United States
Environmental Protection
Agency
A.W. Breidenbach Environmental
Research Center ,
Cincinnati OH 45268
Toxic Substances
Control Manual
Policies and Regulations for
Control of Toxic Substances
in the Laboratory
FOR VOUR
SAFETY
DRINKING
IN LABORATORY AREA
PROTECTIVE
CLOTHING
REQUIRED
IN THIS AREA
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TOXIC SUBSTANCES CONTROL MANUAL
POLICIES AND REGULATIONS FOR CONTROL
OF TOXIC SUBSTANCES IN THE LABORATORY
A. W. BREIDENBACH ENVIRONMENTAL RESEARCH CENTER
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
CINCINNATI, OHIO 45268
August 1982
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FOREWORD
This manual was prepared by the Hazardous Materials Handling Guide-
lines Task Group of the Hazardous Materials Subcommittee to provide
laboratory personnel and supervisors a positive control program for the
safe use of toxic chemicals.
Policies, regulations and recommendations are in compliance with
Chapter 8 of the Environmental Protection Agency's Occupational Health
and Safety Manual entitled Laboratory Use of Toxic Substances. In
addition, the Task Group used a document from the Environmental Monitor-
ing Systems Laboratory in Las Vegas as a source of additional information
for the present manual.
A basis for positive control of toxics is presented although no
attempt is made to present specific solutions to all the variety of
problems and conditions that may arise in laboratory situations. Never-
theless, sufficient information is presented to enable users to incorpo-
rate adequate safety into experiments with toxic materials.
For assistance and information regarding the acquisition, safe
handling, use, storage, and disposal of toxic substances, contact the
Chief Safety Officer, George A. Bodmer, Room 201, St. Clair Building,
Extension 7269.
Hazardous Materials Handing Guidelines Task Group Members:
Richard A. Dobbs, Chairman
George A. Bodmer
Carl T. Rybak
Stephen Billets
n
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Concurrence by AWBERC Officials:
Gerald Berg, Ph.D., Chairman
Hazardous Materials Committee
William A. Cawley, Moderator
Occupational Health & Safety Committee
David G. Stephan, Ph.D.
Senior Official, ORD
William A. Benoit, Director
Office of Administration
Robert L. Booth
Acting Director, EMSL
Richard J. Bull, Ph.D.,Director
Toxicology and Microbiology
Division, HERL
David G. Stephan, Ph.D.
Director, IERL
Francis T. Mayo
irector, MERL
L. A. Van Den Berg
Director, TSD
Jerry F- Stara, Ph.D.
Director, ECAO
Calvin 0. Lawrence
Director, CERI
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TABLE OF CONTENTS
Page
Foreword ii
Concurrence iii
I. Policy and Responsibilities
Policy 1
Purpose 1
Background 1
Prime Responsibilities 4
II. Health and Safety Program
Safety Plan 11
Inventory Control 11
Medical Surveillance 13
Records 14
Training 15
Audit . 17
III. Engineering Controls and Work Practices
Control Strategies 18
Requisitioning 23
Receiving 24
Packaging and Shipping 24
Disposal 25
Facility Requirements 26
Operational Practices 27
Personnel Practices 32
IV. Additional Requirements for Animal Experiments 37
IV
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TABLE OF CONTENTS (cont'd)
Page
V. Emergency Procedures
Minor Spills Involving Minimal Toxic Hazards to Personnel . . 39
Major Spills Involving Toxic Hazards to Personnel 40
Accidents Involving Dust, Mists, Fumes, Organic Vapors & Gases 41
Fires and Other Emergencies 42
First Aid 43
APPENDIX
A. Controlled Toxic Substances 45
1. NIOSH's Registry of Toxic Effects of Chemical
Substances 46
2. Carcinogen Assessment Group's List of Carcinogenicity . . 47
3. OHSA's List of Regulated Carcinogens 53
B. Toxic Substance Safety Plan 54
C. Occupational Health and Safety Staff, Laboratory Directors,
and Toxic Substances Committee Members 58
D. Toxic Substance Chemical Inventory, Running Inventory
Sheets, and Toxic Chemical/Environmental Sample Log Sheet . . 60
E. Periodic Health Assessment 63
F. Location of Carcinogen Dilution Laboratory and
Limited Access Areas 65
G. Packaging, Marketing, Labeling, and Shipping of Toxic
Substances Used by Laboratories 66
H. Primary Containment Equipment 70
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TOXIC SUBSTANCES CONTROL MANUAL
I. POLICY AND RESPONSIBILITIES
A. POLICY
The U.S. Environmental Protection Agency is committed to providing
S6fe and healthful working conditions in laboratories where toxic sub-
stances are used. This Manual was prepared as part of a program to ensure
a safe and healthful work environment in areas where toxic substances are
used or stored. An additional objective is to prevent or minimize the
release of toxic substances to the environment.
B. PURPOSE
This Manual establishes policy, responsibilities, and procedures for
the conduct of the Agency occupational health and safety program for the
laboratory use of toxic substances. Specifically, (1) it defines the
responsibilities of all personnel involved in the use of toxic substances,
(2) it details health and safety program requirements, (3) it describes the
work practices and engineering controls that must be used in all labora-
tories, and (4) it provides guidelines necessary for carrying out these
responsibilities.
C. BACKGROUND
Executive Order 12196, 29 CFR 1960, and Chapter 8 of the EPA Occupa-
tional Health and Safety Manual requires the EPA to provide safe and
healthful working conditions for its employees. The EPA is responding to
this requirement with an adaptation of the U.S. Department of Health and
Human Services' Laboratory Use of Chemical Carcinogens, NIH Publication No.
81-2385, May 1981.
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An interagency subcommittee, which included an EPA representative,
developed the Department of Health and Human Services' Guidelines. The
control measures given in the Guidelines consist of the laboratory work
practices and engineering controls necessary to protect laboratory
workers from exposure to carcinogenic (or other highly toxic) substances.
In addition, the Guidelines provide alternative control measures which
are less demanding for low risk situations and more demanding for high
risk situations.
1. Basis of the Guidelines. The Guidelines are based on the
assumption that any exposure to a chemical carcinogen, regardless of how
small, carries some risk. While complete elimination of exposures is
the ideal objective, this is not always obtainable. However, the potential
for exposures must be reduced to the lowest practicable level.
The application of these Guidelines to a specific laboratory activ-
ity must be based on the judgment of the Principal Investigator, who is
responsible for the safety of his or her laboratory operations. No set
of guidelines can be applied uniformly to every situation. It is imper-
ative, therefore, that the Principal Investigator assess those variables
peculiar to each planned activity in establishing appropriate safeguards.
Variables that require specific attention include (1) toxicity, (2)
quantity of the toxic substance to be used, (3) physical and chemical
properties of the agent, and (4) the type of experimental procedures
in which the toxic substances will be used.
2. Substances Considered Toxic. A toxic substance is any material
which can produce injurious or lethal effects on contact with the body
and so present an environmental health hazard. Such substances may be
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solids, liquids, or gases, including fumes, mists, and vapors. Of
special concern are those substances that exhibit acute toxicity and
those that have known or suspected carcinogenic, mutagenic, or terato-
genic potential. Specifically included in the definition of toxic
substances are environmental samples containing, or suspected of con-
taining, any of these substances.
Toxicity is relative and refers to harmful effects on biological
mechanisms. The term relative toxicity is commonly used in comparing
the harmful effects of one chemical or physical agent with another.
Toxicity is the inherent potency of a material or combination of materials
to produce biological injury or harm. The hazard is the possibility
that the material will cause injury when a specific amount is used under
specific external conditions. Control of exposure still remains the
most effective means of preventing injury from hazardous chemicals.
Substances considered toxic for purposes of this Manual are listed
in Appendix A. The Appendix consists of three separate parts as described
below and includes substances exhibiting chronic and acute toxicity.
The ultimate criterion in this Manual for classifying a substance as
toxic is the degree of hazard that the substance may pose to the health
of laboratory employees. Since persons, in addition to the Director,
Occupational Health and Safety Staff (OHSS), may make this determination,
the Manual includes the sources of the lists and selection criteria for
reference. The lists, which may be added to locally, will be up-dated by
the Director, OHSS, at least annually. The three parts include:
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a. Selected compounds from the National Institute for
Occupational Safety and Health's Registry of Toxic
Effects of Chemical Substances.
b. Carcinogen Assessment Group's List of Carcinogens.
c. Occupational Safety and Health Administration's
List of Regulated Carcinogens.
D. PRIME RESPONSIBILITIES
The following are responsibilities imposed by Executive Order 12196,
29 CFR 1960, and Chapter 8 of the EPA Occupational Health and Safety Manual.
1. Assistant Administrators(AA) and Regional Administrators(RA)
Assistant and Regional Administrators are responsible for developing
and implementing a health and safety program for laboratories under their
organizational jurisdiction which use toxic substances. AA's and RA's
must coordinate the development of their health and safety program with
the Director, OHSS, and must submit their health and safety programs to
the Director for review to assure consistency of these programs throughout
the EPA.
The AA for the Office of Administration (OA), as the Designated
Agency Safety and Health Official, is responsible for administering the
EPA's health and safety programs for laboratory use of toxic substances.
The AA for OA must ensure the allocation of adequate resources in the
EPA's Zero Base Budget to support and monitor these programs and must
identify, with designated object class codes, the resources as required
by OMB Circular No. A-ll.
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2. Laboratory Directors
Each Laboratory Director is responsible for implementing the health
and safety program for the laboratory use of toxic substances at their
reporting unit. (See EPA Occupational Health and Safety Manual, Chapter
1, paragraph 5, for a detailed description of health and safety responsi-
bilities). The Laboratory Director is charged with assuring that any
Principal Investigator using toxic substances is qualified by training or
experience, has the equipment and facilities to handle the materials safe-
ly, and proposes a use which is safe to all concerned. The Laboratory
Director is also responsible for assuring the completion of semi-annual
program reviews and audits.
3. The Toxic Substances Committee
The Toxic Substances Committee by order of the Senior ORD official
(ref: see below) is responsible for aiding and advising the Laboratory
Directors on employee health and safety matters and policies and pro-
cedures for the Agency occupational health and safety program for handling
toxic substances in the laboratory. (See EPA Occupational Health and
Safety Manual, Chapter 5, paragraph 4, for a detailed description of the
health and safety responsibilities). The Committee should include or have
access to individuals who possess expertise in chemistry, toxicology,
medicine, engineering, and laboratory safety.
In managing the toxic substances program the Toxic Substances Committee:
a. Reviews and approves Safety Plans prepared by each Principal
Investigator and forwards plans and protocols to the Chief
Safety Officer.
(Memorandum dated January 11, 1978, "Occupational Health and Safety Committee.
