Knight:Chemical Hygiene Plan
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\documentclass{article} \newcommand{\firstrevision}{May 27, 2004} \newcommand{\lastrevision}{Feb. 11, 2008} \usepackage{xspace} \usepackage{verbatim} \usepackage{rotating} \usepackage{textcomp} \usepackage{url} \usepackage[usenames]{color} \usepackage[backref,colorlinks,citecolor=BrickRed,bookmarks,bookmarksnumbered,% bookmarksopen,pdfpagemode=UseOutlines,pdftitle={Chemical Hygiene Plan}]{hyperref} \newcommand{\degreeC}{\textcelsius\xspace} \newcommand{\fullDLC}{Computer Science and Artificial Intelligence Laboratory\xspace} \newcommand{\DLC}{CSAIL\xspace} \begin{document} \begin{center} \Huge {\bf \fullDLC} \vspace{1in} Chemical Hygiene Plan \vspace{3in} \large This document prepared by:\\ Austin Che\\ Initial Revision: \firstrevision\\ Last Revised: \lastrevision \end{center} \thispagestyle{empty} \pagebreak \section*{Abbreviations} \begin{tabular}{ll} ACGIH & American Conference of Governmental Industrial Hygienists\\ BSP & Biosafety Program (2-3477)\\ CHO & Chemical Hygiene Officer\\ CHP & Chemical Hygiene Plan\\ CSAIL & Computer Science and Artificial Intelligence Laboratory\\ DLC & Department, Lab, or Center\\ EHS & Environmental Health and Safety (2-EHSS)\\ EHS-MS & Environmental Health and Safety Management System\\ EPA & Environmental Protection Agency\\ HMIS & Hazardous Materials Identification System\\ HW & Hazardous Waste\\ IHP & Industrial Hygiene Program (2-3477)\\ LCSS & Laboratory Chemical Safety Summaries\\ MSDS & Material Safety Data Sheet\\ OSHA & Occupational Safety and Health Agency\\ PEL & Permissible Exposure Limit\\ PHS & Particularly Hazardous Substances\\ PPE & Personal Protective Equipment\\ SAA & Satellite Accumulation Area\\ SOP & Standard Operating Procedure\\ TLV & Threshold Limit Value\\ TSCA & Toxic Substances Control Act \end{tabular} \pagebreak \tableofcontents \pagebreak \part{General Administration} \label{part:admin} \section{Introduction} \subsection{Purpose, Policy, and Scope} \paragraph{Purpose} This document constitutes the Chemical Hygiene Plan required by the U.S. Occupational Safety and Health Act of 1970 and regulations of the U.S. Department of Labor including 29 CFR 1910.1450 ``Occupational Exposure to Hazardous Chemicals in Laboratories'' (the ``Laboratory Standard''). The purpose of the Plan is to describe proper practices, procedures, equipment, and facilities to be followed by employees, students, visitors, and other personnel working in the \fullDLC(\DLC) to protect them from potential health and physical hazards presented by chemicals used in the workplace, and to keep exposures below specified limits. \paragraph{Policy and Scope} It is the policy of the Massachusetts Institute of Technology (as represented by the MIT Corporation and the Office of the President) to provide a safe and healthy workplace in compliance with the U.S. Occupational Safety and Health Act of 1970 and regulations of the U.S. Department of Labor including the Laboratory Standard referenced above. The full OSHA Laboratory Standard can be found at \url{http://www.osha.gov/pls/oshaweb/owadisp.show_document?p\_id=10106&p\_table=STANDARDS}. This plan applies to all laboratories in \DLC that are located in the Stata Center, MIT Building 32, and all personnel who supervise or work in these labs. The primary applicable labs are located in one neighborhood of the building in rooms 306, 308, 311, 316, and 322. \begin{comment} While not required, non-laboratory areas where hazardous chemicals are used or stored may be included and subject to this plan. Special provisions for non-laboratory areas are outlined in Section~\ref{sec:osha_hazard_communication}. \end{comment} \subsection{Plan Organization} Part I contains information regarding the general administrative components of this Chemical Hygiene Plan. This part outlines the policy, purpose, and scope of the plan, and defines the roles and responsibilities for developing and implementing the Plan. Requirements for plan preparation and review, training, medical evaluation, exposure assessment, recordkeeping, inspections and audits, and overviews of other relevant regulations are detailed in this part as well. Part II contains the minimum required precautions and standard operating procedures for working with laboratory chemicals in MIT laboratories. These precautions address broad classes of chemicals and include information and guidance in the following areas: \begin{itemize} \item Prior approvals \item Common chemical hazards \item Procedures for work with hazardous chemicals \item Procedures for work with particularly hazardous substances \item Personal protective equipment \item Other safety equipment and engineering controls \item Chemical labeling and storage \item Chemical waste management \item Signs and symptoms of chemical exposure \item Emergency procedures \item Shipping hazardous and dangerous materials \end{itemize} Part III contains standard operating procedures for specialized materials, procedures, or practices related to chemical use that are not adequately addressed in Part~II of this plan. A Standard Operating Procedure (SOP) Template is contained in this part to provide assistance to laboratory personnel generating specific safety procedures. \subsection{MIT EHS Management System} MIT has designed and implemented a comprehensive and integrated Environment, Health, and Safety Management System (EHS-MS). A highly collaborative effort that drew on the leadership and expertise of faculty, researchers, students, administrators, and staff, the EHS Management System has reshaped how all members of the MIT community view their environment, health, and safety responsibilities, carry out MIT's comprehensive and integrated environmental commitment in their day-to-day activities, and assess MIT's performance against our goals. This management system provides better institutional accountability for achieving and maintaining compliance with federal, state, and local environment, health and safety regulations in MIT's departments, laboratories, and centers, while simultaneously retaining the independence of research and teaching. The EHS-MS also seeks to create a more sustainable campus by encouraging the incorporation of positive initiatives into activities, such as reducing wastes and toxics, preventing pollution, and conserving and reusing resources. One of the defining features of MIT's EHS-MS is to integrate regulatory compliance with positive initiatives and educational programs in a decentralized academic research setting. This Chemical Hygiene Plan is an integral component of the EHS-MS. It is an administrative tool that provides for the establishment of safe and sound workplace practices in the laboratory, and ensures the Institutes regulatory compliance with the OSHA Laboratory Standard, 29 CFR 1910.1450. The Chemical Hygiene Plan incorporates and advances core components of the EHS-MS, such as clarifying roles and responsibilities, outlining training requirements, identifying chemical risks, and documenting safe operating procedures to mitigate those risks. More information on the EHS Management System can be found at \url{http://web.mit.edu/environment/ehs/ehs_management.shtml} \section{Roles And Responsibilities} An essential component of any chemical safety program is to clearly articulate and clarify the different roles and responsibilities of all the stakeholders who work or visit in areas where chemicals are present. Clarifying roles and responsibilities for implementing the Chemical Hygiene Plan will establish accountability, streamline processes, enhance safety, and avoid confusion and questions in meeting the Plans objectives. \subsection{Department, Lab, or Center Chair} The head of \DLC is {\bf Rodney Brooks}, room 32-G430, telephone x3-5223. The lab head shall: \begin{itemize} \item Appoint the Chemical Hygiene Officer. The individual selected must be qualified by training or experience to provide technical guidance in the development and implementation of this written Chemical Hygiene Plan. This individual must have appropriate authority to assist with implementation and administration of the Chemical Hygiene Plan. \item Provide or obtain administrative and monetary support, as needed, for implementing and maintaining the Chemical Hygiene Plan and the requirements of the plan. \end{itemize} \subsection{Chemical Hygiene Officer} For \DLC, the Chemical Hygiene Officer is {\bf Tom Knight}, room 32-312, telephone x3-7807. The Chemical Hygiene Officer shall: \begin{itemize} \item Assure the Chemical Hygiene Plan is written and updated. \item Know and understand the requirements of the OSHA Laboratory Standard regulation (29CFR 1910.1450) and this Chemical Hygiene Plan. \item Oversee the implementation of the CHP in the lab and assist Principal Investigators with implementing the Chemical Hygiene Plan. \item Assure the plan is distributed or made available to all in \DLC who are impacted by the plan. \item Submit one copy of the CHP electronically to the MIT EHS Office for reference-use and to facilitate the annual update process as outlined in Section~\ref{sec:chp_update}. \item Advise Principal Investigators concerning adequate facilities, controls, and procedures for work with unusually hazardous chemicals. \item Seek ways to improve the Chemical Hygiene Plan. \item Review and update the Chemical Hygiene Plan annually, when directed by the EHS Office. \item Support the EHS Coordinator, as needed, with audit activities and other requirements of the EHS Management System, such as the space registration database. \item Participate in investigation of serious accidents involving hazardous chemicals, acting as liaison for the EHS Office. \item Assist PIs, as needed, with obtaining services or supplies and equipment for correcting chemical safety problems or addressing chemical safety needs. \item Review proposed experiments, as requested, for significant EHS issues, and contact EHS, if needed, to address concerns. \item Co-Chair the DLC-EHS Committee with the EHS Coordinator. \item Attend annual CHO meeting conducted by the EHS Office. \end{itemize} \subsection{EHS Coordinator} The EHS Coordinator is {\bf Anthony Zolnik}, room 32-366, telephone x3-3562, email anthony@csail.mit.edu. The EHS Coordinator shall: \begin{itemize} \item Provide assistance to the CHO, if appropriate and as requested, with developing and implementing this Chemical Hygiene Plan. \item Be familiar with this Chemical Hygiene Plan. \item Compile information from the laboratory for the EHS Space Registration Data Base. \item Assure routine inspections are conducted in the laboratory areas. \item Participate in biannual inspections of laboratory operations. \item Assure \DLC staff receive training required by regulation for safe handling and proper disposal of chemicals and that the training is documented. \item Serve as contact point for arranging special studies or support from EHS. \item Act as a contact for Building Services and Repair and Maintenance staff to address concerns regarding safety for work in the laboratory area. \item Assure appropriate records are maintained for exposure monitoring, inspections, inventories, training, and accident and incidents. Collect and maintain records regarding laboratory-specific training. \item Arrange for decommissioning of laboratory space. \item Co-Chair the DLC-EHS Committee with the Chemical Hygiene Officer. \item Maintain records regarding, and inspection follow-up for three years. \end{itemize} \subsection{Principal Investigator or Laboratory Supervisor} \label{sec:pi} The principal investigator or laboratory supervisor shall: \begin{itemize} \item Be familiar with this Chemical Hygiene Plan and ensure that all work is conducted in accordance