United States
Environmental Protection
Agency
Office of
Administration And
Resources Management
(3207)
EPA-202-B-98-001
June 1998
&EPA
SHEMP Operations Manual
For Laboratories
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SHEMP Operations Manual for Laboratories Contsnts
Tab Title (Section Color)
Introduction (White)
A. Management and Administration (Light Blue)
Al. Introduction
A2. Management Leadership and Employee Involvement
A . Contractors and Visitors
A4. Recordkeeping and Document Control
A5. Evaluation of Program Effectiveness
B. Hazard and Risk Analysis & Management (Yellow)
BI. lntro4uction
B2. Hazarg tntification
B3. Risk Aáessment
B4. Chang l agement
C. Laboratory SHE P rgrams t en)
Cl. Introduction
C2. Medical SurveiIIan ro ram
C3. SHE Tra ning n
C4. Chemicat H%rglene Thog1aM
C5. Industrial Hygiene PTograr&
C6. Radiation Safety Program
C7. Biosafety Program
C8. Ergonomics Program
C9. Pollution Preventkn Program
ClO. Air Quality Program
Cli. EPCRA Program
Ci 2. Wastewater Program
Cl3. SPCC Program
C14. Waste Management Program
C15. TSCA Program
C16. UST Program
D. Engineering Controls (Grey)
Di Introduction
D2 General Laboratory Design
D3. Process Change
D4. Ventilation
D5. Hazard-Specific Controls
t C U I S 4
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SHEMP Operations Manual for Laboratories Contents
Tab ilti. (Section Color)
E. Protective Clothing and Equipment (Blue)
El. Introduction
E2. Personal Protective Equipment
E3. Respiratory Protection
E4. Emergency Eyewuhes and Showers
F. Wodi Practies Controls (Orange)
Fl. Introduction
F2. General Work Practice Controls
F3. Work Practice Control, for Chemicals
G. LØc ory Em.rgancy Manag.m.nt (Red)
Gi. Ifltrodu ón
G2 EmIrgey*a p n
G3 EmefVe H, 1 n
G4 lnve ation nd Alalysts
Blbuio aphy (Purple)
Acronyms (Light Yellow)
Glossary (LighfM r)
Subject Index (Light Gre.i .
4
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Introduction
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SHEMP Operations Manual for Laboratories
A Message from the SHEM Managing Director
Safety, Health and Environmental Management Programs are the highest priority throughout
EPA. As public sector leaders in environmental management, EPA strives to “set the
standard” for excellence, addressing our employees’ well-being in the process.
The EPA SEEM Division has long been committed to managing Safety, Health and Environ-
mental Division risks throughout our varied operations. This document represents a major
step forward as we continuously strive to strengthen the risk management of our laboratory
operations. It provides guidance on management and administration, hazard identification
and evaluation, laboratory Safety, Health and Environmental Division programs, engineer-
ing controls, protective clothing and equipment, work practice controls and laboratory
emergency situations.
An integral part of the development of this guidance tool was our partnership with selected
Safety, Health and Environmental Division leaders in the “laboratory community,” each with
their own unique background and specialization. A draft copy of this document was critiqued
by them as part of an extensive peer review process. That resulted in valuable insights and
recommendations that have helped “chart the course” towards the development of a docu-
ment that reflects both technical excellence and a practicality that will facilitate reference and
utility.
A fundamental element of our successful risk management is the transfer and sharing of
information and knowledge. The EPA SHEMP Operations Manual for Laboratories supports
that objective. We look forward to collaborating with our partners within the EPA, in other
public agencies, and in the private sector to update and expand this knowledge-base so that
we can minimize risk to our staff and the environment.
Julius Jimeno
Managing Director
EPA SHEM Division
&B’P June 1998 Bibliography-I
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A. Management and Administration
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Al.
Introduction
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
Al. Introduction
Continuous and long-term safety, health, and environmental (SFIE) excellence cannot be
achieved solely by implementing technical programs, exposure controls, and other compli-
ance initiatives. Instead, laboratories must have a systematic management approach for SHE
activities (i.e., well-designed and well-executed management practices that can be applied to
all functional areas and technical programs).
Effective management practices go beyond compliance, enabling employees to work more
independently and allowing management to spend less time on detailed supervision of SHE
matters. In addition, well-designed management systems promote continuous improvement
by stressing clear goals and objectives, frequent measurement of results, and periodic review
of program effectiveness. In fact, the U.S. Occupational Safety and Health Administration
(OSHA) has recognized the importance of effective management in reducing the number and
severity of workplace injuries and illnesses as demonstrated by the promulgation of the
“Basic Program Elements for Federal Employees” and the “Program Management Guidelines
for Managing Worker Safety and Health.”
According to OSFLA and other leading organizations, such as the international Standards
Organization, effective management of SHE involves several activities that are essential to
understanding all hazards and risks, and preventing or controlling these hazards and risks.
Chapter A provides guidance for those practices related to:
Topic
A2
Management Leadership and Employee Involvement
A3
Contractors and Visitors
A4
Recordkeeping and Document Control
A5
Evaluation of Program Effectiveness
&EPA June 1998
Al-i
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A2.
Management Leadership and
Employee Involvement
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
1.0 Introduction
Safety, health, and environmental (SHE)
regulations are increasingly emphasizing
the importance of management leadership
and employee involvement in managing
risks. In fact, the major element of the U.S.
Occupational Safety and Health Adminis-
tration (OSHA) program guidelines
describes the leadership that management
must exhibit to effectively communicate a
commitment to worker safety, and to
encourage employee involvement in the
SHE program. This element consists of the
following management principles:
• Policies and management commitment
• Goals and objectives
• Responsibilities
• Authority and accountability
• Employee involvement
Ideally, these actions should not be devel-
oped or implemented individually, but
used together to complement one another
and add to the overall effectiveness of an
EPA laboratory’s SHE programs. The fol-
lowing sections provide suggestions for
implementing each of these management
principles.
• Clear definition of the roles and
responsibilities of the laboratory staff
and management
• Establishment of a laboratory safety
committee
Program Administration
To effectively implement management
principles, responsibilities should be
assigned for:
• Promoting staff awareness of SHE
policy
• Ensuring that clear roles and
responsibilities have been delegated
and communicated effectively to
laboratory staff
• Incorporating SHE responsibilities
into job descriptions
• Chairing and participating on the labo-
ratory safety committee
• Establishing job performance
measures
EPA Requirements
For effective implementation of manage-
ment principles for EPA laboratory SHE
programs, the following must be
performed:
• Communication of EPA SHE policy
• Establishment of clear goals and
objectives relative to SHE
performance
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S}IEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A2. Management Leadership and Employee Involvement
2.0 SHE Policy and Management
Commitment
A formal written SHE policy issued by top
management is fundamental to the success
of any SHE program. if laboratory staff
can see and read the commitment that
management has made to SHE issues, then
the first step to SHE vigilance has been
taken. In addition, a written commitment
makes it easier for laboratory management
and staff to resolve conflicts between SHE
issues and other priorities (i.e., productiv-
ity, turnaround time, etc.).
At the EPA, senior management leadership
and commitment to strong SHE perfor-
mance is demonstrated through the SHE
policy. The details of this policy and the
importance of communicating this policy
to all staff are discussed in the following
sections.
2.1 EPA SHE Policy
The President has directed the head of
each federal department and agency to
establish a safety, health, and environmen-
tal management program (SHEMP)
to ensure that federal employees are pro-
vided safe and healthful workplaces, and
that federal employees comply with all
federal, state, interstate, and local environ-
mental mandates. The EPA is firmJy corn-
mifled to meeting this order and ensuring
strong SHE performance. As such, the
EPA does the following, as shown in
Figure A2-1.
2.2 C i
ication of Policy
The commitment of Laboratory Directors
is a cornerstone of promoting employee
awareness of the Agency’s SHE policy.
As such, Laboratory Directors should
place a high priority on communicating
the requirements of the policy through
Figure A2-1: Components of the EPA SHE Policy
Establishes
Agencywide
SHEMP to include
professional
practices
Safety
— Occupational health
— Occupational medicine
— Fimess/weilness
- industrial hygiene
- Environmental management
— Pollution prevention
Waste minimization
— Other SHE professional
practices
— During al] phases of the
management process
b Planning
f— Development
L Implementation
During evaluation
activities
Ensures that
SHEMP issues
are addressed
Administers the
. Agency’s activities
Protects safety and
health of staff
i—Provides for safety of
L material assets
Prevents, controls, and
abates environmental
pollution
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June 1998
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SHEMP Operations Manual for Laboratories
CRAPrER A
Management and Administration A2. Management Leadership and Employee Involvement
ongoing and clear communication and dis-
cussion, as well as visible top-management
commitment. The policy statement can be
communicated to laboratory employees in
several ways. Examples are demonstrated
in Figure A2-2.
However, to be effective, the policy state-
ment must be communicated to the
employees not only by word, but also by
action and example. Top-management
commitment must be supported and reaf-
firmed through consistent actions that
demonstrate the resolve and intent of the
statement. Examples include:
Complying with all applicable require-
ments (such as following safety rules
in the laboratory)
Accompanying the safety committee
or chemical hygiene officer (CHO) on
regularly scheduled inspections
• Attending safety meetings regularly
• Maintaining an “open door” policy;
establishing times that employees can
stop by and discuss SHE concerns
• Bringing SHE matters to the attention
of employees through existing
in-house publications and memoranda
(e.g., newsletters, bulletins)
• Using SHE promotional items such as
posters, booklets, pamphlets, and
audiovisual materials
• Acting on recommendations from the
safety committee (or an employee
responsible for safety and health)
in a timely manner
• Making frequent and regular walk-
throughs of laboratory areas, taking
the time to ask questions and solicit
feedback on SHE issues
Figure A2-2: Methods to Communicate SHE Policy
Present the Policy
at New Employee
Orientation
Incorporate
the Policy into the
Chemical Hygiene
Plan or other Written
SHE Programs
r
EPA
SHE Policy
Circulate the Policy
at Meetings and
Through Internal
Communications
Post the Policy
in a Conspicuous
Location
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
This type of visible involvement in the lab-
oratory’s S1{EMP will provide a valuable
role model for employees and increase the
effectiveness of the written SHE programs.
3.0 Goals, Objectives, and Targets
The EPA’s SHE policy is made specific to
each laboratory through the establishment
of clear goals and objectives related to
SHE performance. Goals and objectives, if
properly designed, also set the framework
for assigning SHE responsibilities, since
each employee should be able to see his or
her work activities in terms of a “bigger
picture” or a desired end state.
3.1 Developing SHE Goals
Just as a laboratory may have operational
goals (e.g., testing a chemical for carcino-
genicity), it should also develop specific
SHE goals for the workplace. These goals
should be based on the particular hazards
and risks of that laboratory and should
reflect current SHE issues and priorities.
As part of the goal-setting process, each
laboratory should assess the current state
of its SHEMP and gain a clear understand-
ing of the workplace hazards and risks that
must be managed, as well as any deficien-
cies in the programs. Refer to Chapter B of
this manual for additional information on
hazard evaluation.
Although laboratory-specific goals could
include numerical targets, such as injury
statistics where the ultimate goal is clearly
zero injuries, laboratories should also
adopt broad, descriptive goals that encom-
pass all the potential workplace hazards.
Examples of numerical and descriptive
SHE goals are presented in Table A2-l.
Numerical Goals
Descriptive Goals
Decrease the num-
ber of accidents and
incidents each year
by 10 percent.
Develop a compre-
hensive program to
assess all existing
and potential SHE
hazards.
Decrease the num-
ber of ergonomic-
related injuries by
50 percent.
Perform all opera-
tions in a way that
minimizes risks to
employees and the
environment.
Decrease the amount
of hazardous waste
generated by 20
percent.
Ensure that all
employees are prop-
erly trained.
The Laboratory Director, in cooperation
with the SHEMP Manager and other staff,
as appropriate, will be responsible for
developing SHE goals for the coming fis-
cal year and will document these goals in
any business or operating plans, as appro-
priate. The documentation should also
include the proposed method of imple-
mentation, the time frame for implementa-
tion, and the expected level of resources
(e.g., financial and personnel) that will be
needed. All annual goals (i.e., business or
operating plans) should be submitted to
the Assistant Regional Administrator for
review and approval. This SHE goal-
setting process is summarized in
Figure A2-3.
Table A2-1: Numerical and Descriptive
SHE Goals
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
3.2 Identifying SHE Objectives and
Targets
Once the goals have been established, the
Laboratory Director, in coordination with
the SHEMP Manager, staff, and others,
must identify the specific steps or action
items that will be implemented to attain
the SHE goals. These objectives and tar-
gets must be specific, measurable, realis-
tic, and attainable. Examples could
include the following:
• Develop a training tracking program.
• Create a chemical hygiene committee.
• Conduct weekly safety and health
inspections in each department.
• Eliminate hazards identified during
inspections within 24 hours whenever
possible.
• Hold and evaluate emergency evacua-
tion drills every six months.
In all cases, the objectives should be con-
sistent with the EPA’s SHE policy, linked
to a specific SHE goal, and considered part
of normal laboratory business, rather than
as special projects added on to the regular
workload. In addition, each laboratory
should consider the following guidelines
and best practices when establishing SHE
objectives and targets:
• Link objectives and targets to the
EPA’s SHE policy, laboratory-specific
SHE goals, hazards and risks, and
business realities.
• Develop objectives and targets for
each relevant function and level within
the organization.
Figure A2-3: Laboratory SHE Goal-Setting Process
a;
0
r
— •1
r
.
“ U I
• ‘ -i
Assess Current State of SHEMP
Determine Workplace
Hazards to be Managed
1
Develop Categories of SHE Goals to
Encompass all Workplace Hazards
— Waste generation
— Air emissions
— W astewater discharges
— Recycling
— Fines/violations
Compliance audit results
— Training
— Raw materials and natural resource consumption
— Other laboratory-specific categories
Submit annual SHE goals to the
Assistant Regional Administrator
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SFIEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A2. Management Leadership and Employee Involvement
• Make objectives and targets meas-
urable whenever practical; use a com-
bination of quantitative and qualitative
objectives if possible.
• Ensure that objectives and targets
specify the “what and when,” not the
“why and how.”
• Ensure that objectives and targets are
realistic and contribute to the overall
success of the business.
SHE objectives should be reviewed peri-
odically to ensure that they are meeting the
needs of the laboratory and that they
reflect current SHE issues and priorities.
All objectives and targets should be
documented, and performance against
these objectives should be measured
periodically. Figure A2-4 presents a sum-
mary of the process for identifying SHE
objectives and targets.
4.0 R
• Consider stretch targets, but don’t
make time frames too long without
interim milestones.
Attachment A2- I provides a sample
worksheet that can be used to clearly
define objectives for reaching SHE goals.
Development, implementation, and main-
tenance of a comprehensive SHEMP
requires involvement from all levels of the
laboratory organization. Therefore, clearly
defining the roles and responsibilities of
laboratory staff and management is critical
to ensure that all required activities are
managed and that personnel resources for
SHE are used efficiently.
Figure A2-4: Identifying SHE Objectives and Targets
Develop SHE Goals
Jr
Idenli1 y SHE Objectives
and Targets
Consider SHE Priorities a
Part of Laboratory Business
Specific
Measurable
Realistic
Attainable
Link to EPA SHE Policy and
Laboratory-Specific SHE Goals
Jr
&ER June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
The EPA has outlined the basic responsi-
bilities for SHIEM in EPA Order 1440.1.
Figure A2-5 summarizes the EPA SHEMP
organization. The sections to follow out-
line these responsibilities.
4.1 Assistant Administrator for
OARM
The Assistant Administrator for the Office
of Administration and Resources Manage-
ment (AA-OARM), by delegation of
authority from the Administrator, is
responsible for the following:
• Serving as the Agency-Designated
Safety, Health, and Environmental
Management Official (DSHEMO)
Figure A2-5: EPA SHEMP Organization
• Advising the Administrator and
Agency Management officials on
planning, development, and imple-
mentation of SHEMP policies and
programs as they affect Agency
employees and operations
• Exercising final authority in all
SHEMP matters that involve the juris-
diction of more than one management
official
• Maintaining a national program office
to direct the development and imple-
mentation of the agencywide SHEMP
4
Assistant Administrator
and SHEM Official
T
SHEMP Manager
4
Laborarory Managcri/
Supervisors
Employees
I
Administrator I
Director
0
o
g
9
0
-I
0
—
0
p.
‘
I
Administrator
Regional
Administrator
Assistant
Regional Designated Program Designated
SHEM Official SHEM Official
Laboratory Dkreclorj
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
4.2 Director, SHEM Division
The Director of the Safety, Health, and
Environmental Management Division
(SF1EMD), by delegation of authority from
the AA-OARM, directs the agencywide
SHEMP. As the national program official,
the Director is responsible for:
Formulating and interpreting the
Agency’s SHEMP policies, programs,
standards, protocols, goals, objectives,
priorities, and staffing requirements in
accordance with all applicable stat-
utes, regulations, and guidelines
• Advising the AA-OARM and Agency
Management officials in the planning,
development, and implementation of
SHEMP policies, programs, and stan-
dard operating practices as they affect
Agency employees and operations
• Representing the Agency in rule-
making presentations before advisory,
legislative, or other groups and in
forums regarding activities that affect
the SHEMP
• Contributing to the formulation of
government-wide SHE policy and
practices. This is accomplished
through participation in external com-
mittees, organizations, associations,
standard-setting groups, projects, or
other professional groups affecting
SHEMP activities and affecting fed-
eral employees
• Providing Agency officials with tech-
nical assistance and consulting ser-
vices for complex SHE problems
• Designing, developing, and maintain-
ing computerized management infor-
mation systems for the collection, pro-
cessing, analysis, and dissemination of
data related to the Agency’s SHEMP
• Retrieving, correlating, and analyzing
data related to the Agency’s SHEMP
and making recommendations for cor-
rective actions throughout the Agency
• Conducting inspections and investiga-
tions of Agency workplaces to evalu-
ate any reported unsafe or unhealthful
working conditions and alleged acts of
reprisal towards employees, and issu-
ing reports to the appropriate Agency
officials, including recommended cor-
rective actions
• Evaluating all aspects of the Agency’s
SHEM.P, presenting reports to the
appropriate Agency officials, and pro-
viding consulting services to those
officials pertaining to corrective
actions
• Serving as a focal point for the design
and presentation of SHEMP education
and training courses and materials
• Providing coordination and liaison on
SHEMP activities with the Office of
Personnel Management; Department
of Labor; Department of Health and
Human Services; Consumer Product
Safety Commission; Genera] Services
Administration; Department of Trans-
portation; Department of Justice; state
and local governments; colleges and
universities; and other interested or
affected organizations or parties, to
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Mministration A2. Management Leadership and Employee Involvement
control oversight activities, research,
technical assistance, or other activities
affecting the Agency SHEMP
Establishing “Centers of Excellence”
to support the development of national
program requirements for SHEMP
43 RAs or AAs, S}IEMI)
The Regional Administrators (RAs) or
Assistant Administrators (AAs) are
responsible for:
• initiating and ensuring effective opera-
tion of a comprehensive SHEMP
within their area of responsibility (e.g.,
region or program)
• Designating a senior management offi-
cial to serve as the Designated Safety,
Health, and Environmental Manage-
ment Official (DSHEMO) within their
region or program of responsibility
44 Regional/Program Designated
SEEM Official
The RDSHEMOIPDSHEMO is a
regional/program senior management offi-
cial designated by the RA or AA to have
responsibility and authority to direct all
regional or program SHEMP activities in
coordination with, and under the guidance
of, the Agency DSHEMO. The
RDSHEMOIPDHSEMO is responsible
for:
• Establishing a comprehensive SHEMP
within their area of responsibility that
is designed to: reduce human and
financial losses incurred from injuries
and illnesses; ensure compliance with
all applicable federal, state, and local
regulations and legislation; and com-
ply with all Agency SHEMP policies,
component programs, and SOPs
• Providing the necessaiy qualified sub-
ordinate staffing, financial resourees,
and management support to develop,
implement, and effectively manage the
SHEMP
• Furnishing Agency employees with
places and conditions of employment
that are free from recognized hazards
that may contribute to the occurrence
of occupational-related injury, illness,
death, or environmental pollution
• Ensuring prompt response to all
reports of unsafe or unhealthful condi-
tions and establishing procedures
designed to ensure that no employee is
subject to any interference, discrimina-
tion, or other type of reprisal for
reporting such conditions
• Ensuring that regular (e.g., at least
annual) inspections and audits of all
workplaces are performed by qualified
and properly equipped personnel, and
providing for adequate employee rep-
resentation during such inspections or
audits
• Ensuring prompt abatement of unsafe,
unhealthful, or environmentally
unsound working conditions and the
prompt posting of notices for identi-
fied conditions that cannot be immedi-
ately abated upon discovery
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SHEMP Operations Manual for Laboratories
CHAFFER A
Management and Administration A2. Management Leadership and Employee Involvement
• Providing SHEMP training for
employees and managers
• Ensuring participation by, and consu’-
tation with, employees or their repre-
sentatives in all SHEMP activities
• Ensuring that SHEMP responsibilities
are integrated within job descriptions
and performance standards of manag-
ers, supervisors, and employees
• Taking appropriate disciplinary
actions as required to ensure that man-
agers, supervisors, and employees
understand the importance of, and
faithfully perform, their SHEMP
responsibilities
• Furnishing, upon SHEMD request or
as otherwise directed, all SHEMP-
related reports (e.g., annual evalua-
tions, inspections, audits, investiga-
tions, etc.), statistical information
(e.g., injury, illness, damage, loss,
cost, etc.), and/or other related
information
4.5 Laboratory Director
The Laboratory Director is ultimately
responsible for ensuring the safety and
health of all laboratory employees and for
ensuring compliance with all applicable
SHE requirements. The Laboratory Direc-
tor, in coordination with the SHEMP
Manager and with laboratory managers
and supervisors, has the overall responsi-
bility for implementing the SHE programs
for their laboratories. Specific responsibili-
ties include the following:
• Ensuring that budget submissions
include appropriate funds and other
resources to effectively implement and
administer Agency SHE programs that
apply to their laboratories
• Maintaining a baseline understanding
of the SHE requirements that apply to
their operations
• Ensuring that all their employees have
received adequate training to conduct
their job safely in accordance with
good industrial hygiene and chemical
hygiene practices
• Ensuring that the laboratory personnel
have the right equipment and facilities
to handle materials safely and perfonn
their work in a manner that does not
jeopardize human health or the
environment
• Ensuring that appropriate PPE is avail-
able and maintained in good working
condition
• Providing for regular, formal inspec-
tions of the laboratory to verify com-
pliance with applicable SHE regula-
tions (e.g., inspections of emergency
equipment, housekeeping practices,
hazardous waste storage areas, etc.)
4.6 SHEMP Managers
SHEMP Managers are those managers
who possess the technical skills, manage-
rial ability, and the authority and responsi-
bility (as delegated by their RDSHEMO/
PDSHEMO) to perform the following
duties:
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER A
Management and Administration
A2. Management Leadership and Employee Involvement
• Advise and assist senior managers and
supervisors in developing, implement-
ing, and evaluating comprehensive
SHEMPs based on the Agency’s
national SHE objectives, and the
requirements specific to each program
area activities.
• Investigate and report all work-related
accidents, injuries, and illnesses.
• Manage the laboratory’s emergency
planning and response program and
coordinate with the local fire depart-
ment, state fire marshal office, and the
local emergency planning committee.
• Manage facility compliance with the
federal Clean Water Act and state
and local wastewater discharge
requirements.
• Ensure that all operations generating
hazardous wastes as defined under
RCRA are managing wastes in accor-
dance with federal, state, and local
regulations, and EPA policy. Provide
technical direction to staff regarding
collection and storage of hazardous
wastes. Ensure that adequate records
are maintained to allow efficient and
accurate preparation of hazardous
waste manifests, U.S. Department of
Transportation (DOT) labels, and
reports to regulatory agencies.