D. G. Stephan and W. J. Benoit).
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b. Develops appropriate and timely policies and guidelines to assure
the safety of EPA personnel and protect the general public from
exposures to toxic substances. Such policies and guidelines are
designed on the premises that
. no unwarranted restrictions will be imposed on project operations
or on the selection and use of any type or amount of toxic substance(s);
and
. all means of preventing contamination of equipment and facilities
used in low level experiments will be taken.
c. Advises the Laboratory Directors on proposed use(s) of toxic
substances prior to the acquisition or use of such substances.
d. Acts as a Review Board in matters of health and safety as related
to use of toxic substances and advises the Laboratory Directors
on approval/disapproval of proposed projects in which these
materials are to be used.
e. Acts as a Board of Inquiry in toxic substances spills and
accidents that result in exposures. (The Committee may
investigate accidents irrespective of exposure potential.)
f. Advises the Laboratory Directors on specific programs for Health
Surveillance.
4. Chief Safety Officer
The Chief Safety Officer, appointed by the Director of Administration,
provides advice and assistance to the Laboratory Directors in developing,
organizing, directing, and evaluating their health and safety programs for
laboratory use of toxic substances. In addition, the Chief Safety Officer
must:
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a. Approve all requisitions for toxic materials and ensure that an
approved Toxic Substance Safety Plan is available and a Material
Safety Data Sheet accompanies the requisition.
b. Maintain inventories of specified toxic and hazardous materials.
c. Coordinate the reporting of any accident involving exposure
(inoculation, ingestion, dermal contact, or inhalation) to a
toxic substance, in accordance with the procedures detailed
in Chapter 3 of the Occupational Health and Safety Manual.
In addition, a copy of this type of accident report must be
incorporated in the employee's medical record.
d. Coordinate record keeping and medical monitoring programs.
e. Serve on Toxic Substances Committee.
f. Establish a system for safe disposal of toxic substances and
contaminated residues.
g. Keep Laboratory Safety Officers informed of bulletins and special
programs issued by the OHSS.
5. Laboratory Safety Officer
The Laboratory Safety Officer, appointed by the individual Laboratory
Directors, serves as a member of the Toxic Substances Committee and in
this capacity has the primary responsibility for carrying out the essential
features of the toxic substances control program at the laboratory level.
Thus, he:
a. Ensures overall safety in the handling and use of toxic substances.
b. Enforces regulations and policies in all matters pertaining to
toxic substances.
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c. Maintains records on inventory and history of all toxic sub-
stances from time of arrival to final disposition.
d. Supervises disposal of all toxic substances and wastes.
e. Directs and assists in survey and decontamination activities
required following an uncontrolled release or accident.
f. Maintains and posts current list of personnel authorized access
to controlled limited access areas.
g. Makes documented inspections of storage and working areas to
ensure compliance with established procedures.
h. Coordinates accident reporting and record keeping.
i. Distributes manuals, pamphlets, and memoranda to personnel as
required on toxic substances practice and procedures and main-
tains the timeliness of such information by referral to current
periodicals, Chemical/Environmental Log Sheets, and the literature.
6- Principal Investigator
The Principal Investigator on a project in which toxic substances
are used:
a. Prepares a written Safety Plan for all projects prior to the
use of toxic substances. (See Appendix B for details of the
Toxic Substance Safety Plan.)
b. Selects work practices and engineering controls for handling
toxic substances.
c. Submits the Safety Plan to the immediate Supervisor, Chief Safety
Officer, Laboratory Director, and Toxic Substances Committee for
approval.
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d. Makes available to program and support staff copies of the
appoved Safety Plan.
e. Assures that the program and support staff (including mainte-
nance and housekeeping personnel) are instructed in procedures
to avoid accidental exposure to toxic substances.
f. Supervises the safety performance of the staff to ensure that
the required laboratory practices and engineering controls are
employed.
g. Arranges for immediate medical attention and reports to the
Chief Safety Officer any accident that results in (1) inoculation
of toxic substances through cutaneous penetration, (2) ingestion
of toxic substances, (3) probable inhalation of toxic substances,
or (4) any incident causing overt exposure to personnel or danger
of environmental contamination by toxic substances.
h. Cooperates in the occupational program on medical surveillance
activities.
i. Reports to the Laboratory Safety Officer the location of work
areas where toxic substances will be used, provides a current
listing of personnel authorized to work in these areas, and
provides a current inventory of working quantities of toxic
substances that will be kept in these areas.
j. Assists the Chief Safety Officer in investigating accidents.
k. Investigates and reports in writing to the Chief Safety Officer
problems pertaining to operation and implementation of laboratory
practices and engineering controls.
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1. Corrects work errors and conditions that may result in the
release of toxic substances.
7. EPA Employees
Each employee is responsible for complying with the health and
safety program established by this Manual on the laboratory use of toxic
substances. Each employee shall report to his/her supervisor any unsafe
condition and all facts pertaining to accidents which result in employee
exposure to toxic substances.
8. Director, Division of Occupational Health and Safety
Under the supervision of the Assistant Administrator for Administration
the Director, OHSS, is responsible for reviewing and coordinating the
health and safety programs developed for laboratory, use of toxic sub-
stances for consistency with this Manual. The Director also audits the
laboratories for compliance with their health and safety program, informs
the responsible EPA official of any problem areas, annually updates the
lists of toxic substances presented in Appendix A, provides technical
support, and approves training courses. The Director, OHSS, is the top
technical advisor for EPA on health and safety for laboratory use of
toxic substances.
9. Other Responsibilities
The individuals specified above, and other individuals, have
responsibilities for this program which are described in relevant sections
of the balance of this Manual. (See Appendix C for names of individuals
specified above.)
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II. HEALTH AND SAFETY PROGRAM
A. SAFETY PLAN
The Toxic Substance Safety Plan is a principal means of control in
the use and disposition of toxic substances.
1. Prior to any project or operation involving a toxic substance
the Principal Investigator must prepare a Toxic Substance
Safety Plan. A sample plan is included as Appendix B.
2. The Toxic Substance Safety Plan must be reviewed by the
Laboratory Safety Officer.
3. Approval of the Safety Plan by the immediate Supervisor,
Laboratory Director, Chief Safety Officer, and Toxic Substances
Committee is required.
4. The Chief Safety Officer must maintain the Safety Plan on file
and make it available for distribution. A copy must be provided
to each employee using the toxic substance and an information
copy must be forwarded to the Director, OHSS, Washington, D.C.
(PM-273).
B. INVENTORY CONTROL
1. The Chief Safety Officer must approve all purchase requisitions
for toxic substances. Whenever possible, existing inventories
must be used in order to maintain a minimum of toxic substances
in storage. The Laboratory Director, after consulting with the
Chief Safety Officer, may add to the list of toxic substances
presented in Appendix A for his/her reporting unit. The
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Chief Safety Officer subsequently monitors and records the receipt,
transport, storage, use, and disposal of the newly listed toxic
substances. The Chief Safety Officer must update the inventory
at least semi-annually, and must obtain, maintain, and distribute
safety data sheets and other information needed to use toxic
substances safely.
2. The Laboratory Safety Officer must maintain records, to be up-
dated semi-annually, indicating all types and amounts of toxic
substances in storage and in use for the reporting unit. Semi-
annual reports of the inventory will be provided to the Chief
Safety Officer as a basis for a semi-annual report to the OHSS
for all of EPA-Cincinnati.
3. The Principal Investigator or other authorized user of a toxic
substance must maintain a continuous and current record of each
controlled substance in his/her possession from the time of
acceptance to its final disposition or depletion.
a. The Chief Safety Officer in cooperation with the
Laboratory Safety Officers will use this information
to produce an automatic inventory listing or a manual
system, depending on the number of entries for distri-
bution to the user/storage areas. Appendix D shows a
sample Toxic Substance Chemical Inventory Sheet and a
Toxic Substance Running Inventory Usage Sheet. An
initial inventory is prepared by using the Toxic
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Substance Inventory Sheet for all compounds listed
in Appendix A. A separate Toxic Substance Running
Inventory Usage Sheet is filled out for each toxic
compound. Inventory records and reports are based
on the current amount on hand as listed in the last
column of the usage sheet.
C. MEDICAL SURVEILLANCE
1. Preassignment Health Assessment
The Laboratory Director must ensure that a baseline health assess-
ment is provided to all employees who work with toxic substances or who
are assigned duties in work areas where toxic substances are regularly
used. These health assessments are provided under the EPA Medical
Monitoring Guidelines. The Laboratory Director, after consultation
with an occupational physician, the Chief Safety Officer, and the medical
monitoring coordinator, must also determine the necessity of providing
preassignment health assessments for employees who may be assigned
duties in work areas where small quantities of toxic substances are
infrequently used.
The purpose of this preassignment assessment is to establish a
baseline health record and, if evidence of preexisting or predisposing
conditions is found, to inform and counsel the employee on the inadvisa-
bility of working in areas where toxic substances are used. The pre-
assignment assessment will include a work history, a medical history,
and a physical examination, which includes customary laboratory studies
and agent-specific studies when appropriate.
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2. Periodic Health Assessments
The Laboratory Director must ensure that periodic health assessments
are provided to all employees who work with toxic substances or who are
assigned duties in work areas where toxic substances are regularly
used. The periodicity and content of these assessments must be deter-
mined after consultation with an occupational physician, the medical
monitoring coordinator, and the Principal Investigator.
The assessments will include an updating of the employee's work
and medical histories, including occurrences of any accidental exposures
previously unreported. The following information must be included in
the employee's medical record: names of toxic substances to which the
employees may have been exposed, information on the probability, frequency,
and extent of exposures, and any environmental measurements relating
to toxic substances that may have been made. The periodic health
assessment may also include a physical examination, biochemical or
other surveillance of body fluids, and an evaluation of pertinent
functional systems of the body. (See Appendix E.)
D. RECORDS
The EPA-Cincinnati Medical Services Staff, selected by the Director
of Administration, will maintain health assessment records during the
tenure of the employee's service with the Agency.
1. Upon termination, including retirement or death, of the
employee, the medical records will be maintained for at least
thirty (30) years after the employee's last work with toxic
substances, and in a manner that will ensure ready access as
needed by the health program of the Agency.
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2. Records that cannot be maintained locally will be placed in
custody of the Medical Monitoring Project Officer, OHSS,
Washington, D.C.
E. TRAINING
The Laboratory Director must ensure that all employees subject to
potential exposure to toxic substances are provided adequate health
and safety instruction and training.
1. The Principal Investigator, with assistance from the Laboratory
Safety Officer, the Chief Safety Officer, and the Toxic Substances
Committee, will ensure that laboratory workers receive adequate training
(followed by appropriate refresher courses annually) in the following
topics as applicable:
a. The possible sources of exposure to toxic substances
b. Carcinogenic and other adverse health effects associated
with such exposure
c. Work practice and engineering controls to limit exposures
d. Methods used to monitor control procedures and the health
status of employees
e. Responsibilities in proper work practices to protect fellow
employees
f. Types and functions of monitoring equipment such as personal
samplers
g. Medical monitoring methods, especially unusual procedures
such as sputum cytology and biologic monitoring of metabolites
in the urine
h. Benefits to persons participating in environmental and
medical monitoring programs.