with requirements of this plan. They should contact the CHO for advice and assistance regarding this plan and implementing the provisions of this plan when needed. \item Assess all chemicals in the research laboratories under their purview, and assure measures are established for safe use, storage, and disposal of the hazardous chemicals within the laboratory. Such measures include: \begin{itemize} \item Preparing additional, Standard Operating Procedures (SOPs) for research activities involving hazardous chemicals, when needed. See Section~\ref{sec:sops} for more information on when additional SOPs are required. \item Providing personal protective equipment needed for safe handling of the chemicals. \item Providing proper containers, containment, and cabinetry for safe storage of materials. \item Defining the location and processes where particularly hazardous substances will be used, ensuring these areas are labeled, and ensuring that a list of these substances is maintained. \end{itemize} \item Assure new processes or experiments involving hazardous materials are planned carefully and appropriate hazard information, safety equipment, and SOPs are available prior to commencing work. Always seek to minimize the amount of hazardous chemicals purchased and used for experiments or processes. \item Assure the information regarding the laboratory activities recorded in the Space Registration Database is accurate. \item Plan for accidents and assure that appropriate supplies are in place and procedures are established for responding to an accident, including cleaning up chemical spills. \item Assure all employees working in the laboratory receive required training for work with potentially hazardous chemical, including lab specific training on the hazardous materials that they use. See Section~\ref{sec:lab_training}. Follow procedures for documenting the lab specific training. \item Assure that all personnel obtain medical examinations and medical surveillance when required due to the materials they are working with. \item Monitor the safety performance of the staff to assure that the required safety equipment, practices and techniques are understood and are being employed and ensure that action is taken to correct work practices that may lead to chemical exposures or releases. \item When needed, contact the EHS Office to arrange for workplace air samples, swipes or other tests to determine the amount and nature of airborne and/or surface contamination, inform employees and students of the results, and use data to aid in the evaluation and maintenance of appropriate laboratory conditions. \item Assure laboratory inspections are conducted routinely, to include weekly inspection of Satellite Accumulation areas, and take action to correct conditions that may lead to accidents or exposure to hazardous chemicals. See Section~\ref{sec:inspections}. \item Assure employees who suspect they may have received an excessive exposure to a hazardous chemical report to the MIT Medical Department for assessment. Such exposures may occur through accidental inoculation, ingestion, or inhalation of the chemical. \item Report all accidents involving an employees chemical exposure or involving a chemical spill that may constitute a danger of environmental contamination to EHS and the CHO. \item Investigate all chemical accidents and near misses to determine the cause and take appropriate corrective action to prevent similar accidents. Contact the CHO or EHS, when needed, for assistance with investigations, assessment, and recommendations for corrective action. \item Assure unwanted or excess hazardous chemicals and materials are properly disposed. \item Assist the EHS Office, EHS Coordinator, and CHO as requested. \end{itemize} \subsection{EHS Representative} The EHS Representative assists the principal investigator or supervisor in charge of the individual laboratory or facility space in complying with environmental health and safety (EHS) regulations and MIT practices under MIT's EHS Management System. The EHS Representative will work closely with the principal investigator/supervisor and DLC EHS Coordinator to ensure that EHS Requirements are satisfied. The EHS representative shall: \begin{itemize} \item Be familiar with the content and requirements of this Chemical Hygiene Plan and assist the principal investigator or supervisor, as directed, with implementing and complying with requirements of this Plan. \item Assist with contacting the DLC EHS Coordinator or the CHO, when needed, for assistance with addressing requirements for safe handling of chemicals. \item Assist with or provide lab specific chemical safety training for laboratory personnel, as directed by the PI. \item Assist with dissemination of EHS information to laboratory personnel. \item Assist with required routine inspections of the laboratory, correcting problems that can be readily corrected. \item Assist with assuring essential supplies and equipment are in place for safe work in the laboratory. \item Assist with monitoring staff work practices for safety. \item Report safety problems or concerns to the PI and/or the EHS Coordinator. \item Address, as directed, safety problems or concerns in the laboratory. \item Review and be familiar with the \DLC Emergency Preparedness Plan. \end{itemize} \subsection{EHS Office} The Environment, Health, and Safety (EHS) Office shall: \begin{itemize} \item Oversee process for annual update of the CHP, reminding CHOs and EHS Coordinators when annual CHP updates are due and reviewing updated plans. See Section~\ref{sec:chp_update}. \item Provide a standard CHP template for use in developing and updating Chemical Hygiene Plans. \item Provide General Chemical Hygiene training by classroom, web, or when requested by a DLC. \item Provide Managing Hazardous Waste training by classroom, web, or when requested by a DLC. \item Provide materials and guidance to assist with Lab Specific Chemical Safety training. \item Establish and maintain system for maintaining training records. \item Conduct an annual meeting for CHOs to update them regarding changes in the template, the EHS Management System, and to review significant chemical safety concerns from the year. \item Conduct special investigations and exposure monitoring, as requested or as required by regulations, making recommendations for control when needed. \item Participate in inspections of laboratory operations at least once a year. \item Oversee the fume hood survey program. \item Provide guidance regarding selection and use of Personal Protective Equipment. \item Provide guidance and review SOPs for new experiments or operations, as requested. \item Provide, as requested, chemical safety information and guidance for appropriate controls of hazards such as proper personal protective equipment and local exhaust ventilation. \item Assist with investigations of serious accidents or chemical exposure incidents. \item Report all DLC-specific accidents and incidents, as appropriate, to the DLC EHS Coordinator. \end{itemize} \subsection{Employees, Staff, Students, and Visitors} Employees, staff, students, and visitors working with or around hazardous chemicals in a laboratory shall: \begin{itemize} \item Be familiar with the OSHA Chemical Hygiene Standard and this Chemical Hygiene Plan. \item Understand the hazards of chemicals they handle and the signs and symptoms of excessive exposure. \item Understand and follow all Standard Operating Procedures. \item Understand and apply all training received. \item Understand the function and proper use of all personal protective equipment and wear personal protective equipment when mandated or necessary. \item Report to the Principal Investigator or Laboratory Supervisor any significant problems arising from the implementation of the Standard Operating Procedures. \item Report to the PI or Supervisor all facts pertaining to every accident that results in exposure to toxic chemicals. \item Report to the PI or Supervisor or EHS representative actions or conditions that may exist that could result in an accident. \item Contact the PI or Supervisor, the Chemical Hygiene Officer, the EHS Coordinator, or the EHS Office if any of the above procedures are not clearly understood. \end{itemize} \subsection{DLC EHS Committee} The EHC Committee will consist of the Chemical Hygiene Officer, the EHS Coordinator, and other faculty, staff, or students of \DLC as appropriate. With respect to the Chemical Hygiene Plan, the DLC EHS Committee shall: \begin{itemize} \item Participate in periodic inspections and/or review inspection reports of laboratories and facilities, providing guidance or directives, as needed for correcting problems found. \item Review chemical handling incidents or exposure issues that occur and recommend appropriate corrective action. \end{itemize} \section{CHP Preparation, Review and Update} \subsection{Plan Preparation} The Chemical Hygiene Officer will oversee the preparation of the Chemical Hygiene Plan for \DLC and is responsible for seeing that the plan meets requirements set forth in 29 CFR 1910.1450. Assistance in creating the Chemical Hygiene Plan is provided by the MIT EHS Team. \subsection{Initial Plan Approval} The Chemical Hygiene Officer, is responsible for assuring that the chemical hygiene plan is approved by EHS Office Industrial Hygiene Program (IHP). Once the CHO completes the initial plan, they must submit the plan to IHP for a final review. An IHP representative will review the plan against the requirements of the OSHA standard, the EHS Office, and the EHS Management System, and will provide comments when needed. The CHO must incorporate comments and resubmit the plan for final approval. When a plan meets all requirements, the IHP will provide a letter of approval to the CHO. The CHO must assure the plan is distributed or made available to all in \DLC who are impacted by the plan. One copy of the CHP will be provided electronically to MIT EHS for reference use and to facilitate the annual update process. \subsection{Plan Review and Update} \label{sec:chp_update} On an annual basis, the IHP will notify the CHO when it is time to review and update the plan. At this time, the IHP will also notify the CHO of any changes that must be incorporated into the plan due to changes in EHS operations, the MIT EHS Management System, or changes in regulatory requirements. The Chemical Hygiene Officer will review, update, and submit the plan, with any changes required, to the EHS Office by the deadline specified by the IHP. The CHO should make sure that the plan update factors in changes in operations as well as the changes requested by the IHP. The IHP will review the plan and provide the CHO comments, when needed. When comments are received, the CHO must incorporate them, and resubmit the plan. Once the IHP considers the plan complete, they will provide a letter of approval to the CHO. Upon receipt of the letter of approval, the plan is considered final for the year. The Chemical Hygiene Officer will see that the Chemical Hygiene Plan and updates are distributed to or made available to those who are affected by it. One copy of the Chemical Hygiene Plan and all updates will be provided electronically to MIT EHS for reference use, and to facilitate the annual update process. \section{Training and Information} MIT will provide laboratory personnel with information and training to ensure that they are apprised of the hazards of the chemicals present in their work area. The purpose of information and training is to ensure that all individuals at risk are adequately informed about the work being performed in the laboratory, associated hazards and actions to be taken to protect themselves during normal operations, as well as emergencies. \subsection{General Requirements} {\em Anyone who has not met all training requirements is not allowed to be in a laboratory area unaccompanied by trained lab personnel.