• Conduct periodic SHE compliance
inspections of research laboratories,
offices, hazardous material, and waste
storage areas. Report deficiencies to
senior management and recommend
and/or implement corrective actions.
• Manage the EPA Occupational Medi-
cal Surveillance Program. Communi-
cate program requirements to staff,
organize and schedule employee par-
ticipation, and coordinate delivery of
program services with the U.S. Public
Health Service Division of Federal
Occupational Health or other compe-
tent providers of professional health
care services.
• Plan, organize, and schedule staff
training programs encompassing
all areas of SHE compliance require-
ments. Examples of required training
as found in EPA, OSHA. and DOT
regulations include, but are not
limited to: hazard communication,
hazardous materials/waste manage-
ment, laboratory and field safety,
use of personal protective equipment,
emergency planning, fire extinguisher
training, etc.
• Provide direct assistance to their
RDSHEMOIPDSHEMO and senior
management officials in the develop-
ment, management, implementation,
and evaluation of the SHEMP within
their area(s) of responsibility.
• Ensure that SHEMP activities within
their area(s) of responsibility are
designed and implemented in compli-
ance with requirements set forth in
SHEMP orders and related program
and practice issuances.
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A2. Management Leadership and Employee Involvement
4.7 Laboratory Managers and
Supervisors
According to EPA Order 1440.1, labora-
tory managers and supervisors axe respon-
sible for assisting the SI-IEMP Manager
and the Laboratory Director in imple-
menting the laboratory SFIEMP.
Specifically, laboratory managers and
supervisors are responsible for:
• Providing workplaces that are free
from SHE hazards that may contribute
to job-related injury, illness, death, or
environmental pollution
• Complying fully with all applicable
SHE regulations, policies, and stan-
dards that apply to their individual
laboratories and operations
Other responsibilities may include:
• Ensuring that all their employees have
received adequate training to conduct
their job safely in accordance with
good industrial hygiene and chemical
hygiene practices
• Ensuring that all their employees have
the right equipment and facilities to
handle materials safely and perform
their work in a manner that does not
jeopardize human health or the
environment
• Ensuring that appropriate PPE is avail-
able and maintained in good working
condition
• Ensuring compliance and performance
improvement through management-
led self-assessments and inspections
• Leading or assisting with accident and
incident investigations
4.8 Laboratory Health and Safety
Officer/Chemical Hygiene Officer
Every regional laboratory must have a
health and safety officer or a CHO to sup-
port development and implementation of
the laboratory SHEMP. The CHO is
required to:
• Oversee the procurement, use, and
disposal of hazardous substances.
• Assist in identifying hazardous opera-
tions, establishing safe work practices,
and selecting protective equipment
and other exposure controls.
• Set criteria for evaluating potential
exposures (including description of
circumstances requiring prior approval
for use of hazardous chemicals and/or
conduct of hazardous operations).
• Arrange for employee exposure moni-
toring; inform employees of the results
and use data to aid in the evaluation
and maintenance of appropriate labo-
ratory conditions.
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Management and Administration
A2. Management Leadership and Employee Involvement
• Develop the written chemical hygiene
plan (CHP) to include rules and proce-
dures for safe work practices; review
and evaluate the effectiveness of the
CHP at least annually and update it as
necessary.
• Serve on the chemical hygiene com-
mittee, if applicable.
• Ensure that the CHP is available to all
laboratory employees.
• Develop SHE training plans and pro-
grams, conduct training courses, estab-
lish safety references, and establish
recordkeeping systems to document
training activities.
• Conduct formal, periodic laboratory
inspections to ensure compliance with
laboratory and EPA policies.
• Correct deficiencies in the SHE
program.
• Investigate and report (in writing) to
laboratory management any significant
problems pertaining to the safe opera-
tion of equipment and the facility, and
to the implementation of control
practices.
• Support follow-up to accidents and
incidents and assist with accident
investigation.
• Coordinate with occupational health
services to establish a system for pro-
viding medical consultations and
examinations.
• Coordinate recordkeeping systems for
exposure monitoring and medical
consultations/evaluations.
• Coordinate with the radiation safety
officer, the biosafety officer, etc., on
related SHE matters, as necessary.
• Keep up-to-date on regulatory and
legal requirements associated with the
use of hazardous substances.
4.9 Employees
According to EPA Order 1440.1, all labo-
ratory employees are required to:
• Comply fully with all applicable
SHEMP requirements in the perfor-
mance of their assigned tasks.
• Perform all assigned tasks (including.
those activities not covered by existing
rules or regulations) in a safe and
healthful manner, and with the least
detrimental impact on the
environment.
• Report any unsafe or unhealthful con-
ditions or acts to their supervisor for
corrective action. fNo:e: When local
solutions prove ineffective or are not
provided in a timely manner, employ-
ees have the right and responsibility to
seek further resolution through
Agency channels, she Director,
SHEMD, or OSHA.J
hi addition to the above responsibilities,
laboratory employees should follow the
responsibilities outlined in specific
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S HEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A2. Management Leadership and Employee Involvement
program documents, such as the laboratory
CHP. Specific responsibilities under these
programs may include:
• Wearing and properly maintaining the
necessary personal protective
equipment
• Using engineering controls and safety
equipment properly and according to
all applicable requirements
• Following good industrial hygiene and
chemical hygiene practices
• Participating in all required training
programs
• Reading, understanding, and signing
off on SHE standard operating proce-
dures and similar program documents,
such as the CHP, emergency response
plan, etc.
• Immediately reporting to their supervi-
sor or the CHO all facts pertaining to
accidents, incidents, and potential
exposures to hazardous substances
4.10 Collateral Duty
When an employee is appointed to a
collateral-duty position or to a committee,
training for collateral duty must be com-
pleted prior to beginning their assigned
responsibilities. Such training shall
include the following:
• Agency SHEM program
• Section 19 of the Occupational Safety
and Health Act, Executive Order
12196, 29 CFR 1960
• Procedures for reporting, evaluating,
and abating hazards
• Procedures for reporting and investi-
gating allegations of reprisal, recog-
nizing hazardous conditions and
environments, and identifying and
using SHE standards
• Other appropriate rules and
regulations
The U.S. Department of Labor (DOL)
offers Course #600 “Collateral Duty
Course for Other Federal Agencies.” This
course introduces Agency collateral-duty
(,part-time) SHE personnel to the topics
listed above. It enables them to recognize
basic SHE hazards in their own work-
places and to effectively assist Agency
SHEMP Managers in their inspection and
abatement efforts.
5.0 Authority and Accountability
To ensure that the laboratory SHEMP is
not a “paper tiger” with no real power or
commitment behind it, management must
provide employees with the authority to
execute their responsibilities. For example,
employees who are responsible for main-
taining ventilation equipment should be
given the authority to halt laboratory oper-
ations if the equipment malfunctions.
In addition to the provision of authority,
there must also be a mechanism to hold
each person accountable for fulfilling his
or her responsibilities. At each laboratory,
there must be a formal system to track the
SHE performance of top management,
supervisors, and employees, and to reward
or correct this performance as necessary.
EPA June 1998
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SHEMP O rations Manual for Laboratories
CHAFFER A
Management and Administration
A2. Management Leadership and Employee Involvement
Key elements of any authority and
accountability system, including those
related to SHE responsibilities, include:
• Job descriptions
• Job performance measures
• Discipline and reward programs
Each of these areas are discussed in more
detail in the following sections.
5.1 Job Descriptions
Each level in the organization plays a sig-
nificant role in developing and implement-
ing a laboratory SHEMP. However, before
employees can be held accountable for
these responsibilities, it is critical that they
understand what is expected of them. A
written job description is a simple tool for
accomplishing this objective.
Current job descriptions should be
amended to include the general SHE
responsibilities of a given position. For
example, the job description for a labora-
tory supervisor or manager should include,
at a minimum, SHE responsibilities. For
positions with more extensive SHE
responsibilities, such as the CHO, it may
make more sense to include these respon-
sibilities as an attachment to that person’s
existing job description. If existing job
descriptions cannot be amended or revised,
other mechanisms to document SHE
responsibilities should be used, such as
responsibility matrices, documentation in
SHE manuals and procedures, etc.
In all cases, however, job descriptions
(or equivalent) and SHE responsibilities
should be reviewed with each employee
prior to hire. In addition, documented job
descriptions should be reviewed periodi-
cally and revised as necessary to reflect
changing SHE responsibilities.
5.2 Job Performance Measures
All managers, supervisors, and employees
will be rated on their performance in com-
plying with the requirements of the
SHEMP. This will normally occur during
the routine performance evaluation. To
facilitate this process, it is important that
Laboratory Directors (with the necessary
assistance) develop individual SHE job
performance measures for all positions
with significant SHE responsibilities. The
following considerations will help set rea-
sonable performance measures:
Establish measurable objectives,
rather than general expectations. For
example, “Hold at least one safety
meeting each week” is a better perfor-
mance measure than “Improve safety
and health awareness in the
department.”
• Establish performance measures for all
persons with significant SHE respon-
sibilities, not just full-time SHE staff.
• Establish measures that are directly
tied to, and consistent with, specific
SHE responsibilities and authorities.
For example, if a supervisor is respon-
sible for holding safety meetings, an
appropriate performance measure may
be the number of meetings held per
quarter.
‘&ER h June 1998
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Management and Administration A2. Management Leadership and Employee Involvement
• Establish measures that are realistic
and obtainable, improve SHE perfor-
mance, and encourage employees’s
personal growth.
• Give adequate training and resources
to meet performance expectations.
For example, if a supervisor is
expected to investigate all accidents
within 24 hours, he or she should
have been given training in accident
investigation.
• Ensure that affected persons agree
with the measures. Develop measures
as a cooperative effort between the
employee and the supervisor, and
document the measures when
consensus has been reached.
Examples of common performance mea-
sures for some “generic” job positions are
presented in Table A2-2.
Table A2-2: Generic Job Descriptions
Progress against SHE performance mea-
sures should be evaluated periodically—
at least as part of the employee’s annual
performance review. In addition, for a
SHEMP program to be strong and to
ensure that all persons take their SHE
responsibilities seriously, SHE perfor-
mance should be considered in deterinin-
ing career progression.
5.3 Incentive Programs
A successful accountability system should
ensure that there are incentives for excel-
lent SHE performance and commitment.
Therefore, all laboratories should develop
and implement appropriate SHE-related
incentive programs to motivate employees
and to stress the importance of strong SHE
performance.
Successful SHE incentive programs
emphasize the attainment of specific per-
formance measures rather than on targets
based solely on the avoidance of accidents
Posjth,u
Performance Measures
Supervisor
• Percentage of accident investigations completed within 24 hours
• Number of safety meetings held per quarter
• Level of participation in laboratory inspections
• Number of SHE-focused meetings
SUEMP Manager
Employee
• Number of job hazard analyses completed
• Percentage of audit findings corrected within a given period
• Percentage of employees who have received SHE Training on time
• Number of laboratory inspections completed per year
• Completion of required training
• Attendance at safety meetings
• Number of accidents/incidents involving the employee
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A2. Management Leadership and Employee Involvement
and injuries. In addition, the best programs
reward groups rather than individuals in an
effort to foster teamwork and a collabora-
live approach to SHE management.
However, it should be noted that incentive
programs have limitations (see Table
A2-3) and should not be substituted for
other management processes such as train-
ing and safety meetings (e.g., used for
maintaining employee awareness of SHE
issues and promoting safe work practices).
6.0 Employee Involvement
Effective SHE programs depend on the
commitment and involvement of all
employees, not simply the managerial
staff. The program should reflect the con-
cerns and ideas of personnel from each
level within the organization in order to
accurately address all potential hazards.
In addition, employees often prove them-
selves to be valuable resources for
problem-solving, rule-making, inspecting,
and training. Employee involvement can
also result in higher-quality work, since
employees who feel they are part of the
solution instead of part of the problem are
often more productive and dedicated.
There are a number of ways employees can
become actively involved in managing
SHE, including:
• Developing or revising general safety
rules
• Training newly hired employees in
safe work procedures and rules, and/or
training co-workers in revised safe
work procedures
• Developing programs and presenta-
tions for safety meetings
• Assisting in accident/incident
investigations
To accomplish these activities and foster
employee involvement, each laboratory
shall establish a SHE committee composed
of both “labor” and “management.” In fact,
OSHA’s “Basic Program Elements for
Federal Employees” (29 CFR 1960) sug-
gests that SHE committees be formed to
produce an open channel of communica-
tion for employees and management to
discuss and improve SHE policies, condi-
tions, and practices in the workplace. The
effectiveness of such a committee depends
on several factors, including:
• A well-defined mission
• Appropriate representation
• Regularly scheduled meetings with
well-defined agendas and objectives
6.1 Mission and Responsibilities
• Inspecting for hazards and developing
recommendations for corrective
actions and controls
• Conducting job analyses to locate
potential hazards and develop safe
work procedures
The mission of the laboratory SHE com-
mittee is to assist laboratory management
in providing a safe and healthy workplace.
The specific responsibilities of the SHE
committee, or its charter, should be
decided by laboratory management with
input from appropriate personnel. At a
& A June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration A2. Management Leadership and Employee Involvement
Table A2-3: Incentive Programs
Benefits
• Help develop safe work practices and attitudes; help maintain inter-
est and focus on SHE
• Serve as a good vehicle for employee involvement in the laboratory
SHEMP
• Provide a channel for communication between employees and
management
• Provide evidence of management’s commitment to SI-lB
Limitations
• Cannot compensate for unsafe conditions, inadequate programs, poor
training, and other management weaknesses
• Cannot, by themselves, eliminate accidents and incidents
• Cannot replace visible senior management commitment (e.g., pres-
ence at meetings and walk-throughs)
Pitfalls
• Should change over time, so that they continue to motivate and do
not become seen as “entitlements”
• Programs based solely on injury rates and Suction of accidents may
discourage reporting
minimum, the responsibilities and duties
of the laboratory SHE committee shall
include the following:
• Create and maintain active interest in
SHE.
• Provide a vehicle for discussion and
resolution of SHE issues.
• Promote SHE awareness and raise
issues to the Laboratory Director on
behalf of concerned employees.
• Review procedures, equipment, and
chemicals to identify potential SHE
hazards, and recommend appropriate
controls, work practices, and personal
protective equipment.
• Monitor the effectiveness of the labo-
ratory SHE programs and practices
(e.g., through annual review of CHP)
and make recommendations for
improvement to the Laboratory
Director.
• Assist the CHO, or SHEMP Manager,
in implementing elements of the labo-
ratory SHE programs. For example:
— Review the results of accident and
injury investigations to determine
if appropriate root causes and cor-
rective actions were identified.
— Participate in laboratory
inspections.
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CHAna A
Management and Administration A2. Management Leadership and Employee Involvement
— Monitor findings and reports of
workplace inspections to confirm
that appropriate corrective actions
are implemented in a timely
manner.
— Review the appropriateness of per-
sonal protective equipment used by
laboratory employees.
• Review and comment on standards
proposed by the Agency, reporting
unit, or laboratory.
• Monitor the level of resources allo-
cated and spent on SHE programs at
the laboratory, and recommend
changes to improve efficiency.
6.2 Representation
Membership of the SHE committee will be
determined by the Laboratory Director.
The structure and specific composition of
the SHE committee will vary depending
on the number of employees, laboratory
resources 5 and maturity of SHE programs
at the location. However, each committee
shall have an equal number of manage-
ment and non-management representation.
SHE staff (e.g., the SHEMP Manager)
should not be members of the committee,
but should participate regularly in commit-
tee meetings and assist the chairperson of
the committee as technical advisor.
Committee members shall serve overlap-
ping terms with a minimum of a one-year
duration, except when the committee is
initially formed. The chairperson of the
committee shall be elected by the commit-
tee members, and shall serve a term of
at least 12 months. Management and
nonmanagement members should alternate
the chair positions.
6.3 SHE Committee Meetings
Each SHE committee should establish a
regular schedule of meetings, with the pro-
vision that special meetings will be called
when critical SHE problems arise. The
committee should meet no less than quar-
terly, and preferably on a monthly basis.
To ensure that the committee is effective
and productive in each meeting, it is criti-
cal that an agenda and meeting objectives
be drafted, distributed and agreed upon
prior to the scheduled meeting. Since the
SHEMP Manager should have the best
perspective on the SHE issues of concern
or priority, he or she should draft the
agenda, but should also ensure that input is
obtained from all committee members.
The committee chairperson should
ensure that significant issues covered
in the meeting are adequately documented.
Therefore, detailed minutes of each meet-
ing should be kept, and should contain,
at a minimum:
• The name and title of each person
present
• A summary of each area that was
discussed
• Specific recommendations or action
items
Copies of the minutes should be distrib-
uted to each committee member, the
SHEMP Manager, the Laboratory Direc-
tor, and the laboratory managers, at a
minimum.
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SHEMP Operations Manual for Laboratories
CH i’r R A
Attachment A2-l: Worksheet Relating Objective to Goal
Purpose: To provide an example of a worksheet that can be used to relate objectives
to goals.
Instructions: Use this worksheet to map out the activities, responsibilities, target dates,
and evaluation of results when relating objectives to goals.
&EPA June 1998 A2-20
-------
Worksheet Relating Objective to Goal
Goal
Provide a comprehensive program to assess and prevent or
control all hazards.
Objective
_____________________
Increase employee involvement in laboratory hazard assess-
ment and control.
AC t ivi ty
Person
Responsible
Target Dates
Evaluate
Results
1. Conduct monthly all-
employee meetings to
discuss current safety
and health concerns.
Manager
Begin by June
Annually
2. Establish a joint man-
agementlemployee
committee for inspec-
tions and accident
investigations.
Manager
Committee
functioning by
September 30
Annually
3. Provide hazard recog-
nition training to the
committee members.
Safety Supervisor
Training completed by
December 31
Track
monthly
progress
Source: Occupational Safety and Health Administration (OSHA), “Managing Worker Safety and Health.”
OSHA, Office of Consultation Programs, U.S. Department of Labor, June 1992.
&EI3 % June 1998 A2-21
-------
Worksheet Relating Objective to Goal
Objective
Activity
Go
Source: Occupational Safety and Health Administmtion (OSHA), “Managing Worker Safety and Health.”
OSHA, Office of Consultation Programs, U.S. Department of Labor, June 1992.
Person
Responsible
Target Dates
Evaluate
Results
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A3.
Contractors and Visitors
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
1.0 Introduction
The actions of contractors and visitors at
EPA laboratories can affect the safety and
health of both EPA laboratory staff and the
contractor or visitor. Contractors and visi-
tors and must be informed of the potential
hazards, precautions, and safety, health,
and environmental (SHE) policies associ-
ated with the laboratory. The laboratory
must also be aware of contractor qualifica-
tions, past performance, and policies relat-
ing to SHE to ensure the safety and health
of all potentially affected staff. The labora-
tory must:
• Monitor the established programs,
procedures, and training of the con-
tractor to verify that EPA require-
ments are met.
• Monitor on-site activities for
compliance.
The following sections contain require-
ments, recommendations, and guidelines
relative to contractor selection, training,
and on-site evaluation, as well as visitor
safety.
• All contractor work is conducted in a
safe manner and contractor health and
safety programs meet or exceed
federal and state regulations, EPA pol-
icy, and laboratory-specific SHE
requirements.
Program Administration
In developing and implementing an effec-
tive contractor and visitor health and
safety program, the laboratory should
ensure that the following critical tasks are
completed:
• Development of a contractor and visi-
tor SHE orientation program that high-
lights the significant elements of the
Laboratory’s SHE programs
• Identification of contractor selection
criteria
• Periodic evaluation of the contractor’s
on-site performance
The following sections provide guidance
and recommendations for implementing
each of these key activities.
EPA Program Requiremenis
All EPA laboratories should establish a
contractor and visitor SHE program to
ensure the following:
All contractors and visitors are briefed
on the laboratory’s SHE policies and
procedures, and are informed of the
potential hazards that may be
encountered.
GEPA June 1998
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SHEMP Operations Manual for Laboratories
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A3. Contractors and Visitors
2.0 Laboratory Orientation and
Training
An effective laboratory orientation pro-
gram is critical to achieving a safe and
healthful work environment. Both contrac-
tors and visitors should receive a health
and safety orientation that highlights the
significant aspects of the laboratory’s SHE
program. This training should be given by
a qualified laboratory staff member, such
as a the safety, health, and environmental
management program (SHEMP) Manager,
and should be properly documented. A
sample orientation checklist that can serve
as documentation of laboratory orientation
and training for contractors and visitors is
provided in Attachment A3-l.
As part of the orientation and training pro-
gram, each EPA laboratory should also
develop and distribute a concise handbook
that will familiarize contractors and
visitors with the SHE policies and the
procedures that have been developed to
eliminate or minimize unsafe actions and
conditions. This handbook will serve as a
useful reference tool for contractors while
they are performing work on-site. A sam-
ple table of contents for a contractor and
visitor SHE handbook is provided in
Attachment A3-2.
The following sections provide guidance
related to the information and procedures
that should be included in a contractor and
visitor safety orientation program. Figure
A3-l summarizes the main components of
this training program.
These areas are not meant to be all-
inclusive; each individual laboratory
should determine the specific safety
policies and procedures that need to be
communicated to contractors and visitors.
It should also be noted that, in most cases,
contractors will need more information
and training related to SHE hazards and
Figure A3-1: Topics for Laboratory Orientation and Training
SHE
Hazards
Emergency
Procedwes
Roles and
Responsibilities
General
Health and
Safety Policies
Hazard
Communication
Hazardous
Work Permit
Pro ams
Laboratory
Orientation
and Training
EPA June 1998
A3-2
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
laboratory SHE requirements than visitors,
since visitors are usually escorted by a lab-
oratory representative.
2.1 Laboratory SHE Hazards
To ensure the safety of contractors and
visitors, it is important that the laboratory
provide them with relevant information
related to SHE hazards that they may
encounter. The training does not need to
be detailed, but should give the contractors
and visitors enough information to know
where the hazards are, what special pre-
cautions need to be taken, and what the
restrictions to access are because of these
hazards. Hazards that should be discussed
with contractors and visitors include, but
are not limited to, those presented in
Figure A3-2.
Contractors should also be informed of
certain areas and operations where extra
precautions must be taken because of the
unusual nature of the hazards. Such areas
may include:
• Confmed spaces
• Roof areas
• Areas under construction
• Areas where asbestos-containing
materials are located
• Laboratories where highly hazardous
materials are used
• Chemical and hazardous material
storage areas
To ensure that these hazards are ade-
quately communicated to all contract per-
sonnel, contract management should be
instructed, as part of the orientation and
training program, to hold pre-job meetings
with their employees and subcontractors.
These meetings should review the specific
hazards that may be present at each work
location or that may be associated with a
given work activity.
2.2 Emergency Procedures
It is essential that the laboratory inform
both contractors and visitors of the specific
emergency procedures that they may need
to know in the event of a fire, spill, explo-
sion, or exposure incident. For instance,
the handbook should contain, at a mini-
mum, the following information:
Figure A3-2: SHE Hazards to Discuss with Contractors and Visitors
Chemical l44!mhhh1P,.
Laboratory
SHE
Haza
(
Physical
Biological
Fire and Explosion
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Management and Administration
A3. Contractors and Visitors
• Explanation of the laboratory alarms
• Emergency telephone numbers and
points of contact
• Evacuation procedures and designated
safe areas
• Spill response procedures
• Procedures for responding to and
reporting emergencies
• General safety procedures to follow in
the event of a fire, chemical spill, or
similar emergency
Prior to their beginning work, contractors
and visitors should be shown the primary
and alternate exits in their work area, as
well as the location of any emergency
equipment.
2.3 Roles and Responsibilities
Table A3-1 outlines typical responsibilities
for contractors as compared to those for
laboratory employees. These are based on
best practices seen in various industries.