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2. The Chief Safety Officer must obtain the approval of the Director,
OHSS, of the initial training and refresher courses and must issue a
certificate to employees upon completion of the courses.
3. The Chief Safety Officer and Principal Investigator (and, if
warranted, professional instructors on the subject) will train all
persons who work with or may be exposed to a specific toxic substance,
to enable them to work safely with and to understand the relative
significance of potential hazards as they relate personally. This
training will include:
a. The safe handling of the specific substance, including
emergency procedures
b. A non-technical summary of the nature and extent of
potential hazards, with periodic refresher review
c. A procedural review of an actual project in which the
discussed toxic substance will be used.
4. The Chief Safety Officer will instruct warehouse and stock-
room personnel in the safe handl-ing of toxic substances, including:
a. Special handling of containers to avert damage by dropping,
improper stacking, or inadequate environmental controls.
b. The possibility and effects of exposures.
c. Segregating chemicals into safe groupings during storage.
5. The Laboratory Director must ensure that employees identified
to respond to emergencies involving toxic substances receive additional
training, repeated at least annually, which includes directing general
evacuation, decontamination of uncontrolled releases of toxic substances,
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maintaining a respirator program at least equivalent to 29 CFR 1910.134,
using other personal protective equipment, first aid, and CPR.
6. The Chief Safety Officer must keep the Safety Plan, safety
data sheets, and other appropriate written information describing the
relevant toxic, physical, and chemical properties of toxic substances
used or stored in the laboratory, in a file that is continuously and
readily available to employees.
F. AUDIT
The Laboratory Director must ensure that semi-annual program reviews,
including inspections, of the health and safety program for laboratory
use of toxic substances are conducted by persons with appropriate back-
ground and training and that any deficiencies are corrected as soon as
possible (or immediately if the deficiency is an imminent hazard). The
Laboratory Director must forward a copy of the program review and abate-
ment actions to the Director, OHSS, for review. The Director, OHSS,
will conduct independent audits to evaluate compliance with the health
and safety program.
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III. ENGINEERING CONTROLS AND WORK PRACTICES
A. CONTROL STRATEGY
The purpose of this section is to describe situations in the
handling of toxic substances where different levels of safeguards are
specified to protect the laboratory worker. Any modification to the
laboratory practices and engineering controls described must be care-
fully considered and reviewed by the Principal Investigator, the Chief
Safety Officer, and the Toxic Substances Committee.
The hazard in working with toxic substances is a function of the
exposure potential and the toxicity of these substances. The risk of
exposure to a toxic substance is related, among other things, to the
quantity and physical properties of material used and the nature,
frequency, and complexity of the experimental procedure. There is a
greater risk of exposure when working with 100 mg of material than
with 1 mg of material. Similarly, the potential for exposure is greater
during blending, preparation of dry feed mixture, and in the manipulation
of powders than during the preparation of aliquots of stock solution.
The toxicity and carcinogenic potency are also important factors
in the selection of safeguards. For example, experimental data suggests
that the carcinogenic potency of aflatoxin Bl is magnitudes greater
than that of chloroform.
Based on the factors just discussed a three-level control system
will be used for laboratory operations at EPA-Cincinnati. Specific
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control practices for each laboratory operation will be spelled out in
detail in the individual Safety Plans submitted by the Principal Investi-
gator on a case-by-case basis. General guidelines which apply to all
projects for both use and storage of regulated substances will now be
defined for each list of compounds in Appendix A. The strategy for
control of specific toxic compounds is as follows:
COMPOUNDS RISK STORAGE USE
List 1 Low Low Laboratory Cabinet Unrestricted
List 2 intermediate Limited Access Area u«t"ft
Area
. . . 0 .... r- • n-n 4.- 0.1% w/w Concentration
List 3 High Carcinogen Dilution . . ., . ,, , ,, ,
s Module Limit in Non-controlled
Area
Concentrations in excess of those specified above require special written
approval from the Toxic Substances Committee.
Each control level will now be discussed in more detail.
1. Low Risk Situation
Safety during operations with compounds in this category can normally
be achieved by strict adherence to good laboratory practice. The labora-
tory worker must not eat, drink, smoke, chew gum or tobacco, apply cos-
metics, or store food in areas where the toxic substances are used or
stored. Hands must be washed following the completion of a procedure in
which toxic substances are used. The laboratory workers must develop
the habit of keeping hands away from mouth, nose, eyes, and face. A
fully fastened laboratory coat and gloves must be worn when handling
toxic substances. Mechanical pipetting aids must be used for all pipet-
ting procedures.
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Stock quantities of compounds must be maintained in a secured and
appropriate storage area when not in use. Locked laboratory cabinets,
labeled with a sign bearing the legend: CAUTION - TOXIC SUBSTANCE, are
required. Compounds controlled at this level are those contained on List 1
entitled "NIOSH's Registry of Toxic Effects of Chemical Substances".
(See Appendix A.)
2. Intermediate Risk Situation
More stringent safeguards are required for certain research investi-
gations that present higher risk situations than those subject to the
general requirements. More stringent requirements may also be required
for research activities that involve highly potent toxic substances. The
toxic substances and laboratory activities for which additional controls
are required will now be described.
Any laboratory operation involving the use of a compound contained
on the Carcinogen Assessment Group's (CA6) List of Chemicals Having
Substantial Evidence of Carcinogenicity (see List 2, Appendix A) requires
additional engineering controls.
a. Stock quantities of compounds in this category must be stored
in a limited access area. All weighing and dilution procedures
necessary to provide daily working quantities must be done by a
qualified person under controlled conditions in the limited
access area. Limited access areas are specially designed modules
for storage and use of toxic substances. These modules must be
locked at all times. Upon entering or leaving a limited access
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area a sign-in/sign-out record book must be signed by each
user. In addition, the facility must provide the following:
a laboratory hood, glove box, sink, refrigerator (explosion-
proof preferred), locked storage cabinets, an analytical
balance, mechanical pipetting aids, disposable laboratory
coats, and plastic or latex gloves. Location of all limited
access areas are listed in Appendix F.
b. The maximum allowable concentration permitted in non-controlled
areas is 1.0% by weight or volume.
c. Organic solvents on the CAG list are permitted in normal
laboratory modules for experimental purposes but not for
storage. The level of written approval required is based on
the quantity needed for laboratory operations as follows:
Principal Investigator <_1 Liter
Branch Chief <^5 Liters
Toxic Substances Committee <^5 Liters
d. The preparation of dilute solutions or the removal of small
amounts of a toxic substance from stock quantities must
always be performed within a laboratory fume hood or glove
box. The work surfaces of the hood must be covered with stain-
less steel or plastic trays, dry absorbent plastic-backed paper,
or other impervious material.
e. Each person using the "limited access area" must sign in and
sign out in a permanent log book posted inside the area.
f. Only persons with approved Safety Plans can use the "limited
access areas",
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3. High Risk Situations
All laboratory procedures that involve the use of an OHSA regulated
chemical carcinogen (see OSHA's List of Regulated Carcinogens, List 3,
Appendix A) require work practices and engineering controls in addition to
those previously discussed. These include: additional or more frequent
changes of protective clothing, shower facility and change room, use of
primary containment devices, work area access control, and monitoring for
environmental contamination resulting from certain laboratory operations.
Protective clothing such as disposable pants, shirts, jumpsuits, shoe and
head covers, and plastic and latex gloves must be worn as appropriate.
Showers are recommended after each exit from the work area.
Special facilities are required for handling carcinogens. The module
for carcinogen handling must have a separate hood exhaust and a glove box or
other completely closed containment system. Work areas must be separated by
a controlled access area from areas that are open to unrestricted traffic
flow. This controlled access area may be an anteroom, a change room, an air
lock, or any other door arrangement that separates the laboratory from areas
of unrestricted traffic flow. Areas which meet these requirements are
called Carcinogen Dilution Modules. EPA-Cincinnati has two modules that
meet the above requirements. (See Appendix F - Location of Carcinogen
Dilution Modules and Limited Access Areas). Laboratories which do not have
a Carcinogen Dilution Module must obtain permission from the appropriate
Laboratory Director for the use of the existing facilities or must construct
an equivalent facility of their own for laboratory operations that involve
the storage or handling of any OSHA regulated chemical carcinogens.
Additional requirements and considerations for the high risk situation
include the following:
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a. Stock quantities of toxic substances must be the minimum quantity
required for efficient use; the primary containers must be stored
in an unbreakable outer container. Containers may consist of
plastic-coated glass bottles with polypropylene caps, both of
which can satisfy a 4-foot drop test.
b. The maximum allowable concentration of these materials permitted
in a non-controlled area is 0.1% by weight or volume.
c. Environmental monitoring may be required in work areas where the
potential of exposure to a known potent toxic substance is great.
An example of such an area might be a dry feed mixing operation
where a large amount of the toxic substance is handled in an
activity that can produce significant'amounts of aerosol.
B. REQUISITIONING
The following procedures reflect Office of Research and Development
procedures and Toxic Substances Committee recommendations for controlling
toxics substances:
1. To requisition toxic chemicals, complete Standard Form EPA-
1900-8 (Rev. 12/80).
2. Prior to authorizing the requisition by signing the EPA-1900-8
form, the Principal Investigator will ensure that an approved
Safety Plan is available for using the chemical and that the
chemical is not available from existing inventories.
3. The Program Administrative Officer will forward the requisition
to the Chief Safety Officer for final approval before the chemical
is ordered. Existing inventories should be checked prior to approv-
ing any requisition for toxic substances. Receiving warehouse
personnel will be informed of special handling procedures to be
used when the substance arrives.
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C. RECEIVING
Receipt of all toxic substances and/or samples delivered to EPA-
Cincinnati must be recorded on the Toxic Chemical/Environmental Sample
Log Sheet (see Appendix D). A copy of each Log Sheet will be forwarded
to the Chief Safety Officer at the end of each quarter.
1. Persons receiving or carrying toxic substances into the EPA-
Cincinnati facilities outside the normal shipping and mailing
channels will, immediately on arrival of such materials,
notify their Division Directors. The material must not be
opened or handled until inspected and logged by the appropriate
Division Director or Branch Chief or an authorized representative.
2. Prior to delivery to the requisitioner, any toxic substance
listed in Appendix A, must be inspected, logged, and approved
for dispersal by the Laboratory Safety Officer or designee.
a. Log-in entails recording the required information on the
Toxic Chemical/Environmental Sample Log Sheet.
b. Inspection entails removal of the toxic substance/sample(s)
from the shipping container, checking for evidence of
physical damage, leakage, or other possible external
contamination.