} \subsubsection{Training Requirements} \label{sec:lab_training} Chemical hygiene training requirements are detailed in the EHS-MS training system (see \url{http://web.mit.edu/environment/training}). The following 4 components are required if you indicate in the Training Needs Assessment within the training system that you use potentially hazardous chemicals in a laboratory or are a Principal Investigator or Supervisor for those who use potentially hazardous chemicals in a laboratory. \begin{enumerate} \item {\bf General Chemical Hygiene Training} -- can be taken as a web-based course or taken by attending a class offered by the EHS Office. Required once only before beginning work with potentially hazardous chemicals in a laboratory. \item {\bf Read the Chemical Hygiene Plan} -- see your EHS Representative if you do not know where to find this. Sign-off required once only before beginning work with potentially hazardous chemicals in a laboratory. \item {\bf Lab specific chemical hygiene training} -- provided by the Principal Investigator or his or her designee on lab specific chemical hazards. Required before beginning work with potentially hazardous chemicals in a laboratory and annually thereafter (usually within a lab group meeting). The topics covered will depend, in part, on the nature of the lab and research being done. However, some suggested topics are as follows: \begin{enumerate} \item Information about physical and health hazards of chemicals used in the lab. Many lab groups use too many chemicals to discuss each one individually, so a grouping of chemicals by hazard type may be used. \item Lab specific rules for the use of fume hoods. \item Information about location, use, and maintenance of personal protective equipment, including designation of who is responsible for assuring that a stock of this equipment is maintained. \item Information about location of emergency response equipment, such as, eyewash, safety showers, spill supplies, fire extinguishers, etc. \item Procedures established for labeling materials. \item Information on lab procedures for storing materials. \item Information on lab specific waste management practices. \item You will be asked to sign a roster indicating your attendance. \end{enumerate} \item {\bf Managing Hazardous Waste} -- can be taken as a web-based course or taken by attending a class offered by the EHS Office. Required before beginning work with potentially hazardous chemicals and annually thereafter. \end{enumerate} \subsubsection{Information Requirements} Information that must be provided or made available to laboratory personnel include: \begin{itemize} \item A copy of the OSHA Lab Standard. This information also can be found from the OSHA web site. \item The location and availability of the Chemical Hygiene Plan. \item The Permissible Exposure Limits (PELs) for OSHA-regulated substances and the AGCIH Threshold Limit Values (TLVs) for hazardous substances not given OSHA PELs. \item Signs and symptoms associated with exposure to hazardous substances used in the laboratory. General information is provided in Section~\ref{sec:symptoms}. \item The location and availability of known reference materials on hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory. \end{itemize} Hard copies of available safety information, including a copy of this chemical hygiene plan, will be located on the shelves in the area of 32-311. A first aid kit exists in the cabinet outside room 32-322. \subsection{Chemical Safety Information Sources} There are numerous sources of chemical safety information. These sources include: \begin{itemize} \item Chemical Container Labels \item Material Safety Data Sheets (MSDS) or Laboratory Chemical Safety Summaries (LCSS) \item Laboratory Signs \item Health and Safety Reference Literature \end{itemize} In addition, your lab supervisor, Chemical Hygiene Officer, and EHS Office staff are available to provide safety information. Safety information sources are discussed in greater detail below. \subsection{Chemical Container Labels} Chemical container labels are a good resource for information on chemical hazards. All containers of hazardous chemicals must have labels attached. Labels on purchased chemicals must include: \begin{itemize} \item The common name of the chemical; \item The name, address and telephone number of the company responsible for the product; and \item An appropriate hazard warning. \end{itemize} The warning may be a single word (i.e. Danger, Caution, Warning) or may identify the primary hazard both physical (i.e. water reactive, flammable, or explosive) and health (i.e. carcinogen, corrosive or irritant). Most labels provide additional safety information to help workers protect themselves from the substance. This information may include protective measures and/or protective clothing to be used, first aid instructions, storage information and emergency procedures. Laboratory personnel are responsible for: \begin{itemize} \item Inspecting incoming containers to be sure that they are labeled with the information outlined above. \item Reading the container label each time a newly purchased chemical is used. It is possible that the manufacturer may have added new hazard information or reformulated the product since the last purchase. \item Ensuring that chemical container labels are not removed or defaced, except when containers are empty. \item Labeling any secondary containers used in the laboratory, to prevent unknown chemicals or inadvertent reaction. \item Verifying that chemical waste containers have complete and accurate chemical waste labels. \end{itemize} \subsection{Material Safety Data Sheets (MSDSs)} Material Safety Data Sheets (MSDSs) are documents, prepared by chemical manufacturers that describe the physical and chemical characteristics of hazardous chemicals; provide information about the chemicals physical and chemical hazards; and list the means for controlling those hazards. MSDSs also provide information about first aid, emergency procedures, waste disposal and recommended exposure limits. An MSDS should be reviewed before beginning work with a chemical to determine proper use and safety precautions. Once a chemical is present in the lab, the MSDS should be either book marked electronically or a hard copy kept on hand for reference, in case of emergencies. Information required by OSHA to be on an MSDS include: \begin{tabular}{ll} Product Identity & Reactivity Hazards\\ Hazardous Ingredients & Spill Clean-UP\\ Physical/Chemical Properties & Protective Equipment\\ Fire and Explosion Hazards & Special Precautions\\ Health Hazards \end{tabular} MSDSs and similar documentation can be obtained from a variety of sources as outlined below: \begin{itemize} \item {\bf The Internet}. The EHS Office has compiled a list of links to sites that contain MSDSs. This list can be accessed at \url{http://web.mit.edu/environment/ehs/topic/msds.html}. \item {\bf Laboratory Chemical Safety Summaries (LCSS)}. The LCSSs provide concise critical discussions of the toxicity, flammability, reactivity, and explosibility of 88 chemicals commonly used in scientific research laboratories. These are particularly useful as they address laboratory use of chemicals. They are available from the Howard Hughes Medical Institute website at \url{http://hhmi.org/research/labsafe/overview.html}. \item {\bf Chemical Manufacturer}. A request may be made directly to the chemical manufacturer or supplier. This is often the best source for products or mixtures to determine what hazardous ingredients are contained in the formulation. \item {\bf EHS Office}. A comprehensive file of MSDS's for common chemicals that are in use at MIT or have been used at MIT is available through the EHS Office on the fourth floor of Building N52. They can be reached at 2-EHSS (2-3477). \end{itemize} Please contact the EHS Office if you need assistance help in interpreting MSDS information. \subsection{Laboratory Emergency Contact Signs} Each laboratory using hazardous materials at the Institute is required to post a standardized sign on the entry door containing emergency contact information on the key responsible parties for the laboratory. This includes information on the department, lab, or center; PI/Supervisor; EHS Representative; EHS Coordinator; and the Department of Facilities. These signs are commonly called {\em Emergency Green Cards}, and can be generated only by the EHS Office or the DLC EHS Coordinators. In addition, all laboratories must post appropriate laboratory entrance precautionary signs if they are using biological, radiological, laser, or other specialized hazards. These signs can be obtained by contacting the EHS Office. \subsection{Health and Safety Reference Literature} The EHS Office maintains a library of reference materials addressing environment, health and safety issues. These references include applicable exposure standards and recommended exposure levels, as well as copies of the OSHA Lab Standard and its Appendices. These materials, as well as additional health and safety references, may be reviewed by visiting the EHS Office located on the fourth floor of Building N52. \section{Medical Evaluation and Surveillance} \subsection{Medical Evaluation} Employees or students who wish to discuss occupationally-related medical issues with the MIT Medical Department, Occupational Medicine Service may do so. During this medical evaluation, the clinician will determine if a medical examination is necessary. Medical evaluations and examinations may be arranged by contacting the Medical Department, Occupational Medicine Service at 253-8552. \subsubsection{When a Medical Evaluation May be Necessary} Any employee who exhibits adverse health effects from an exposure as a result of MIT-related research or work should report to the Medical Department immediately for a medical evaluation. Employees or students who work with hazardous materials are entitled to a medical evaluation when any of the following conditions occur: \begin{itemize} \item the individual develops signs/symptoms associated with hazardous chemicals to which they were exposed; \item exposure monitoring results are routinely above action level or PEL (permissible exposure limit) for a substance for which there are monitoring/medical surveillance requirements; or \item a spill, leak, explosion or other incident creates a likelihood of exposure. \end{itemize} \subsubsection{Information to Provide to the Clinician} At the time of the medical evaluation, the following information shall be provided to the clinician: \begin{itemize} \item identity of the hazardous chemicals to which the individual may have been exposed; \item description of the conditions under which the exposure occurred; \item a description of the signs and symptoms of exposure, if any; and \item where the exposure involves a new chemical, a copy of the chemical information sheet (MSDS, or Material Safety Data Sheet) shall be provided as well. \end{itemize} If a Supervisor's Report of Occupational Injury or Illness has been completed, the Supervisor will provide the information above. In instances where time does not permit for the Supervisors report to be completed, the employee or individual assisting the employee to the Medical Department will provide the information. \subsubsection{Clinician's Written Opinion} The MIT Medical Department and the Industrial Hygiene Program within the Environment, Health, and Safety Office have a collaborative relationship in dealing with chemical and other work-related exposures that may result in the need for medical care. This collaborative relationship includes protecting patient