What does MCW consider to be a hazardous chemical?
Hazardous chemicals are defined as:
- Those chemicals that present physical or health hazards to those working in clinical or academic laboratories, as well as chemicals used in facility maintenance, based on OSHA 29 CFR 1910.1200 or 29 CFR 1910.1450;
- Any chemical for which the chemical manufacturer/importer (as listed on the Safety Data Sheet) indicates it is hazardous;
- Any chemical for which there is scientifically valid evidence that it is a combustible liquid, compressed gas, explosive, flammable, organic peroxide, pyrophoric, unstable/reactive, or reacts violently with water;
- Any chemical regulated by the Department of Transportation, 49 CFR, Subchapter C, Parts 171-172;
- Any chemical that is capable of causing environmental or health damage if disposed of improperly, as specified in the U.S. Environmental Protection Agency, Title 40 CFR;
- Any mixture untested as a whole to determine whether it is a physical or health hazard is presumed to present the same physical or health hazard as its individual components; and
- Any compound created in the laboratory that has unknown characteristics, and may present a physical or health hazard.
What is the definition of Particularly Hazardous Substance (PHS)?
Adapted from OSHA Laboratory Standards
For the purposes of requiring submission of a safety protocol and review by the Hazardous Chemical Safety Subcommittee, a hazardous chemical is one that falls into any one or more of the following four categories:
A chemical is considered a carcinogen and subject to safety review, if it is included in any of the following lists:
Reproductive toxicants are substances that have adverse effects on various aspects of reproduction, including fertility, gestation and/or fetal development (teratogens), lactation, and general reproductive performance. See MCW’s online list of Particularly Hazardous Substances.
Substances with High Acute Toxicity
High acute toxicity includes any chemical that are assigned a NFPA category 2, 3 or 4 (see MSDS) or falls within any of the following OSHA-defined categories (often listed on MSDS):
- A chemical with a median lethal dose (LD50) of 50 mg or less per kg of body weight when administered orally to certain test populations.
- A chemical with an LD50 of 200 mg less per kg of body weight when administered by continuous contact for 24 hours to certain test populations.
- A chemical with a median lethal concentration (LC50) in air of 200 parts per million (ppm) by volume or less of gas or vapor, or 2 mg per liter or less of mist, fume, or dust, when administered to certain test populations by continuous inhalation for one hour, provided such concentration and/or condition are likely to be encountered by humans when the chemical is used in any reasonably foreseeable manner.
Chemicals of Unknown Toxicity
For safety purposes, any chemical for which there is no known or limited toxicity data must be assumed to be Particularly Hazardous until proven otherwise.
What approvals do I need to work with chemicals?
Step 1: Determine if my lab uses chemicals considered Particularly Hazardous Substances (PHS). PHSs include carcinogens, mutagens, teratogens, acutely toxic chemicals, Department of Homeland Security Chemicals of Interest, EPA Extremely Hazardous Substances, and highly reactive chemicals. The Medical College of Wisconsin list of PHSs, though extensive, is not exhaustive. Some chemicals not included on the list may still meet the definition of PHS.
Step 2: If you work with a PHS as part of an animal Institutional Animal Care and Use Committee (IACUC) protocol or Institutional Biosafety Committee (IBC) protocol, you will need to submit the following information to the Hazardous Chemical Committee at email@example.com:
- Project Approval Form for Particularly Hazardous Substances;
- Hazardous Agent Information Sheet (HAIS) for work involving animals (this form is used primarily for the benefit of the animal handlers in the Biomedical Resource Center (BRC). Prior to initiation of live animal work involving chemicals, the BRC will arrange for a meeting for you with the animal care staff, where you will review the HAIS Form, and discuss the hazardous nature of the chemical to be used in animals.
- Standard Operating Procedures (SOP) – Some frequently used chemicals have SOPs, which will require only minimal work to complete. If your chemical has an existing SOP, and this is your only PHS used in your work, refer to this SOP on Sections 4 and 5 of the Project Approval Form (you do not need to re-enter information).
- Safety Data Sheet (SDS) for your chemical. This should be specific for your chemical and can be obtained from the manufacturer.
If you have any questions relating to this process, those questions can also be addressed in an email to firstname.lastname@example.org.
Step 3: If you have PHSs in use in your lab, but do not use them in any IBC or IACUC protocols:
- If an SOP is listed for this particular chemical or group of chemicals, download the form, the SDS, complete customizable sections of the SOP, have your lab staff read/sign; and file with your Chemical Hygiene Plan (this should be used as a training tool with your staff).
- If an SOP is not listed for your specific chemical, you can download a PHS template and customize it for your work. Environmental Health and Safety (EHS) can assist you in your risk assessment and will help ensure you have the correct pathways for disposal. Contact EHS at email@example.com.
- Any listed SOP for a specific chemical that is customized for your lab does not require review and approval by the Hazardous Chemical Committee.
- Any chemical for which you customize an SOP based on the PHS template does require review and approval by the Hazardous Chemical Committee.