3. On release of the requested material, the material will be
placed in the proper storage area (as defined in Section III A).
D. PACKAGING AND SHIPPING
Toxic substances must be packaged to withstand shocks, pressure
changes, and any other conditions which might cause the leakage of
contents incident to ordinary handling during transportation.
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The transfer of any toxic substance or mixture of substances
from EPA-Cincinnati for any purpose shall meet the requirements for
monitoring, packaging and labeling of the U.S. Department of Transportation
(DOT), as described in Title 49, Code of Federal Regulations, and shall
be further in compliance with the regulations governing the shipment of
such materials as required by the Interstate Commerce Commission, Federal
Aviation Agency, Bureau of Explosives, U.S. Coast Guard, and as appro-
priate for the mode of transportation and recipient. For more extensive
detail see "Final National Guidance Package for Compliance with DOT
Regulations in the Shipment of Environmental Laboratory Samples" available
from Laboratory or Chief Safety Officer. (See Appendix G.)
E. DISPOSAL
All EPA-Cincinnati toxic wastes will be disposed of through a com-
mercial contract disposal agency.
1. Principal Investigators will arrange through the Laboratory
Safety Officer for disposal of toxic wastes resulting from
their projects. The Principal Investigator must:
a. Convert very hazardous wastes into lesser hazardous
substances, if possible, before placing them in
disposal containers. For example, oxidize strong
carcinogens in solution; neutralize acids; or moderate
reactions by dilution, cooling, or slow addition of a
neutralizing agent. For water-miscible materials,
pouring the reaction mixture onto a bed of ice can
often cool and dilute it.
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b. Promptly dispose of unlabeled containers and chemicals no
longer needed. We must not allow excess chemicals or
wastes to accumulate in the laboratory.
c. When a toxic substance listed in Appendix A, List 3, has
been used, decontaminate or dispose of all equipment,
residual labware, toweling, gloves, dishwater, and other
materials that have been in contact with the substance as
specified in the Safety Plan.
F. FACILITY REQUIREMENTS
1. Handwashing Facility. A handwashing facility must be available
within the work area. (This need not be a facility used exclusively for
handwashing). The use of liquid soap is recommended. In new facilities,
foot or elbow operated faucets should be provided.
2. Shower Facility. A shower facility, other than emergency drench
showers, must be located in the building in which toxic substances are
used. The shower facility must be available at all times. Shower
facilities adjacent to the work areas are highly recommended.
3. Eye Wash Facility. An emergency eye wash facility must be located
in each laboratory. The eye wash facility should be designed to wash
both eyes at the same time with a continuous stream of potable water.
4. Exhaust Air from Primary Containment Equipment. The exhaust air
from glove boxes must be treated by filtration, reaction, absorption,
adsorption, electrostatic precipitation or incineration, as appropriate,
depending on the nature of the compound. The need for, and type of,
treatment for other primary containment equipment, including laboratory
fume hoods and biological safety cabinets, must be determined by the
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Chief Safety Officer. Exhaust air treatment systems that remove toxic
substances from the exhaust air by collection mechanisms such as filtra-
tion, absorption,and adsorption must be serviced in a manner that avoids
direct contact with the collection medium. Trained maintenance employees
may remove the spent collection medium with a bag-in/bag-out collection
system or garbed in appropriate personal protective clothing and equip-
ment. All exhaust air from primary containment equipment must be dis-
charged by roof-mounted blowers to the outdoors so that such air is
dispersed clear of occupied buildings and air intakes.
5. Exhaust Ventilation. A mechanical exhaust ventilation system
must be provided for controlling laboratory room air movement. The
movement of air must be from areas of lower contamination potential to
areas of higher contamination potential (i.e., from entry corridors to
the laboratory). This directional air flow may be achieved by a common
building exhaust system, provided that the exhaust air is not recirculated
to any other area of the building. The exhaust air from laboratory areas
must be discharged outdoors in a way that entry into a building's air
supply is minimized. Exhaust air from laboratory areas which is not
derived from primary containment equipment can be discharged to the out-
doors without being treated.
G. OPERATIONAL PRACTICES
1. Work Area Identification. Entrances to all work areas where
toxic substances are being used or stored must be posted with signs
bearing the legend: "CAUTION - TOXIC SUBSTANCE - Authorized Persons
Only", followed by the name of Principal Investigator.
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2. Access Control. Work areas where toxic substances are used or
stored may be entered only by persons authorized by the Principal Investi-
gator. Access doors to work areas must be kept closed while experiments
with toxic substances are in progress.
3. Work Surfaces. All work surfaces (bench tops, hood floors, etc.)
on which toxic substances are used must be covered with stainless steel or
plastic trays, dry absorbent plastic-backed paper, or other impervious
material. The protective surfaces must be examined for possible contami-
nation immediately after each procedure with a toxic substance has been
completed. Contaminated surfaces must be decontaminated or disposed of
as described in the Safety Plan.
4. Use of Primary Containment Equipment. Procedures involving
volatile toxic substances and those involving solid or liquid toxic sub-
stances that may result in the generation of aerosols must be conducted
in a laboratory fume hood, a glove box, or other containment equipment
approved for toxic substances by the Chief Safety Officer. Examples
of aerosol-producing procedures are: the opening of closed vessels,
transfer operations, weighing, preparation of feed mixtures, and the
application, injection or intubation of a toxic substance into experi-
mental animals. Tissue culture and other biological procedures involv-
ing toxic substances may be conducted in a Class II Type A or B bio-
logical safety cabinet when approved by the Toxic Substances Committee.
(Personnel protection factors for Class II biological safety cabinets
have not yet been established; however, when installed with total
exhaust, these devices are currently acceptable for tissue cultures
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and other biological procedures involving toxic substances.) The selection
and use of a Class II biological safety cabinet for procedures involving
toxic substances must be a joint decision of the Principal Investigator
and the Chief Safety Officer. Primary containment equipment used for con-
tainment of toxic substances must display a label bearing the legend:
CAUTION-TOXIC SUBSTANCE. All bidding documents and installation plans for
primary containment equipment must be reviewed by Facilities Management and
Services Division prior to procurement. (See Appendix H for additional
information on primary containment equipment).
5. Use of Analytical Instrumentation. Toxic vapors or aerosols pro-
duced by analytical instruments must be captured through local exhaust
ventilation or appropriate trap at the site of their production. The
instruments may be placed entirely within a laboratory fume hood if this
will not impair hood performance (i.e., towards the back and raised on
legs to minimize turbulence of inflowing air). When a sample is removed
from the analytical instrument, it must be placed in a tightly stoppered
sample tube or otherwise safeguarded from contaminating the laboratory. In
the event that the analytical equipment becomes contaminated, it must be
labeled "CAUTION - TOXIC SUBSTANCE" until it has been completely decon-
taminated. This operational practice applies to analytical equipment even
when only infrequently used for toxic substances.
6. Use of Respirators as Personal Protective Devices. A respirator
use program must be provided for emergency and maintenance personnel who
enter areas where a potential for inhalation exposure to a toxic substance
is present. This program will meet the requirements of the OSHA General
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Industry Standards for respiratory protection as detailed in 29 CFR 1910.134.
The respirators must be certified in accordance with the requirements of
the National Institute for Occupational Safety and Health (NIOSH) under
the provisions of 30 CFR Part 11. The selection and use of respirators
must be approved by the Chief Safety Officer.
7. Storage Inventory and Identification. Stock quantities of toxic
substances must be stored in a specific storage area that is secured at
all times. The storage area must be posted with a sign bearing the legend:
CAUTION - TOXIC SUBSTANCE - Authorized Personnel Only. Principal Investi-
gators must maintain inventory records of toxic substances for which they
are individually responsible and must provide copies to the Chief Safety
Officer. The inventory records must include the quantities of toxic sub-
stances acquired and dates of acquisition and disposition. Storage vessels
containing stock quantities must be labeled: CAUTION - TOXIC SUBSTANCE.
Additional storage precautions may be required for compounds with properties
such as flammability, radioactivity, etc.
8. Working Quantities. Quantities of toxic substances present in
the work area must not exceed the amounts required for use in one week or
the limits set by III. A. This does not include amounts stored in a
specific toxic substance storage area or cabinet that is located within
the laboratory work area. Storage vessels containing working quantities
must be labeled: CAUTION - TOXIC SUBSTANCE.
9. Laboratory Transport. Storage vessels containing toxic sub-
stances must be placed first in an unbreakable outer container before
being transported to the laboratory work areas. Good standard transfer
practices must be used. Freight elevators must be used to transfer
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regulated substances from one floor to another. Plastic-coated glass
bottles with polypropylene caps, which can satisfy a 4-foot drop test,
are currently available and can serve as both the storage vessel and
the unbreakable outer container combined. Contaminated materials which
are transferred from work areas to disposal areas must first be placed in
a closed plastic bag or other suitable impermeable and sealed primary con-
tainer. The primary container must be placed in a durable outer container
before being transported. The outer container must be labeled with both
the name of the toxic substance and the warning: CAUTION - TOXIC SUBSTANCE.
10. Housekeeping. General housekeeping procedures which suppress
the formation of aerosols, such as the use of a wet mop or a vacuum cleaner
equipped with a High Efficiency Particulate Aerosol (HEPA) filter to remove
particulates, must be used. Dry sweeping and dry mopping are prohibited
because of the hazard of aerosol formation. Training of personnel in
appropriate cleaning techniques to avoid or minimize exposure is the
responsibility of the Principal Investigator. In those instances where
the toxic substance or contaminated material is spilled, special pro-
cedures developed for the individual compounds must be followed as
described in the approved Safety Plan.
11. Protection of Vacuum Lines. Each vacuum service, including
water aspirators, must be protected with an absorbent or liquid trap and a
HEPA filter to prevent entry of any toxic substance into the system. When
using a volatile toxic substance, a separate vacuum pump or other device
approved for toxic substances must be used.
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12. Decontamination. Contaminated materials must either be decon-
taminated by procedures that decompose the toxic substance to produce a
safe product or be removed for subsequent disposal. Toxic substances
which have spilled out of a primary container so as to constitute a hazard
must be inactivated jji situ or must be absorbed by appropriate means for
subsequent disposal. Adequacy of clean-up must be tested with wipe-test
or fluorescence tests or by other appropriate means as described in the
Safety Plan.
13. Handling and Disposal. Prior to the start of any laboratory
activity involving a toxic substance, plans for the handling and ultimate
disposal of contaminated wastes and surplus amounts of the toxic sub-
stance must be completed. Principal Investigator and Chief Safety Officer
should jointly determine the best methods available that are in com-
pliance with Federal, State and Local codes and ordinances.