information while ensuring that supervisors receive the information necessary to ensure that an individual's return to work following medical treatment for a work-related exposure does not compromise the patient's health. All patient medical information is protected by law and is considered strictly confidential. A patient, however, is entitled to view his/her medical record. When a work-related exposure has occurred that results in medical examination and/or treatment, the Medical Department will notify the supervisor of the incident, along with any recommended restrictions on work activity. \subsubsection{Additional Steps to be Taken} MIT requires the Supervisors Report of Occupational Injury and Illness to be completed within 24 hours, when a spill or other accident triggers a medical evaluation or examination. The report, to be completed by the Supervisor, is available online at: \url{http://web.mit.edu/environment/ehs/topic/accident.html}. \subsection{Medical Surveillance} Medical surveillance is the process of using medical exams and/or biological monitoring to determine potential changes in health as a result of a hazardous chemical or other exposure. Certain OSHA standards require a clinician evaluation as part of medical surveillance. Medical surveillance is required when initial monitoring reveals exposure levels that exceed levels (called action levels) allowed under OSHA standards. MIT Medical Department provides medical surveillance services. If you expect that your work will involve a hazardous exposure that can not be adequately controlled by administrative or engineered measures, a baseline exam is advised before beginning work. That baseline is compared against follow up exams to determine any changes in health that may have resulted from exposure to the hazard. In addition, medical surveillance is offered to employees or students who are routinely exposed to certain hazards. Examples of hazards that are monitored through the medical surveillance program include: \begin{itemize} \item Asbestos \item Beryllium \item Noise (Hearing Loss) \end{itemize} This is not a full list of hazards for which medical surveillance is available. Individuals with questions pertaining to occupational hazards and the possible need for medical surveillance are encouraged to contact the Medical Department. The Medical Department in turn works collaboratively with the EHS Office to determine the need for and extent of medical surveillance. \subsubsection{Enrollment in Medical Surveillance} For those individuals whose work involves exposures with potential medical surveillance requirements, it is the responsibility of supervisors to identify new employees/students who are exposed to hazards, and to provide names, work addresses, and MIT Identification Numbers (MIT ID) to the EHS Office. Individuals not otherwise identified but who believe that they incur hazardous exposures, or believe they may have been inadvertently omitted, may self-enroll by dialing 253-1740. Supervisors who believe that individuals have been inadvertently omitted from medical surveillance may also contact this number. Finally, the EHS Office may identify individuals or populations of individuals at risk and invite their participation. More information on Medical Consultation, Evaluation, and Surveillance may be obtained from the Medical Departments Occupational Medicine webpage at \url{http://web.mit.edu/medical/services/s-occupational.html}. \section{Exposure Assessment} \subsection{Exposure Assessment (Monitoring \& Reporting)} The EHS Office Industrial Hygiene Program provides exposure assessment services to the Institute community. Exposure assessments are measurements of air contaminants, noise levels, or other health hazards such as heat stress to determine if they are within limits that are considered safe for routine occupational exposure. Any employee who believes s/he has had an exposure should contact the Chemical Hygiene Officer or the Industrial Hygiene Program (2-3477) for evaluation. In addition, anyone with a reason to believe that exposure levels for a substance routinely exceed the action level, or in the absence of an action level the PEL, may request exposure monitoring. Monitoring may be requested at any time, however, the Chemical Hygiene Officer must be notified of monitoring requests. The Industrial Hygiene Program will conduct, or arrange to have conducted, exposure monitoring. If the initial monitoring reveals an employee exposure over the action level (or the PEL) for a hazard for which OSHA has developed a specific standard (e.g. lead), the exposure monitoring provisions of that standard, including medical surveillance, shall be followed. It will be the responsibility of the Principal Investigator/Supervisor to insure that necessary periodic monitoring requirements are met. Within 15 working days after the receipt of any monitoring results, the Industrial Hygiene Program will notify the employee or student of the results in writing, either individually or by posting results in an appropriate location that is accessible to employees. In addition, the results of any personal air sampling conducted will be given to the individual and a copy kept in the Industrial Hygiene Office's records. The Industrial Hygiene Program and the Chemical Hygiene Officer will establish and maintain for each employee an accurate record of any measurements taken to monitor exposures. Records, including those from monitoring provided by other qualified services, will be managed in accordance with OSHA standard 29 CFR 1910.1020, Access to Employee Exposure and Medical Records. \section{Workplace Hazards Policy} It is MIT policy that employees and students who may be exposed to hazards on the job should be informed of the nature of the hazards and how to protect themselves. Work place hazards may potentially affect the reproductive health of both male and female employees if proper procedures and controls are not used. To evaluate any potential concerns about work and reproductive health, an employee has multiple resources within MIT to assist him or her. The MIT Medical Department has on staff an occupational health physician and occupational health nurse. They are available for consultation about reproductive health concerns related to work exposure at no cost to the MIT community. Industrial hygienists, health physicists, and microbiologists are available to evaluate an Institute laboratory or workplace for reproductive hazards. Any employee or student can call the Medical Department for a medical consultation and EHS for a workplace evaluation. All medical evaluations are kept strictly confidential and issues of confidentiality are considered when the decision about worksite evaluation is made. Employees and students should be informed that at any time they may make an appointment to see an occupational health physician at MIT Medical Department at no charge. If they prefer to see them before a worksite evaluation, that is acceptable. If the workplace or laboratory involves chemicals, the Industrial Hygiene Program will evaluate the worksite as follows: an industrial hygienist will visit the workplace and talk with the concerned employee or student. A list of all chemicals in use and the procedures in which they are used will be generated. A review of the scientific literature for reproductive hazards of the chemicals will be conducted and reviewed by the occupational health physician. If warranted, any exposure controls such as local exhaust ventilation or personal protective equipment will be evaluated. Air sampling may be conducted to ensure that if there is any exposure, it is below safe levels. In addition to chemical exposures, IHP will also evaluate other workplace factors that may affect reproductive health, including heat stress, noise, and ergonomic stresses of the job. Prolonged standing, bending, lifting can have an impact on pregnancy outcomes; in addition, carpal tunnel syndrome is 2.5 times more prevalent in pregnant women so that careful ergonomic evaluation of job activities are important. If the employee works with radioisotopes or ionizing radiation, the Radiation Protection Program will be contacted for an evaluation. If certain occupational infections (hepatitis, HIV, toxoplasmosis-rubella-cytomegalovirus-herpes) are a source of concern, the Biosafety Program will be contacted for evaluation and infection control methods. Though there is no formal written Personnel Policy for temporary change of jobs should employees be concerned about reproductive hazards, Departments, the Personnel Department, and EMS work together to provide safe work for pregnant workers. Pregnant employees with illness or disabilities are covered under regular MIT sick leave and disability policies. \section{Recordkeeping} \subsection{Exposure Evaluation} The Industrial Hygiene Program and the Chemical Hygiene Officer will establish and maintain an accurate record of any measurements taken to monitor exposures. Records, including those from monitoring provided by other qualified services, will be managed in accordance with OSHA standard 29 CFR 1910.1020, Access to Employee Exposure and Medical Records. \subsection{Medical Consultation and Examination} Results of medical consultations and examinations will be kept by the MIT Medical Department for a length of time specified by the appropriate medical records standard. This time will be at least the term of employment plus 30 years as required by OSHA. \subsection{Training} The PI or designee should keep a copy of the outline of the topics covered in Lab Specific Chemical Hygiene Training. The roster or lists of researchers who have completed the lab specific training and read the chemical hygiene plan, must be submitted to the EHS Coordinator. These training records are then entered into the EHS-MS central training records database. When an employee or student leaves the Institute, their training records are moved into an archive training database. Training records are kept for 30 years after an employee or student leaves the Institute. \subsection{Fume Hood Monitoring} Data on annual fume hood monitoring will be kept by the EHS Office. Fume hood monitoring data are considered maintenance records and as such the raw data will be kept for one year and summary data for 5 years. \subsection{Inspection Reports} A copy of the most recent Level II. {\em Laboratory Inspection Checklist} and {\em PI Inspection Report}, as outlined below, should always be maintained locally within the DLC. An additional copy will be maintained centrally by the EHS Office. \subsection{Laboratory-Specific Policies and SOPs} If standard operating procedures (SOPs) are developed in addition to the SOPs contained in Part~II of this Chemical Hygiene Plan, they may be included in Part~III of this Chemical Hygiene Plan and a copy maintained in the laboratory, accessible to laboratory personnel. \subsection{MSDSs for New Materials} If your laboratory operations generate new materials for which existing Material Data Safety Sheets do not adequately address, an MSDS-type document must be written and maintained in the laboratory with the laboratory's other MSDSs. \section{Laboratory Inspections and Audits} \label{sec:inspections} \subsection{Inspections} As a component of the MIT Environment, Health, and Safety Management System (EHS-MS), the Institute has implemented a framework for conducting laboratory/work space inspections and audits to determine laboratory/work space-specific compliance with environmental, health, and safety policies, laws, and regulations. In addition to laboratory chemical hygiene practices, the EHS-MS inspections examine a broad spectrum of areas including postings, documentation and training, safety equipment, laboratory/shop protocol, waste, and satellite accumulation areas (SAA). The purpose of the inspection and audit system is to assist the Institute and laboratories in maintaining a safe work and study environment, ensuring compliance with regulations, identifying the locations where training or retraining is needed, and to fulfill MITs commitment to environment, health and safety stewardship. This program will satisfy the DLC requirements for chemical hygiene inspections. The Chemical Hygiene Officer and EHS Coordinator will assist with the inspections, as noted below. The Industrial Hygiene Program is available to the Chemical Hygiene Officer and EHS Coordinator in the inspection process and in all related matters. The MIT EHS-MS requires three levels of inspection and audit that must be implemented across the Institute: \subsubsection{Level I Inspection} {\em Individual laboratory/work space compliance self-inspection.