- Download and revise the customizable PHS SOP template
- Attach the SDS for your particular chemical
- Send the customized SOP and SDS to firstname.lastname@example.org
Create an inventory of chemicals used in your lab, and keep the list with your Chemical Hygiene Plan.
What can I do to streamline the approval process?
The Project Approval Form for Particularly Hazardous Substances is reviewed by the Hazardous Chemical Committee. The committee reviews the form to ensure safety measures are in place which:
- address the protection of lab personnel;
- guard against accidental spills, and;
- address storage, use and disposal issues associated with the project.
Please ask questions if you are unsure of how to fill out the form by contacting the Environmental Health and Safety Department at email@example.com.
Is auditing or monitoring required?
The Environmental Health and Safety (EHS) staff carries out routine laboratory assessments in order to ensure that federal and state requirements for the handling and storing of hazardous materials are being met. Occasionally, additional assessments must be conducted, depending upon the source of funding, or acquisition of a material. If you have questions about the assessment process, please contact the EHS Department by emailing firstname.lastname@example.org
EHS may perform Industrial Hygiene air monitoring to quantify exposure to chemical vapors or dusts, depending upon the chemical and engineering controls used. This monitoring is completed at no cost to the investigator, if deemed necessary by EHS.
What can I do to prevent problems in the laboratory?
Top five tips to prevent problems in your laboratory:
- Ensure your chemicals are properly segregated and stored correctly. Do not let peroxide formers become an explosion hazard.
- Know how to properly dispose of your waste. Do not put chemicals down the drain unless Environmental Health and Safety (EHS) has indicated it is safe to do so.
- Store hazardous waste properly (closed, labeled, in secondary containment). Do not let waste accumulate, and notify EHS for waste pickups.
- Make sure study staff wear their safety equipment when working in the lab (e.g., proper gloves, safety eyewear/face shields, full length lab coat, closed-toed shoes); and know to properly use fume hoods, eyewashes and safety showers in your lab.
- Make sure all study staff have reviewed the Safety Data Sheets (SDS) for materials used; protocols; MCW Safety Manual and Chemical Hygiene Plan.
What training is required?
- Laboratory Chemical Safety Training is required for all individuals who work in a lab. Training is conducted upon initial employment, and every three years thereafter.
- Training in the specific Particularly Hazardous Substance (PHS) is required if the lab works with a PHS on the Medical College of Wisconsin list (the PI or lab manager would conduct this training for all staff).
- Formaldehyde Safety Training is required for those individuals who work with large amounts of formaldehyde, formalin, and paraformaldehyde (currently required only for pathologists, morgue staff, and anatomy instructors, and optional for all others).
What resources and optional training are available?
Environmental Health and Safety is the main resource for laboratory training related to chemicals. All training materials are available via an electronic computer-based training module or in person.
Complete details on training for researchers using biologicals can be found on MCW’s intranet site. If you have access to InfoScope, search for keywords “safety training” and select the link for Environmental Health & Safety Training.
What are the relevant policies, procedures and guidelines?
Standard Operating Procedures
The Medical College of Wisconsin Department of Environmental Health & Safety maintains Standard Operating Procedures for chemical use. These are available on the EHS intranet site. If you have access to InfoScope, search for keywords “EHS SOP.”
Safety Manual and Laboratory Chemical Hygiene Plan
The Medical College of Wisconsin, concerned with the health and safety of its students, faculty, staff and visitors, acknowledges its responsibility to endeavor to create, maintain, and enhance a healthful and safe environment for all individuals associated with the institution. To this end, MCW is committed to provide reasonable resources and support for the development, implementation and maintenance of an effective health and safety program.
MCW is committed to the principle that such a program will minimize institutional losses, reduce costs, improve morale and increase productivity. For these reasons, MCW requires that health promotion and accident prevention be integrated into all its academic and operational activities and has established a central Department of Environmental Health and Safety (EHS) on campus which is part of Finance and Administration. This department has been charged to oversee the development and implementation of an effective health and safety program. To best fulfill this responsibility, the Department of Environmental Health and Safety will develop and assist in implementing MCW guidelines and standards compatible with existing external agencies’ rules and regulations. Compliance with all MCW health and safety guidelines will be required. All supervisory personnel shall bear primary responsibility for the health and safety concerns within their respective area.
The Safety Manual is available at MCW’s intranet site. If you have access to InfoScope, search for keyword “EHS” and select the link for the EHS website. Then look within the right panel Quick Links for the 2012 Safety Manual and Lab Chemical Hygiene Plan (pdf).
The Medical College of Wisconsin maintains Corporate Policies relating to research safety. In particular, the policy Materials of Trade Exception (CO.OH.030) applies to the transportation of small amounts of some chemicals within personal vehicles. For a complete listing of all institutional policies, search for keyword “corporate policies” on MCW’s intranet site InfoScope.
Alternatively, you can directly view the details of an individual policy by searching on InfoScope for the policy number (e.g. CO.OH.030).
Whom do I contact if I have additional questions?
Please contact the Environmental Health and Safety (EHS) Department at email@example.com or 414-955-8060.