H. PERSONNEL PRACTICES
Each laboratory worker must observe the following rules:
1. Precautionary Considerations
a. Know the safety rules and procedures that apply to the
work you are doing; make note of the appropriate safety
precautions and potential hazards before beginning any
operation.
b. Review the applicable emergency procedures; know where the
emergency equipment is located in your area, how to use it,
and how to obtain help in an emergency.
c. Assure the availability of the proper protective equipment
and use the proper type for each operation.
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d. Be alert to unsafe conditions and actions and have them
promptly corrected. Someone else's accident can be as
dangerous to you as any you might have.
e. Remain out of the area of a fire or personal injury
unless it is your responsibility to help meet the
emergency.
2. Protective Clothing
A two-level control system for laboratory coats is required. A
fully fastened color-coded laboratory coat must be worn by all employees
working in laboratories with controlled toxic substances. These color-
coded laboratory coats must not be worn outside the toxics work area. A
fully fastened white laboratory coat must be worn by visitors (including
fellow employees) in laboratory areas where toxic substances are used or
stored. It is common for visitors to toxic work areas to accidentally
brush against presumedly decontaminated work benches or to unconsciously
rest against them. Since it is unlikely that visitors to toxic work
areas can be prevailed" upon to remove laboratory coats when leaving
toxic work areas and again to put them on each time they return, the
standard white laboratory coat may also be worn outside the toxic work
area. Thus, the white laboratory coat is protection for street clothes
in laboratory areas. Its major purpose is to reduce the probability of
taking contamination from the laboratory to the home environment. The
use of the white laboratory coat reflects an awareness by those respon-
sible for safety that such a coat in non-controlled areas no more suggests
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contamination than street clothes in the same areas suggests freedom
from contamination. The white laboratory coat should not be worn in the
cafeteria, library, conference rooms, auditorium or other common meeting
places.
Clothing contaminated by toxic substances must be decontaminated or
disposed of immediately after an obvious exposure. Contaminated clothing
must not be sent to the laundry until decontaminated. In situations
where decontamination is not feasible, clothing must be disposed of in an
appropriate manner. Gloves which are appropriate to the specific situ-
ation must be used when handling toxic substances. Disposable gloves may
be used only once and then must be discarded into a properly labeled con-
tainer. Such gloves must be discarded immediately after known contact
with a toxic substance.
3. Pipetting
Mechanical pipetting aids must be used for all pipetting procedures.
Oral pipetting is prohibited.
4. Eye Protection
Safety glasses must be worn by all workers and visitors in all
laboratory work areas. Contact lenses shall not be worn in any laboratory
work area.
a. It is the responsibility of the laboratory supervisor or
the Principal Investigator to determine what additional eye
protection may be required for a particular operation.
5. Personal Conduct
a. Personal hygiene must be maintained; fingernails must be short
and clean; hands and arms must be washed thoroughly before
handling any object that goes to the mouth, nose or eyes, and
before leaving the laboratory.
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b. Toxic materials may not be handled by personnel with a break in
the skin below the wrist, unless the wound is so protected that
no toxic material can gain access; the break must be covered with
adhesive tape and appropriate rubber or vinyl gloves must be
worn.
c. There must be no eating, drinking, chewing gum or tobacco,
smoking, and applying cosmetics while working in areas where
toxic substances are in use; refrigerators in such areas must
not be used for storing food or beverages.
d. Distracting or startling other workers must be avoided;
practical jokes or horseplay cannot be tolerated at any time
in the laboratory.
6. Housekeeping
a. Laboratories where toxics are handled must be kept neat
and clean; clean-up procedures are required upon completion
of each operation at the end of each day.
b. Work areas must be free of equipment and material not required
for the immediate operation.
c. All chemicals must be correctly and clearly labeled and stored;
warning signs are required when unusual hazards exist such as
radiation, laser operations, flammables, biological hazards,
or other special concerns.
d. Applicable waste disposal procedures must be followed; chemical
reactions may require traps or scrubbing devices to prevent
the escape of toxic gases.
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e. Exposure to toxic vapors, mists, gases, and dusts must be
minimized by preventing the escape of such materials into the
working atmosphere; adequate ventilation must be ensured by
use of exhaust hoods.and other local ventilation.
f. Equipment must be used only for its designed purpose.
g. Reaction apparatus must be carefully positioned and clamped
to permit manipulation without the need to move the apparatus.
Ji. Reagents must be combined in appropriate order; avoid adding
solids to hot liquids.
7. Personal Monitoring
Each person is responsible for ensuring that his person, clothing,
shoes, laboratory equipment, and work area surfaces are kept free of
contamination. Before leaving the laboratory for even short periods,
contaminated clothing must be removed; showering will also be mandatory
before leaving the laboratory for lunch and at the end of the day when
highly toxic materials are being used by anyone in the laboratory. (When
in doubt concerning the degree of toxic substance hazard present, consult
the Chief Safety Officer for advice and assistance.)
8. Working Alone
Generally, it is prudent to avoid working in a laboratory building
alone. Arrangements should be made with persons working in nearby
laboratories to cross check periodically, especially during irregular
working hours. (The Security Guard can be asked to check on conditions
periodically.)
a. Experiments known to be hazardous should not be performed by an
unaccompanied laboratory worker.
b. The laboratory Supervisor or Principal Investigator is respon-
sible for determining when two or more persons are required.
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IV. ADDITIONAL REQUIREMENTS FOR ANIMAL EXPERIMENTATION
INVOLVING TOXIC SUBSTANCES
All work practice and engineering controls specified in this Manual
apply to animal experimentation when toxic substances are used. Addition-
ally, animal care personnel must wear a completely closed jumpsuit or
undergo a complete clothing change including laboratory-issue shoes or
booties, head cover, and gloves. Clean clothing must be provided daily or
more frequently when needed. Animal care personnel engaged in pro-
cedures where exposure to airborne particulates contaminated with toxic
substances could occur must use appropriate respiratory protection. The
selection and use of an appropriate respirator must be approved by the
Chief Safety Officer. The face mask or respirator must not be worn
outside the animal room. Used filters must be disposed of, the respi-
rator housing must be decontaminated daily, and the respirator must be
stored in a clean location. Personnel required to wear respirators must
shower after completion of procedures that may result in the creation of
airborne contamination in the animal room.
Experimental animals must be housed in cage systems that confine
feed, feces, urine, and bedding within the enclosure. When a volatile
toxic substance is used, the cage must be appropriately sealed or venti-
lated to prevent evolution of contaminants. Alternative animal housing
methods must be approved by the Chief Safety Officer.
The Safety Plan prepared for animal studies must include descriptions
of the proposed animal housing methods, safeguards appropriate for dose
preparation and challenge procedures, procedures for bulk storage and
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disbursement of test material, waste management practice, and personnel
protection requirements. An operations manual must be prepared for
facilities in which large-scale animal studies and inhalation challenge
studies are conducted. Equipment use procedures for all inhalation
challenge studies must be described in detail.
All animal use must comply with the Animal Welfare Act, Public Law
89-544, 1966, amended in 1970 and 1976 (P. L. 91-579 and P. L. 94-279)
and must conform with the Guide for the care and use of Laboratory
Animals, DHEW No. 78-23, revised 1978 or succeeding editions.
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V. EMERGENCY PROCEDURES
Emergencies will generally be in the nature of spills, fires, or
explosions, which may result in the spread of toxic material. Since it
is not possible to devise a set of rules or procedures to govern all
possible emergencies, the following considerations are presented only as
a guide to aid the user in establishing more specific emergency procedures
applicable to his working conditions.
NOTE
All employees are responsible for reporting any accidental
spill of a toxic substance and accidents involving potential
exposure (inoculation, ingestion, dermal contact, inhalation)
to the Chief Safety Officer and the Principal Investigator.
The Principal Investigator must follow up to ensure that the
Chief Safety Officer is notified. The Chief Safety Officer will
coordinate the accident-reporting requirements and the clean-up
procedures.
A. MINOR SPILLS INVOLVING MINIMAL TOXIC HAZARDS TO PERSONNEL
1. Notify all other persons in the room at once and, before proceeding
with the cleanup, notify the Chief Safety Officer.
2. Confine the spill immediately.
3. Permit into the area only the minimum number of persons
required to deal with the spill.
a. Liquid spills:
(1) wear protective gloves
(2) place absorbent paper on the spill
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b. Dry spills:
(1) wear protective gloves
(2) dampen spilled materials thoroughly taking care not
to spread the contamination: use caution in damp-
ening fine, dry particulate material so as not to
create an aerosol; where chemical reactions with
water are possible, use oil as an agent
(3) use wipe tests or fluorescence tests to assure
adequate cleanup
4. Establish a plan and begin decontamination.
5. Monitor all persons involved in the spill and cleanup operation.
6. Prepare and submit to the Chief Safety Officer a complete
description of any accident or spill involving a toxic
substance and subsequent remedial and protective actions taken.
B. MAJOR SPILLS INVOLVING TOXIC HAZARDS TO PERSONNEL
1. Anyone involved in a spill must notify all persons not involved
in the spill to vacate the area at once and limit the movement
of displaced persons to confine the spread of contamination.
2. If the spill is liquid, use a stick, tongs, or lever to place
the spill container upright; the hands may be used only if
protected or gloved appropriately. Spill kits are available
and are required for limited access areas and laboratory rooms.
3. If the spill is on the skin, wash the affected parts thoroughly
with water or appropriate solution.
4. If the spill is on clothing, remove and discard the contaminated
clothing immediately.
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5. Shut off the power to all fans and air circulators.
6. Vacate the room.
7. Notify the Chief Safety Officer as soon as possible and
include identification of material involved.
8. Decontaminate personnel involved; obtain medical aid if
necessary.
9. Decontaminate the area; personnel involved in decontamination
must be adequately qualified and protected.
10. Spills should be inactivated in situ or be absorbed by any
appropriate methods; check up with wipe tests or fluorescence
tests.
11. Monitor all persons involved in the spill and clean up.
12. Permit no one to resume work in the area without the approval
of the Chief Safety Officer.
13. Prepare and submit to the Toxic Substances Committee a
complete history of the accident and subsequent remedial
actions.
C. ACCIDENTS INVOLVING DUST, MIST, FUMES, ORGANIC VAPORS AND GASES
1. Anyone involved in an accident must notify all other persons
to vacate the area immediately.
2. Refrain from breathing as much as possible; close the
escape valves on the continer leaking the contaminant.
Use a respirator if necessary.
3. Vacate the room and, if necessary, activate the fire
alarm to vacate the building.
4. Notify the Chief Safety Officer at once.
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5. Ascertain that all doors to the room are closed; post
conspicuous warnings or guards to prevent accidental
opening of the doors or entry.
6. Monitor all persons suspected of contamination.
7. Proceed with decontamination of personnel.
8. Report at once all known or suspected inhalations of toxic
materials.
9. Evaluate the hazard and the necessary safety devices for
safe re-entry.
10. Determine the cause of contamination and rectify the con-
dition prior to the start of any area decontamination
operations.