2.4 General Health and Safety Policies
Contractors and visitors should be briefed
on the general safety policies that must be
followed by all personnel while at the lab-
oratory. Although they will be specific for
each laboratory, they may include the poli-
cies as shown in Figure A3-3.
Examples of general SHE policies and
information that should be communicated
to contractors and visitors for each of these
topics are presented in the following
sections.
The delineation of roles and responsibili-
ties for SHE between the contractor and
the laboratory staff must be covered during
orientation to ensure that all SHE require-
ments are properly implemented. It is
important that the laboratory management
clearly define and communicate the activi-
ties it expects contractors to conduct (e.g.,
periodic inspections, safety meetings) to
avoid confusion and gaps in coverage.
2.4.1 Safe Work Practices
The following general safe work practices
should be included in contractor and visi-
tor orientation:
• Be alert to unsafe conditions, and
report them promptly to the SI-tEMP
Manager.
• Do not attempt a new task unless ade-
quately trained and aware of potential
hazards.
Figure A3-3: General Health and Safety Policies
Safe Work
Practices
General Health and
Safety Policies
PPE and
Tool Use
I
Housekeeping
I
I
Site Security
Vehicle
Safety
&EPA June 1998
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Management and Administration A3. Contractors and Visitors
Table A3-1: Contractor Roles and Responsibilities
Laboratory • Require contractors to conform to applicable SHE regulations,
iesponsibilities standards, and policies.
• Provide contractors with formal SHE orientation and training that
includes signs and their meaning.
• Inform contractors of known conditions or operations that may
affect the safety and health of contract employees, including chemi-
cal substances and physical agents (e.g., noise, radiation, heat).
• Provide contractors with laboratory-specific safety and health
requirements prior to their beginning work. Require contractors to
verify that this information has been disseminated to all contract
employees.
• Require contractors to provide and mandate use of appropriate
personal protective equipment.
• Conduct periodic inspections of contractor activities to verify
compliance.
• Monitor contractor performance.
______________ Investigate serious contractor injuries, illnesses, and near misses.
Contractor • Comply with all applicable SHE regulations, standards, and policies
Responsibilities relevant to their work.
• Distribute laboratory-specific SHE programs and requirements to
all employees.
• Be familiar with the conditions existing at the laboratory that
might affect the safety and health of contract employees and
subcontractors.
• Conduct periodic safety meetings and safety training as appropriate.
• Provide and use appropriate personal protective equipment to
protect contract employees and subcontractors from conditions
associated with their work.
• Supervise employees and conduct periodic self-inspections to verify
adherence to applicable SHE requirements.
• Notify the SHEMP Manager immediately of any accident, injury, or
illness involving contract employees.
• Investigate all work-related accidents and incidents. Allow the
SHEMP Manager to investigate any accidents and incidents deemed
necessary.
• Inform the SHEMP Manager immediately if a regulatory inspector
arrives at the laboratory.
&EPA June 1998 A3-5
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
• Keep fingers, hair, and jewelry away
from moving parts when operating
machinery.
• Wear properly fitting clothing suitable
for the laboratory (e.g., sandals, open-
toed shoes, and high heels are not
acceptable in the laboratory).
• Avoid practical jokes or other behavior
that might confuse, startle, or distract
another worker.
• Do not participate in horseplay in any
area of the laboratory.
• Clean all spills immediately; clean all
work surfaces thoroughly after use.
• Dispose of waste promptly and in the
proper receptacle.
• Keep electrical cords away from
pedestrian areas.
2.43 Provision and Use of PPE and
Tools
The following requirements for the provi-
sion and use of PPE and tools should be
included in contractor and visitor
orientation:
2.4.2 Housekeeping Requirements
The following general housekeeping
requirements should be included in con-
tractor and visitor orientation:
• Keep work areas clean and
uncluttered.
• Keep aisles, walkways, hallways, and
exits free of obstructions and tripping
hazards.
• Keep stairwells well-lighted and free
from extraneous items.
• Carefully stack and locate stored mate-
rial so that it does not block emergency
equipment, fixed ladders, stairways,
electrical breaker panels, or any other
safety equipment.
• Close all drawers and doors when they
are not in use.
• Do not hang clothing on or near radia-
tors, steam pipes, or other heat sources.
• Ensure that the proper personal protec-
tive equipment is available and worn by
all contract and subcontract
employees.
• Do not store tools, equipment, pipes,
debris, etc., above eye level.
• Use equipment only for its designated
purpose and in accordance with safe
operating procedures.
• Do not use any equipment or tools that
are not in good condition; do not use
electrical equipment with frayed or de-
fective cords.
2.4.4 Laboratory Security and
Restricted Access
The following general requirements for
laboratory security and restricted access
should be included in contractor and
visitor orientation:
• Obtain the proper passes and permits
before entering the laboratory.
• Display personnel identification at all
times.
&EPA June 1998
A3-6
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
• Park only in designated areas.
• Adhere to all speed limits while at the
laboratory.
• Avoid working alone in a building
whenever possible.
2.5 Hazard Ca
. a
During the safety orientation, the labora-
tory should inform contractors and visitors
of the applicable elements of the hazard
coznniunication program, including the
following:
• The location of material safety data
sheets (MSDSs) for hazardous
chemicals
• The procedure for obtaining an MSDS
while on site, including a demonstration
of any electronic system used to store
and generate MSDSs
• An explanation of any internal labeling
systems
• Requirements for right-to-know training
if possible, contractors should be given a
list of hazardous substances present within
their particular work area and copies of the
MSDSs for these materials prior to begin-
ning work. In addition, contractors should
be required to furnish the MSDSs and any
other pertinent information for any hazard-
ous materials that they bring on site. It is
also the responsibility of the contractor to
ensure that any hazardous substance
brought on site is clearly and correctly
labeled for easy identification.
2.6 Coordination of Hazardous Work
Permit Programs
The laboratory’s contractor SHE program
must also include a means for the contrac-
tor to coordinate all hazardous work per-
mit programs, including lockout/tagout,
hot work, and confined space entry. As
part of the health and safety orientation,
the laboratory should provide contractors
with an overview of permit programs, if
any, and should include a brief description
of the programs in the contractor SHE
handbook.
For permitted work involving more than
one employer, it is essential that the labo-
ratory SHEMP Manager openly communi-
cates with the contractors and coordinate
hazardous work with other laboratory
activities. Part of this coordination should
include a determination of which permit
program is to be used by the contractor.
The SHEMP Manager has the option of
requiring that contractors comply with the
laboratory’s permit program to minimize
confusion and misunderstanding. In fact,
the laboratory may choose to condition its
contract to ensure the contractor’s compli-
ance with the SHE program. If contractors
are allowed to use their own programs,
then the laboratory must ensure that all
permits are tracked and all operations are
communicated to any affected staff.
3.0 Contractor Selection Guidelines
At the very initial stages of the contracting
process, all EPA laboratories should
develop and implement control mecha-
nisms to manage the risks associated with
SERA June 1998
A3-7
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
using contractors. As such, effective
contractor management programs should
ensure the following:
• Contractor past SHE performance is
evaluated prior to initiation of the con-
tract; only qualified contractors are
accepted.
• Contractor SHE programs and proce-
dures are reviewed prior to initiation of
the contract to ensure that these pro-
grams meet or exceed regulatory
requirements.
Each of these are discussed in the follow-
ing sections. In addition, all contracts
awarded should, where appropriate,
contain written provisions that require
contractors to follow the same SHE
regulations and guidelines as EPA staff
performing similar work, in addition,
contractual provisions should address
responsibilities, accountability, and
enforcement, and should require that
all safety equipment and services be
equivalent to that provided to EPA staff.
Attachment A3-3 provides a sample
checklist that can be used to guide the
contractor selection process.
3.1 Review of Past Perfonnance
Information on a contractor’s past safety
record can provide an objective prediction
of future performance. Although most
companies rely on accident and incident
statistics to determine past performance,
there are several parameters that may be
useful, including the following:
• U.S. Occupational Safety and Health
Administration (OSHA) statistics (e.g.,
incident frequency and severity, fatali-
ties, lost-time cases, etc.)
• Experience modification rates’
• Past regulatory violations
• Past performance at the location
• Confirmation of insurance; previous
insurance records
• References from past clients
After a careful review of the information
listed above, the laboratory SHEMP Man-
ager should eliminate any unsatisfactory
contractors from the bidders list.
3.2 Review of Contractor Safety
Programs
In addition to evaluating past safety
records, the laboratory should ensure that
the contractor’s SHE programs and proce-
dures meet or exceed regulatory require-
ments. Prior to beginning work, contrac-
tors should be asked to submit the written
SHE programs and training records appli-
cable to the tasks that they will perform.
The SHEMP Manager, or other qualified
staff, should evaluate these programs and
any relevant records to determine whether:
‘Experience Modification Rate is an insurance prenuum
adjuster rate that anticipates future loss performance
cases based on past experience averaged over a 3-year
period. Lower rates mean fewer, or less severe, accidents
occurred than were expected (e.g.. the industry standard
is 1.0).
EPA June 1998
A3-8
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A3. Contractors and Visitors
• The programs comply with federal and
state regulations and EPA policies.
• Contractors have received the appropri-
ate SHE training (e.g., respiratory pro-
tection, hazard communication).
• Contractors possess the safety equip-
ment required for the job, including ade-
quate personal protective equipment and
clothing.
This type of review can serve as the basis
for an approved list of contractors, and it
will enable the laboratory to take a proac-
tive approach to minimizing accidents and
injuries involving both contractor and
laboratory personnel.
4.0 Contractor On-Site
Performance Evaluation
In establishing a contractor safety pro-
gram, the laboratory should develop a
means of evaluating a contractor’s on-site
safety performance. Best practices related
to contractor oversight and evaluation are
presented below:
• Contractors are required to conduct
periodic self-assessments and
ix spections to ensure that work is
conducted in accordance with safety
requirements.
• The laboratory conducts periodic
audits or inspections to verify compli-
ance with safety requirements.
• To address safety issues and areas of
noncompliance, SHEMP Managers
work through contractor supervisors
whenever possible (except in cases of
imminent danger).
• Contractors are required to investigate
all accidents and report accidenta/
incidents to a representative from the
laboratory.
• The laboratory tracks injury/illness
statistics for contractors to evaluate
performance and identify needed
improvements.
• Contractor safety performance is eval-
uated when the job is completed. Con-
tractors who fall short of standards
and expectations are not rehired.
4.1 Inspection of Contractor
Activities
Contractor operations should be periodi-
cally monitored (i.e., audits or inspections)
to ensure compliance with applicable labo-
ratory work practices, fire protection stan-
dards, and SHE regulations. These inspec-
tions should be conducted by the SHEMP
Manager or other persons with appropriate
training and familiarity with the contrac-
tor’s operations. Examples of the types of
issues that should be monitored for con-
tractors are provided in a sample inspec-
tion checklist in Attachment A3-4. All
areas of noncompliance should be reported
promptly to the contractor supervisor so
that corrective actions can be taken.
&EPA June 1998
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A3. Contractors and Visitors
In addition to periodic inspections, the
laboratory should ensure that a mechanism
is in place to track contractor violations.
For instance, the laboratory should use a
standard form to report significant infrac-
tions and review the forms periodically to
identify any recurring problems or sys-
temic weaknesses in the contractor’s SHE
programs.
4.2 Accident/Incident investigation
Another way that the laboratory can moni-
tor contractor performance is through a
review of accidents and incidents involv-
ing contractors. For all accidents, injuries,
and incidents involving contractors, the
contractor should be required to report the
accident immediately to the SHEMP Man-
ager. In addition, investigations should be
conducted for significant accidents/
incidents so that root causes can be identi-
fied. The level of laboratory participation
in the investigation of accidents involving
contractors can range from low to high as
shown in Figure A3-4.
Each laboratory should determine how
involved staff will be in the investigations.
In all cases, however, laboratories should
maintain copies of all contractor accident
investigation reports on file and use these
reports to evaluate contractor performance,
as needed. Another method to track con-
tractor activities is through the use of a
laboratory injury and illness log (i.e.,
OSHA Form 200-F) for contractors.
For more information on accidentlincident
investigation refer to Chapter 0.
Figure A3-4: Contractor Involvement in Accident/Incident Investigation
High Involvement
0 Low Involvement
SHEMP Manager
Conducts Investigation
1
Supervisor and
Contractor Assist
Low Severity
•0 High Severity
Contractor Performs
Investigation
Contractor Performs
Investigation
Provide Report to
Laboratory
SHEMP Manager
Assists for Significant
Accidents / Incidents
&E . June 1998
A3- 10
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SHEMP Operations Manual for Laboratories
CHAFrER A
Attachment A3-1: Contractor and Visitor Safety Orientation Checklist
Purpose To provide a standardized checklist that can be used by laboratories to
ensure that contractor and visitor safety orientation is being conducted.
Instructions: Complete this checklist at the time of contractor or visitor safety orientation.
&EPA June1998 A3-11
-------
Contractor and Visitor Safety Orientation Checklist
Date:
L ication of Work:
Description of Work to be Done:
Name of Contractor or Visitor: Number of Workers Involved:
Date Work is to Begin:
Topic
CompLded
Not Applicable
I
Emergency alarms—sound and location
2
Headcount evacuation
— local headcount locations
— central headcount locations
3
Emergency numbers
4
Accidents and injuries
5
Laboratory security and restricted access
6
General laboraxoiy safety rules
7
Traffic safety
8
Standard personal protective equipment
9
Special protective equipment
10
Respirators
11
Proper use of cools and equipment
12
Waste disposal
13
Hazards of specific work area
14
Material safety data sheets
15
Rot work permits
16
Equipment isolation
17
Confined space enuy
Yes
No
Have safety and insurance agreements been completed and approved?
Have contractor responsibilities been reviewed?
Other:
Onentation conducted by: Date
Onentacion received by: Date
-------
S}ffiPbkration ManUal for Laboratories
CIVWrER A
Attachment A3-2: Contractor and Visitor Handbook
Purpose: To provide a sample of the contents that should be included in a contractor
and visitor handbook.
Instructions: Use this table of contents when developing a contractor and visitor hand-
book or when determining if current materials are complete.
6ER6 June 1998 A3-13
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Contractor and Visitor Handbook—Table of Contents
L Introduction
A. Scope and application
B. Laboratory SHE policy
C. Duties and responsibilities
Ii. Laboratory emergency procedures
A. Alarm system and evacuation procedures
B. Emergency numbers and contacts
C. Fireslexplosions/spills
D. Medical emergencies
ifi. Laboratory security and access
A. Identification badges
B. Vehicle safety requirements
C. Restricted access areas
D. Working alone and working off-hours
IV. Laboratory hazards
A. Hazardous chemicals
B. High-noise areas
C. Asbestos
D. Confined spaces
E. Biological hazards
F. Radiation hazards
V. General SHE policies and procedures
A. Laboratory safe work practices
B. Housekeeping
C. Personal protective equipment
D. Tools and equipment
VI. Hazardous work (non-routine tasks) policies and procedures
A. Site permitting
B. Lockout/tagout
C. Confined space entry
D. Hot work
VII. Hazard communication
A. MSDSs
B. Signs and labels
C. Training
Viii. Oversight and evaluation
A. Workplace inspections
B. Laboratory audits
C. Accident/injury reporting and investigation
SEAG . June 1998 A3 14
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SHEMP Operations Manual for Laboratories
CHAFFER A
Attachment A3-3: Contractor Selection Checklist
Purpose: To provide a standardized checklist that can be used by laboratories when
selecting contractors.
Instructions: Complete this form during the contractor selection process to evaluate their
SHE performance.
&EPPt June 1998 A3-15
-------
Contractor Selection Checklist
Contractor:
Description of Contract Work:
Information Requested
Received (1)
Acceptable (‘1)
I. Incident and severity rates
2. Experience modification rate
3. Proof of insurance
4. References
5. SHE programs applicable to the task
List programs reviewed:
6. SHE training records applicable to the task
List records reviewed:
7. Equipment maintenance records/programs for
contraztor equipment brought on-site
Other:
1995
1996
1997
Fatalities
Restricted work-day cases
Days away from work
is approved to conduct the contract work de-
scribed above.
Contractor Name
SHEMP Manager
Purchasing Manager (or designee)
-------
SHEMP Operations Manual for Laboratories
CHiu’mi A
Attachment A3-4: Contractor Inspection Checklist
Purpose: To provide laboratories with a standardized checklist to use when evaluating
contractor performance.
Instructions: Use this form during an inspection to evaluate the performance of a contrac-
tor while working in the laboratory.
&EPA June 1998 A3-17
-------
Contractor Inspection Checklist
Contractor:
Laboratory/Location:
Person(s) Conducling Inspection:
Date:
Program Administration
Yes
No
N/A
1
Are safety meetings held?
2
Have accidents/incidents involving contractors been
reported and investigated?
3
Are self-inspections conducted?
4
Are emergency procedures understood and communicated?
S
Has SHE training been conducted and documented?
6
Are appropnate SHE programs or plans in place?
7
Have contractor orientations and/or pm-job meetings been
conducted?
Housekeeping
I
Is the laboratory orderly?
2
Are materials properly stored and stacked?
3
Are aisles, passageways, and roadways unobstructed?
Fire Prevention
I
Are fire extinguishers available?
2
Are smoking and open-flame policies adhered to?
3
is grounding/bonding in place for the storage and transfer of
flammables?
4
Are flammables stored in approved containers and/or
cabinets?
Personal Protective Equipment -
1
Are contractors wearing the appropnate PPE?
• Eye protection
• Hardhats
• Safety shoes
• Hearing protection
• FaB protection
• Protective clothing and gloves
• Welding helmets/goggles
• Respirators
-------
Contractor Inspection Checklist (continued)
Contractor:
Laboratory/Location:
Person(s) Conducting Inspection:
Date:
Program Administration
Yes
No
N/A
2
Are safe-work-permitting procedures followed?
• Confined space entry
• Lockout/tagout
• Hotwork
liazird Communlealiwi
I
Are containers properly labeled?
2
Are MSDSs available for contractor chemicals?
3
Are chemicals properly stored?
4
Are compressed gas cylinders secured?
5
Have contractors received hazard commurneation training?
Equipment
I
Are hand and portable power tools in good condition?
2
Are GFC1s in use or is there a ground assurance program?
3
Are scaffolds properly erected and in good condition?
4
Are ladders in good condition?
5
Are fork trucks and heavy equipment properly inspected and used
by trained personnel only?
Other deficiencies noted:
Corrective action required:
Inspection Report Sent To:
Name Position
Date
-------
A4.
Recordkeeping and Document
Control
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A4. Recordkeeping and Document Control
LU Introduction
Regulations, litigation, and employee
awareness of potential workplace hazards
have forced employers to maintain accu-
rate documentation of laboratory safety,
health, and environmental (SHE) programs
and their implementation. As such, writ-
ten programs, policies, guidelines, and
records are key components of sound labo-
ratory SHE programs. Numerous regula-
tions and standards require that laborato-
ries maintain specific documentation to
establish programs and demonstrate com-
pliance. This chapter presents the require-
ments for documentation, as well as guid-
ance for establishing and maintaining a
data control system.
Identifying federal, state, and
local requirements for recordkeeping
relative to SHE programs and their
implementation
• Developing, maintaining, and
updating required written programs
• Incorporating SHE requirements into
existing standard operating procedures
(SOP)
o Maintaining all required records,
(e.g., accident/injury, training,
exposure monitoring, medical, and
equipment)
• Completing OSHA Form 200-F
EPA Program Requirements
To ensure accurate documentation related
to SHE programs and their implementa-
tion, each laboratory must:
Follow federal, state, and local regula-
tions for recordkeeping, including
record retention, confidentiality, avail-
ability, and updating.
o Follow requirements of U.S. EPA
Directive 21 00—Tnformation
Resources Management Policy
Manual, Chapter 10 —Records
Management.
o Establish a document control and
retention procedure for SHE records.
Program Administration
To effectively manage recordkeeping and
document control, responsibilities should
be assigned for:
• Establishing effective document con-
trol and retention procedures for SHE-
related records
GERA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Adminis ation
A4. Recordkeeping and Document Con ol
2.0 Recordkeeping Requirements
EPA laboratories must follow all federal,
state, and local regulations, and maintain
the corresponding documentation. Specific
recordkeeping requirements are provided
in the following sections and depicted in
Figure A4-l.
In addition, EPA Directive 2100 defines
the EPA records management program,
including requirements and standard
Agency practices.
2.1 Written Programs and Procedures
All laboratories are responsible for having
up-to-date programs and procedures in
place to ensure that their activities are con-
ducted in compliance with applicable SI{E
requirements and policies. This documen-
tation is not limited to compliance pro-
graIns, but should also include SOPs and
emergency response plans. Figure A4-2
presents examples of the written programs
and procedures.
2.1.1 Written Programs
Each laboratory will be responsible for
developing comprehensive laboratory SHE
programs, as described in Chapter C of
this manual. Chapter C provides the mini-
mum program requirements, as specified
by regulations and EPA policy.
Although every laboratory is required to
develop and maintain a written chemical
hygiene plan (CHP), written programs for
other areas may not be required for all
laboratories. Therefore, the chemical
hygiene officer (CHO), or a similarly qual-
ified person at each laboratory, should be
responsible for determining the applicabil-
ity of these programs to laboratory
operations, and for ensuring that written
programs are developed if required.
For all written programs, including the
CHP, up-to-date copies must be main-
mined at each laboratory and be available
to all personnel, their designated represen-
tatives, or other interested parties. Typi-
cally at EPA laboratories, copies of written
Figure A4-1: Specific Recordkeeping Requirements
Recordkeeping Requirements j
F .1:..
Written Accident/Injury Medical and Traiiung Equipment.
Programs and and Illness Exposure Records Inspections
c 1 s Records. Records
IBEPA June 1998
A4-2
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SI-tEMP Operations Manual for Laboratories
CHA PT ER A
Management and Administration
A4. Recordkeepin and Document Control
programs are maintained in the library and
in the CHO’s office. Copies should also be
available for each field (e.g., trailer) labo-
ratory. The CHIP must be reviewed and
evaluated at least annually and updated as
necessary.
2.1.2 Standard Operating Procedures
Stand-alone compliance programs may not
always be sufficient to effectively manage
SHE. Compliance systems and activities
should be integrated with other operational
control systems as much as possible. Labo-
ratories should identify functions, activi-
ties, and processes that are associated with
potentially significant SHE issues or
impacts, and develop SOPs to address
these issues. For instance, these activities
may include certain maintenance opera-
tions, construction activities, contractor
work, or emergency response functions,
At laboratories, there are SOPs that may
be required above and beyond written
compliance programs as shown in Figure
A4-2.
No specific format is required for SOPs;
however, each should address the proce-
dure to be followed, the PPE needed, the
training and medical monitoring required,
and any special approval or review process
involved (e.g., hazardous work permits).
SOPs may be incorporated into the labora-
tory’s ClIP or other programs to the extent
feasible.
All SHE SOPs must be readily available
for examination during inspections, audits,
and program reviews. As with written
compliance programs, SOPs should be
reviewed and updated as needed (i.e., at
least annually) to reflect changes in
requirements, operating conditions, or
SHE hazards and risks.
- Chemical hygiene
- industrial hygiene
- Radiation safety
- Biosafety
- Ergonomics
- Pollution prevention
—Air quality
-EPCRA
—Wastewater
-SPcc
- Solid and hazardous waste
— Toxic substances control
— Visitor access
- Contractor safety
- Ventilation system maintenance
- Confined space entry
- Lockout/tagout
- Storage, receipt, transport, and
shipping of hazardous materials
- Permitting
- Spill cleanup and emergency
response
— Accident/incident investigation
- Hazardous waste transport
and disposal
Figure A4-2: Examples of Written Programs and Procedures
Written Programs
and Procedures
Standard
Operating
Procedures
GEPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A4, Recordkeeping and Document Control
2.2 Accident/Injury and illness Records
All accidents, incidents, and injuries
involving EPA staff, visitors, and contrac-
tors will be reported, investigated, and
documented. This will help to ensure that
adequate investigation of root cause is
completed, unsafe conditions are cor-
rected, and that employees receive proper
medical attention when necessary. Specific
guidance related to accident investigation
is presented in Chapter G of this manual.