} This is to be conducted by the PI or EHS Representative on a weekly basis to reinforce training and measure compliance. Record-keeping will be optional, but may be required if there are repeated compliance issues. Inspection questions and guidance material for these Level I inspections can be obtained from the EHS website. It is important that action is taken to correct problems found during these inspections. If a problem cannot be corrected by the PI/Supervisor for any reason, the problem should be reported to the EHS Coordinator for follow-up. \subsubsection{Level II Inspection} {\em DLC-wide compliance inspection of all lab/work spaces where potentially hazardous materials are stored and used.} This inspection is to be conducted by the EHS Coordinator and the DLC EHS Committee, or other designated personnel, twice annually, with at least one inspection jointly conducted by the EHS Office Lead Contact and DLC personnel. Records of these inspections will be kept centrally. Inspection questions and guidance material for these Level II inspections can be obtained from the EHS website. Once the inspection is complete, the PI/Supervisor will receive a report and must act to correct the problems found and then submit, in writing to the CHO and EHS Coordinator, the actions taken to resolve the problems. If the PI/Supervisor cannot correct a problem for any reason, he/she must notify the CHO and the EHS Coordinator. \subsubsection{Level III Audit} {\em System implementation and operation audit by MIT.} This audit is arranged by the EHS Office and will be carried out by the MIT Audit Division and/or outside consultants. These audits will be conducted at least once every two years, and may or may not impact all DLCs. The purpose of these audits is to evaluate the EHS Management System. Generally, follow-up will not involve a specific PI/Supervisor. \subsection{Compliance and Enforcement} If a PI/Supervisor does not take appropriate action to address problems noted during inspection or audits, he/she may be subject to compliance and enforcement action. Issues of non-compliance will be taken to the DLC EHS Committee for recommendations regarding disciplinary action. The EHS Committee will provide recommendations to the Department Head for action. Deliberate failure to comply that results in serious jeopardy to personnel safety and health or the environment may result in loss of laboratory privileges. A framework for establishing consequences for poor EHS performance and incentives for promoting best management practices has been adopted by the Institute. \begin{comment} Details of this framework can be found at [place URL here]. % where's the URL? barry says url doesn't exist yet \end{comment} \begin{comment} \section{OSHA Hazard Communication Standard} \label{sec:osha_hazard_communication} This Plan also applies to the non-laboratory operations in \DLC where hazardous chemicals are used. All components of this plan applicable to laboratory areas apply to these non-laboratory areas. Additional requirements or options for these non-laboratory areas are provided below. Added responsibilities for PIs/Supervisors. In addition to their responsibilities noted in Section~\ref{sec:pi}, PIs/Supervisors for the non-laboratory areas shall: \begin{itemize} \item Assure a list of all hazardous chemicals used in the non-laboratory area is compiled. The list shall include chemical or product name (as found on the label), manufacturer, location of use or storage, and maximum quantity likely to be present at one time during the year. This list must be updated annually, and a copy of the old list submitted to the EHS Office for archiving. \item Assure that for each chemical on the list, there is a copy of an MSDS in a notebook readily accessible to all personnel using the chemical. This notebook should be updated annually when the list is updated. \item Assure all personnel are informed of the chemical list and the MSDS notebook during work area specific training. \end{itemize} Employees and students working in these areas may choose to take General Chemical Safety for laboratories or General HAZCOM training for non-laboratory areas. All potentially hazardous chemicals transferred from their original container to a second container must be labeled with the chemical name and the principal hazard. \end{comment} \section{Toxic Substances Control Act (TSCA)} The Toxic Substances Control Act (TSCA) is a set of EPA regulations (40 CFR 700-799) designed to review new chemicals for environmental and health risks before they are widely distributed in commerce. A New Chemical is a substance that is not currently on the {\em TSCA Inventory}. The TSCA regulations also provide EPA with the power to restrict or ban the circulation of chemicals currently in commerce that are known to cause harm to the environment or human health (e.g. PCBs and asbestos). Though TSCA is most widely understood and used among industrial and manufacturing facilities, EPA has begun looking at universities to determine their compliance with TSCA, specifically the syntesis of new chemicals. The sections of TSCA of specific concern to MIT include: \begin{itemize} \item Import Notification (Section~13) \item Export Notification (Section~12b) \item Pre-Manufacture Notices (Section~5) --- Research and Development exemption \item Allegations of Adverse Reactions (Section~8c) and Notice of Substantial Risk (Section~8e) \end{itemize} DLCs need to determine whether or not a chemical substance is covered under TSCA if there are plans to: \begin{itemize} \item import a chemical substance; \item export a chemical substance; \item synthesize a chemical substance, in which case you need to determine whether that chemical substance is currently in commerce. If the chemical is not currently in commerce, you need to determine whether it is regulated by another agency; if it isn't, the substance is regulated under TSCA. New chemicals have additional requirements under TSCA. \item transfer a chemical substance to another lab outside your own (on campus or to another facility in the US) you need to determine if the chemical substance is regulated under TSCA. If it is, and little to nothing is known about the environmental and/or health effects of that chemical substance, then TSCA requires you to warn other users of that fact. Labeling requirements for containers also apply. \end{itemize} {\em Transfers/Shipments of Chemicals within the US and Chemical Information Sheets} for risk notification are also critical components of the program. These last two requirements also dovetail with the hazard communication requirements of the OSHA Laboratory Standard, 29 CFR 1910.1450 (Chemical Hygiene Plan) and DOT shipping requirements for dangerous and hazardous goods, 49 CFR 173-179. Specific instructions and forms for developing a TSCA compliance file are available from the EHS Office. If you have specific questions on how your project may be affected by TSCA, please contact the Chemical Hygiene Officer or EHS Coordinator or contact the EHS Office at 2-3477. \pagebreak \part{General Chemical Safety} \section{Chemical Safety Overview} Part II of this Chemical Hygiene Plan provides MIT laboratory personnel with information regarding hazardous chemicals that may be present in the laboratory and appropriate work practices, procedures and controls to protect laboratory workers from those hazards. Hazardous chemicals can cause harm when they enter the body in sufficient amounts via inhalation, ingestion, injection, or skin absorption. Harmful effects can also occur by eye or skin contact alone. The nature of the hazardous chemical and the routes by which it enters or contacts the body determine the type of controls that are needed. The Occupational Safety and Health Administration (OSHA) and other organizations have set occupational exposure limits on airborne chemical exposure. Keeping exposures below these limits is generally believed to protect employees and students. Permissible Exposure Limits (PELs) set by OSHA are at \url{http://www.osha-slc.gov/SLTC/pel/index.html}. Threshold Limit Values (TLVs) established by the American Conference of Governmental Industrial Hygienists (ACGIH) can be obtained from the EHS office or purchased at \url{http://www.acgih.org/home.htm}. Regardless of the established exposure limit for a particular chemical, all laboratory workers should take steps to minimize chemical exposure via all routes of entry. OSHA recognizes that some classes of chemical substances pose a greater health and safety risk than others. To differentiate this different risk characteristic, OSHA identifies two categories of hazardous chemicals: hazardous chemicals and particularly hazardous substances. Particularly hazardous substances (PHSs) is a subset of hazardous chemicals that is regulated more stringently because they have been deemed to pose a substantially greater risk. Because of this, OSHA requires additional precautions and procedures be undertaken when particularly hazardous substances are used in the laboratory. This Chemical Hygiene Plan provides two sets of standard operating procedures, one for hazardous chemicals (Section~\ref{sec:hazardous}) and one for particularly hazardous substances (Section~\ref{sec:particularly_hazardous}). Four methods are used to limit chemical exposure for all types of chemicals: \begin{itemize} \item Chemical elimination or substitution; \item Administrative controls; \item Engineering controls; and \item Personal protective equipment (PPE). \end{itemize} \subsection{Chemical Elimination or Substitution} The first step in evaluating a new experiment, process or operation is to investigate the possibility of eliminating the use of hazardous materials or substituting a less hazardous material. For example, instead of using an organic solvent or chromic acid based material for washing glassware, one should substitute an aqueous based detergent. Aromatic compounds (i.e., benzene) and chlorinated hydrocarbons (i.e., methylene chloride) in some experiments should be replaced with aliphatic compounds or nonchlorinated hydrocarbons, if possible. The particular process, experiment or operation may also be modified to reduce the quantity of the hazardous material(s) necessary or limit the potential emission release rate or exposure time. For example, the use of microscale techniques may be applicable in measuring boiling points of a material. Another example is the substitution of closed systems for open vessels. The use of a secondary containment device such as a pan can be helpful in preventing or minimizing the effects of chemical spills. The Industrial Hygiene Program (2-3477) should be consulted for advice. \subsection{Administrative Controls} Administrative controls are policies and procedures for minimizing inhalation and physical contact exposures. This Chemical Hygiene Plan is the