11. Establish a plan of operation and begin decontamination of
the area. Check adequacy of clean up with wipe tests or
fluorescence tests.
12. Perform an air survey of the area before permitting normal
work to be "resumed.
13. Prepare and submit to the Toxic Substances Committee a complete
history of the accident and subsequent remedial actions.
D. FIRES OR OTHER MAJOR EMERGENCIES
1. Anyone involved in a fire or other emergency must notify
all other persons in the room and building at once. If the
building must be evacuated, individuals wearing protective
clothing must segregate themselves from others until the
clothing can be disposed of.
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2. Contact the Fire Department and safety personnel including
the Chief Safety Officer.
3. Extinguishing the fire may be attempted if a toxic hazard is
imminent.
4. Restrict firefighting and other emergency activities to
the guidelines and rules prescribed by the Chief Safety
Officer.
5. Monitor all persons involved in combating the emergency.
6. Following the emergency, monitor the area and determine
the protective devices required for safe decontamination.
7- Establish a plan of operation and begin decontamination
in the area.
8. Permit no one to return to work without the approval of
the Chief Safety Officer.
9. Prepare and submit to the Toxic Substances Committee and
the Chief Safety Officer a complete history of the
emergency and subsequent remedial or protective actions.
E. FIRST AID
Report all toxic material accidents with possible health effects,
wounds, ingestion, inhalation, etc., to a physician or other professional
medical person immediately; use extreme care in providing emergency
comfort or first aid treatment, so as to avoid aggravating the injury.
(Washing under running water may be attempted.)
1. For wounds:
a. wash wound or affected area immediately under running
water, spreading the wound sufficiently to allow
good rinsing.
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b. Call or take the injured person to a physician or
other person qualified to treat toxic injuries.
c. Employ appropriate measures to prohibit the spread
of toxic material by the injured.
d. Permit no person injured by toxic substances to.return
to work without the approval of the physician and the
Chief Safety Officer.
e. Prepare accident and injury reports as required for
the Chief Safety Officer and the Personnel Office.
f. Prepare and submit to the Chief Safety Officer and
Toxic Substances Committee a complete history of the
accident and subsequent actions.
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APPENDIX A
CONTROLLED TOXIC SUBSTANCES
Substances considered toxic are contained in the following three
lists.
List 1 was generated by searching the National Institute for
Occupational Safety and Health's Registry of Toxic Effects of Chemical
Substances. Compounds selected were those which met the following
criteria:
ACUTE TOXICITY
Dosage Method Type of Measure
Oral LD*Q
Inhalation LD™
bU
Dermal LD™
List 2 comprises the Carcinogen Assessment Group's "Chemicals Having
Substantial Evidence of Carcinogenicity."
List 3 comprises the Occupational Safety and Health Administration's
List of Regulated Carcinogens.
(List 1 will be added to the Manual when the selection criteria are
established and the printout obtained.)
*
To be established in cooperation with the Occupational Health
and Safety staff.
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LIST 1 *
NIOSH'S REGISTRY OF TOXIC EFFECTS
OF CHEMICAL SUBSTANCES
*To be established in cooperation with the Occupational Health and
Satety staff.
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LIST 2
CHEMICALS HAVING SUBSTANTIAL EVIDENCE OF CARCINOGENICITY
Compounds
Aflatoxins
Aldrin
Amitrole
Aramite
Arsenic and Arsenic Compounds
Auramine and the manufacture of Auramine
Azaserine
Benz(c)acridine
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Beryllium and Beryllium Compounds
N,N-Bis(2-Chlorethyl)-2-Naphthylamine
(Chlornaphazene)
Cadmium and Cadmium Compounds
Carbon Tetrachloride
Chlorambucil
CAS No.
64365-29-3
309-00-2
61-82-5
140-57-8
39277-51-5
12237-78-4
115-02-6
225-51-4
56-66-3
54682-86-9
50-32-8
205-99-2
205-82-3
7440-41-7
494-03-1
7440-43-9
56-23-4
305-03-3
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-48-
Compounds CAS No.
Chloroalkyl Ethers
Bis(2-chloroethyl)ether 111-44-4
Bis(chloromethyl)ether 108-60-1
Chloromethyl methyl ether (CMME),
technical grade (IARC) 107-30-2
Chlordane 52002-35-4
Chlorinated Ethanes
1,2-Dichloroethane (Ethylene Chloride,
Ethylene Dichloride EDC) 52399-93-6
Hexachloroethane 67-72-1
1,1,2,2-Tetrachloroethane 1299-89-4
1,1,2-Trichloroethane 79-00-5
Chlorobenzilate 510-15-36
Chloroform 8013-54-5
Chromium Compounds, Hexavalent 18540-29-9
Chrysene 27274-05-1
Citrus Red No. 2 6358-53-8
Coal Tar and Soot (CAG, included in lARC's soots,
tars, and oils designation)
Creosote 8001-58-9
Cycasin 453-95-2
Cyclophosphamide 50-18-10
Daunomycin 20830-81-3
DDT (Dichlorodiphenyltrichloroethane) 50-29-3
Dial late 58904-04-4
Dibenz(a,h)acridine 226-36-8
Dibenz(a,j)acridine 224-42-0
Dibenz(a,h)anthracene 53-70-3
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Compounds CAS No.
7H-Dibenzo(c,g)carbazole 194-59-2
Dibenzo(a,e)pyrene 192-65-4
Dibenzo(a,h)pyrene 189-64-0
Dibenzo(a,i)pyrene 189-55-9
1,2-Dibromo-3-chloropropane 96-12-8
1,2-Dibromoethane 8003-07-4
Dieldrin 60-57-1
Diepoxybutane 1464-53-5
1,2-Diethylhydrazine 1615-80-1
Diethylstilbestrol 56-53-1
Dihydrosafrole 94-58-6
3,3'-Dimethoxybenzidine 119-90-4
7,12-Dimethylbenz(a)anthracene 57-97-6
3,3'-Dimethylbenzidine 119-93-7
Dimethylcarbamoyl Chloride 79.44.7
1,1-Dimethylhydrazine 57-14-7
1,2-Dimethylhydrazine 540-73-8
Dimethyl Sulfate 77-78-1
2,4-Dinitrotoluene 121-14-2
1,4-Dioxane 123-91-1
1,2-Diphenylhydrazine 122-66-7
Epichlorohydrin 106-89-8
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Compound
Ethylene Bis Dithiocarbamate
Ethylene Oxide
Ethylenethiourea
Ethyl Methanesulfonate
Formaldehyde
Glycidalhehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexach1orocyc1ohex ane
aHCH
gHCH
YHCH
Technical HCH
Hydrazine
Indeno(l,2,3-cd)pyrene
Iron Dextran
Isosafrole
Kepone
Lasiocarpine
Melphalan
Methapyrilene
3-Methylcholanthrene
Methyl Iodide
Methyl Methanesulfonate
N-Methyl-N'-nitro-N-nitrosoguanidine
CAS No.
142-59-6
19034-08-3
96-45-7
62-50-0
50-00-0
765-34-4
76-44-8
118-74-1
87-68-3
608-73-1
319-84-6
319-85-7
58-89-9
75013-58-0
193-39-5
9004-66-4
120-58-1
143-50-0
303-34-4
8057-25-8
91-80-5
56-49-5
74-88-4
66-27-3
70-25-7
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Compounds CAS No.
Methylthiouracil 56-04-2
Mitomycin C 7481-68-7
Mustard Gas 505-60-2
Nickel and Nickel Compounds 7440-02-0
Nitrogen Mustard and its hydrochloride 55-86-7
Nitrogen Mustard N-oxide and its hydrochloride 302-70-5
5-Nitro-o-toluidine 99-55-8
4-Nitroquinoline-l oxide 56-57-5
Nitrosamines
N-Nitrosodiethanolamine 1116-54-7
N-Nitrosodiethylamine 55-18-5
N-Nitrosodi-n-butylamine 924-16-3
N-Nitrosodi-n-propylamine 621-64-7
N-Nitrosomethylethyl amine 10595-95-6
N-Nitrosomethylvinyl amine 4549-40-0
N-Nitroso-N-Ethylurea 2151-05-5
N-Nitroso-N-Methylurea 684-93-5
N-Nitroso-N-methylurethane 615-53-2
N-Nitrosomorpholine 59-89-2
N-Nitrosonornicotine 16543-55-8
N-Nitrosopiperidine 68374-62-9
N-Nitrosopyrrolidine 930-55-2
N-Nitrososarcosine 68374-66-3
Pentachloronitrobenzene 82-68-8
Phenacetine 62-44-2
Polychlorinated Biphenyls
Pronamide 23950-58-5
1,3-Propane Sultone 1120-71-4
Propylthiouracil 51-52-5
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Compounds CAS No.
Reserpine 50-55-5
Saccharin 474-91-9
Safrole 94-59-7
Selenium Sulfide 7446-34-6
Streptozotocin 18883-664-4
Tetrachloroethylene 127-18-4
Thioacetamide 1482-80-0
Thiourea . 62-56-6
o-Toluidine Hydrochloride 636-21-5
Toxaphene 8001-35-2
Trlchloroethylene 79-01-6
2,4,6-Trichlorophenol 88-06-2
Tris(l-aziridinyl)phosphine sulfide 639-23-6
Tris(2,3-dibromopropyl)phosphate 126-72-7
Trypan Blue, commercial grade 72-57-1
Uracil Mustard 66-75-1
Urethane 51-79-6
Vinylidene Chloride 75-35-4
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LIST 3
OSHA'S LIST OF REGULATED CARCINOGENS
Compounds CAS No.
2-Acetylaminofluorene 53963
Acrylonitrile 29754-21-0
4-Aminodiphenyl 92671
Asbestos
Benzidine 92875
Bis-Chloromethyl ether 542881
3,3'-Dichlorobenzidine (and salts) 91941
4-Dimethylaminoazobenzene 60117
Dioxin (2,3,7,8-Tetrachlorodibenzo-p-dioxin)* 1746016
Ethyleneimine 151564
Methyl-chloromethyl ether 107302
4,4'-Methylene bis (2-chloroaniline) 101144
a-Naphthylamine 134327
B-Naphthylamine 91598
4-Nitrobiphenyl 92933
N-Nitrosodimethylamine 62759
8-Propiolactone 57578
Vinyl Chloride 75015
*0n List 3 because of extremely high toxicity.
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APPENDIX B
TOXIC SUBSTANCE SAFETY PLAN
Assistance in preparing the safety plan can be obtained from the
Laboratory Safety Officer.
USE CATEGORY
Routine Infrequent
REVIEW:
Laboratory Safety Officer
APPROVALS:
Supervisor of Principal Investigator
Laboratory Director
Chief Safety Officer
Toxic Substances Committee
PRINCIPAL INVESTIGATOR:
Laboratory or Branch
Building, Room
Phone
DATE OF P1AN PREPARATION:
TOXIC SUBSTANCE(S)
Name(s) CAS No(s).