However, there are recordkeeping require-
ments and guidelines for all occupational
accidents, incidents and injmies. Records
related to this process include, but are not
limited to, the following:
• EPA Form 1440-9 “Supervisor’s
Report of an Accident/Illness”
• OSHA Form 200-F, “Log of Federal
Occupational Injuries and ifinesses”
• OSHA Form 102-F, “Annual Sum-
mary of Federal Occupational Injuries
and Illnesses”
• Forms related to Workers’ Compensa-
tion claims, such as the “Federal
Employee’s Notice of Traumatic
Injury” or “Federal Employee’s
Notice of Occupational Disease”
Records related to accidents and incidents
must be maintained for five years follow
ing the end of the calender year to which
they relate. These records may be stored at
a Federal Records Retention Center that
has reasonable access. However, in all
cases, records must be available for
inspection and copying by representatives
of the U.S. Department of Labor (DOL), or
the Department of Health and Human Ser-
vices, or states accorded jurisdiction under
OSHA. Additional guidance for complet-
ing the OSHA forms is presented in the
following sections.
Figure A4-3 provides a summary of the
accident/injury and illness records.
2.2.1 OSHA Form 200-F
OSHA requires employers with 11 or more
employees to collect and maintain injury
and illness records for their own employ-
ees at each establishment. The DOL’s
Figure A4-3: Accident/Injury and I]lness Records
—Form 200-F
—Form 102-F
—Form 101
Accident/Injury and
EPA OSHA I
LForm 1440-9
—Federal Employee’s Notice
of Traumatic Injury
— Federal Employee’s Notice
of Occupational Disease
o rii June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A4. Recordkeeping and Document Control
publication “Recordkeeping Guidelines
for Occupational Injuries and finesses”
explains precisely how cases are to be
recorded on the required forms. However,
the following guidelines apply to EPA
laboratories:
o Every OSHA recordable injury and
illness must be recorded on an OSHA
Form 200-F, or equivalent, within six
working days from the time the
employer learns of the injury or
illness.
° OSHA Form 200-F must be main-
tained at each laboratory and available
for inspection, if the OSHA Form
200-F is prepared and maintained at
another location, a copy of the form,
updated to within 45 calendar days,
must be present at all times at the
laboratory.
o A supplementary form, the OSHA
101, must also be completed within
six working days from the time that
the employer learns of a work-related
injury or illness. Workers’ compensa-
tion reports, insurance reports, or other
reports may be used as substitutes if
they contain all the information
required by the OSHA 101 Form.
o The OSHA Form 200-F must be main-
mined on a calendar-year basis and
must be retained for five years at each
laboratory.
o Each year the employer must post the
annual summary of the previous calen-
dar year’s occupational injuries and
illnesses. This must be posted in a
conspicuous place by February 1st of
the calender year and remain posted
until at least March 1St.
Forms and summaries must be maintained
for five years following the end of the cal-
ender year to which they relate. They are
not considered confidential medical
records and shall be made available to
SHE committees, employees, former
employees, etc., upon request.
2.2.2 Classification of Occupational
Injuries/Illnesses
When determining whether to record a
case on the OSHA Form 200-F, it is
important to understand the classifications
of injuries and illnesses.
An occupational injury is an injury (e.g., a
cut, puncture wound, fracture, sprain or
strain) that results from a work accident or
from an exposure involving a single inci-
dent in the work environment. Injuries are,
by definition, the result of instantaneous
events.
An occupational illness Is any abnormal
condition or disorder, other than one
resulting from an occupational injury,
caused by exposure to environmental fac-
tors associated with employment. Occupa-
tional illnesses are, by definition, the result
of exposures over time, and include ill-
nesses or diseases caused by inhalation,
absorption, ingestion, and direct contact.
Table A4-1 provides some examples of
occupational illnesses and injuries. In ad-
dition, it should be noted that occupational
bloodborne pathogen exposure incidents
are typically classified as injuries, since
&EPA June 1998
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SFIEMP Operations Manual for Laboratories
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Management and Administration
A4. Recordkeeping and Document Control
Table A4-l: Occupational Injuries and Illnesses
Occupational Injuries
Occupational Illnesses
•
Animal or insect bites
•
Skin diseases
•
Cuts or puncture wounds
•
Dust diseases of the lungs
•
Fractures or sprains
•
Systemic effects of poisoning
•
Amputations
•
Heatstroke, sunstroke, heat exhaustion
•
Needlesticks
•
Repetitive trauma disorders
•
Exposures to bloodborne pathogens
•
Noise-induced hearing loss
they are generally the result of instanta-
neous events, such as needlesticks, blood
splashes, etc. However, ergonomics-
related injuries, such as repetitive trauma
disorders, are typically classified as ill-
nesses since they result from long-term
exposure.
2.2.3 Definition of Recordable
All occupational deaths and nonfatal ill-
nesses are recordable. Nonfatal occupa-
tional injuries are only recordable on the
OSHA Form 200-F if they involve one or
more of the following:
• Loss of consciousness
• Restriction of work or motion
• Termination or transfer to another job
• Medical treatment beyond first aid
• Lost workdays
2.3 Medical and Exposure Records
OSHA’s “Access to Employee Medical
and Exposure Records” standard in 29
CFR 1910.1020 requires employers to
maintain medical and exposure records
produced because of an employee’s expo-
sure to toxic substances and harmful phys-
ical agents. Employees or their designated.
representatives have a right to review their
individual employee medical or exposure
records at any time, upon request. Figure
A4-4 summarizes medical and exposure
records to be maintained.
2.3.1 Medical Records
EPA laboratory employees may be subject
to specific medical surveillance require-
ments, depending on where they work and
to which hazards they are exposed. In
addition, EPA employees may receive
medical attention following a potential
exposure incident, after responding to an
emergency, or if they experience signs and
symptoms of overexposure. Specific
medical surveillance requirements are
included in Chapter C2 of this manual.
OSHA also requires that, when an
employee first enters into employment,
and at least annually thereafter, each
employer shall inform them of the
following:
• The existence, location, and
availability of medical records
• The person responsible for
maintaining and providing access to
medical records
• Each employee’s rights to access
medical records
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
Figure A4-4: Medical and Exposure Records
A4. Recordkeeping and Document Control
Medical Records
— Pre-employment screenings
—Yearly medical examinations
— Termination examinations
— Chemical-specific medical
surveillance
— Hepatitis B vaccination
— Respiratory protection
qualification
— Audiometric testing
— Vision testing
Exposurc Records I
23.2 Exposure Records
An employee exposure record is a record
containing the information used to assess
an employee’s exposure to harmful agents.
These records include, but are not limited
to, the following information:
Material safety data sheets (MSDSs);
records of the amounts of high-risk
hazardous and OSHA toxic substances
stored and used, with the dates of use
and the names of users; or hazard
summaries that describe the
chemical(s) to which the employee
was exposed and that identify where
and when the chemical(s) were used
Radiation exposure records for
ionizing and nonionizing radiation
Each employee exposure record must
be maintained for at least 30 years,
unless a specilic SHE standard requires
a different period. However, background
data, such as laboratory reports and work-
sheets, need to be retained for only one
year. This exception applies only if the
information listed in the first bullet above
is retained for at least 30 years.
Medical and
Exposure Records
—
Environmental
and Industrial Biological MSDSs or Radiation
Hygiene Monitoring Hazard Exposure
Monitoring Results Summanes Records
Sampling results
—Collection methods
—Analytical and
mathematical methods
—Summary of relevant
background data
o Environmental and industrial hygiene
monitoring results
o Biological monitoring results that
directly assess the absorption of a haz-
ardous compound
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SHEMP Operations Manual for Laboratories
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A4. Recordkeeping and Document Control
2.4 Training Records
EPA laboratory employees will be given
initial and periodic SHE training to
address regulatory requirements and to
ensure that employees have sufficient
knowledge to conduct their work in a safe
and healthful manner without endangering
human health and the environment. All
EPA laboratories must maintain training
records for all SHE compliance to ensure
that all employees who need training
receive it, that refresher courses are pro-
vided at the appropriate intervals, and that
documentation is available should it be
needed. Figure A4-5 presents a summary
of some training topics as well as docu-
mentation information.
Some regulations, such as OSHA’s
Bloodborne Pathogens Standard, have
additional requirements for documenta-
tion. However, as shown in Table A4-2,
these requirements are typically consistent
with the general requirements. Additional
requirements for training and training
documentation are provided in Chapter C3
of this manual.
All training records should be maintained
by the CHO or the employee’s stipervisor
for the duration of employment, at a mini-
mum. Employee training records are not
confidential, and should not be maintained
with the employee’s medical records.
Figure A4-5: Summary of Recordkeeping and Training Requirements
Topics
General SHE awareness
Chemical hygiene
Substance-specific SHE
requirements
Radiation safety
Bloodborne pathogens
Protective clothing and equipment
Hearing conservation
Hazard communication
Hazardous waste handling
Occupant emergency plans
Documentation I
Topic of training
Training course agenda/content
Names of employees attending the session
Name(s) of instructor(s)
Date of training
Duration of training
Trainh Records
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SHEMP Operations Manual for Laboratories
CHA PTER A
Management and Administration
A4. Recordkeeping and Document Control
Table A4-2: Training Program Documentation Requirements
Training Program
Bloodhorne Pathogens
Documentation Requirements
Dates of the training
• Contents or a summary of the training
• Names and qualifications of the persons conducting the
training
• Names and titles of all persons attending the training
PPE
.
• The date of training
• Subject of training (i.e., what types of PPE)
• The name of the trainer
• The name of the employee trained
2.5 Equipment Records
Laboratories should also ensure that proper
documentation is maintained for all equip-
ment, particularly safety and emergency
equipment. Documentation should be kept
for all inspections, testing, and mainte-
nance, and should include the information
in Figure A4-6.
This figure also provides examples of the
types of equipment records that should be
maintained by each laboratory. This list is
not meant to be all-inclusive, and should
be supplemented with any laboratory-
specific or program-specific requirements.
Equipment records should be maintained
for at least three years and kept in an
accessible location so that users or
maintenance personnel can refer to them
when suspected malfunctions occur.
2.6 Other Records
In addition to the records discussed in the
previous sections, laboratories should
ensure that their document control systems
address the maintenance, retention, and
archiving of the following records:
o Laboratory SHE goals, objectives, and
targets
o Hazard information, including the
results of risk assessments, chemical
inventories, job hazard analyses, etc.
o Results of PPE assessments
o Minutes from safety meetings
o Major safety suggestions from
personnel
o Complaints from personnel and from
the community
o Inspection and audit reports
o Spill log
o “Near-miss” reports
o Corrective action log
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Adnumstration
Figure A4-6: Sununary of Equipment Records
A4. Recordkeeping and Document Cormol
— Testing, calibration, and maintenance of
industhal hygiene equipment
— Quarterly inspection and testing of local
exhaust ventilation
— Annual maintenance of local exhaust and
general ventilation
— Testing and maintenance of biological
safety cabinets
— Inspection and maintenance of respirators
and self-contained breathing apparatus
— Inspection and maintenance of eyewashes and
safety showers
— Inspection, testing, and maintenance of
sprinkler systems
Inspection, testing, and maintenance of fire
extinguishers
3.0 Document Control/Availability
All laboratories should ensure that SHE-
related documentation is cost-effectively
collected, stored, processed, analyzed, and
reported. To ensure that the documentation
program meets these objectives, documen-
tation control procedures must be estab-
lished that address standardized format,
sign-off, record retention requirements,
provisions for archiving information, etc.
An effective document control program
should generate a paper trail that will
provide the employee, employer, and
regulatory agencies with an accurate
representation of how exposures to
laboratory hazards are, controlled.
3.1 Document Control
Each laboratory should establish a docu-
ment control system that is consistent with
International Standards Organization (ISO)
9000 quality requirements and industry
standards. This system will be used to
create, track, store, and maintain docu-
ments related to SHE compliance. The
laboratory’s document control system
should ensure that all SHE documents are:
Approved for adequacyand quality by
qualified personnel
• Periodically reviewed and revised or
updated as necessary
• Replaced by superseded versions
when they are obsolete
• Legible, dated, identifiable, orderly
and readily retrievable
Equipment Records
Inspection, Testing and I
Maintenance Informati j
Types of Records
_Equipment type, manufacturer,
and serial number
—Names of persons conducting the
test, inspection, or maintenance
—Date of test, inspection, or
maintenance
— Summary of work performed
—Results, including any deficiencies
noted or specifications not met
—Corrective actions taken
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A4. Recordkeeping and Document Control
o Properly labeled (e.g.; for legal
requirements; as confidential; as a
regulatory report; etc.) and archived
o Protected against damage or loss
o Maintained according to established
record retention requirements
3.1.1 Identification of Requirements
As a first step in developing a document
control process, members of the Health
and Safety Committee and other key staff
should review pertinent SHE regulations
and EPA policies. This will help to ensure
that all documentation requirements that
apply to operations and activities have
been identified. If a documentation pro-
gram already exists at the facility, a
periodic review should be conducted to
ensure that the documentation program is
current. Careful consideration of the
physical form and location of records and
written programs should also be included
in this first phase.
31.2 Distribution of Documents
After documents have been developed,
laboratory management should ensure that
they are distributed, posted, and/or cir-
culated to employees, principal inves-
tigator(s), regulators, and/or other affected
parties. Audits, inspections, or other types
of review should verify that the documents
are actually used. The laboratory manage-
ment must also ensure that the documents
are readily available for regulatory inspec-
tions and annual program reviews. The
distribution system should include a list of
documents and locations with the names
of staff who keep them; signed statements
that employees have read program docu-
ments; and notification that individuals or
groups have received copies of program
documents and/or records.
3.1.3 Maintenance and Update of
Documents
Documentation programs need to remain
current, and the documentation itself needs
to be maintained as the program is imple-
mented. The laboratory should establish a
system to ensure that written compliance
programs are reviewed, updated, and
approved as frequently as necessary. In
addition, documents subject to certain
regulations (e.g., OSHA) must be retained
for specified lengths of time (e.g., medical
surveillance and exposure monitoring
records). The recordkeeping system should
be designed to ensure that staff with
“need-to-know” requirements have access
to particular records and documents, and
that confidential records are maintained as
such, in accordance with the Privacy Act.
3.2 Information Technology
Where feasible, information technology
should be used to make the management
of SHE-related data more efficient and
cost-effective. Initially, each laboratory
should assess the information system and
technology needs of their SHE activities,
and should explore options for automation
and database use.
June 1998
A4-l I
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A5.
Evaluation of Program
Effectiveness
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A5. Evaluation of Program Effectiveness
1.0 introduction
Executive Order 12196 and 29 CFR
1960.78 require the EPA to establish a
program to evaluate the effectiveness of its
own safety and health programs and to
submit an annual summary of this evalua-
tion to the Secretary of Labor. In addition.
the unique nature and diversity of hazards
at EPA laboratories make periodic inspec-
tions and walk-throughs essential. Evalu-
ating program effectiveness will ensure
that hazards are comprehensively and rou-
tinely identified, evaluated, and controlled.
The following sections provide detailed
guidance on three levels of program evalu-
ation as shown in Figure A5-l.
o Annual reviews of program effective-
ness and laboratory safety, health, and
environmental (SHE) management
systems
o Independent compliance audits and
management systems assessments
every three years, through the Safety,
Health, and Environmental Manage-
ment Division (SI{EMD).
Program Administration
To effectively implement this program,
responsibilities should be assigned for
o Conducting semiannual laboratory
inspections and annual chemical
hygiene program reviews
EPA Program Requirements
To ensure that necessary safeguarding is
provided to protect against hazards, the
following inspections, audits, and assess-
ments will be performed:
Semiannual inspections of each labo-
ratory by individuals qualified to rec-
ognize and evaluate hazards, and with
sufficient experience to suggest abate-
ment procedures
Figure AS-i: Levels of Program Evaluation
o Developing, documenting, and imple-
menting corrective actions in response
to deficiencies identified during
inspections, audits, or management
systems assessments
o Updating programs, as necessary, to
address any deficiencies or changes
identified during the inspections and
program reviews
Evaluation of
Effe
Laboratory SHEMD . Management Svs•tems
Self-Assessments Compliance Audits. Assessments
&ER4. June 1998
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SHEMP Operations Manual for Laboratories
CHAFrER A
Management and Administration A5. Evaluation of Program Effectiveness
• Maintaining all documentation related
to inspections, audits, and assessments
• Tracking trends in inspection, audit,
and assessment findings to identify
opportunities for continuous
improvement
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A5. Evaluation of Program Effectiveness
2.0 Laboratory Self-Assessments
Each laboratory shall conduct periodic
inspections and program reviews to
ensure the continued effectiveness of
SHE programs and procedures. These
self-assessments should include formal,
documented inspections, as well as annual
program reviews, as required by the U.S.
Occupational Safety and Health Adminis-
tration (OSHA) Laboratory Standard and
presented in Figure A5-2.
Laboratory inspections and program
reviews shall be conducted by Safety,
Health, and Environmental Management
Program (SHEMP) Managers or other des-
ignated, qualified personnel. Staff with
collateral-duty ShE responsibilities are
expected to be qualified to conduct labora-
tory inspections. When necessary, the
expertise of the SHEMP Manager and
collateral-duty staff should be supple-
mented by employees who specialize in
the operation of certain processes.
2.1 Semiannual Inspections
Visual inspections of federal workplaces
are required by 29 CFR 1960. For EPA
laboratories, these inspections shall be
performed by the chemical hygiene officer
(CHO) or other designated and qualified
(i.e., adequately trained) individuals (e.g.,
members of the safety committee).
The inspections shall be conducted at least
semiannually, since laboratories have an
increased risk of accidents, injuries, and
illnesses compared to the typical office
environment due to the nature of the work
performed. Prudent practice recommends:
Quarterly housekeeping inspections
for laboratories
Frequent change of inspection
personnel
o Semiannual inspections for other
laboratories
Figure 45-2: Types of Laboratory Self-Assessments
Annual Program
Reviews
— Management leadership
— Employee involvement
— Laboratory analysis program
— Emergency controls
— Employee exposure assessment
— Administrative controls
— Accident investigations
— Personal protective equipment
— Safety and emergency equipment
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SHEMP Operations Manual for Laboratories
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Management and Administration
A5. Evaluation of Program Effectiveness
In addition, more frequent inspections are
recommended if SHE performance has
been poor (i.e., if there was a significant
number of violations during previous
inspections).
A laboratory inspection checklist may be
used to guide the laboratory inspections to
ensure the integrity of the process. In addi-
tion, particular attention should also be
given to the areas discussed in the follow-
ing sections.
2.1.1 Maintenance of Equipment
For emergency and first-aid equipment
(e.g., eyewash stations and safety show-
ers), a visual inspection is not adequate.
This equipment should be tested as part
of the semiannual inspections. Additional
guidance for the testing of emergency
equipment can be found in Chapter G3
of this manual.
2.1.2 Work Practices
For accurate and representative results, the
laboratory inspection should be conducted
during normal laboratory hours and opera-
tions. Personnel may then be observed to
ensure that they are following safe work
practices and wearing proper personal
protective equipment.
2.1.3 Recordkeeping
A sample of laboratory records (e.g., train-
ing, inspection, and standard operating
procedures) should also be reviewed.
Since the purpose of the inspections is to
identify and correct safety issues, previous
inspection reports should be consulted to
ensure that past discrepancies were cor-
rected. All inspection reports should be
dated, signed, and promptly submitted to
the CHO. The review of the laboratory
records and the inspections will facilitate
the program review and evaluation of the
chemical hygiene plan (CHP), which is
required at least annually.
2.2 Annual Program Reviews
The OSHA Laboratory Standard requires
an annual review of the CHP to determine
its effectiveness. The evaluations should
be conducted in accordance with the crite-
ria and guidelines contained in the Man-
agement Systems Review Protocol in the
EPA SHE Audit Protocol.
The program assessment differs from a
simple laboratory inspection, in which
only the laboratory, processes, and work
practices are examined for areas of non-
compliance and any hazards or risks that
are inadequately controlled. Instead, a pro-.
gram review evaluates each of the manage-
ment systems that constitute the SHE pro-
gram, including the following:
• Level and effectiveness of manage-
ment leadership
• Level of employee involvement in the
SHE program
• Quality and effectiveness of laboratory
analysis programs (e.g., inspections,
surveys, job hazard analyses, etc.)
• Adequacy of engineering controls
such as laboratory hoods and other
local exhaust ventilations
EPA June 1998
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SHEMP Operations Mañtiàl foi LáboratöHés
CHAPTER A
Management and Administration
A5. Evaluation of Program Effectiveness
o Assessment of employee exposures
that may exceed the action-level, or in
the absence of the action-level, the
permissible exposure level
o Adequacy of administrative controls
(e.g., recordkeeping, medical surveil-
lance, training, etc.)
o Adequacy of accident and “near-miss”
investigations
o Appropriateness, availability, and
condition of personal protective
equipment
o Availability, location, and condition of
safety and emergency equipment
The annual program review should be con-
ducted by the CHO and the results of the
assessment should be communicated to the
S HEMP Manager, laboratory supervisors
and Laboratory Director, at a minimum.
3.0 SHEMD Compliance Audits
The SHEMD will conduct compliance
audits of each laboratory at least every
three years.
The objectives of the SI{EMD audit are to:
o Determine the laboratory’s compliance
status with applicable SHE regulations
o Evaluate the effectiveness of SHEM
systems
o Make recommendations to improve
compliance and correct identified
compliance problems
o Increase the overall level of SHE pro-
gram awareness at the laboratory
The audit will consist of the activities as
presented in Figure A5-3.
4.0 Management Systems Assessments
Each SHEMD audit will also include a
review of management systems and
practices.
Figure A5-3: Components of SHEMD Compliance Audits
Evaluation of
Compliance with
Regulations.
Policies and
Requirements I
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER A
Management and Administration
A5. Evaluation of Program Effectiveness
Management systems assessments will
identify risks and hazards that result from
both a lack of knowledge (i.e., knowledge-
based deficiencies) and a failure to take the
appropriate actions (i.e., action-based defi-
ciencies). By distinguishing between the
two types of deficiencies, the review will
uncover the root causes of problems in the
SHE program. For example, the failure to
use appropriate personal protective equip-
ment may be linked to inadequacies in the
chemical hygiene training program. By
identifying the underlying problem, or
“bottom line,” management will be better
equipped to make effective changes or
revisions to the existing SHE policies.
There are several methods that can be used
to evaluate the design and effectiveness of
a laboratory’s SHE management systems;
however, a thorough review will include
the following three activities, at a
minimum:
• Examination of documentation
• Review of laboratory conditions
• Formal and informal interviews
with employees at each level of the
organization
5.0 Assessment Documentation
Written reports of inspections, audits, and
assessments are necessary to document the
hazards discovered and responsibility
assigned for correction, and to track cor-
rections to completion. As such,
laboratories must maintain records that
document the results of all inspections,
audits, and assessments and the corrective
actions that were implemented to address
deficiencies. In addition, notices of unsafe
or unhealthful working conditions must be
prepared and maintained, as necessary.
5.1 Inspection and Audit Records
For laboratory inspections, the CHO
and/or SHEMP Manager is responsible for
maintaining all documentation related to
the inspection, including the following:
• The specific procedures followed in
the inspection
• The name of the person(s) conducting
the inspection
• The scope of the inspection
• A description of all findings that result
from the inspection
• Documentation of corrective actions
taken
For SHEMD audits and management sys-
tems assessments, copies of the reports
will be mailed to the laboratory, where
they should remain on file.