master administrative control. Specific administrative controls include: \begin{itemize} \item General safety procedures; \item Chemical use and procedure approval and/or review. \item Exposure monitoring and signage; \item Labeling; \item Environment, health and safety training, and information dissemination; \item Laboratory inspections by laboratory workers and supervisors; and \item Record keeping. \end{itemize} \subsection{Engineering Controls} Properly exhausted fume hoods, other local exhaust ventilation, glove boxes and other special purpose hoods must be used when there is a likelihood of excessive exposure to air contaminants generated by laboratory activity. Used in conjunction with good work practices, properly designed and operated exhaust ventilation is effective in minimizing inhalation exposure. \subsection{Personal Protective Equipment} The use of personal protective equipment (PPE) is necessary when feasible engineering and administrative controls are unavailable or if there is a need to supplement those controls. The following types of PPE are used to minimize inhalation and physical contact exposures: \begin{itemize} \item Eye and face protection: safety glasses, face shields, and chemical splash goggles. \item Protective clothing: lab coats, aprons and arm covers. \end{itemize} More detailed information on PPE is outlined below in Section~\ref{sec:ppe}. \subsection{General Principles} To provide for the safety of the MIT community and to protect MIT and surrounding property from damage, the following general principles apply to all faculty, staff and students performing work in laboratories: \begin{itemize} \item {\bf Perform Hazard Assessment:} Prior to initiation of new experiments or procedures, assessment of potential hazards must be performed. Appropriate protective measures, including personal protective equipment and engineering controls, must be identified and implemented. Laboratories should develop process- or experiment-specific guidelines and protective procedures. \item {\bf Minimize Chemical Exposures:} Since few laboratory chemicals are without hazards, general precautions for chemical handling, storage and disposal should be implemented as outlined in Section~\ref{sec:hazardous} in all laboratories. Use of less hazardous materials, implementation of engineering controls whenever feasible, and use of personal protective equipment to avoid skin contact with or inhalation of chemicals is encouraged. \item {\bf Avoid Underestimation of Risk:} Even for substances with no known significant hazard, exposure should be minimized. For work with particularly hazardous substances, special precautions must be taken as outlined in Section~\ref{sec:particularly_hazardous}. It should always be assumed that the toxicity of a mixture would be more toxic than its most toxic component. All substances of unknown toxicity should be considered toxic. \item {\bf Provide Adequate Ventilation:} The best way to prevent exposure to airborne substances is to prevent their escape into the working atmosphere by using chemical fume hoods or other ventilation devices. \item {\bf Observe Established Standards:} The permissible exposure limits and threshold limit values established by OSHA and other organizations should be observed. Where a regulatory standard does not exist, other recognized exposure limits should be followed. \item {\bf Follow the Chemical Hygiene Plan:} Procedures described in this Chemical Hygiene Plan are designed to minimize or prevent exposure to hazardous chemicals. Implementation of the CHP should be a regular, continuing effort. \item {\bf Be Prepared for Accidents.} \end{itemize} \subsection{Standard Operating Procedures} \label{sec:sops} A Standard Operating Procedure (SOP) is a written set of instructions or guidelines that detail the uniform procedures to be followed routinely when carrying out a particular activity. The development and implementation of standard operating procedures for critical activities is a core component of promoting excellence in a laboratory and for ensuring a safe, healthy, and environmentally sound workplace. For these reasons, the development of SOPs is an essential administrative tool to be used in the laboratory. Not only are SOPs good practice, they are also required by the federal laws governing laboratory safety practices. The OSHA Laboratory Standard requires laboratories to have standard operating procedures that ensure the safe use of chemicals. This Chemical Hygiene Plan contains standard operating procedures for the safe use of two categories of chemicals: hazardous chemicals, and particularly hazardous substances (PHS). These two sets of standard operating procedures are contained in Sections~\ref{sec:hazardous} and \ref{sec:particularly_hazardous} respectively. These general safety procedures are designed to ensure basic levels of staff health and safety in the laboratory, for routine and common practices, uses, and chemicals. The OSHA Laboratory Standard requires that laboratories develop additional written standard operating procedures if the general SOPs of this Plan DO NOT adequately ensure the protection of personal health and safety, and the environment. If a particular chemical, activity, or usage falls outside of the general guidelines provided here, the laboratory must prepare written procedures that mitigate environment, health and safety risks. This is particularly applicable if a procedure requires detailed and specific guidance to avoid dangerous exposure or consequences. SOPs must be developed prior to initiating any of the particularly hazardous procedures. Guidelines and a template for preparing SOPs for these specialized, unique and/or particularly hazardous chemicals, practices, and uses are contained in Part III. of this Plan. A copy of all SOPs developed must be located in the laboratory spaces and available to all people in the laboratory. It is recommended that all additional SOPs be included in Part III of this Chemical Hygiene Plan. \section{Prior Approvals and Procurement} \subsection{DLC-Based Prior Approvals} \label{sec:dlc_approval} Prior approvals are required before work with certain hazardous materials in \DLC can commence. Researchers are required to obtain prior approval from the EHS Committee for work with chemicals in the following list: {\em Restricted Chemicals Requiring Prior Approval} \begin{itemize} \item hydrofluoric acid \item sodium azide \item ether \item PMSF \item formaldehyde \item benzene \item toluene \item xylene \item halogenated solvents \item strong acids or bases \end{itemize} Researchers intending to work with any of these restricted chemicals must prepare a plan to ensure for safe use including the development of standard operating procedures. Subsequently, these SOPs should be included in Part III of this Chemical Hygiene Plan and kept on file in the laboratory. \subsection{MIT-Wide Prior Approvals} The MIT Procurement Department through its Purchasing Policies and Procedures has established Institute-wide restrictions on the purchase of certain hazardous materials. These materials require pre-approval by authorized MIT agents prior to purchase. These materials include: \begin{itemize} \item Radioactive Materials \item Controlled Substances, such as drugs \item Hypodermic Needles and Syringes \item Ethyl Alcohol \item Certain Poisons \item Nitrous Oxide Gas \item Explosives \item Liquid Petroleum Gases \item Certain Biological Materials \end{itemize} Detailed information on the purchase of these materials can be found on the Procurement Departments website at \url{http://web.mit.edu/purchasing/pol&proced/4.1.pdf}. For more information on the registration and use of restricted biological materials, please visit the EHS Office website. \subsection{Purchase of Large Chemical Quantities} MIT discourages the practice of bulk ordering of chemicals that reduces the chemical cost per unit volume. Although bulk orders can save individual DLCs money in the short-term, in the long run, the cost of disposal of unused chemicals can far outweigh any savings from the bulk order. The following points should be addressed to determine the proper volume of any chemical to order. Consider the following when placing an order: \begin{itemize} \item Investigate if there is a less hazardous substitute that can be used to achieve the same results. This could reduce the hazards involved in the process as well as the waste disposal costs. \item Order only the amount likely to be used for its intended purpose within the specified shelf life of the material and within the planned timeframe of the procedure. This can minimize chemical waste if processes or research changes and previously purchased chemicals are no longer needed. Although many chemicals can be safely stored over long periods of time, decomposition can result in explosions, ruptured containers and the formation of hazardous by-products. \item Evaluate the chemical properties that may preclude long-term storage before the chemical quantity to be ordered is decided. \item Order only the quantity that will fit into the appropriate storage area(s). Storing excess chemicals in a fume hood or outside adequate storage facilities will create other hazards. \item Request that the chemical vendor package the material in smaller containers on large orders and request that stock be delivered on an as needed basis. This is particularly useful when one lot or a special blend is required. \item Consult laboratory chemical inventory lists, if available, before ordering additional stock. \item Manage the stock so that the oldest materials are used first. \item Obtain the adequate quantity and type of spill control material available to contain the maximum possible spill. \end{itemize} If you need assistance in making a determination on the most appropriate quantity of chemical to purchase, please contact the EHS Office at 2-3477. \subsection{Purchase of Non-Returnable Gas Cylinders} The purchase of non-returnable gas cylinders should be avoided. All gas cylinders should be returned to the supplying vendor when their use is completed. All non-returnable cylinders will have to be disposed of as hazardous waste, and the cost of doing so will be charged to the DLC. ``Lecture bottles'' are often considered non-returnable by the vendor. However, MIT has an agreement with their preferred chemical vendor, BOC Group, to take back non-returnable gas cylinders, including lecture bottles that where purchased through them. Contact BOC Group on-campus directly at 3-4761 for more information. \section{Hazardous Chemicals} \label{sec:hazardous} \subsection{Classification of Hazardous Chemicals} Many of the substances encountered in the laboratory are known to be toxic or corrosive, or both. Compounds that are explosive and/or are highly flammable pose another significant type of hazard. New and untested substances that may be hazardous are also frequently encountered. Thus, it is essential that all laboratory workers understand the types of toxicity, recognize the routes of exposure, and are familiar with the major hazard classes of chemicals. The most important single generalization regarding toxicity in chemical research is {\em treat all compounds as potentially harmful, especially new and unfamiliar materials, and work with them under conditions to minimize exposure by skin contact and inhalation}. When considering possible toxicity hazards while planning an experiment, it is important to recognize that the combination of the toxic effects of two substances may be significantly greater than the toxic effect of either substance alone. Because most chemical reactions are likely to contain mixtures of substances whose combined toxicities have never been evaluated, it is prudent to assume that mixtures