Sy n o nym s
Safety Data Sheet Available Yes No
Location of Use
Intended Use
Location of Storage
INVENTORY DATA
Date Toxic Substance Ordered or Synthesized
Quantity
Period of Use
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
DETAILED DESCRIPTION OF INTENDED USE OF TOXIC SUBSTANCE(S)
(Use additional sheets if necessary)
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated surfaces, materials,
instruments, equipment, etc.)
Disposal Procedures (wastes and unused stock):
EMERGENCY PROCEDURES
In event of overt personnel exposure (inhalation, ingestion, dermal
contact, inoculation):
In event of environmental contamination (spill):
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
HAZARD ASSESSMENT (toxic and pharmacologic effects, reactivity, stability
flammability, and operational concerns - weighing,
mixing, etc):
MONITORING PROCEDURES (If required by the Chief Safety Officer)
Medical surveillance procedures for evidence of personnel exposure:
Personnel monitoring procedures:
Surveillance procedures for environmental contamination:
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
PERSONNEL POTENTIALLY EXPOSED TO TOXIC SUBSTANCES
Personnel Authorized to Use Toxic Substances:
1. 4.
2. 5.
3. 6.
Other Personnel Assigned to Locations Where Toxic Substance is Used;
1. 4.
2. 5.
3. 6.
ALTERNATIVE WORK PRACTICE AND ENGINEERING CONTROLS (if Used)
(Describe alternative controls not specified in this Manual for the
Laboratory Use of Toxic Substances. Indicate controls specified
in the Manual for which proposed alternative controls will serve
as substitute methods).
READ AND UNDERSTOOD (Signatures of all Personnel Potentially Exposed).
1. 4.
2. 5.
3. 6.
LITERATURE CITATIONS
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APPENDIX C
OFFICE OF OCCUPATIONAL HEALTH AND SAFETY, LABORATORY DIRECTORS,
AND TOXIC SUBSTANCES COMMITTEE MEMBERS
Occupational Health and Safety Staff
Robert C. Magor, Director
Occupational Health and Safety Staff (PM-273)
Washington, D. C. 20460
(Telephone: 382-3640)
David Weitzman, Industrial Hygiene Program Manager
Occupational Health and Safety Staff (PM-273)
Washington, D. C. 20460
(Telephone: 382-3647)
Laboratory Directors
Robert L. Booth, Acting Director
Environmental Monitoring and Support Laboratory (EMSL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7301)
Richard J. Bull, Director
Toxicology and Microbiology Division
Health Effects Research Laboratory (HERL)
U. S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7401)
David G. Stephan, Director
Industrial Environmental Research Laboratory (IERL)
U. S. Environmental Protection Agency
5555 Ridge Avenue
Cincinnati, Ohio 45268
(Telephone: 684-4402)
Francis T. Mayo, Director
Municipal Environmental Research Laboratory (MERL)
U. S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7951)
L. A. Van Den Berg, Director
Technical Support Division (TSD)
U.S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7904)
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APPENDIX C (continued)
Toxic Substances Committee Members
George A. Bodmer, Chief Safety Officer
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7269)
Gerald Berg, Chairman
Hazardous Materials Committee
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7357)
Stephen Billets, Laboratory Safety Officer
Environmental Monitoring and Support Laboratory (EMSL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7494)
Charles R. Feldman, Laboratory Safety Officer
Technical Support Division (TSD)
U. S. Environmental Protection Agency
26 W. St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7943)
Lawrence J. Kamphake, Laboratory Safety Officer
Municipal Environmental Research Laboratory (MERL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7957)
Carl T. Rybak, Laboratory Safety Officer
Toxicology and Microbiology Division
Health Effects Research Laboratory (HERL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7457)
Donald G. Silvis, Laboratory Safety Officer
Industrial Environmental Research Laboratory (IERL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7514)
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APPENDIX D
TOXIC SUBSTANCE CHEMICAL INVENTORY SHEET
Date:
Inventory Quantity,
No. Chemical Name CAS No. gms Bldg. Room
i
User
en
-------
APPENDIX D (CONT'D)
TOXIC SUBSTANCE RUNNING INVENTORY USAGE SHEET
NAME OF MATERIAL:
DATE RECEIVED: QUANTITY RECEIVED:
CAS NUMBER:
r>ATC IICC /AMTMAI TCCTC rUCM DCArTTnMC CTP ^ AMOUNT WHERE AMOUNT
DATE USE (ANIMAL TESTS, CHEM. REACTIONS. ETC.) U$E[) USED REMAINING
CTi
ro
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APPENDIX D (CONT'D)
TOXIC CHEMICAL/ENVIRONMENTAL SAMPLE LOG SHEET
LOG SHEET CONTROL IDENTIFICATION NUMBER:
NAME OF MATERIAL:
BILL OF LADING OR PURCHASE ORDER NO.:
DATE OF RECEIPT: NAME OF RECEIVER:
QUANTITY: CONTAINER SIZE:
FORM OF SHIPMENT:(i.e. Federal Express,etc.)
CONDITION OF SHIPPING OR SAMPLE CONTAINER:
SAMPLE COLLECTION DATA:
EXACT LOCATION OF SAMPLING:
NEAREST TOWN: TIME: DATE:
SOURCE OF SAMPLE: (Drum,evaporative pond, stream,ground water,etc.)
MANUFACTURING/INDUSTRIAL PROCESSES IN AREA:
SUSPECTED CONTAMINANTS:
COLLECTED BY: ORGANIZATION: _PHONE:
AUTHORIZED BY:
DISTRIBUTION OF MATERIAL: AMOUNT: BUILDING:
ROOM NO.: NAME OF PRINCIPAL INVESTIGATOR:
DATE: SIGNATURE OF RECIPIENT:
EXACT STORAGE LOCATION:
MATERIAL SAFETY DATA SHEET AVAILABLE: YES NO
APPROVED SAFETY PLAN AVAILABLE: YES NO _
DISPOSAL: AMOUNT: DATE: PROGRAM: _
DISPOSAL DATA:
HEALTH AND SAFETY IMPACT:
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APPENDIX E
PERIODIC HEALTH ASSESSMENT
The nature of a program for providing periodic health assessments is
complicated by several factors. Among these are (1) many laboratory
workers handle a variety of toxic substances so that the medical sur-
veillance should ideally seek evidence of adverse effects from all these
substances, (2) some toxic substances cause cancer but have little or no
toxicity other than the production of neoplasms, and (3) most tumors do not
become evident until many years (often 20-30) after the initiating events.
Medical monitoring will, therefore, sometimes for necessity and more
often for efficiency, usually concentrate on events likely to precede
overt evidence of serious health effects such as tumorigenesis. For
example, some carcinogens, such as dimethylnitrosamine, have high acute
toxicity, especially to the liver, and evidence of such acute toxicity
can be obtained within a few hours or days following exposure. Some
tumors, such as those induced by carbon tetrachloride, are normally pre-
ceded by marked changes in liver cells, usually detectable by clinical
tests. Others, e.g., angiosarcomas induced by such substances as vinyl
chloride, will often cause detectable cell changes in nearby tissue as
the probable result of space occupation. It should be noted that detec-
tion of such toxic changes does not necessarily presage tumor develop-
ment, but should nevertheless precipitate the instruction of corrective
work practices and improved engineering controls. The occupational
physician, to be effective, must have relevant information such as mode
and mechanism of toxic action, frequency and severity of exposure, and
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exposure concentrations, if known. Some of this information will be
available in individual safety data sheets. However, this information
should be supplemented by the Principal Investigator when appropriate.
Biologic monitoring is sometimes a useful method of detecting
exposure and. perhaps, of estimating the degree of exposure. Biologic
monitoring usually involves the analysis of body fluid or excreta
(usually urine, sometimes blood, rarely expired air^ for the toxic
substance or a biotransformation product. An example is the detection
of reaction products of biphenylamines in the urine samples of persons
absorbing benzidine or its derivatives. Even if exposure cannot be
quantified, as is sometimes the case, the rrere detection of the meta-
bolite, if its presence is specific to the individual toxic substance
or class, is sufficient to indicate the need for corrective action.
In some cases, especially with some less well known carcinogens,
those in the research laboratory will be better informed on possible
biologic monitoring procedures than will the occupational physician.
In such cases, the investigators should discuss the possibilities with
the occupational physician. It may also be that specialized analytical
procedures and equipment will be needed for some of this monitoring.
Some procedures and equipment that may not be available to the medical
laboratory are available in the research laboratory. The investigators
should undertake such monitoring procedures themselves only with prior
approval of and in participation with the occupational physician.
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APPENDIX F
LOCATION OF CARCINOGEN DILUTION MODULES AND LIMITED ACCESS AREAS
*Carcinogen Dilution Module (EMSL) ST. Clair Room 576
*Carcinogen Dilution Module (HERL) St. Clair Room 608
IERL St. Clair Room
MERL St. Clair Room 411
TSD St. Clair Room 411
**TMD (HERL) St. Clair Rooms 762-768
*Presently the only approved areas for storage and handling of neat
chemical carcinogens regulated by OSHA (List 3, Appendix A).
**These rooms have been set aside as the only rooms in which dosing of
animals can exceed the amounts prescribed for a non-controlled area.
Carcinogens are not to be stored in these rooms.
Personnel other than EMSL and HERL must obtain permission from
the appropriate Laboratory Director for use of Carcinogen Dilution
Laboratories.
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APPENDIX G
PACKAGING, MARKING, LABELING, AND SHIPPING OF TOXIC
SUBSTANCES USED BY LABORATORIES
1. GENERAL PROVISIONS
These procedures apply to substances considered toxic for this
Manual (identified in Appendix A) which are shipped between laboratories
or the field. Applicable laboratories include any EPA laboratory or
private laboratories under contract with EPA who handle these toxic
substances.
a. Most of the toxic substances identified in Appendix A are not
materials specifically identified in the Department of Trans-
portation (DOT) Hazardous Material Table (49 CFR 172.101). Any
material listed in the DOT Table should be transported accord-
ing to the Table or according to applicable DOT packaging
exemptions (e.g., a Poison B, n.o.s. can be packed in Label-
master, Inc.'s package #38, or Dow Chemical Co.'s Imbiber Pack
for shipment by United Parcel Service). Substances that are
judged to be environmental samples should be shipped according
to EPA national guidance (Compliance with Department of
Transportation Regulations in The Shipment of Environmental
Laboratory Samples, draft memo by water media DAA's, available
from Division of Occupational Health and Safety).
b. Toxic substances may be transported by rented or common carrier,
truck, bus, railroad, and by Federal Express Corporation*
*These procedures are designed to enable shipment by entities like Federal
Express and should not be construed as an endorsement by EPA of a particular
commercial carrier.