5.2 Notice of Unsafe or Unhealthful
Working Conditions
If warranted, a notice of unsafe or
unhealthful working conditions must be
issued no later than 15 days after comple-
tion of the inspection for safety violations
and no later than 30 days for health viola-
tions. A copy of these notices must be sent
to key personnel (e.g., CHO, Laboratory
Director, supervisor), and where there are
compelling reasons why such notice can-
not be issued within this time frame, the
key personnel must be orally informed. All
notices must describe the nature of the
hazard and the severity of the unsafe or
unhealthful working condition, and, if pos-
sible, should also include reference to the
applicable standard or other requirement.
In addition, the notice should include a
reasonable time for the correction or abate-
ment of the condition.
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SHEMP Operations Manualror Liborátories
CHAPTER A
Management and Adniinistration
A5. Evaluation of Program Effectiveness
All notices must be posted immediately
at or near each place where the condition
exists, and must remain in place until the
unsafe or unhealthful working condition
has been abated or for three working days,
whichever is later. A copy of the notice
must be filed and maintained for a period
of five years after abatement.
6.0 Corrective Action
All areas of noncompliance identified
through inspections, program reviews,
audits, and assessments should be docu-
mented in an abatement plan. Noncom-
pliance could be defined as a deviation
from regulations; laboratory policies, pro-
cedures, objectives and targets; or the prin-
ciples of sound management.
The CHO, with input from laboratory
management and employees, will be
responsible for investigating noncompli-
ance and identifying appropriate corrective
actions. The abatement plan should clearly
describe the corrective actions that will be
taken to address the root cause of the defi-
ciency, mitigate potential impacts, and
prevent recurrence. In addition, the docu-
mented abatement plan should include, at
a minimum, the individuals responsible for
the corrective action and the expected date
of completion. If it is determined that the
deficiency eannot be corrected, the
abatement plan should clearly state the
reason behind the determination, a
description of any interim measures,
and a description of the long-term final
correction, if applicable.
If corrective actions cannot be made
within 30 calendar days, SFIEMP Manag-
ers should contact the SI-IEMD for assis-
tance in developing an abatement plan.
This plan will include the following
elements :
An explanation of the circumstances
of the delay in abatement
• A proposed timetable for the
abatement
o A summary of steps being taken in the
interim to protect employees from
being injured as a result of the unsafe
or unhealthful working condition
Completion of corrective action plans
should be monitored, and the effectiveness
of corrective actions will be evaluated
through subsequent audits and perfor-
mance monitoring.
7.0 Continuous Improvement
All inspection and audit data will be used
to drive the continuous improvement
cycle. Data on audit results, regulatory
noncompliance, etc., should be analyzed
periodically to determine trends, identify
improvement opportunities, and update
programs and procedures as necessary.
The CHO and/or SHEMP Manager will be
responsible for tracking trends in
performance. Important lessons learned
and issues identified through this process
will be shared throughout the organization.
For situations or conditions of
imminent danger, the unsafe or
unheaLthfuL condition should be
corrected inunediately or isolated
to prevent worker exposure.
a mA
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B. Hazard and Risk Analysis
& Management
-------
Bi.
Introduction
-------
SI-IEMP Operations Manual for Laboratories
CHAPTER B
Hazard & Risk Analysis and Management
Bi. Introduction
Hazards are biological, chemical, or physical conditions that have the potential for causing
harm to people, property, or the environment. They can include both equipment and material
hazards. If a hazard is combined with unexpected circumstances, unreliable physical systems,
or irresponsible actions, then it can become a risk.
The degree and complexity of management commitment and employee participation in a
safety, health, and environmental (SHE) program should be based on the degree of hazard
and risk that exists at a laboratory. Therefore, the complete and accurate identification of
potential hazards and risks is essential to the effective management of SHE issues.
EPA laboratories must implement a multi-faceted approach to hazard and risk analysis and
must also ensure comprehensive identification, evaluation, and control. Without effective
analysis, the laboratory staff will not know when controls and training are needed to mini-
mize employee exposures to any existing hazards.
The hazard and risk analysis techniques outlined in this chapter are intended to complement
one another and add to the overall effectiveness of a laboratory’s safety, health, and environ-
mental management program (SHEMP). A laboratory that relies primarily on a single
approach, such as inspections, may not completely estimate or identify hazards. For example,
a job hazard analysis may be an invaluable technique to identify hazards for certain tasks or
jobs where the hazards are not readily apparent in a walk-through inspection or superficial
observation of the operation. Implementing the approaches discussed in this chapter will
allow EPA laboratories to assume a proactive stance on hazard and risk analysis and
management. Participation by employees and other affected parties during all stages of the
risk management process is critical to successful decision-making and implementation.
Laboratory personnel involvement is encouraged throughout all phases of risk management.
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER B
Hazard & Risk Analysis and Management Bi. Introduction
These chapters provide guidance for EPA laboratories on hazard and risk analysis and
management:
Chapter
Topic
B2
Hazard Identification & Evaluation
B3
Risk Assessment
B4
Change Management
ER June 1998 81-2
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B2.
Hazard Identification and
Evaluation
-------
SHEMP Operations Manual for Laboratories
CHAFFER B
Hazard and Risk Analysis & Management
B2. Hazard Identification & Evaluation
1.0 Introduction
There are a number of different methods
that laboratories can use to identify and
evaluate safety, health, and environmental
(SHE) hazards. When used together, these
methods will provide the laboratory with
the information needed to recognize and
understand all hazards and potential haz-
ards. Approaches for hazard identification
and evaluation include:
• Surveys
• Job hazard analysis
• Hazard reporting
• Inspections
• Accident and incident investigation
• Analysis of injury and illness trends
The first two approaches listed above
address the need for developing a com-
plete hazard inventory for the laboratory
and anticipating potential hazards for a
particular job. The last four techniques
focus primarily on detecting hazards that
may not have been controlled by existing
systems. Change management, which is a
crucial and integral element of laboratory
operations, is discussed in Chapter B4 of
this manual.
The following sections outline methods for
hazard identification and evaluation. These
methods have been categorized as baseline
or periodic. Obviously, many techniques
used for baseline evaluation may also be
valuable tools for periodic analysis. This
categorization is purely used to organize
the material and is not meant to be
exclusive.
EPA Program Requirements
For an effective hazard identification and
evaluation program, each laboratory must:
Conduct a baseline identification of all
SHE hazards or potential hazards.
• Implement systems and approaches for
the periodic identification of any haz-
ards not controlled through existing
programs and procedures, including an
annual inspection.
• Implement a procedure that encour-
ages the reporting of hazards by
employees.
• Investigate accidents and incidents
with an emphasis on determining root
cause. -
• Determine any trends in accidents and
incidents.
• Identify and implement the appropri-
ate corrective action(s).
SHEM Guide 53, “Workplace Inspec-
tions,” should be referenced for detailed
guidance on conditions or situations that
warrant inspections, as well as on inspec-
tion preparation, procedures, and follow-
up activities.
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Hazard and Risk Analysis & Management B2. Hazard Identification & Evaluation
Program Administration
To effectively manage the hazard identifi-
cation and evaluation program, responsi-
bilities should be assigned for:
• Conducting a baseline identification of
hazards
• Coordinating the ongoing identifica-
tion and evaluation of hazards through
inspections, reporting, etc.
• Performing inspections
• Quickly responding to, and evaluating,
any hazards reported by employees
• Investigating accidents and incidents
• Completing accident and incident
records and investigation reports
• Periodically evaluating accident and
incident data to determine any trends
• Identifying corrective actions for any
hazards or deficiencies identified
through inspections, employee reports,
incident investigations, or other means
• Tracking corrective actions
• Implementing and evaluating the
effectiveness of corrective actions
• Maintaining documentation for the
hazard identification and evaluation
program (e.g., inspection checklists,
accident/incident reports and investi-
gations, corrective action logs, etc.)
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2.0 Hazard Identification and
Evaluation Methods
Identifying and evaluating hazards is a
four-step process:
Involve
+ Personnel
The steps can be performed in order, but
do not have to be, depending on the situa-
tion. Each step, and examples of methods
to complete the step, is described below.
2.1 Identify the Problem
A variety of methods are used to identify
problems. For example:
• Inspection of S hE monitoring results
and/or reports
• Literature reviews of toxicology and
epidemiology studies
• Review of accident and incident
records
• Sensory perception (e.g., irritation,
odor, etc.)
Two fundamental approaches toithtial
hazard identification and evaluation are
baseline surveys and job hazard analyses
(JHAs). These techniques should be used
to establish a baseline for new or modified
operations or procedures, but can also be
used in the ongoing management of haz-
ards. In addition, ongoing identification
and evaluation methods must be imple-
mented to determine if new hazards are
introduced and if control methods are
successful.
2.1.1 Baseline and Periodic Surveys
Surveys, both baseline and periodic, are
fundamental to identifying hazards. Base-
line surveys are used to establish an inven-
tory of the hazards and potential hazards at
the laboratory without the use of in-depth
analyses. Additional periodic updates of
the baseline survey can be conducted later
to ensure that previously detected hazards
have been controlled and that new hazards
have been identified. In addition, periodic
surveys can be used to conduct a more
intensive analysis in areas that have a high
potential for new or less obvious hazards.
At a minimum, EPA laboratories should
conduct a preliminary baseline survey,
followed by annual periodic surveys to
update the original findings. These
surveys should be conducted by a multi-
disciplinary team with sufficient experi-
ence and expertise to recognize hazards in
their area of review, and to identify effec-
tive corrective actions. For some laborato-
ries, it may be necessary to supplement the
team with appropriate personnel from out-
side the laboratory, such as independent
SHE consultants or regional personnel.
When conducting a survey, the team
should divide the process into four phases
as shown in Figure B2-1.
Figure B2-1: Four Phases of Baseline
Surveys
Phase!
Preparation
Phase II
Walk-Through
1
Phase IlL !
Field
Measurements
4,
Phase IV
Analysis
Identify the
Problem
—+ Determine
Goals
I I
Determine
- + Problem
Context
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CHAFFER B
Hazard and Risk Analysis & Management
B2. Hazard Identification & Evaluation
The components of each of these phases
are discussed in more detail in the follow-
ing sections.
Phase I: Survey Preparation
Adequate preparation is essential to the
success of a survey. Prior to a survey, the
team should become familiar with the
operations at the laboratory, and identify
which areas or operations have potentially
significant risk and might require closer
evaluation. Since the survey team must
understand the extent of the regulatory
requirements, it is also necessary to have
an up-to-date list of applicable regulations,
as well as the laboratory-specific require-
ments, prior to starting the survey. This
task should be completed before every
baseline and periodic survey, since exist-
ing regulations may have changed and new
regulations may have been promulgated.
Once the survey team has gained a clear
understanding of laboratory operations,
and has reviewed all of the relevant
documentation, it should be able to
evaluate the potential hazards that may be
encountered in the laboratory. The survey
team should then use this information to
develop a strategy that will result in an
efficient and thorough hazard identifica-
tion. Refer to Figure B2-2 for a summary
of the components of Phase I.
Phase ii: Walk-Through
Once the survey preparation has been com-
pleted and the potential hazards have been
identified, the team should conduct a
walk-through survey to:
• Verify compliance and conclusions
made in Phase I.
• Identify easily recognizable hazards
not anticipated in Phase I.
• Assess the effectiveness of the hazard
controls in place.
• Determine which detailed studies will
be needed for Phase ifi.
Figure B2-2: Phase I of a Baseline or Periodic Survey
- Laboratory
operations
- SHE regulations
- EPA requirements
- High-risk operations,
chemicals, or agents
Review
_MSDSs and SHE
documents
— Hazard inventories
— Industhal hygiene
monitoring and environ-
mental sampling records
— Accident, incident and
illness reports
— Findings from previous
surveys
Phase I:
Survey
Preparation
Develop
L Survey strategy
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CHAPTER B
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B2. Hazard Identification & Evaluation
Dwing the wallc-through, the survey team
must be ready to accept any new informa-
tion that may change the direction or focus
of the survey from the original design
established in Phase I. Team members
should observe and interview employees
performing routine and special tasks;
review equipment and facilities (including
ventilation systems); and note obvious
signs of exposure, contamination, or emis-
sions. For example, signs of exposure
could include: airborne dust, smoke, mist,
and aerosols; surface accumulation of dust,
liquid, or oil; odors from solvents or gases;
unusual tastes; and burning or irritation of
the nose or throat.
If industrial hygiene or environmental
sampling is needed in Phase ifi, a walk-
through will also provide the survey team
with critical details for the design of an
effective sampling plan. As the survey
team conducts the walk-through, they
should ensure that the following items are
documented pertaining to potential Phase
ifi concerns:
• Description of tasks and operations
having potential exposures or
emissions
• Description of associated controls for
these tasks and operations
• Frequency and duration of operations
with potential exposures or emissions
• Number of employees potentially
exposed
• Description of air, water, solid, and
hazardous waste generated
Although a walk-through survey is only a
snapshot in time, the effectiveness of the
hazard controls in place (e.g., engineering,
administrative, and work practice) can be
assessed easily through observation.
Issues that should be evaluated include,
but are not limited to, chemical and waste
storage, disposal, ventilation, respiratory
protection, protective clothing, radiation
shielding, training, general work practices,
standard operating procedures (SOPs),
written programs, and recorcikeeping.
Refer to Figure B2-3 for a summary of the
components of Phase II.
Figure B2-3: Phase II of a Baseline or
Periodic Survey
Observe
_Tasks and
operations
-Compliance with
SHE practices
—Engineering controls
- Obvious signs of
exposure, contamination,
or emissions
- Waste generated
Phase III: Field Measurements
Once the walk-through has been com-
pleted, enough information should have
been obtained to determine whether
follow-up investigation is needed. For
example, after determining that workers
may be exposed to levels of methylene
chloride above acceptable limits, the
survey team should coordinate industrial
hygiene monitoring to quantify the
potential exposure more accurately.
Refer to Chapter C5 of this manual for
additional information on industrial
hygiene sampling.
Refer to Figure B2-4 for a summary of the
components of Phase 111.
Phase II:
Walk-Through
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Figure B2.4: Phase Ill of a Baseline or
Periodic Survey
Phase m:
Field
Industrial hygiene
monitoring
Environmental
sampling
Phase IV Analysis
The final phase of a survey involves evalu-
ating information obtained in Phases I
through III. Both the qualitative and quan-
titative findings concerning hazards
encountered in the survey should be used
to develop a list of needed controls or
work practices, as well as improvements to
the management systems. In addition, this
final phase should include an evaluation of
any new permitting or monitoring require-
ments that were identified during the walk-
through. Refer to Figure B2-5 below for a
summary of the components for Phase 1V.
Information obtained from the surveys
can also be incorporated into other hazard
analysis techniques. For instance, obser-
vations recorded in the walk-through can
be used to develop a checklist for routine
inspections. Once the analysis has been
completed, the team, along with the appro-
priate laboratory personnel, should review
the concerns identified in the survey.
In addition to the baseline survey, the
team should evaluate hazards with the
potential for off-site impact. The evalua-
tion should include determining the appli-
cability of the U.S. Occupational Safety
and Health Administration’s (OSHA’s)
Process Safety Management Standard in
29 CFR 1910.119 as well as EPA’s Risk
Management Program requirements in
40 CFR 68.
2.1.2 Job Hazard Analysis
A job hazard analysis (JHA) is a syste-
matic method for identifying the hazards
of a particular task or job, hazards that
may not be readily apparent from a cursory
examination of the operation. This tech-
nique is a process that provides a thorough
evaluation of the entire procedure in ques-
tion. First, all the basic steps required to
complete ajob or task are identified in the
sequence in which they occur. Next, each
step is closely examined to identify where
potential accidents could occur, where
exposure to hazardous agents could exist,
and which changes in practice or condi-
tions could create new hazards.
After each hazard or potential hazard has
been listed and reviewed with the
employee performing the job, recommen-
dations on eliminating the hazards are
Figure B2-5: Phase IV of a Baseline or Periodic Survey
Phase IV:
Analysis
Develop a list
of hazards for
control and
training
Conduct
Review and
analyze data
from
Phases I to III
Incorporate
findings into
other hazard
analysis elements
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Hazard and Risk Analysis & Management
B2. Hazard Identification & Evaluation
developed. Table B2-l outlines the steps
of the JHA process. A sample JHA
worksheet is presented in Attachment
B2-l to this chapter.
For a JHA to be most effective, it should
be conducted by trained personnel who
have experience in many aspects of SHE
management (e.g., industrial hygiene, fire
safety). In many cases, a team approach
will provide the most valuable informa-
tion. Whether JHAs are conducted by
Table B2-I: ,JHA Process
individuals or teams, it is essential to
always involve an individual who per-
forms the task being assessed.
Recommendations resulting from a JHA
can take many forms. Some may involve
combining or changing the sequence of job
steps, adding engineering controls, or
revising written programs. For instance, a
properly conducted JHA may reveal that
the laboratory’s SOPs are incomplete or
nonexistent, or that the personal protective
Select the job to be analyzed.
Break the job down into successive steps.
Identify the hazards and potential accidents. For each job step, determine what
accidents could happen to the employee performing the job step:
• Recall past accidents and incidents.
• Examine how the task and environment interact with the employee:
— Can the employee be struck by anything?
— Can the employee strike up against or come into contact with anything?
— Can the employee be caught in, on, or between anything?
— Can the employee fall?
— Can the employee overexert?
— Can the employee be exposed to anything injurious?
• Examine how the employee interacts with the each job step:
— In what ways can the employee’s implementation of steps (sequence) present
hazards?
— In what ways can the time frame for the job step present hazards?
— In what ways can the employee’s use of materials present hazards?
— I.n what ways can other deviations of expected actions and assumptions
present hazards?
Evaluate the effectiveness of existing control measures.
Review the findings with employees who perform the job task.
Formulate recommendations for improved SHE management.
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B2. Hazard Identification & Evaluation
equipment selected does not adequately
protect the employees from the hazardous
agents used. A i RA may also show that
the training provided to employees has not
been effective. In other instances, it may
be necessary to redesign equipment,
change tools, or provide extra machine
guarding. In all cases, however, recom-
mendations should be clearly communi-
cated to the employee, and should be as
specific to the procedure as possible.
A JHA should be updated periodically,
even if changes have not been made in the
job. Also, if an accident or injury occurs,
the JHA specific to that job should be
reviewed to determine if changes in the
procedure are necessary. When changes
are mandated, SHEMP Managers should
ensure that affected employees have been
properly trained in the new procedure.
2.13 Ongoing Hazard Identification
and Evaluation
Periodically, the laboratory should deter-
mine if hazards identified through the
baseline survey are being effectively con-
trolled by existing systems and procedures.
In addition, ongoing identification and
evaluation methods are important in iden-
tifying any new hazards that may not have
been captured by change management pro-
cedures. Ongoing hazard identification and
evaluation techniques include:
• Hazard reporting
• Inspections
• Accident and incident investigation
and analysis
• Tracking and trending
• Employee input and participation
Each of these techniques are described in
the following sections.
Hazard Reporting
Employees who work in a laboratory every
day are an invaluable source of SHE infor-
mation. With proper training, employees
are likely to be the first to identify a hazard
or a possible inadequacy in protective sys-
tems, equipment, or procedures. For this
reason, the laboratory should institute a
reliable system for employees to notify
management of existing or potentially haz-
ardous conditions. In an effective system,
employees must have no fear of reprisal,
and management must take credible and
timely action to address problems that are
revealed, in EPA laboratories, employees
should be encouraged to first report a
hazard to theft supervisor and the SHEMP
Manager. If this is not possible, SHE com-
mittee members should be contacted. If
any of these persons cannot be reached,
the Laboratory Director should then be
contacted.
As discussed in Chapter A2 of this man-
ual, employee involvement is critical to
the success of a SHEMP. Each laboratory
should develop a mechanism to encourage
hazard reporting; this system should be
based on management controls that are
founded on employee involvement,
responsibilities, authority, and resources.
inspections
Once hazards have been identified in a
workplace and hazard controls have been
established, the laboratory should conduct
routine SHE inspections to monitor the
effectiveness of these controls and to iden-
tify new or previously undetected hazards.
Unlike comprehensive surveys or audits,
inspections require minimal time and are
conducted more frequently.
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B2. Hazard Identification & Evaluation
EPA laboratories are required to conduct
an inspection at least annually, but most
locations conduct some form of inspection
on a weekly, monthly, or semiannual
basis depending on laboratory, regional,
or divisional requirements.
Also, since routine inspections require less
expertise than surveys and JHAs, the
inspection team should consist of labora-
tory SHE professionals and laboratory
employees who have received training in
hazard recognition. This integration
enhances employee involvement in the
overall SHEMP. Inspections of this type
should not be used in place of surveys or
audits since they will not identify all regu-
latory requirements or management system
deficiencies for the laboratory; they should
be used only as a routine tool for hazard
identification.
To conduct the inspection, the team should
develop a checklist of SHE issues that
need to be examined and reviewed (e.g.,
safety equipment, general work practices,
personal protective equipment, chemical
storage and handling, etc.). The inspection
team can develop customized inspection
lists for each work area from the hazards
identified in the baseline and periodic
surveys.
A sample laboratory inspection checklist
is presented in Attachment B2-2 to this
chapter. This is a generic checklist that
should be used only as a reference tool.
Appendix A of SHEM Guide 53 lists the
topic-specific inspection checklists that
can be found in other SHEM Guide
chapters. Each EPA laboratory should
develop a checklist that addresses the haz-
ards at the labortory and incorporates labo-
ratory policies and procedures.
Each laboratory inspection should be doc-
umented, and written records should be
maintained. A review of these records will
help identify hazards for which controls
have not been developed, as well as recur-
rent problems in the control systems and
accountability systems. Also, since the
success of the inspection process depends
on the completeness of the follow-up, doc-
umentation will improve the program by
providing a written tracking system to
monitor the correction of deficiencies.
Accident and Incident Investigation
A comprehensive accident and incident
investigation program can uncover hazards
missed by other approaches. In addition,
when causes of accidents and injuries are
identified and analyzed, effective measures
can be developed to prevent future occur-
rences. For more information on accident
and incident investigation, refer to Chapter
G of this manual.
Tracking and Trending
Periodically, a laboratory should review all
accident and incident investigation reports
to determine if any trends or patterns are
evident. This review may indicate the need
to modify procedures, and may also pro-
vide justification for taking actions that
may require significant time or money to
implement. Furthermore, this review can
reveal when incident rates have increased
or decreased, and can be used to measure
the effectiveness of the SHEMP.
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Hazard and Risk Analysis & Management
B2. Hazard Identification & Evaluation
Trends may be identified in a variety of
investigation report components. For
example:
• Job task
• Department or work area
• Body part
• Type of incident (e.g., laceration)
• Hazardous agent involved, if
applicable
• Root cause
2.2 Determine the Problem Context
Inherent in the identification and evalua-
tion processes is the consideration of the
context of a potential risk. Key factors to
consider include:
• Multiple sources of exposure to the
same hazard
• Multiple exposure routes (e.g., absorp-
tion, inhalation, ingestion)
• Exposure to multiple hazards from the
same source
• Multiple risks from multiple
exposures
Each of these are discussed in the follow-
ing sections.
2.2.1 Multiple Sources of Exposure
Persons responsible for identifying and
evaluating hazards must determine if there
is more than one opportunity for employee
exposure to a given hazard. Evaluations of
risk may be underestimated if this factor is
not considered. it is important to include
the potential for exposure outside the
workplace. For example, laboratory per-
sonnel may be exposed to loud noise dur-
ing the work day, but may also be exposed
to loud noises at home (e.g., lawnmowers
and chainsaws). The resultant effect
of these exposures is important in deter-
mining risk.
2.22 Multiple Exposure Routes
All potential mutes of exposure to a given
hazard must be considered, especially if
not inherently obvious. Common multiple
exposure mutes in the laboratory involve
inhalation and absorption. If multiple
mutes are not considered, the risk may be
underestimated. This underestimation will
ultimately affect decisions such as conse-
quence determination and control method
selection.