of different substances (e.g., chemical reaction mixtures) will be more toxic than the most toxic ingredient contained in the mixture. Furthermore, chemical reactions involving two or more substances may form reaction products that are significantly more toxic than the starting reactants. The OSHA Laboratory Standard (29 CFR 1910.1450) defines a {\bf hazardous chemical} as ``a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term `health hazard' includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, and agents which damage the lungs, skin, eyes, or mucous membranes''. Highly flammable and explosive substances comprise a category of hazardous chemicals. The major classes of hazardous chemicals are discussed in further detail below. {\bf Particularly hazardous substances} are addressed in Section~\ref{sec:particularly_hazardous}. \subsubsection{Possible Carcinogens} Carcinogens are chemical or physical agents that cause cancer. Generally they are chronically toxic substances; that is, they cause damage after repeated or long-duration exposure, and their effects may only become evident after a long latency period. Chronic toxins are particularly insidious because they may have no immediate apparent harmful effects. For a large number of compounds there is limited evidence of carcinogenicity from studies involving experimental animals. These compounds should be handled using the general procedures for work with hazardous substances outlined in Section~\ref{sec:sop_hazardous}. Certain {\bf select carcinogens} are classified as ``particularly hazardous substances'' and must be handled using the special precautions described in Section~\ref{sec:particularly_hazardous}. Select carcinogens include compounds for which there is evidence from human studies that exposure can cause cancer. It is important to recognize that some substances involved in research laboratories are new compounds and have not been subjected to testing for carcinogenicity. Always keep in mind that as a general rule, all new and untested compounds should be regarded as being toxic substances. \subsubsection{Corrosive Substances} Corrosive substances cause visible destruction of, or visible alterations in, living tissue by chemical action at the site of contact. Major classes of corrosive substances include strong acids (e.g., sulfuric, nitric, hydrochloric, and hydrofluoric acids), strong bases (sodium hydroxide, potassium hydroxide, and ammonium hydroxide), dehydrating agents (sulfuric acid, sodium hydroxide, phosphorus pentoxide, and calcium oxide), and oxidizing agents (hydrogen peroxide, chlorine, and bromine). \subsubsection{Irritants} Irritants are defined as non-corrosive chemicals that cause reversible inflammatory effects on living tissue by chemical action at the site of contact. A wide variety of organic and inorganic compounds are irritants and consequently skin contact with all laboratory chemicals should always be avoided. \subsubsection{Toxic and Highly Toxic Agents} For many chemicals, the health effects in humans may not have been tested. Frequently, only basic animal testing has been done, such as the LD$_50$ or the LC$_50$. The LD$_50$ is the Lethal Dose that kills 50 percent of the animals when the chemical is given orally or applied to the skin. The LC$_50$ is the Lethal Concentration in air that kills 50 percent of the animals. OSHA regulations (29 CFR 1910.1200) define toxic and highly toxic agents as substances with median lethal dose (LD$_{50}$) values as given in Figure~\ref{fig:toxic}. \begin{figure} \begin{tabular}{lll} &{\bf Toxic} & {\bf Highly Toxic}\\ Oral LD$_{50}$ (albino rats) &50-500 mg/kg & $<$50 mg/kg\\ Skin Contact LD$_{50}$ (albino rabbits) &200-1000 mg/kg&$<$200 mg/kg\\ Inhalation LC$_{50}$ (albino rats) &200-2000 ppm/air&$<$200 ppm/air \end{tabular} \caption{Definitions of ``Toxic'' and ``Highly Toxic'' agents.\label{fig:toxic}} \end{figure} It is important to note that the above classification does not take into consideration chronic toxicity (i.e. carcinogenicity and reproductive toxicity). Also, note that LD$_{50}$ values vary significantly between different species, and the human toxicity for a substance may be greater or less than that measured in test animals. In evaluating the {\bf acute toxicity} of chemical substances, the HMIS (Hazardous Materials Identification System) rating criteria developed by the National Paint and Coatings Association may be helpful. HMIS numbers can often be found in MSDS's. LD$_{50}$ values can be found in MSDS's and in references such as the {\em Sigma-Aldrich Library of Chemical Safety Data} and Patnaik's {\em A Comprehensive Guide to the Hazardous Properties of Chemical Substances}. (See Figure~\ref{fig:ratings}). \begin{sidewaysfigure} \begin{tabular}{ccccccc} \hline {\bf Hazard} & {\bf HIMS \#} & {\bf Rating} & {\bf Oral LD$_{50}$} & {\bf Skin Contact LD$_{50}$}& {\bf Inhalation} & {\bf LC$_{50}$ (Rats)}\\ {\bf Level} & & & {\bf (Rats, per kg)} & {\bf (Rabbits, per kg)} & {\bf (ppm for 1 h)} & {\bf (mg/m$^3$ for 1 h)}\\ \hline {\bf High} & 4 & {\em Extremely Toxic} & $<1$~mg & $<20$~mg & $<20$ & $<200$\\ (Poison) & 3 & {\em Highly Toxic} & $1-50$~mg&$20-200$~mg& $20-200$& $200-2,000$\\ \hline {\bf Medium} & 2 & {\em Moderately Toxic} & $50-500$~mg & $200$~mg - 1~g & $200-2,000$& $2,000-20,000$\\ (Harmful)\\ \hline {\bf Low} & 1 & {\em Slightly Toxic} & 500~mg - 5~g & 1-5~g & $2,000-20,000$ & $20,000-200,000$\\ & 0 & {\em Practically non-toxic} & $>5$~g & $>5$~g & $>20,000$ & $>200,000$\\ \hline \end{tabular} \caption{Definitions of the toxicity ratings for hazardous chemicals. \label{fig:ratings}} \end{sidewaysfigure} \subsubsection{Hazardous Substances with Toxic Effects on Specific Organs} Substances included in this category include (a) hepatotoxins (substances that produce liver damage such as nitrosamines and carbon tetrachloride); (b) nephrotoxins (agents causing damage to the kidneys such as certain halogenated hydrocarbons), (c) neurotoxins (substances which produce their primary toxic effects on the nervous system such as mercury, acrylamide, and carbon disulfide), (d) agents which act on the hematopoietic system (such as carbon monoxide and cyanides which decrease hemoglobin function and deprive the body tissues of oxygen), and (e) agents which damage lung tissue such as asbestos and silica. \subsubsection{Sensitizers} A sensitizer (allergen) is a substance that causes exposed people to develop an allergic reaction in normal tissue after repeated exposure to the substance. Examples of allergens include diazomethane, chromium, nickel, formaldehyde, isocyanates, arylhydrazines, benzylic and allylic halides, and many phenol derivatives. \subsubsection{Flammable and Explosive Substances} A number of highly flammable substances are in common use in campus laboratories. Explosive substances are materials that decompose under conditions of mechanical shock, elevated temperature, or chemical action, with the release of large volumes of gases and heat. \subsection{Risk Assessment for Hazardous Chemicals} The following outline provides a summary of the steps that laboratory workers should use to assess the risks of handling hazardous chemicals. Note that if a Laboratory Chemical Safety Summary is not already available, then following the protocol outlined here should enable a worker to prepare their own LCSS. For a detailed discussion of how to evaluate hazards and assess risks in the laboratory, see Chapter~3 of {\em Prudent Practices in the Laboratory} (National Academy Press, Washington D. C., 1995). \subsubsection{Identify Chemicals to be Used} Identify the chemicals involved in the proposed experiment and determine the amounts that will be used. Is the experiment to be done once, or will the chemicals be handled repeatedly? Will the experiment be conducted in an open laboratory, in an enclosed apparatus, or in a fume hood? Is it possible that new or unknown substances will be generated in the experiment? Are any of the workers involved in the experiment pregnant or likely to become pregnant? Do they have any known sensitivities to specific chemicals? \subsubsection{Consult Sources of Information} Consult an up-to-date LCSS for each chemical involved in the planned experiment (examine an up-to-date MSDS if an LCSS is not available). In cases where substances with significant or unusual potential hazards are involved, it may also be advisable to consult additional more detailed references such as NIOSH/OSHA Guidelines, Patnaik, Patty's, and other sources discussed above. Depending on the researcher's level of experience and the degree of potential hazard associated with the proposed experiment, it may also be necessary to obtain the assistance of supervisors and safety professionals before proceeding with risk assessment. \subsubsection{Evaluate Type of Toxicity} Use the above sources of information to determine the type of toxicity associated with each chemical involved in the proposed experiment. Are any of the chemicals to be used acutely toxic or corrosive? Are any of the chemicals to be used irritants or sensitizers? Will any select carcinogens or possibly carcinogenic substances be encountered? For many substances, it will be necessary to consult a listings of carcinogens to identify chemical similarities to known carcinogens. Are any chemicals involved in the proposed experiment suspected to be reproductive or developmental toxins, or neurotoxins? \subsubsection{Consider Possible Routes of Exposure} Determine the potential routes of exposure for each chemical. Are the chemicals gases, or are they volatile enough to present a significant risk of exposure through inhalation? If liquid, can the substances be absorbed through the skin? Is it possible that dusts or aerosols will be formed in the experiment? Does the experiment involve a significant risk of inadvertent ingestion or injection of chemicals? \subsubsection{Evaluate Quantitative Information on Toxicity} Consult the information sources to determine the LD$_{50}$ for each chemical via the relevant routes of exposure. Determine the acute toxicity hazard level for each substance, classifying each chemical as highly toxic, moderately toxic, slightly toxic, etc. For substances which pose inhalation hazards, take note of the TLV-TWA, STEL, and PEL values. \subsubsection{Select Appropriate Procedures to Minimize Exposure} All work involving chemicals in MIT laboratories should be conducted using the Standard Operating Procedures for Work with Hazardous Chemicals outlined in Section~\ref{sec:sop_hazardous}. In addition, laboratory workers must determine whether any of the chemicals to be handled in the planned experiment meet the definition of a particularly hazardous substance due to high acute toxicity, carcinogenicity, and/or reproductive toxicity. If so, consider the total amount of the substance that will be used, the expected frequency of use, the chemical's routes of exposure, and the circumstances of its use in the proposed experiment. Use this information to determine whether it is appropriate to apply the additional procedures for working with particularly hazardous substances outlined in Section~\ref{sec:particularly_hazardous}. For very toxic or hazardous substances, or specialized practices, consideration must be given to whether additional consultation with safety professionals and development of specialized SOPs is warranted. \subsubsection{Evaluate Hazards of Flammable and Explosive Substances} It should be noted that the risk assessment procedures described so far in this section address only the hazards due to the toxic effects of chemicals. Hazards due to flammability, explosion, and reactivity are equally important in risk assessment, and are discussed in Section~\ref{sec:flammable}. Sources of information should be consulted to evaluate the flammability, reactivity, and explosability of each chemical involved in the proposed experiment, and appropriate steps to minimize risks should then be taken. \subsubsection{Prepare for Contingencies} Note the signs and symptoms of exposure to the chemicals to be used in the proposed experiment. Note appropriate measures to be taken in the event of exposure or accidental release of any of the chemicals, and in the event of a fire. \subsection{SOP for Hazardous Chemicals} \label{sec:sop_hazardous} Literally thousands of different compounds are involved in the research being conducted in campus laboratories. The specific health hazards associated with many of these compounds are unknown, and many substances are new compounds which have not been reported previously in the chemical literature. Consequently it is impossible in this Chemical Hygiene Plan to provide standard operating procedures for specific hazardous substances. Instead, this section outlines general procedures which should be employed in the use of all hazardous substances. Individual research groups may wish to supplement these general procedures with standard operating procedures for handling specific hazardous substances that are in frequent use in their laboratories. Several general principles apply to all work conducted in the laboratories involving hazardous substances. \begin{itemize} \item {\bf Preparation.