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(air cargo), but they may not be transported by any other
common carrier air transport or even by "cargo only" air-
craft other than Federal Express at this time.
c. If toxic substances are transported by any type of government-
owned vehicle, including aircraft, DOT regulations are not
applicable. However, EPA personnel must still use the pack-
aging procedures described below.
2. PRELIMINARY STEPS
The following procedures should be followed before toxic substances
are shipped:
a. Place a sufficient quantity of the toxic substance in glass
and/or polyethylene containers to determine whether it will
react with or substantially reduce the effectiveness of the
container.
b. Pack toxic substances according to "Packaging, Marking, and
Labeling Requirements for Toxic Substances Used by Laboratories.
3. PACKAGING. MARKING AND LABELING REQUIREMENTS FOR TOXIC SUBSTANCES
USED BY LABORATORIES
a. Place the toxic substance in a 16-ounce* or smaller glass or
polyethylene container with nonmetallic, Teflon-lined screw
cap. Allow sufficient ullage (approximately 10% by volume)
so container is not liquid full at 130 °F. If an air space
in the innermost container cannot be tolerated in order to
maintain sample integrity, place the container within a
* Larger capacity containers, up to one gallon, may be used for toxic sub-
stances with a flash point of 73 °F or higher. In this case, such should
be marked on the outside container (carton, etc.) but only a single (one
gallon or less) bottle may be packed in an outside container. Ten percent
ullage and requirements 2, 5, 6, and 7 must also be followed. On the
shipping papers (if required) state that flash point is 73 °F or higher.
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second container which provides the required ullage. If
collecting a solid material, the container plus contents must
not exceed one pound net weight.
b. For toxic substances which are samples taken in the field,
attach properly completed sample identification tag to
sample container.
c. Seal the toxic substance container and place it in 2-mil-
thick (or thicker) polyethylene bag, one container per bag.
Plastic-coated glass bottles with polypropylene caps, which
can satisfy a 4-foot drop test, are currently available and
can serve as both the container and polyethylene b-ag.
(Labels and/or tags should be positioned to enable them
to be read).
d. Place sealed bag or plastic bottle inside a metal can with
incombustible, absorbent, cushioning material (e.g., vermic-
ulite, coarse grade to minimize dust), one bag or plastic
coated bottle per can. Pressure-close the can and use clips,
nylon reinforced tape, or other positive means to hold the
lid securely, tightly, and effectively.
e. Mark and label this can as indicated in 3. h. below.
f. Place one or more metal cans (or a single one-gallon bottle;
see footnote on previous page), surrounded with incombustible
packaging material for stability during transport, into a
strong outside container, such as a fiberboard box.
g. Mark and label the outside container and complete shipping
papers (if required) as described in 3. h. below.
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h. Place the following information on strong outside container,
either hand printed or in label form:
(Laboratory name and address)
Tosic Substance, not regulated by DOT, (chemical name):
EPA Laboratory Sample
Use abbreviations only where specified for DOT listed
hazardous materials. "THIS SIDE UP" or "THIS END UP" should
also be marked on the top of the outside container, and
upward pointing arrows should be placed on all four sides of
the exterior container.
i. Shipping papers are not required for toxic substances which
are not DOT listed hazardous materials. Regulations for
shipping papers for DOT listed hazardous materials are
presented in 49 CFR 172. 200-204.
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APPENDIX H
PRIMARY CONTAINMENT EQUIPMENT
1. PURPOSE
The purpose of primary containment equipment is to protect the
laboratory worker from exposure to vapors or aerosols of hazardous
materials that may be released by procedures performed within the
equipment. Primary containment equipment that is properly designed,
located, maintained, and operated can prevent or minimize the escape of
hazardous materials from the equipment into the laboratory. The labora-
tory fume hood, the biological safety cabinet, and the glove box are
the principal primary containment equipment upon which laboratory
workers depend for their protection while working with toxic substances.
2. LABORATORY FUME HOOD
The laboratory fume hood (a Class I device) is the primary hazard
control device that laboratory workers depend upon for their protection
while working with toxic or other hazardous materials. If-designed,
installed, operated, and maintained properly, the laboratory fume hood
will provide personnel with a high degree of protection and allow the
user to safely work with a wide range of potentially hazardous materials.
a. Hood Function The purpose of a laboratory fume hood is to
prevent or minimize the escape of contaminants from the hood
back into the laboratory. This is accomplished by drawing air
pest the operator through the zone of contaminant generation
and into the hood.
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b. Conditions Affecting Hood Performance. The ability of a
laboratory hood to control contaminants generated in the hood
will depend on many factors. Of prime concern are the control
velocity at the hood face, air movement in the room, turbulence
within the hood working space, and hood location. It is the
proper selection and control of these factors as a group that
determines the performance of the hood from the standpoint of
hazard control.
(1) Face Velocity. Air flow rates, to provide protection
from operations performed in the hood, must provide
positive control of air movement against competing
influences. Control velocities required at the face
of the hood range from 80 FPM (ft. per minute) for
"ideal" laboratory conditions to 100 FPM for "good"
conditions.
(2) Operator Effect. The operator standing in front of the
hood has a significant effect on the air flow patterns.
The "eddies" formed around the -operator can carry
contaminants from the hood to the operator's breathing
zone. Proper use of make-up air at the hood face, with
emphasis on filling the void or minimizing the low
pressure area in front of the operator, is necessary for
optimum hood performance.
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(3) Air Movement In the Laboratory. Air movement within the
laboratory affects the performance of hoods and is influ-
enced by hood location and room air supply systems. Hood
locations must be away from doors, operable windows, and
pedestrian traffic. Air from these sources can attain
velocities several times greater than the hood face
velocity, creating potential for dragout or displacement
of contaminated air from the hood. Ceiling and wall
diffusers for distribution of make-up air are also
serious potential sources of interference. Air from such
outlets should either be controlled to assist in the per-
formance of the hood or directed so that the energy is lost
before entering the zone of influence. Experience indicates
that air from make-up systems should not exceed 25 FPM in
the hood face areas (measured with hood exhaust "off").
Air drawn from adjacent areas (by the hood exhaus-t system)
must enter in a manner that does not create excessive
turbulence.
(4) Hood Turbulence. Upon entering the hood, the air is drawn
past equipment and sources of contamination toward the ex-
haust slots. Much of the air within the hood is in a tur-
bulent state. At air-flows greater than needed to provide
a good vector and contain the contaminant, the resulting
turbulence can be excessive causing a "rolling effect" in
the hood chamber. This increases the potential for greater
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mixing of contaminated air and room air at the hood face.
Often, a combination of poor hood arrangement and interior
turbulence will result in loss of contaminated air to the
room.
(5) Hood Location. Location of a hood at the end of room or
bay, where the operator is essentially the only one who
enters the zone of influence, is the most desirable.
In any arrangement, pedestrian traffic past fume hoods
should be minimized. Hood location parameters are detailed
in subparagraph 2.C.
c. Hood Location Classification.
"Ideal" (1) End of room or bay, no nearby doors or windows.
(2) Essentially no pedestrian traffic, other than hood
operator.
(3) All of the required laboratory hood make-up air drawn
or induced to enhance over-all hood performance. For
example, a properly designed and located perforated
ceiling section or well designed auxiliary air hood
plenum.
(4) No other grilles or diffusers exist that produce air at
measurable velocities in the hood area.
"Good" (1) Not on a main aisle, no nearby doors or windows.
(2) Minimum traffic other than hood operator.
(3) Have air supplied to lab so velocity from diffusers or
grilles does not exceed 25 FPM in vicinity of hood.
"Poor" (1) Any one or more of the above conditions are not met.
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d. Additional Specification and Procedures. Additional specifica-
tion and performance evaluation procedures for laboratory
fume hoods can be found in:
(1) EPA Laboratory Fume Hood Specifications and Performance
Testing Requirements, available from the EPA OHSS.
(2) U.S. Environmental Protection Agency Facilities Safety
Handbook, Amendment No. 1., available from the EPA
Facilities Engineering and Real Property Management
Branch.
3. CLASS II BIOLOGICAL SAFETY CABINET.
The Class II biological safety cabinet is a primary containment
device designed to protect the laboratory work as well as the laboratory
worker.
a. Cabinet Function. The Class II biological safety cabinet
provides a blanket of clean air over the work, contains air
contaminants in the work area, and conveys the contaminated
air away from the operator. It accomplishes these functions
by combining recirculation with filtration and exhaust.
High Efficiency Particulate Aerosol (HEPA) filtered air
descends over the work surface and splits at the center.
A portion of the downflow air exits through a front air
intake grille, and the balance exits through a rear air
exhaust grille. The downflow air is reunified under the
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work surface and forced up through a rear or side positive
pressure plenum to the unit's top. Type A (30%) or Type B
(70%) of this air is filtered and exhausted and the balance
is filtered and forced down to blanket the work. The make-up
air (30% Type A or 70% Type B) enters from the room through
the front intake grille and sweeps by and protects the oper-
ator. Total exhaust Class II biological safety cabinets
which have recently become available presumably provide high
personnel protection factors.
b. Conditions Affecting Cabinet Performance. The conditions
that affect cabinet performance are essentially the same as
the conditions ttiat affect laboratory hood performance which
were presented in detail above. The operator effect can be
particularly pronounced since the operator's arms interfere
with the recirculating downflow air vector.
c. Additional Specifications and Procedures. The OHSS is develop-
ing standards for these cabinets using the EPA laboratory
hood standard as a model. Meanwhile, equipment descriptions,
recommended specifications and certification procedures can
be found in the following documents:
(1) Laboratory Safety Monograph, A Supplement to the NIH
Guidelines for Recombinant DNA Research. U.S. Depart-
ment of Health, Education and Welfare, Public Health
Service, National Institutes of Health, January, 1979.
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(2) National Sanitation Foundation Standard No. 49.
National Sanitation Foundation, Ann Arbor, Michigan, 1976.
4. GLOVE BOX
a. The Glove Box, or Class III biological safety cabinet, is
a totally enclosed ventilated cabinet of gas-tight construction.
Operations within this equipment are conducted through attached
rubber gloves. When in use, the equipment is maintained under
negative air pressure of at least 0.5 inches water gage. A
small volume of supply air, to prevent contamination build-up,
is drawn into the equipment through a HEPA filter and the
exhaust air is treated to prevent the discharge of contaminants
into the environment. This equipment provides the highest
level of personnel and environmental protection.
b. The Glove Box is generally recommended for the isolation of
procedures involving stock quantities of toxic substances.
Worker protection can be compromised by puncture of the gloves
or accidents creating positive pressure. Flammable solvents
should not be used in this equipment unless a careful
evaluation has been made to determine that concentrations will
not reach dangerous explosive levels. When the use is deter-
mined safe, these materials should only be introduced into the
glove box in closed, nonbreakable containers. These materials
should not be stored in the glove box. Flammable gas should
not be piped to this equipment.
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