2.23 Exposure to Multiple Hazards
The potential for exposure to more than
one hazard from a given source must be
determined. The cumulative effect of mul-
tiple hazard exposures is critical to deter-
mining risk. Effects may be additive,
multiplicative, or synergistic. For example,
employees may be exposed to an aerosol
and a chemical simultaneously. The chem-
ical may attach to the aerosolized particle,
which may transport it to unexpected areas
of the respiratory tract. This could pose an
additional and/or completely different
risk potential.
2.2.4 Multiple Risks from Multiple
Exposures
The variety of hazards that a laboratory
employee may encounter must be consid-
ered as a whole. This involves not only a
consideration of cumulative or resultant
effects as described above, but also a com-
parison of the different types of hazards
people face each day. This may complicate
risk analysis, but it is intended to be an
additional method to put a risk into
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CHAPmR B
Hazard and Risk Analysis & Management
B2. Hazard Identification & Evaluation
context. Multiple risks from multiple
exposures are considered when looking
at one given effect. For example:
• What are the potential hazards that
may cause this effect?
• What are the controls for different
hazards and risks than can be imple-
mented to result in one overall effect?
2.3 Determine Goals
Another step in the hazard identification
process is to determine goals. This must
be done early in the process, as goals
should guide identification and analysis.
Analysis may lead to a redefinition of
goals. Goals are often dictated by statute
and/or regulation, policy, and internal stan-
dards. Goals should be general or specific,
as needed for a given situation. Examples
of general goals include the following:
• Reducing or eliminating risks of expo-
sure to hazardous substances and
agents
• Reducing the incidence of adverse
effects
• Reducing environmental impact
Specific goals will typically focus on
determining compliance with specific
aspects of a regulation, policy, and/or
written program.
2.4 Involve Personnel
Involvement of EPA laboratory personnel
in hazard identification, risk analysis, and
decision-making processes is critical. With
employee involvement, decisions are typi-
cally more widely accepted, as well as
more effective. Various personnel will add
important experience and expertise to the
process, along with different interpreta-
tions and perceptions of risk.
The involvement of personnel will depend
on the particular situation. Certain persons
may become involved based on expertise,
experience with similar risks in the past,
and even based on interest. The nature,
extent, and complexity of personnel
involvement should be appropriate to the
scope and impact of the decision. For posi-
tive participation, personnel will need
management support, training, guidance
from experts, and experience. It is also
very important to involve personnel from
the very beginning of the process.
3.0 Corrective Actions
All hazards or areas of noncompliance
identified through surveys, inspections,
reporting or other means must be docu-
mented and investigated. Hazards include
any condition or situation that could pose
a threat to human health or safety or to the
environment. Noncompliance could be a
deviation from EPA policies and proce-
dures; regulatory noncompliance; or devia-
tion from laboratory objectives and targets.
Corrective actions should start as a list of
options that address the root cause of the
deficiency. For example, if, during the
course of repeated inspections of an area,
the emergency exits are continually
obstructed by stored objects, the appropri-
ate corrective action would involve two
steps. First, remove the stored objects to
provide clear egress. Second, to reempha-
size the importance of keeping exits clear,
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Hazard and Risk Analysis & Management B2. Hazard Identification & Evaluation
provide additional awareness training,
post signs, review the issue during
monthly meetings, etc.
For each, the cost and benefit must be
weighed. Other important factors to con-
sider include the following:
• Who receives the benefits?
• Who bears the cost?
• How feasible is the option, consid-
ering the time, money, resources, and
other potential limitations?
• Could a solution create another
problem?
Corrective actions may include education
and training, incentives, monitoring (e.g.,
data gathering), surveillance (e.g., observa-
tion of effects), and others. Additional
research is often necessary to analyze
options and/or assess costs and benefits.
Documented corrective action plans
should be developed to include, at a mini-
mum, a description of the corrective
action, the individuals responsible, and the
target date for completion. Completion of
corrective action plans must be tracked by
an individual in the laboratory. The desig-
nation of the appropriate individual (e.g.,
SHEMP Manager, chemical hygiene offi-
cer, etc.) will depend on the organizational
structure at each laboratory.
The effectiveness of corrective actions
must be evaluated through subsequent
inspections, audits, and performance
monitoring.
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CHAPTER B
Attachment B2- 1: JHA Worksheet
Purpose: To be used to perform a job hazard analysis (JHA).
Instructions: Complete the table for each activity/task to be assessed. An example of a
completed table is included for guidance.
&ER4Ih June 1998 B2-13
-------
lilA Worksheet
Approved By:
Job Title or Task:
Team Leader:
Analyzed By:
Employee/Operator:
Area:
Reviewed By:
Required Personal Protective Equipment:
Sequence of Basic Job Steps
Potential Hazards,
Unsafe Acts, or Conditions
A ,fLm aw Procedure
Recommended
-------
A Worksheet
Approved By:
Job Title or Task:
Bulk Unloading (Truck)
Team Leader:
John Doe
Analyzed fly:
Bill Smith
Employee/Operator:
Ann Johnson
Area:
Bulk Unloading
Reviewed By:
Sally Brown
Required Personal Protective Equipment: ANSI Th7 I Safety Glasses with Permanent Side Shields, ANSI Z41-1991 Safety Shoes & Ear Protection
Sequence of Basic Job Steps
Potential Hazards,
Unsafe Acts, or Conditions
Recommended Action or Procedure
Safrly guide truck back into loading area.
Truck backs into person and/or equipment.
Slowly guide truck to designated area (look out
for people and equipment).
Using portable ladder, climb up ladder to top of
truck and obtain sample using probe. The em-
ployee doing the sampling hands the probe to
another employee on the ground to empty the
probe into the tray. Three samp lcs are taken from
the truck; front, middle and back.
Fall off ladder.
Ladder slips out from under person.
Probe is dropped and strikes employee.
Slowly climb up ladder using caution. Attach
ladder safety hooks to top of truck.
Make sure hose is attached to the proper silo,
reaflaching it as necessary.
Slip/trip on loose product and/or tools (hoses).
Use caution when walking and keep area clean.
Place tarp under truck compartment opening.
Slip/trip on loose product and/or tools.
Watch where walking and keep area clean.
Place unloading hose on top of tray (under truck
compartment opening).
Back/shoulder/arm injury due to improper lifting
technique.
Slip/trip on loose product and/or tools.
Use caution when lifting hose (keep back straight
and bend knees). Watch where walking and keep
area clean.
Hit sides of truck compartment opening with
rubber hammer until product drops.
Arm/shoulder injury.
Bump into ratchet.
Slip/trip on loose product and/or tools.
Use control when swinging hammer. Keep body
clear of ratchet. Watch where walking and keep
area clean.
-------
JHA Worksheet (continucd
Approved By:
Job Title or Task:
Bulk Unloading (Truck)
Team Lender:
John Doe
Analyzed By:
Bill Smith
Employee /Operator:
Ann Johnson
Area:
Bulk Unloading
Reviewed By:
Sally Brown
Required Personal Protective Equipment: ANSI Z87. I Safety Glasses with Permanent Side Shields. ANSI Z41- 1991 Safety Shoes & Ear Protection
Sequence of Basic Job Steps
Potential hazards,
Unsafe Acts, or Conditions
Recommended Action or Procedure
Check pressure gauge on hose, keeping pressure
between 8 and 10 psi.
Pressure set too high, causing hose to blow off
and spew material,
Check pressure as soon as the system is turned
on.
Climb ladder to top of truck and rake out product
using metal tool.
Fall off ladder.
Ladder slips out from under person.
Slowly climb up ladder, using caution. Attach
safety hook to top of truck.
Shovel leftover product into unloading hose
(only after last compartment is empty).
Back/anu/shoulder injury due to repetitive
shoveling,
Slip/trip on loose product and/or tools,
Use caution when shoveling (keep back straight
and bend knees). Only shovel amount that can be
reasonably transported. Watch where walking
and keep area clean.
Pull unloading hose nozzle and tarp from under
the truck compartment opening.
Back/arm/shou lder injury due to improper lifting
technique,
Slip/trip on loose product and/or tools.
Keep back straigjn and bend knees when lifting
hose. Watch where walking and keep area clean.
-------
SHEMP Operations Manual for Laboratories
CHAPTER B
Attachment B2-2: Laboratory Inspection Checklist
Purpose: To conduct a walk-through SHE survey of EPA laboratories.
Instructions: Conduct the survey using the portions of the checklist that are applicable to
the potential hazards of the laboratory to be inspected.
‘&EPA June1998 B2-17
-------
Laboratory Inspection Checklist
Location:
Position:
1.0 General Safety
Item Yes
No
N/A
Comments
Corrective Action
3 feet wide
have proper hoses
in good condition
grounded
not overloaded
used only
UL listed
penetrations (holes)
in traps
not overfilled
of biohazards
properly
point manager
of glass and
in secondary
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position:
2.0 InformatIon
Item
Yes
No
N/A
Comments
Corrective Action
2.1
CHP available
2.2
Specific SOPs available
2.3
Safety raining documented
2.4
MSDS locations known
2.5
Chemical inventory available
2.6
Chemical inventory up-to-dare
2.7
Chemicals labeled properly
3.0 Slgnage
Item
Yes
No
N/A
Commi. its
Corrective Action
3.2
Hazard signs on cabinets
3.3
No-smoking signs present
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position:
4.4) Chemicals
Item
Yes
No
N/A
Comments
Corrective Action
4.1
Chemicals stored by compatibility
4.2
Containers labeled properly
4.3
No chemicals stored on the floor
4.4
No hazardous liquids stored above
eye level
4.5
Storage shelves have lips
4.6
No polymerized or unstable
chemicals
4.7
Bottle carriers available
4.8
Peroxidizables dated and tested
4.9
Flammable liquids in approved
storage areas
4.10
Over-b-gal containers of flamma-
ble Liquids stored in safety cabinet
4.11
Flammables stored in approved
refrigerator or freezer
4.12
Combustibles not adjacent to
flammables
5.0 Toxic Gases
Item
Yes
No
N/A
Comments
Corrective Action
5.1
Containers properly secured
5.2
Leak test performed routinely with
gas
5.3
Tox&c gas scored in ventilated
cabinet
5.4
Toxic gas has detection system
Toxic gas respirator program in
place
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position:
6.0 Compressed GnseslCryogens
Item
Yes
No
N/A
Comments
Corrective Action
6.1
No more than one spare tank stored
in room
6.2
Tanks stored properly
6.3
Compressed gases properly secured
6.4
Compressed gases equipped with
regulator or cap
6.5
Leak test routinely performed on
cylinders
6.6
Cryogenic materials stored in proper
containers
6.7
Cryogenic PPE available -
7.0 ElectrIcal Safety
Item
Yes
No
N/A
Comments
Corrective Action
7.1
Electrical cords in good condition
7.2
Extension cords used only
temporarily
7.3
Electrical outlets secure
7.4
Only approved space heaters used
7.5
Power strips being used
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position:
8.0 Fire Safety
Item
Yes
No
NM
Comments
Corrective Action
8.1
Corridors free of obsiructions
8.2
Floor clean and dry (no loose carpet
or tiles)
8.3
No holes in corridor walls
8.4
Doors not blocked
8.5
Doors self-close and Latch
8.6
Free access to fire extinguisher
8.7
Stairwells clear of obstnictions
8.8
Elevator lobby clear of obstacles
8.9
Ceiling is intact
8.10
IUuxninatcd exit signs visible in
corridor
9.0 Ventilation Systen
Iteni
Yes
No
N/A
Comments
Corrective Action
9.1
Fume hoods certified
9.2
Fume hoods not blocked
9.3
Fume hoods working properly
9.4
Sash moves freely
9.5
Traps filled with water
9.6
Hood alarms operational
9.7
Biosafety cabmets certified
9.8
Gloveboxes certified
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position
10.0 Sharps
Item
Yes
No
N/A
Comments
Corrective Action
10.1
Sharps containers available
10.2
Sharps containers leak-proof and
puncture-proof
10.3
Sharps contarnera properly labeled
11.0 Pereonal Protective Equl
pment
Item
Yes
No
N/A
Comments
Corrective Action
11.1
Correct eye protection worn
11.2
Appropriate gloves worn
11.3
Nitrile!butyl rubber gloves used for
spills
11.4
Appropriate lab coat or apron worn
1.5
Respirator available
11.6
Respirator naining documented
11.7
Medical evaluation for respirator
use performed
11.8
Fume hood without obsnuctions
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Locatiom
Conducted By:
Position:
12.0 Emergency $quipment
Item
Yes
No
N/A
Comments
Corrective Action
12.1
Safety shower within 100 feet of
hazard
12.2
Safety shower clear of obstacles
12.3
Eyewash within 100 feet of hazard
12.4
Eyewash flushed weekly
12.5
Spill kit for corrosives available
12.6
Spill kit for solvents available
12.7
Spill kit for biohazards available
12.8
Spill kit for mercuiy available
12.9
Fire extinguisher unobstiucted
12.10
Fire extinguisher inspected within
one year
12.11
Emergency lighting adequate
12.12
First-aid kit available
12.13
Emergency numbers posted
13.0 Other Equl
pment
Item
Yes
No
N/A
Comments
Corrective Action
13.1
Vacuum pumps properly maintained
13.2
Vacuum pumps filtered, trapped, or
ventilated
13.3
Auto shutoffs for unattended
operations
13.4
Guards and interlocks in place
-------
Laboratory Inspection Checklist (continued)
Date of Inspection:
Location:
Conducted By:
Position:
14SpeLabOrate
Item
Yes
No
N/A
Comments
Corrective Action
14.1
Animals used
14.2
Human/primate tissues used
14.3
Recombinant DNA used
14.4
Etiological/pathogenic agents used
14.5
Radioactive materials used
14.6
Lasers used
*A “yes” answer here indicates that the laboratory must be in compliance with additional federal, state, and local regulations
and policies (i.e., CDC, NRC, HSS. etc.).
-------
B3.
Risk Assessment
-------
SHEMP Operations Manual for Laboratories
CHAFFER B
Hazard & Risk Analysis and Management
B3. Risk Assessment
1.0 Introduction
Risk assessments arc very useful tools for
laboratory management and safety, health,
and environmental (SHE) professionals.
Risk assessment techniques allow efforts
to be focused on the most serious hazards
or those that are most likely to result in an
adverse outcome. They can be used to help
make better, scientifically qualified deci-
sions and to perform cost/benefit analysis.
Risk assessments go further than tradi-
tional hazard identification and evaluation
techniques, and they attempt to define the
hazard in terms of its probability and con-
sequence, or risk:
• Hazard probability deals with how
likely the incident is to occur, or how
likely the adverse effects are to occur
from exposure to the hazard.
• Hazard consequence relates to the
magnitude or severity of an outcome.
For effective hazard and risk analysis and
management, an integrated approach must
be taken that involves hazard identifica-
dun, risk assessment, decision-making and
implementation, and review processes.
There are many tools available for each
phase of risk management. It is important
to recognize that phases of risk manage-
ment often overlap and need revisiting.
This chapter provides an overview of
risk assessment and its application to
laboratory SHE management. It is not
intended to provide a thorough discussion
on the intricacies of risk assessment
methodologies.
EPA Program Requirements
For an effective risk management pro-
gram, each laboratory should:
• Identify laboratory-specific risks.
• Use risk assessment techniques, as
appropriate, to evaluate laboratory
risks and prioritize corrective actions.
Program Administration
In support of the hazard and risk analysis
program, responsibilities should be
assigned for:
• Identifying laboratory-specific risks
through qualitative risk screening
along with traditional hazard evalua-
tion and identification methods
• Coordinating (e.g., with regional,
divisional, or outside consultants)
the application of comprehensive risk
assessment techniques, as appropriate
(e.g., special cases)
SEPA June 1998
B3-1
-------
SHEMP Operations Manual for Laboratories
C mR B
Hazard & Risk Analysis and Management
B3. Risk Assessment
2.0 Risk Assessment Methodologies
Application of risk assessment methodolo-
gies will allow laboratories to focus
resources on problem areas and to leverage
business advantage, essentially getting
“more for less.” Risk assessment method-
ologies can be used for a variety of SHE
applications:
• Prioritizing audit/inspection findings
and corrective actions
• Assessing employee exposures and
prioritizing monitoring
• Determining personal protective
equipment requirements
• Justifying training programs
• Supporting capital expenditures for
new equipment or modifications
Risk assessments can be qualitative, semi-
quantitative, or quantitative. Examples of
methodologies include:
• HAZOP
• “What If” analysis
• Fault tree analysis
• Risk screening
Figure B3-1: Risk-Screening Process
A Hazard and Operability Study (HAZOP)
is used to identify process hazards and
operability problems in design, proce-
dures, etc. “What If” analysis is used to
identify potential accident sequences, thus
identifying hazards, consequences, and
methods of risk reduction. Fault tree analy-
sis identifies combinations of equipment
failures and human errors that can result in
an accident event. A risk screening pro-
vides general hazard identification infor-
mation and can assist with prioritization.
The qualitative risk screening approach is
a technique that can be applied to all EPA
laboratories. This methodology can be
used to analyze and prioritize the hazards
or findings generated from traditional
hazard identification and evaluation
techniques. The risk screening process
is presented in Figure B3-l.
Risk assessments are concerned with eval-
uating two variables: hazard consequence
and hazard probability.
Identify the
Hazard
Screen
the
Risk
No
‘&ER4 June 1998
B3-2
-------
SHEMP Operations Manual for Laboratories
CR4PTER B
Hazard & Risk Analysis and Management
B3. Risk Assessment
Examples of parameters related to hazard
consequence variables are presented in
Figure B3-2.
These parameters are based on fatality and
personal injury. However, similar parame-
ters could be developed for business inter-
ruption (e.g., less than 24 hours, 24 to 72
hours, 72 to 168 hours, over 168 hours).
When assessing parameters for business
Figure B3-2: Hazard Consequence Parameters
interruption, include internal systems
(e.g., elecirical, HVACI and information
technology) and external events (e.g., ad-
verse weather and contiguous hazardous
material transportation incidents). In addi-
tion, there are more intangible conse-
quences such as the potential for adverse
publicity.
Parameters related to hazard probability
variables are presented in Figure B3-3.
Critical
May cause severe injury or occupational illness f
Marginal
May cause minor injury or occupational illness
and result in lost workdays
Negligible
Violates program/standard, but probably would
not affect employee safety or health
S .a&_.
Figure B3-3: Hazard Probability Parameters
High
Likely to occur immediately or within a short
period of time upon exposure
Moderate
Probably will occur after repeated exposure
I
Low
Possible to occur after repeated exposure
Very Low
Unlikely to occur
I
Catastrophic May cause fatalities
I
6EPA June 1998
B3-3
-------
SHEMP Operations Manual for Laboratories
CHAPTER B
Hazard & Risk Analysis and Management
B3. Risk Assessment
The parameters used to describe hazard
consequence and probability can be modi-
fied based on the scope and objectives of
the study. The impact can be presented in
terms of:
.
S
S
S
S
.
Loss of life
Injury or illness
Natural resource damage
Volume of soil contaminated
Property damage
Business interruption
Loss of reputation
Figure B3-4: Risk Assessment Matrix
Once each of these two variables—
consequence and probability—are defined,
a matrix is used to represent the overall
risk level. This risk assessment matrix is
presented in Figure B3-4.
By using this matrix, laboratories can pri-
oritize the implementation of corrective
actions. For instance, a risk categorized as
Level A would require immediate correc-
tion, while one of lesser urgency may be
addressed over the next few months or
years.
0
Consequence
Level A: High-risk condition—Immediate action (highest priority for risk mitigation and contingency
planning)
Level B: Moderately high-risk condition—Prompt action (addresss risk by mitigation and contingency
planning)
Level C: Low to moderate risk condition—Planned action (risk condition sufficiently high to fuaher
mitigation and planning)
Level D: Low-risk condition—Advisory in nature (additional mitigation and contingency planmi )
High
Moderate
Low
Very Low
B A A
-J
I
, u
t
June 1998
B3-4
-------
SHEMP Operations Manual for Laboratories
CHAPTER B
Hazard & Risk Analysis and Management
B3. Risk Assessment
3.0 Decision-Making and
Iniplementanon
Once results have been gathered, decisions
to reduce or eliminate the identified risk
must be made. These decisions should:
• Consider scientific and technical
resources.
• Address the problem’s root cause.
• Include a careful cost/benefit
justification.
• Give priority to risk prevention, not
control.
• Include incentives for innovation,
evaluation, and research.
• Involve employees and their
recommendations.
After identifying the risk level, consider
all possible control options, and perform a
cost/benefit analysis (CBA) for those
options capable of reducing program costs
and improving results. Although the CBA
may differ by hazard type and available
control and prevention opportunities, it is
essential to consider information from var-
ious sources (e.g., SFIEMP manager,
employees, reference materials), and to
include indirect costs and additional
factors. Examples of situations where
CBAs may be applied include program
implementation, prevention projects,
and compliance activities.
A CBA’s results can be difficult to quan-
tify because the benefits may reflect
changes in employee attitudes (e.g., indi-
vidual productivity and morale) or event
occurrence (e.g., reduced likelihood or
severity, the effects of an avoided loss).
Nevertheless, always seek to implement
recommendations designed to reduce both
risk occurrence and magnitude.
Employee involvement during the
implementation phase is crucial. When
involved, employees are most likely to
understand and support the agreed-upon
decision (e.g., employee education and
training, empowerment, and risk manage-
ment involvement).
4.0 Evaluating Effectiveness
Evaluating the effectiveness of risk
management actions that have been
implemented involves monitoring and
measurement. One measurement includes
comparing actual costs and benefits to the
estimates made for decision-making pur-
poses. The decision-making process, itself,
should also be evaluated at this phase.
An evaluation can answer the following
important questions:
• Were actions successful? Did they
accomplish what was intended?
• Were predicted costs and benefits
accurate?
• What actions can be taken to improve
the risk management plan and process?
• Has any new information surfaced to
trigger re-evaluation of the decision?
• Was any critical information missing?
• How did employee involvement con-
tribute to the outcome?
• Were scarce resources (e.g., time, per-
sonnel, money) used wisely?
To perform an evaluation, employees must
be interviewed, relevant records must be
reviewed, and costs and benefits must be
analyzed. Frequent evaluation is vital and
the evaluation focus may shift throughout
the implementation nhase.
June 1998
B3-5
-------
SHEMP Operations Manual for Laboratones
CHAPTER B
Hazard & Risk Analysis and Management B3. Risk Assessment
It often takes a significant amount of time
to determine the full impact of a decision.
It is important to involve employees in the
evaluation process, assisting to:
• Establish the criteria of the evaluation.
• Ensure the integrity of the evaluation
process.
• Determine if an action is successful.
• identify lessons to be learned.
• Identify information gaps.
• Determine whether cost and benefit
estimates were reasonable.
June 1998 B3-6
-------
B4.
Change Management
-------
SI-IEMP Operations Manual for Laboratories
CH PmR B
Hazard & Risk Analysis and Management
B&Change Management
1.0 Introduction
Over time, laboratory activities and
workforces may change, and it is impor-
tant for management to both respond to
change and to anticipate change. Change
management activities can include the
following:
• Identification of new hazards or risks
• Evaluation of process changes to
anticipate safety, health, and environ-
mental (SHE) implications
• Continuous improvement of programs
to improve effectiveness or efficiency
• Modification of programs to reflect
personnel changes
The evaluation of new facilities, processes,
operations, materials, and equipment prior
to their design or use is instrumental to an
effective hazard analysis program. In addi-
tion, as risks and requirements change, it
may be necessary to adapt laboratory pro-
grams and procedures to respond to these
changes.
EPA Program Requirements
For an effective change management pro-
gram, EPA laboratories should:
• Implement procedures to anticipate
and identi1 proposed changes in pro-
cedures, equipment, materials, etc.,
prior to making any decisions.
• Review proposed changes for
implications to SHE programs.
• Discuss results with involved parties.