} A cardinal rule of laboratory research is that workers must determine the potential hazards associated with an experiment before beginning it. Before working with any chemical, it is the responsibility of the researcher to determine what physical and health hazards are associated with the substance. This determination may require consulting library references and material safety data sheets, and may involve discussions with the laboratory supervisor and Industrial Hygiene Program. \item {\bf Minimize exposure to chemicals.} All skin contact with chemicals in the laboratory should be avoided. Use laboratory hoods and other ventilation devices to prevent exposure to airborne substances whenever possible (note that the use of hoods is {\em required} for work with many hazardous substances). \item {\bf Do not underestimate risks.} Assume that any mixture of chemicals will be more toxic than its most toxic component. All new compounds and substances of unknown toxicity should be treated as toxic substances. \item {\bf Be prepared for accidents.} Before beginning an experiment, know what specific action you will take in the event of the accidental release of any hazardous substances involved. Know the location of all safety equipment including fire extinguishers, fire blankets, eye washes, safety showers, spill carts and spill control materials, be familiar with the location of the nearest fire alarm and telephone, and know what telephone numbers to call in the event of an emergency. Know the location of the circuit breakers for your laboratory. \end{itemize} As indicated above, the majority of chemicals involved in research in laboratories must be considered to be ``hazardous substances''. In addition to the four general principles outlined above, the following procedures should be standard practice for all work involving the use of hazardous substances. \subsubsection{Eye Protection} MIT policy requires that all personnel, including visitors, wear eye protection at all times while in Institute laboratories. Eye protection is discussed in detail in Section~\ref{sec:eye_protection}. \subsubsection{Personal Apparel} Do not wear sandals or open-toed shoes or shoes made of woven material when working with hazardous substances. Confine long hair and loose clothing. Use suitable protective apparel including gloves as discussed in detail in Section~\ref{sec:ppe}. It is advisable to wear a laboratory coat when working with hazardous substances. This is particularly important when wearing clothing such as shorts, miniskirts, and T-shirts that leave a significant area of skin exposed. In some cases laboratory supervisors may identify situations where the use of lab coats or more protective apparel is mandatory. \subsubsection{Avoid Skin Contact and Ingestion of Hazardous Substances} Contact with the skin is a frequent mode of chemical injury. A common result of skin contact is localized irritation, but an appreciable number of hazardous substances are absorbed through the skin with sufficient rapidity to produce systemic poisoning. Avoid contact with hazardous substances by taking the following precautions: \begin{itemize} \item Wear gloves that are not permeable to the hazardous substances being used. \item Never use mouth suction to pipet chemicals or to start a siphon; a pipet bulb or aspirator should instead be used to provide vacuum. \item Never taste laboratory chemicals. \item Wash your hands with soap and water immediately after working with hazardous chemicals. \item Eating, drinking, smoking, gum-chewing, and applying cosmetics in laboratories where hazardous substances are in use is prohibited. Do not store food, beverages, cups, or other drinking and eating utensils in areas where hazardous chemicals are used or stored. \end{itemize} \subsubsection{Avoid Inhalation of Toxic Substances} Inhalation of toxic vapors, mists, gases, or dusts can produce poisoning by absorption through the mucous membranes of the mouth, throat, and lungs, and can seriously damage these tissues by local action. Inhaled gases or vapors may pass rapidly into the capillaries of the lungs and be carried into the circulatory system. This absorption can be extremely rapid. Procedures involving volatile toxic substances and those operations involving solid or liquid toxic substances that may result in the generation of aerosols should be conducted in a laboratory hood or other containment device. See Section~\ref{sec:hoods} for a detailed discussion of laboratory hoods. OSHA Permissible Exposure Limits (PELs) and American Conference of Governmental Industrial Hygienists Threshold Limit Values (TLVs) should be observed when working with hazardous substances for which PELs and TLVs have been established (see the ACGIH booklet in the Library of Lab Safety for tables of TLV values of laboratory chemicals). Never smell compounds of unknown toxicity. \subsubsection{Use and Maintenance of Equipment and Glassware} Good equipment maintenance is important for safe, efficient operations. Equipment should be inspected and maintained regularly. Servicing schedules will depend on both the possibilities and the consequences of failure. Maintenance plans should include a procedure to ensure that a device that is out of service cannot be restarted. Improper use of glassware is a frequent cause of injuries and accidents in the laboratory. \begin{itemize} \item Careful handling and storage procedures should be used to avoid damaging glassware. Always carefully inspect glassware for flaws and cracks before use. Damaged items should be discarded or repaired. \item Adequate hand protection should be used when inserting glass tubing into rubber stoppers or corks or when placing rubber tubing on glasshose connections. Tubing should be fire polished or rounded and lubricated, and hands should be held close together to limit movement of glass should fracture occur. The use of plastic or metal connectors should be considered. \item Glass-blowing operations should not be attempted unless proper annealing facilities are available. \item Vacuum-jacketed glass apparatus should be handled with extreme care to prevent implosions. Equipment such as Dewar flasks should be taped or shielded. Only glassware designed for vacuum work should be used for that purpose. \item Hand protection should be used when picking up broken glass. (Small pieces should be swept up with a brush into a dustpan). \item Broken glassware syringes, and other ``sharp objects'' must be disposed of properly. Such waste should be separated from other trash and stored for pickup in clearly marked containers labeled ``sharps''. \end{itemize} \subsubsection{Housekeeping} There is a definite relationship between safety and orderliness in the laboratory. The following housekeeping rules should be adhered to in all laboratories: \begin{itemize} \item Work areas (including floors) should be cleaned regularly. Do not allow trash to accumulate. \item Access to exits and safety equipment must not be obstructed. \item All gas tanks should be secured to walls or benches. \item Solvents should not be stored on the floor and large containers (more than 1 liter) must be stored below eye level (e.g. in cabinets). \item Chemical storage refrigerators should be defrosted periodically and should not be overcrowded. \end{itemize} \subsubsection{Work Conducted Outside Normal Hours} Researchers should avoid conducting work with hazardous substances when they are alone in the laboratory. When working alone, arrange with Campus Police or workers in other laboratories to check on you periodically. Some experiments are too hazardous to be conducted alone under any circumstances; it is the responsibility of researchers to consult with their supervisor to identify such particularly hazardous operations. Laboratory operations involving hazardous substances are sometimes carried out continuously or overnight. It is the responsibility of the researcher to design these experiments with provisions to prevent the release of hazardous substances in the event of interruptions in utility services such as electricity, cooling water, and inert gas. Laboratory lights should be left on and appropriate signs should be posted identifying the nature of the experiment and the hazardous substances in use. In some cases arrangements should be made for periodic inspection of the operation by other workers. Information should be left indicating how to contact you in the event of an emergency. \subsubsection{Children and Pets in Laboratories} Pet animals are not permitted in laboratories where hazardous substances are stored or are in use. It is urged that children not be permitted in laboratories. However, if they are allowed, they must be under the direct supervision of their parent or other qualified adult, and should only allowed to visit only for a brief period of time. \subsubsection{Storage of Hazardous Substances} Researchers should consult the EHS Office SOP on Chemical Storage and {\em Prudent Practices in the Laboratory} pp. 72--76 for a discussion of procedures for storing chemicals in laboratories. All procedures employed must comply with OSHA regulations. The following minimum guidelines must be adhered to: \begin{itemize} \item Access to all hazardous chemicals, including toxic and corrosive substances, should be restricted at all times. Specifically, these materials should be stored in laboratories or storerooms that are kept locked at all times that laboratory personnel are not present. In the case of unusually toxic or hazardous materials, additional precautions are advisable, such as keeping the materials in locked storage cabinets. Due to the unique design of the Stata Center, the locations of the laboratories, and the fact that most visitors would not be expecting the presence of hazardous chemicals in the building, additional access control is necessary. In particular, not only should the doors to the laboratory rooms 32-306, 32-308, and 32-322 be locked whenever possible, all doors to the ``neighborhood'' that includes these rooms should be locked and only accessible to those who have a need to enter the area. Reducing incidental and unnecessary foot traffic through the lab neighborhood area creates a safer environment for both researchers and visitors. In case of a building fire emergency, all doors should unlock, so that people can reac