Ensure employees’ exposure to regulated substances do not exceed specified limits.

b. Determination of employee exposure level if limits are suspected to be exceeded.

c. Develop and implement a Chemical Hygiene Plan

d. Provide employee information and training.

e. Provide medical consultation and medical examination when employee is believed to have been overexposed or is exhibiting symptoms associated with exposure.

f. Ensure that labels on incoming containers are not removed or defaced, MSDS’s are maintained and readily accessible to employees, and include materials that are produced in the laboratory in the employee training program.

g. If respirators are used, ensure they are used correctly and by individuals who are medically fit.

h. Maintain records of any employee exposure or medical monitoring conducted.

i. Non-mandatory appendices are included as reference documents for accepted “good practice.”

2. Employee Exposure limits: ensure employees’ exposure to regulated substances do not exceed specified limits. Employee exposure determination if limits are suspected or exceeded.

3. Provide employee information and training.

4. Hazard Identification (Labels & MSDS).

5. Respirators: ensure used correctly and by individuals who are medically fit.

6. Provide medical consultation and medical examinations when employee is believed to have been overexposed or is exhibiting symptoms associated with exposure.

7. Record keeping of exposures & medical consultation.

8. Appendix A — National Research Council recommendations concerning chemical hygiene in laboratories (non-mandatory)

A. Hazardous Waste and Emergency Response (29 C.F.R. § 1910.120 et seq.)

1. Spills — Laboratory worker aware of hazards.

1. Must provide employees with information and training to ensure they are apprised of the hazards of chemicals present in their work area.

2. Provisions for employee information and training must be included in Chemical Hygiene Plan (Tit. 8, §5191(e)(3)(D))

1. All stored chemicals must be labelled with chemical name and hazard warning.

1. Ensure that labels are on incoming containers are not removed or defaced, MSDS’s are maintained and readily accessible to employees, and include materials that are produced in the laboratory in the employee training program.

1. Closed container

2. No evaporation of VOCs

1. Covered by good lab practice stds. Spill/release standards: open containers make for poor QA/QC in laboratory.

2. Practical point of view, corrosives are closed

Key: high level of education

1. Maximum 1 gal. container for Class I and II liquid outside of storage room/cabinet, except in safety cans (max. 2 gal. can).

2. Maximum 10 gal. of Class I and II liquids combined outside of safety cabinet/room, except if kept in safety cans.

3. Maximum 25 gal. of Class I and II liquids combined outside of storage room/cabinet.

4. Maximum 60 gal. of combustible liquids stored outside of storage/cabinet.

1. Total materials, including waste — not just materials used in process.

2. Extremely conservative quantity levels.

a. Determined per Bldg. or Control Area — Max. of 4 Control Areas per Bldg.

3. Quantities based on experiences Nationwide.

4. Inverse relationship between hazard and quantity: Increased hazard results in decreased quantity that can be kept:

a. 2 times increase in quantity if building has sprinklers

b. 2 times increase in quantity for cabinets or special rooms

5. UFC (4.108 and Table 4.108-C): Fire Prevention Permit required for storing, transporting on site, handling or using hazardous materials in amounts exceeding amounts listed in Table 4.108-C (Table attached).

1. RMPP Process (Cal.)

2. Threshold Planning Quantities: creates incentive to stay below TPQ

3. (Also have TQP’s on other chemicals that are not acutely hazardous, but hit UFC quantities typically before hit TPQ.)

1. Creates incentive to stay below AB 2588 Triggers

1. Ex: San Diego requirements

a. VOC emissions from laboratory equipment above 5 lbs./day requires a permit, and operator cannot discharge greater than 15 or 40 lbs. per day (depending upon certain operating conditions).

b. TAC’s: need a permit above detectible levels of compounds listed as Acutely Hazardous. In the future, operators may be subject to a local rule prohibiting increased emissions of TACs from new or modified sources greater than a risk factor of 10-5 (after installing best available control technology for toxics).

1. Clean Water Act —

a. Release of Reportable Quantity of hazardous substance or oil to surface water in any 24 hour period (Immediately after knowledge of discharge);

b. Discharge that could cause problems for POTW (Immediately).

2. CERCLA/SARA/EPCRA — Release of Reportable Quantity (RQ): (Immediately after assessment/knowledge of release).

3. UFC (80.105) — must report to fire chief all reportable discharges. Required to remedy effects of release.

4. H&S Code § 25507 (Hazardous Materials Release Response Plans): Release or threatened release of a hazardous material (to Local Administering Agency): (immediately upon discovery).

1. All of the above, except H&S Code § 25507

2. RCRA — Hazardous Waste Release that could threaten health or offsite environment (Immediately after assessment).

3. California: Current Interpretation — Any release that poses a threat to human health or the environment (i.e. fire, explosion and/or release and contingency plan is implemented).

1. Hazardous Materials Business Plan (H&S Code § 25503.5): Any business handling a hazardous material in quantities greater than the following shall establish and implement a business plan for emergency response to a release or threatened release of a hazardous material:

2. Any amount of Carcinogen or reproductive toxin;

3. Any amount of Hazardous compressed gas;

4. 200 cu. ft. compressed gas;

5. 55 gal. of liquid or 500 lb. of solid; or

6. Radioactive materials that are handled in quantities for which an emergency plan is required.

7. UFC (80.301(l)) — Secondary containment required for quantities exceeding exempt limits of Table 4.108-C (i.e. when permit required, need to install secondary containment).

1. EPA’s National pretreatment standards: Prohibited Discharges. (40 C.F.R. § 403.5)

a. General Prohibition: EPA does not allow a facility to introduce to a POTW any pollutant which causes a “pass through” or “interference” with the POTW.

b. Specific Prohibition: EPA lists certain pollutants which cannot be discharged to a POTW (ex: pollutants which create a fire or explosion hazard at the POTW, or pollutants which cause corrosive structural damage to POTW)

2. EPA’s National Pretreatment Standards: Categorical Standards

a. EPA has set national pretreatment standards by a particular industrial category that specify quantities or concentrations of pollutants which may be discharged to a POTW

Ex:

1) Pharmaceutical Manufacturing Point Source Category

2) Hospital Point Source Category

1. Any substance that would cause or tend to cause a flammable or explosive condition to result in the wastewater system;

2. Toxic or poisonous materials in such quantities that may create a health hazard to humans, animals or the environment;

3. Any matter having pH lower than 5 or high enough to cause encrustation on the sewer walls;

4. Any matter promoting or causing the promotion of toxic gasses;

5. Any radioactive material, except in limited prescribed circumstances;

6. Any toxic material, including but not limited to, heavy metals, phenols, cyanide, chlorinated hydrocarbons, and other organic compounds unless limited to a concentration that complies with all local, State, and Federal discharge limitations and that does not interfere with the operation of the POTW.