Program Administration
To effectively manage change, responsibil-
ities should be assigned for:
• Overseeing and coordinating the labo-
ratory change management program
• Performing a technical review of pro-
posed changes in procedures, equip-
ment, hazardous materials, location,
etc., for implications to SHE programs
This chapter provides an overview of
change management for the following
types of laboratory change:
• Procedures
• Equipment
• Purchases
• Location
In addition, this chapter describes the use
of SHE research protocols as tools to iden-
tify and manage changes in laboratory
operations.
• Providing recommendations on the
proposed change and any additional
measures needed (e.g., further
research, control measures, etc.)
• Following-up, once changes have been
implemented, to perform any neces-
sary final evaluations
• Providing administrative support by
tracking proposed changes, evaluation
and feedback reports, etc.
j
*‘ rM June 1998
B4-l
-------
SHEMP Operations Manual for Laboratories
CHAI’rER B
Hazard & Risk Analysis and Management
B4. Change Management
2.0 General Change Management
Procedures
Often, laboratories will change operations
without considering the implications of
these changes. Items that were once haz-
ardous may no longer exist and new haz-
ards may be overlooked. By conducting
SHE evaluations at an early stage, EPA
laboratories can ensure that changes do not
result in new hazards.
Effective change analyses can be accom-
plished by several methods, depending on
the type of operation. Methods for change
analyses of procedures, equipment, chemi-
cal purchases, or location are discussed in
the following sections and summarized in
Figure B4-l.
2.1 Procedures
Any modifications to existing laboratory
procedures, or the introduction of new pro-
cedures, should be reviewed for SHE
implications. The review should be con-
ducted as early as possible during the mod-
ification or development process to ensure
that time and effort are not wasted on a
procedural change that is not acceptable
for SHE reasons. It is essential that new or
revised procedures are not implemented
without an effective SHE review.
2.2 Equipment
Prior to the purchase of any new equip-
ment, a review must be conducted to
ensure that:
The equipment specifications meet all
relevant SHE requirements (e.g., ma-
chine guarding).
• EPA guidelines for energy efficiency
are met.
• The equipment will not introduce any
additional hazards (e.g., high noise
levels).
• The need for additional training or
other controls is identified and imple-
mented prior to installation and use of
the equipment.
Any retrofitting of existing equipment
should also be reviewed for implications
to SHE programs.
23 Chemical Purchases
Each laboratory must implement a system
to manage the purchase of hazardous
chemicals. This is important for a number
of masons:
• To track the materials coming into the
laboratory
• To ensure that less-hazardous substi-
totes are considered where applicable
• To identify the need for additional
training, monitoring, or controls for
the use of a chemical
• To ensure that the chemical is not
available in the laboratory through a
chemical adoption program (a past
user of a particular chemical may have
excess in stock)
Depending on the organization and struc-
tore of the laboratory, suitable options for
managing chemical purchases may include
the following, alone or in combination:
GEPA June 1998
B4-2
-------
SHEMP Operations Manual for Laboratories
CHAPTER B
Hazard & Risk Analysis and Management
Figure B4-1: Methods for Change Analyses
Methods
B4. Change Management
2.4 Location
• Requiring a formal SHE review and
sign-off by designated authorized
individuals before the purchasing
department will process an order for
a chemical
• Providing the purchasing department
with a list of routinely used chemicals
that can be ordered without the
required sign-off
• Requiring the purchase of all chemi-
cals to go through one appropriately
trained individual (e.g., chemical
hygiene officer), or through depart-
ment managers, etc.
Many laboratories may find an electronic
database useful in managing the chemical
purchasing process.
If laboratories are choosing a location for
the construction of new facilities, it is
essential that implications to SHE pro-
grams are considered during the selection
of a suitable site, as well as during the
design of the buildings and systems. This
special case of change management is
addressed in more detail in Chapter D2
of this manual.
3.0 SHE Research Protocols
Researchers using any toxic or hazardous
agents must complete a SHE research pro-
tocol before ordering the material. A blank
protocol is included in Attachment B4-1.
A protocol must be completed and
approved for all hazardous chemicals and
agents.
Procedures
I
I I I I
Equipment
1
Chemical Purchases
— Review modifications
to procedures
— Review new
procedures
— Do not implement
without a SHE
review
I
Location
I
Ensure that
— Perform a sE Lbeterrm implica-
-
specifications meet
SHE requirements
Verify that EPA
energy efficiency
guidelines are met
review and sign-off tions to SHE programs
Provide a list of
- commonly ordered
chemicals to purchas-
ing for sign-off
-
Verify that no — Require the purchase of
additional hazards all chemicals through
will be introduced designated persons
Determine the need
for training and other
controls
&EPA June 1998
B4-3
-------
SHE?vIP Operations Manual for Laboratories
C i ’r B
Hazard & Risk Analysis and Management
B4. Change Management
According to OSHA’s Laboratory Stan-
dard, a hazardous chemical is a chemical
for which there is statistically significant
evidence (based on at least one study con-
ducted in accordance with established sci-
entific principles) that acute or chronic
health effects may occur in exposed
employees.
A hazardous agent possesses one or more
of the characteristics presented in
Table B4-l.
Protocols are also required for certain
research involving hazardous equipment.
Hazardous equipment or facilities are
defined as equipment or facilities that
present a potential physical hazard (e.g.,
excess heat, electrical shock, steam, explo-
sion, etc.) to employees.
The protocol must be signed by the appro-
priate personnel at the Branch and l)ivi-
sion levels and submitted to the SHEMP
Manager. The protocol will be reviewed
by an industrial hygienist. If any deficien-
cies in SFIE compliance precautions are
noted, the protocol will be
returned to the researcher for clarification
or additional input.
After the initial review is complete, the
SHEMP Manager will distribute the proto-
col to the review panel. The members are
given two weeks to review the protocol.
If panel members discover problems or
discrepancies, the protocol will be returned
to the researcher for clarification or
additional input.
Once the protocol is approved by all panel
members, the industrial hygienist approves
it for the review panel. Any restrictions or
special requirements pertaining to the pro-
posed research are noted at that time. The
protocol is then submitted to the Labora-
tory Director for final approval.
Table B4-1: Hazardous Agent Characteristics
LD
<50 mglkg body weight [ oral, rat]
<200 mg&g body weight [ dermal, rat]
LC
2 mg L [ particulate, rat]
200 ppm [ vapors and gases]
Carcinogenic, teratogenic, or mutagenic
Infectious
Explosive or violently reactive
Causes an irreversible illness
EPA June 1998
B4-4
-------
SHEMP Operations Manual for Laboratories
CHAFrER B
Hazard & Risk Analysis and Management
B4. Change Management
The Laboratory Director then signs the
protocol and it is considered “approved.”
After this final approval, a copy of the
protocol, with all appropriate signatures
and any noted restrictions or special
requirements, is returned to the researcher.
The original protocol is maintained on file
by the SHEMP Manager.
Protocols must be updated annually or
whenever there is a significant change in
chemicals or equipment used, or other
modification to protocol. Update forms
will be sent to each researcher for review.
If research continues and involves the
same procedures, the update form must be
signed, dated, and returned to the SFIEMP
Manager. If any conditions related to the
research have changed, the SHEMP
Manager must be notified. The changes
must be submitted to the SHEMP Manager
as amendments to the protocol. They may
travel through the same approval process
and then be entered into the researcher’s
protocol file.
This protocol review, approval and update
process in depicted in Figure B4-2.
Figure B4-2: Review, Approval and Update of SHE Research Protocols
Inilial Review
Panel Review
Final Approval
Protocol Update
R crsd conip1e*cs
the proo oJ
Protocol signed by
Sfr, IC per o
1
Industrial hygiene review
Are th e Yne
107 fic1cnc ne
No
i bem
review d —
Re dctioos or special
inquhonness sec noted
‘I ,
Iiob ial hyg eiüst
approves the —
Protocol mibmiucdto -
the iAboThtWy Dizec
— the protocol
‘I,
Copy of apprmnved
ixotocol is newited to
the
‘I ,
jgin.1 protocol is
filed by tin
E Ma
1
Protocols no —
annuafly or LI thete
to a change
U onn
sent to is. aithcr
Mo thorc
changes In tin
Yj’
No
Rcsevchor —
dates form and returns I L
In the SHEMP Mainger
Anteed the l otoco1
1
No* tin
S IWIvW Manager
‘ii
Protocol Is sent through
rite anitisi review
MP Manager
distrIbutes the protocol
to the review panel
& A June 1998
B4-5
-------
SHEMP Operations Manual for Laboratories
CHAPTER B
Attachment B4- I: SHE Research Protocol
Purpose: To ensure adequate review of proposed SHE precautions, procedures, and
techniques for the use, storage, and disposal of hazardous agents used in
research activities. The Principal Investigator should be most cognizant of
the specific or potential hazards associated with agents being investigated.
Instructions: This SHE research protocol should be completed by the Principal Investiga-
tor and sent to the SHEMP Manager for review and approval.
&EPA June 1998
-------
SHE Research Protocol
Title of Study:
Principal Investigator:
Last Middle First
Location
Telephone Number
Office:
Office:
Lab:
Lab:
Principal Investigator (Signature)
Date
Approvals
Branch Chief
Date
Division Director
Date
(Obtain signatures above prior to
sending to the SHEMP Manager)
Review Panel Chairman
Date
SHEMP Manager
Date
&EPA June1998 Page lof 5
-------
Safety and Health Research Protocol (continued)
Title of Study:
Principal Investigator:
Duration:
Last Middle First
Part 1. Personnel Potentially Exposed to Hazardous Agent
lA Personnel Authorized to Use Hazardous A
gents
1.
6.
Last Middle First
2.
Last Middle First
7.
Last Middle First
3.
Last Middle First
8.
Last Middle First
4.
Last Middle First
9.
Last Middle First
5.
Last Middle First
10.
Last Middle First
Last Middle First
Note: Personnel Qualification form must be completed and signed for each authorized person.
LB. Location(s) Where Work Will Be Conducted (Include Storage Location)
1(1 Description of the Study (Attach the Research Protocol)
11) Hazardous Operations and Their Duration
Note: Describe the procedure used to weigh the hazardous agent, where and how weighing will be
performed, total quantity weighed, how solvent will be added, etc.
June1998 Page2of5
-------
Safety and Health Research Protocol (continued)
Title of Study:
Principal Investigator:
Duration:
Last Middle First
1E. Hazardous Agent
Common name:
Chemical name:
Quantity to be ordered:
Maximum quantity needed:
Method of storage:
Storage location:
Physical Chemical Properties
Form:
Solubilicy:
Flash point:
Vapor pressure:
Stability:
Other:
Reactivity:
Volatility:
Other:
Special handling procedures (e.g., weighing of stock in glovebox):
iF. Toxicity
LD (carcinogen, etc.):
Note: Anach a copy of reference
Acute symptoms:
Chronic symptoms:
Are antidotes readily available for emergency use if needed? Yes D No
if yes, where and by whom?
1G. Types of Protective Equipment Required
Eye: Hearing: Respiratory:
Face: Gloves: Other:
EPA June1998 Page3of5
-------
Safety and Health Research Protocol (continued)
Principal Investigator:
Title of Study:
Last
Middle First
Duration:
1H. Precautionary Procedures
Controlled access:
Fume hood:
Covered work surfaces:
Type:
Certification date:
IL Emergency Procedures
Personal exposure (e.g., inhalation, ingestion, inoculation):
Spill plans:
Ii. Ih zardous Waste Disposal
Type of Waste
Volume s
Waste M1n1odi tIon
Method
Labeling Requirements
Paper, plastic, glass
Unused stock
Solvent
Gas
Solid
Carcass, bedding
Other
*Jnclude tune period for generation of waste (e.g., 1 liter of solvent per week, etc.)
1K. Material Safety Data Sheet
Attach a copy of the MSDS for each hazardous material, or a copy of information found in NIOSH
Registry of Toxic Effects of Chemical Substances.
1L. Animal Use
Will animals be used in this study? 0 Yes 0 No
If yes, complete Part 2 of this Protocol.
&EPA June 1998
Page 4 of 5
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Safety and Health Research Protocol (continued)
Title of Study:
Principal Investigator: Duration
Last Middle First
Part 2. Animpl Use Information
2A. Species
Number of animals: Person dosing animals: Dosing method:
Location of dosing: Concentration of dose per animal:
Animal Maintenance
Location: Duration:
Person responsible: Housekeeping:
2B. Coordination with Miim l Resources Staff
Has the planned study been coordinated with Animal Resources Staff to discuss technician
responsibilities, precautions, and availability of proper housing and space?
0 Yes If no, explain:
ONo
2C. Animal Diet Preparation
If the test agent will be incorporated into the animal diet; desciibe the method, by whom and where
the diet is to be prepared, where it will be stored, what quality assurance will be done and by whom.
If that is the plan, has the animal diet been coordinated with animal resourees staff to obtain timely
delivery?
2D. Protective Equipment and Procedures
EPA June1998 Page5of5
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Personnel Qualifications for Working with Hazardous Agents
Name: Location:
Last Middle First
Protocol Title
Research-specific formal training:
( Note: Also include all safety and health courses applicable to ihis type of work) .
Relevant on-the-job training:
(Note: Work with spec jflc hazardous agents related to this research, quantities worked with, and tiuining
received on these hazardous materials.)
Medical Monitoring
Restrictions (to be completed by the SHEMP Manager):
I have read the Safety and Health Research Protocol and agree to comply with all proce-
dures and protective measures outlined in the protocol.
Signature Date
& A June 1998 Page 1 of I
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C. Laboratory SHE Program
-------
Cl.
Introduction
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs Cl. Introduction
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The EPA laboratory safety, health and environmental (SHE) programs discussed in this
chapter, span three major areas: administrative programs, safety and health programs, and
environmental programs. These programs are intended to cover all elements necessary to
provide a safe workplace for EPA employees, contractors, and the visitors, as well as to
ensure that the environment is not adversely effected by the laboratory operations.
These chapters on EPA laboratory SHE programs are as follows:
Chapter Topic
C2 Medical Surveillance Program
C3 SHE Training
C4 Chemical Hygiene Program
C5 Industrial Hygiene Program
C6 Radiation Safety Program
C7 Biosafety Program
C8 Ergonomics Program
C9 Pollution Prevention Program
ClO
Air Quality Program
Cli
EPCRA Program
C12
Wastewater Program
&EPA June 1998 Cl-!
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
Cl. Introduction
Chapter
Topic
C13
SPCC Program
C14
Waste Management Program
C15
TSCA Program
C16
UST Program
ER June 1998
C1-2
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C2.
Medical Surveillance
Program
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C2. Medical Surveillance Program
1.0 Introduction
A medical surveillance program serves to
assess critical variables in an employee’s
health before, during, and after employ-
ment. Medical surveillance involves
monitoring the health of employees, with
particular emphasis on the adverse health
effects that may be caused by exposure to
chemical, physical, or biological agents in
the workplace.
The fundamental purpose of medical sur-
veillance is to evaluate the pathological
effects of past exposure. This information
is used to evaluate the level of morbidity
and mortality attributed to the develop-
ment of disease in the monitored popula-
tion. Medical monitoring focuses on
establishing the probability of a disease
being present, rather than on confirming
the diagnosis of the disease. Thus, the
tests that are conducted in a medical sur-
veillance program tend to be simpler, less
expensive, less invasive, and more com-
fortable than diagnostic test procedures.
This chapter presents minimum require-
ments for, and addresses specific
components of, a medical surveillance
program as required by the U.S. Occupa-
tional Safety and Health Administration
(OSHA). It also discusses biological moni-
toring considerations and program imple-
mentation issues.
are based on EPA Order 1460.1, “EPA
Occupational Medical Surveillance Pro-
gram Document.”
Program Administration
To effectively manage the laboratory med-
ical surveillance program, responsibilities
should be assigned for:
• Designing a medical program appro-
priate for potential exposures
• Determining which employees will be
included in the program
• Ensuring that employees in the pro-
gram receive medical examinations
when assigned to a task where expo-
sures to hazardous agents could occur
• Providing follow-up care, including
annual examinations
• Maintaining medical records
EPA Program Requirements
The EPA medical surveillance program
was developed to ensure that, to the best
extent feasible, EPA employees subject to
extraordinary physical demands or hazard-
ous exposures have not suffered adverse
health effects. The requirements set forth
&ERA. June 1998
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CHAFrER C
Laboratory SHE Programs
C2. Medical Surveillance Program
2.0 Scope and Application
Minimum requirements for occupational
medical surveillance programs include:
• Medical examinations for personnel
who will be working with potentially
hazardous agents, both at the time they
are assigned to the program and before
they are exposed
• Medical examinations on an annual
basis, and upon termination of an
employee’s participation in the
research
• Medical approval by a physician
for the use of negative-pressure
respirators
The scope of the medical examination
must be specified in the laboratory’s safety
and health plan and/or chemical hygiene
plan.
These minimum requirements also specify
that laboratories comply with applicable
federal, state, and local statutes regarding
medical surveillance.
The recommended participant selection
criteria for the EPA medical surveillance
program is based on the employee’s posi-
tion description and regularly assigned
tasks and duties. An employee should be
selected for the medical surveillance pro-
gram if their position description, or regu-
larly assigned tasks and duties, meet any of
the following criteria:
• Presents a routine or periodic exposure
to hazardous chemical, physical, or
biological agents
• Requires the use of animals or human
pathogenic materials
• Requires the use of respiratory
protection
• Involves physically demanding work,
such as routine heavy lifting and
carrying
• Involves emergency response
activities
• Involves an activity or known expo-
sure that is currently regulated by
OSHA, and the applicable regulation
mandates medical surveillance
The EPA laboratory shall provide all
required medical surveillance at no cost
to affected staff, without loss of pay, and
at a reasonable time and place.
3.0 Types of Examinations
A medical surveillance program should be
developed for each EPA laboratory based
on the specific needs and potential expo-
sures of employees. The program should
be designed by an experienced occupa-
tional health physician or other qualified
occupational health consultant in conjunc-
tion with the laboratory’s SHEMP Man-
ager. The director of the facility’s medical
surveillance program and the physician
performing the examinations should be
Board-certified in occupational medicine.
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C2. Medical Surveillance Program
Alternately, the director could be a medi-
cal doctor who has had extensive experi-
ence managing occupational health
services.
Although medical surveillance require-
merits may vary from laboratory to labora-
tory, a medical program should provide the
following types of surveillance:
• Pre-employment screening
• Periodic medical examinations
• Termination examinations
• Treatment examinations (e.g.,
emergency and non-emergency)
• Recordkeeping
Each of these are discussed in the follow-
ing sections and shown in Figure C2-1.
Figure C2-1: Components of a Medical
Surveillance Program
Medical Surveillance
Program
‘I ,
Pre-einployment Screenings
Periodic Medical Exams
I
Treatment
Emergency Non emergencYj
Termination Medical Exams
I
3.1 Pre-employment Screening
Pro-employment screening has two major
functions:
Determining an individual’s fitness for
their work assignment
• Providing baseline data for compari-
son with future medical data
To ensure that prospective employees are
able to meet work requirements, the pro-
employment screening should focus on the
areas as shown in Figure C2-2.
Pre-employment screening may be used to
establish baseline data that will verify the
effectiveness of protective measures and
determine if exposures have adversely
affected the worker. In this case, examina-
tions may include both medical screening
tests and biological monitoring. Where
applicable (e.g., work with infectious
agents), pre-employment blood specimens
and serum may be collected and frozen for
later testing. Baseline monitoring may be
particularly relevant if there is a likelihood
of potential exposure to a particular agent.
3.2 Periodic Medical Examinations
Periodic medical examinations should be
developed and used in conjunction with
pre-employment screening to track biolog-
ical trends that may signal adverse health
effects. Yearly medical examinations are
required at EPA laboratories. More fre-
quent examinations may be necessary,
depending on the extent of potential or
actual exposure, the type of chemicals
involved, the duration of the work assign-
ment, and the individual employee’s
profile.
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C2-3
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C2. Medical Surveillance Program
Figure C2-2: Components of Pre-employment Screening
Occupational and
Medical History
— Complete a medical history
questionnaire.
— Review past and present
illnesses and chronic diseases.
— identify relevant lifestyle
habits.
— Discuss hobbies.
Assessment of Limitations
LAssess ability to wear
PPE
Periodic medical examinations should
include the components as shown in
Figure C2-3.
3.3 Termination Examinations
At the end of their employment, a
medical examination must be given
to all employees who are enrolled in
a medical surveillance program. This
examination may be limited to obtaining
medical history of the period since the
last full examination (e.g., medical history,
physical examination, and laboratory tests)
if all of the following conditions are met:
• The last complete medical examina-
tion was within the last six months.
• No exposure occurred since the last
exantination.
• No symptoms associated with
exposure occurred since the last
examination.
3.4 Treatment Examinations
Provisions for emergency and non-
emergency treatment should be made
at each EPA laboratory. Preplanning is
vital. When developing emergency medi-
cal plans, procedures, and lists of required
supplies and equipment, the range of
actual and potential hazards specific to
the facility should be considered, including
chemical, physical, and biological hazards.
In addition to laboratory employees, other
personnel, such as contractors and visitors,
may require medical treatment.
3.4.1 Emergency Treatment
EPA laboratories that do not have a nurse
or physician on-site, or where additional
first-aid support is deemed necessary,
should establish a first-aid team. In addi-
tion to receiving basic first-aid training, it
its recommended that the team members
become qualified in cardiopulmonary
resuscitation (CPR).
— a wfl
Scr
Comprehensive
!hysical Exam
I
L.jFocus on systems:
hPulmonary
1—Cardiovascular
1 —Musculoskeletal
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laboratory SHE Programs
Figure C2-3: Components of Periodic Medical Exams
C2. Medical Surveillance Program
Periodic Medical
Exams
Physical Exam
.1
I
I
Medical Testing Specific to
a Job, Duty, or Exposure
— Pulmonaiy function tests
for respirator wearers
Audiometric tests for
- personnel subjected to high
noise levels
—Vision tests
_Blood and urine tests when
indicated
EPA laboratories should establish a first-
aid station(s) that permits stabilization of
patients requiring off-site treatment and
general first aid (e.g., minor cuts, sprains,
and abrasions). It should include a stan-
dard first-aid kit, or equivalent supplies, as
well as additional items such as stretchers,
potable water, ice, emergency eyewash,
safety shower, and fire-extinguishing blan-
kets. First-aid supplies should be approved
by the consulting physician.
Plans should be made in advance for trans-
portation to, and treatment at, a nearby
medical facility. Ambulance and hospital
personnel should be informed of hazards
at the laboratory that could result in the
need for medical treatment. The names
and telephone numbers of the emergency
service providers should be conspicuously
posted (e.g., nurse/physician, ambulance,
medical facility, fire/police, and poison-
control hotline).
In addition, laboratory personnel have the
right to obtain medical exams in the event
of a spill or other exposures.
3.4.2 Non-emergency Treatment
Medical examinations and consultations
shall be perfonned by, or under the direct
supervision of, the employee’s physician
and without cost or loss of pay to the
employee. All medical examinations shall
be provided to EPA laboratory employees
at a reasonable time and place under the
following circumstances:
• Whenever an employee develops signs
or symptoms associated with possible
exposure to hazardous chemicals han-
dled in the laboratory
• Where exposure monitoring reveals
an exposure level routinely above the
action level or—in the absence of an
action level—the permissible exposure
limit for an OSHA-regulated sub-
stance for which there are exposure
monitoring and medical surveillance
Medical History
Changes in health status
Illnesses
Possible work-related
symptoms
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SHEMP Operations Manual for Laboratories
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C2. Medical Surveillance Program
requirements (other medical surveil-
lance requirements of relevant stan-
dards shall also be observed)
Following a medical consultation
during which the physician determines
the need for a medical examination;
for example, in response to an event
such as a spill, leak, explosion, or
other occurrence causing likely
exposure
For all medical consultations and examina-
tions, EPA laboratories shall provide the
following information to the physician:
• The identity of the hazardous chemi-
cals(s) to which the employee may
have been exposed
• A description of the conditions under
which the exposure occurred, includ-
ing quantitative exposure data, if
available
• A description of the signs and symp-
toms of exposure that the employee
has experienced, if any
For all medical consultations and examina-
tions performed in accordance with the
OSHA Laboratory Standard, the examin-
ing physician shall provide to the labora-
tory a written opinion that includes the
following:
• Any medical condition that may be
revealed in the course of the examina-
tion and that may place the employee
at increased risk of exposure to a
hazardous chemical found in the
laboratory
• A statement that the physician has
informed the employee of the results
of the consultation or medical exami-
nation and any medical condition that
may require further examination or
treatment
The physician’s written opinion to the
employer shall not reveal specific findings
or any diagnosis unrelated to occupational
exposure even if he chooses to relay them
to the employee.
