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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 hazchem@mcw.edu:

  • 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 hazchem@mcw.edu.

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 safetyinfo@mcw.edu.
     
  • 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 hazchem@mcw.edu

Create an inventory of chemicals used in your lab, and keep the list with your Chemical Hygiene Plan.
 

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Page Updated 05/02/2014