All medical records must be maintained in
accordance with 29 CFR 1910.1020.
4.0 Specific Surveillance Requirements
In a laboratory, there are certain hazardous
materials and operations that have addi-
tional medical surveillance requirements.
Table C2- 1 provides a summary of OSHA
standards that have specific medical sur-
veillance requirements. The following sec-
tions describe some of these surveillance
requirements for common hazardous mate-
rials and operations. Figure C2-4 summa-
rizes the common materials and operations
discussed in this section.
• Recommendation for further
follow-up
4.1 Bloodborne Pathogens
• Results of the medical examination
and any associated tests
EPA laboratories must provide all employ-
ees who are occupationally exposed to
bloodborne pathogens (BBP) and other
June 1998
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SHEMP Operations Manual for Laboratories
CHAFrER C
Laboratory SHE Programs
Table C2-1: OSHA Standards with Spe-
cific Medical Survefflance Requirements
Standard
Citation
Acrylonitrile
29 CFR 19101045
Arsenic (inorganic)
29 CFR 1910.1018
Asbestos
29 CFR 1910.1001
Benzene
29 CFR 1910.1028
Bloodborne pathogens
29 CFR 1910.1030
1,3-Butadiene
29 CFR 1910.1051
Cadmium
29 CFR 1910.1027
Carcinogens (specific
chemicals)
29 CFR 1910.1003
1,2-dibromo-3-
chioropropane (DBCP)
29 CFR 1910.1044
Ethylene oxide
29 CFR 1910.1047
Formaldehyde
29 CFR 1910.1048
Laboratory
29 CFR 1910.1 450
Lead
29CFR1910. 1025
Methylene chloride
29 CFR 1910.1052
Methylenedianiline
(MDA)
29 CFR 1910.1050
Occupational noise
exposure
29 CFR 1910.95
Respiratory protection
29 CFR 1910.134
Vinyl chloride
29 CFR 1910.1017
potentially infectious materials (OPIM)
with medical surveillance per the require-
ments of OSHA’s Bloodborne Pathogens
Standard. Medical surveillance required
under the standard includes administering
the Hepatitis B vaccine and conducting
post-exposure evaluation and follow-up.
C2. Medical Surveillance Program
Refer to Chapter Cl of this manual for
additional information on the components
of a biosafety program.
Figure C2-4: Hazardous Materials and
Operations with Specific Medical
Surveillance Requirements
Bloodborne Pathogens
Laboratory Animal Research
Chemicals
Formaldehyde
L Methylene Chloride
Respiratory Hazards
Noise Hazards
4.1.1 Hepatitis B Vaccination
A vaccine is available to protect personnel
against infection from Hepatitis B. OSHA
requires that employers make this vaccine
available free of charge to all personnel
with potential occupational exposure to
blood or OPIM. Vaccination programs
must be administered in accordance with
the recommendations of the U.S. Public
Health Service and under the supervision
of a licensed physician or healthcare
professional.
The vaccine is noninfectious, and will not
prevent Hepatitis A, C, orE. The vaccine
is typically administered as three injections
in the arm over six months. The second
injection is given one month after the first,
and the third is given at six months. To
ensure adequate immunity, it is important
for employees to receive all three
injections.
Hazardous
Materials and
Operations
&EPA June 1998
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There are special considerations for
employees who provide first aid for inci-
dents occurring in the workplace, since
the risk of exposure for these employees
is considered to be low. According to
OSHA, these responders only need to be
offered the Hepatitis B vaccine within 24
hours of exposure to blood or OPIM. This
exemption only applies to employees
whose routine work assignments do not
include administering first aid. In addition,
the employer must meet other provisions
of the OSHA standard.
In both cases, employees may decline the
Hepatitis B vaccine, and may request to
be vaccinated at a later date. However,
employees who choose not to receive the
vaccine must sign a mandatory declination
statement.
• Collecting and testing the source indi-
vidual’s blood if HIV and HBV status
are not already known
• Informing the employee of test results
• Providing counseling to the employee
• Administering post-exposure prophy-
laxis (e.g., Hepatitis B immunoglobu-
un) when medically indicated
• Evaluating any reported illness
related to the exposure incident
• Offering additional HIV testing to the
affected employee six weeks after
exposure and periodically thereafter
4.2 Laboratory Animal Research
4.1.2 Post-exposure Evaluation and
Follow-up
An exposure incident is defined as blood
or OPIM contact with eyes, mouth, mu-
cous membrane, or broken skin, resulting
from the performance of an employee’s
duties. Immediately following an exposure
incident, employees are required to receive
confidential post-exposure medical evalua-
tion and follow-up.
The medical evaluation and follow-up
involves:
• Evaluating the incident and document-
ing the route of exposure, HBV and
HIV status of the source (if known),
and the circumstances of exposure
• Collecting and testing the exposed
employee’s blood to determine lilY
and HBV status
Allergies and musculoskeletal injuries are,
the primary health risks to individuals
using and caring for laboratory animals.
Allergies are a significant problem, but
they can be reduced by using protective
equipment. Musculoskeletal injuries can
be minimized by good laboratory planning,
use of transport equipment (e.g., carts),
and training in lifting techniques and
equipment use.
Infectious diseases may constitute a
significant risk depending on the species
and health status of animals involved, and
the level to which animal care personnel
are exposed to viral infections (e.g., rabies
from random source dogs and lymphocytic
choriomemngitis from hampsters and
mice).
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Cell cultures, animal tissues, and excreta
can also serve as sources of infectious dis-
ease. Careful monitoring and quarantine
of any animals with potential viral or bac-
terial infections is a critical part of quality
assurance in animal care programs. Partic-
ular care must be taken in laboratories
handling nonhuman primates (NHPs),
because these animals are most prone to
carry infections that are known to cause
serious disease in humans (e.g., Herpes B,
encephalitis, and tuberculosis). Routine
periodic mycobacterial skin testing of
employees and associated NHPs is
essential.
Animal bites and scratches are hazards
common to animal care personnel. All
cases should be documented by complet-
ing an incident report and recording it in
an incident log. Tetanus inununizations
should be routinely administered every
10 years and at the time of a potential
exposure.
Laboratory employees working with
BacillusCalmetze-Guerjn (BCG)-injected
animals will be provided tuberculin skin
testing during employment examinations
and annually thereafter.
Employees working with NHPs will
receive the following:
• Blood serum tests wherein the serum
is sampled, frozen, and stored during
pie-employment examinations, annu-
ally, and on exiting
• Tuberculin skin testing with a
purified protein derivative during
pie-employment examinations and
every six months
• Chest x-ray for those with a history
of positive reaction to tuberculin skin
testing
• Hepatitis B vaccination (optional)
• Stool samples to check for salmonella,
shigella, and campylobacter
Protection against Herpes B virus should
be provided in the event of a monkey bite
or scratch.
4.3 Chemical-Specific Surveillance
As required by the OSHA Laboratory
Standard, all laboratory employees work-
ing with hazardous chemicals shall have
access to medical attention, including any
follow-up examinations that the examining
physician determines to be necessary.
Two chemicals commonly used in EPA
laboratories with medical monitoring
requirements arc formaldehyde and methy-
lene chloride. Their requirements are out-
lined in the following sections. For other
chemical-specific medical surveillance
requirements, refer to the OSHA standard
for that chemical.
4.3.1 Formaldehyde
The use of formaldehyde in histology,
pathology, and anatomy laboratories is
covered by OSHA’s Formaldehyde Stan-
dard in 29 CFR 1910.1048. For these oper-
ations, EPA laboratories must institute a
medical surveillance program for all
employees who are:
I A
June 1998
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C2. Medical Surveillance Program
• Exposed to formaldehyde at concen-
trations at or above an 8-hour time-
weighted average (1’WA) or above
the short-term exposure limit (STEL)
• Developing signs and symptoms of
overexposure to formaldehyde
• Exposed to formaldehyde in an
emergency
The OSHA standard presents information
pertaining to formaldehyde medical stir-
veilance, emergency examinations, provi-
sion of information by an employer to the
physician, and medical removal due to the
significant exposure symptoms. These
components are summarized in Figure
C2-5 and are discussed in the following
sections.
Medical Surveillance
Unlike some other specific standards, the
formaldehyde standard does not require
periodic medical examinations for employ-
ees exposed at or above the action level.
Instead, medical surveillance is performed
by completing medical questionnaires,
submitting reports of exposure signs and
symptoms, and obtaining medical exami-
nations when necessary as
detailed below.
Medical surveillance for employees
exposed at or above the action level or
STEL, and who experience signs or symp-
toms indicating probable exposure, must
include the following:
Figure C2-5: Components of the OSHA Formaldehyde Standard
Medical
Questionaires
Reports of
Exposure Signs
and Symptoms
_Medicai and work
history
Observation of
— formaldehyde
exposure symptoms
OSHA
Form kIrhyde
Standara
Provision of
Information
Exposure levels
PPE used
Liob duties
Medical Removal
— Significant exposure
symptoms presented
Comparable work,
- salary, seniority, and
benefits
Medical
Surveillance
Emergency j
Examlna t io!I
I
— Multiple-physician
review mechanism
available
Other exams as
Medical Exam — needed
— Physical exam
— Laboratory exam for
respirator wearers
— Other tests
— Counseling of employees
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C2. Medical Surveillance Program
Completing Medical Questiortnaires.The
medical questionnaire, such as the one
included in Appendix D of the OSHA
Formaldehyde Standard, is designed to
elicit information on:
• Work history
• Smoking history, evidence of eye,
nose, and throat irritation
• Chronic airway problems or hyperac-
tive airway disease
• Allergic skin conditions or dermatitis
• Upper and lower respiratory problems
Submitting Reports of Exposure Signs
and Symptoms. In conjunction with the
medical questionnaire, employees should
submit reports of any exposure signs and
symptoms to medical staff.
if an employee reports signs or symptoms,
and the physician determines that a medi-
cal examination is not immediately neces-
sary, a two-week observation period then
begins. The purpose of this observation
period is to provide an opportunity to
evaluate the problem and to treat the con-
dition or causative factors in the work-
place. This provision is supported by the
fact that many formaldehyde-induced signs
and symptoms often resolve themselves
within a few hours or a few days. Also,
the observation period will allow the labo-
ratory to determine whether signs or symp-
toms subside spontaneously, with minimal
treatment, or whether improvements to
working conditions can be made to allevi-
ate the exposure, and the resulting condi-
tion, without unnecessary expenditure. If
the signs or symptoms have not subsided
or been remedied by the end of the two-
week observation period, the affected
employee must be examined by the physi-
cian. If the signs and symptoms worsen
during the two-week period, the employee
must be examined by the physician as soon
as this fact is determined.
Obtaining Medical Examinations. Based
on evaluation of the medical questionnaire,
a physician determines whether a medical
examination is necessary for employees
who are not required to wear respirators to
reduce their exposure to formaldehyde.
Medical examinations shall be given to
any employee who the physician feels may
be at increased risk from exposure to
formaldehyde, based on the information in
the medical questionnaire. All employees
required to wear a respirator to reduce
exposure to formaldehyde must obtain a
medical exam at least annually. The medi-
cal examination shall include:
• A physical examination with emphasis
on evidence of irritation or sensitiza-
tion of the skin and respiratory sys-
tems, shortness of breath, or irritation
of the eyes
• Laboratory examinations for respirator
wearers consisting of baseline and
annual pulmonary function tests
• Any other test that the examining phy-
sician deems necessary to complete
the written opinion
• Counseling of employees having ined-
ical conditions that would be directly
or indirectly aggravated by exposure
to formaldehyde, or result in an
increased risk of impairment to their
health
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Emergency Examinations. For employees
exposed to formaldehyde in an emergency,
examinations must be made as soon as
possible following the emergency. These
examinations shall include a medical and
work history with emphasis on any evi-
dence of upper or lower respiratory prob-
lems, allergic conditions, skin reaction,
or hypersensitivity, and any evidence of
eye, nose, or throat irritation. Other exami-
nations shall consist of those elements
considered appropriate by the examining
physician.
Provision of infonnation
OSHA has set specific requirements
concerning the information that must be
provided by the employer to the physician.
This information includes exposure levels
in the employee’s job assignment, any
personal protective equipment used by
the employee, and a description of the
employee’s job duties as they relate to the
exposure. OSHA has established specific
requirements concerning the written opin-
ion that the physician must provide for
each examination required under the form-
aldehyde standard.
Medical Removal Provisions
The OSHA Formaldehyde Standard
includes medical removal provisions that
apply when an employee reports signifi-
cant irritation of the mucosa of the eyes
or upper airways, respiratory sensitization,
dermal irritation, or dermal sensitization
attributed to workplace formaldehyde
exposure.
In the case of dermal irritation and
dermal sensitization in the absence of
other symptoms, the medical removal
provisions do not apply when the percent-
age of formaldehyde in the product sus-
pected of causing the dermal condition is
below 0.05 percent. This restriction was
established based on evidence that only
those products with higher concentrations
have clearly been associated with dermal
irritation or sensitization.
In the event of a recommendation of
removal by the examining physician, the
affected employee must be removed from
the current formaldehyde exposure and, if
possible, transferred to work having no (or
significantly less) exposure to formalde-
hyde. OSHA requires that the employee be
transferred to a position involving compa-
rable work for which the employee is qual-
ified. if there is no such work available,
the employer is required to maintain the
employee’s current earnings, seniority, and
other benefits until:
• Such work becomes available.
• The employee is determined to be
unable to return to the workplace
because of formaldehyde exposure.
• The employee is determined to be able
to return to the original job status; or
for six months, whichever comes first.
Within six months of the medical removal,
the physician must then decide whether the
employee can be returned to his or her
original job status, or if the removal is to
be permanent.
OSHA provides for a multiple-physician
review mechanism in the Formaldehyde
Standard to ensure successful operation of
the program. Multiple-physician review
provides employees with an opportunity
for a second medical opinion when a
worker questions the recommendations
from a physician chosen by the employer.
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C2. Medical Surveillance Program
This provision serves to ensure employee
confidence in the soundness of any medi-
cal determinations that may significantly
affect their health or their job status.
4.3.2 Methylene Chloride
The EPA laboratory shall make medical
surveillance available for staff who are, or
may be, exposed to methylene chloride as
follows:
• At or above the action level on 30 or
more days per year, or above the 8-
hour TWA permissible exposure limit
(PEL) or the STEL on 10 or more days
per year
• Above the 8-hour TWA PEL or
STEL for any time period where an
employee has been identified by a
physician or other licensed health
care professional as being at risk
from cardiac disease or from some
other serious methylene chloride—
related health condition and such
employee requests inclusion in the
medical surveillance program
• In the event of an emergency
In addition, the EPA laboratory shall pro-
vide all required medical surveillance at no
cost to affected staff, without loss of pay,
and at a reasonable time and place. All
medical surveillance procedures are to be
performed by a physician or other licensed
health care professional. The frequency of
medical surveillance provided to staff
should be as presented in Table C2-2.
The standard presents information on
medical surveillance and provision of in-
formation, as shown in Figure C2-6
and discussed in the following sections.
Table C2-2: Frequency of Medical Surveillance for Methylene Chloride
Frequency of
Surveillance
Description
Initial
Initial medical surveillance must be provided under the schedule, or before the time of
initial assignment of the employee, whichever is later.
Periodic
Update of the medical and work history for each affected employee must be performed
annually. Periodic physical examinations, including appropriate laboratory surveillance,
should be provided, as follows:
For employees 45 years of age or older, within 12 months of the initial surveillance or
any subsequent medical surveillance
• For employees younger than 45 years of age, within 36 months of the initial surveil-
lance or any subsequent medical surveillance
Termination
Upon termination of employment or reassignment to an area where exposure to methylene
chloride is consistently at or below the action level and STEL, medical surveillance shall
be made available if six months or more have elapsed since the last medical surveillance.
Additional
Additional medical surveillance should be provided at frequencies other than those listed
above when recommended in a written medical opinion.
at 11%A
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Laboratory SHE Programs
C2. Medical Surveillance Program
Figure (2-6: OSHA Methylene Chloride Standard Medical Surveillance Requirements
V
Routine
Examinations
(_Medical and work
history
— Physical examination
L Laboratory
r surveillance
L. Other information or
reports
Routine Examinations
The content of medical surveillance per-
formed on staff occupationally exposed
to methylene chloride should include the
information in the following sections.
Medical and Work History. The compre-
hensive medical and work history shall
include identification of the following
symptoms: neurological, dermatological,
hematological, hepatological, and cardio-
vascular. In addition, information on risk
factors for cardiac dIsease, methylene
chloride exposures, and work practices and
personal protective equipment used during
such exposures should be gathered.
Physical Examination. The extent and
nature of the physical examination should
be determined based on the health status
of the employee and analysis of the medi-
cal and work history. During the physical
examination, the physician or other
licensed health care professional shall pay
Emergency
Examinations
_Eniergency treatment
and decontamination
— Physical examination
Updated medical and
— work history
— Laboratory surveillance
particular attention to the lungs, cardiovas-
cular system (including blood pressure and
pulse) , liver, nervous system, and skin.
Laboratory Surveillance. The physician
or other licensed health care professional
shall determine the extent of any required
laboratory surveillance based on the
employee’s observed health status and
the medical and work history.
Other Infonnation or Reports. The medi-
cal surveillance shall also include any
other information or reports the physician
or other licensed health care professional
determines are necessary to assess the
employee’s health in relation to methylene
chloride exposure.
Emergency Examinations
The employer shall ensure that medical
examinations are made available when an
employee has been exposed to methylene
chloride in emergency situations. Exami-
nations shall include, at a minimum:
OS IIA Methylene
Chloride Standard
Medical
Surveillance
Provision of
Information
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Laboratory SHE Programs
C2. Medical Surveillance Program
• Appropriate emergency treatment and
decontamination of the exposed
employee
• Comprehensive physical examination
with special emphasis on the nervous
system, cardiovascular system, lungs,
liver, and skin
• Updated medical and work history, as
appropriate for the medical condition
of the employee
• Laboratory surveillance, as indicated
by the employee’s health status
Where the physician or other licensed
health care professional determines it is
necessary, the scope of the medical exami-
nation shall be expanded and the appropri-
ate additional medical surveillance, such
as referrals for consultation or examina-
tion, shall be provided.
Provision of Information
The employer shall provide the follow-
ing information to a physician or other
licensed health care professional who is
involved in the diagnosis of methylene
chloride—induced health effects:
• A copy of OSHA’s Methylene Chlo-
ride Standard in 29 CFR 1910.1052
• A description of the affected
employee’s past, current, and antici-
pated future duties as they relate to
their methylene chloride exposure
• The employee’s former or current
exposure levels, or, for employees
not yet occupationally exposed to
methylene chloride, the employee’s
anticipated exposure levels in normal
and emergency situations
• A description of any personal protec-
tive equipment used or to be used (e.g.,
respirators)
• information from previous
employment—related medical surveil-
lance of the affected employee that
is not otherwise available to the physi-
cian or other licensed health care
professional
For each physical examination required by
this section, the employer shall ensure that
the physician or other licensed health care
professional provides the employer and the
affected employee with a written opinion
regarding the examination results within
15 days of completing and evaluating
medical and laboratory findings, but not
more than 30 days after the examination.
The written medical opinion shall be lim-
ited to the following information:
• The physician’s or other licensed
health care professional’s opinion con-
cerning whether the employee has any
detected medical condition(s) that
would place the employee’s health at
increased risk of material impairment
from exposure to methylene chloride
• Any recommended limitations on the
employee’s exposure to methylene
chloride or on the employee’s use of
protective clothing or equipment and
respirators
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• A statement that the employee
has been informed by the physician
or other licensed health care profes-
sional that methylene chloride is a
potential occupational carcinogen,
that it increases risk of heart disease,
and that it can exacerbate underlying
heart disease by being metabolized to
carbon monoxide
• A statement that the employee has
been informed by the physician (or
other licensed health care professional)
of the results of the medical examina-
tion and any medical conditions result-
ing from methylene chloride exposure
that require further explanation or
treatment
The employer shall instruct the physician
or other licensed health care professional
not to reveal to the employer, orally or in
the written opinion, any specific records,
findings, or diagnoses that have no bearing
on occupational exposure to methylene
chloride.
4.4 Respiratory Protection
Employees who are required to wear
positive- or negative-pressure respirators
must obtain written medical clearance
from a physician to use this equipment.
This medical qualification represents an
assessment by a physician that the person
in question will not be placed at elevated
risk of injury or illness as a consequence
of wearing the respirator. In addition,
OSHA has issued specific medical surveil-
lance requirements for employees who
wear respirators, and has included specific
respirator requirements in its substance-
specific regulations.
In its Respiratory Protection Standard,
OSHA does not identify the specific
tests or examinations to be included in
the respirator qualifying physical exan,ina-
tion. However, the American National
Standards Institute (ANSI) publication that
addresses physical qualifications for respi-
rator users (ANSI Z88.6-1984) identifies
medical conditions that may preclude or
limit the extent to which respirators may
be worn by an individual, including those
conditions presented in Table C2-3.
Employees who use, or may be required to
use, respiratory protective devices shall
receive a respirator physical examination
prior to employment, and annually thereaf-
ter. After completing the examination, the
physician will submit a written opinion on
each employee’s respirator qualification
status to the EPA laboratory.
4,5 Hearing Protection
At EPA laboratories where hearing
protection devices are used to reduce occu-
pational noise levels, an audiometric test-
ii g program must be established for
all employees whose exposures equal
or exceed an 8-hour TWA action level
of 85 decibels. Within 6 months of an
employee’s first exposure at or above
the action level, EPA laboratories must
establish a valid baseline audiogram
against which subsequent audiograms
can be compared. At least annually after
obtaining the baseline audiogram, the lab-
oratory shall obtain a new audiogram for
each employee.
Each employee’s annual audiogram must
be compared to their baseline audiogram
to determine if a standard threshold shift
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Table C2-3: Physical Qualifications for Respirator Users
Physical Qualification
Description
Hearing Deficiency
The employee’s hearing must be adequate to ensure communicanon
and response to alarms and instructions. In addition, the presence of a
perforated tympanic membrane (eardrum) may allow absorption of
contamination.
Respiratory Diseases
An employee with insufficient pulmonary function may be disquali-
fied from wearing a respirator. Where a question exists regarding
pulmonary function, spirometry should be performed.
Cardiovascular Diseases
Since the use of a respirator may place additional stress on the cardio-
vascular system, existing cardiovascular disease should be careflully
evaluated as a disqualifying condition.
Endocrine Disorders
An employee who is subject to sudden loss of consciousness or
response ability could be placed in significant danger if such an event
were to occur while in a contaminated environment.
Neurological Disability
Loss of consciousness and reduced response ability caused by a
neurological condition may disqualify an employee for the same
reasons as endocrine disorders. Epilepsy controlled by medication
should not necessarily be a disqualifying condition.
Psychological Conditions
Certain psychological conditions, such as claustrophobia, may dis-
qualify an employee from respirator use.
Medications
Past and current use of some medications may disqualify an employee
from respirator use.
(STS) has occurred. Following the detec-
tion of an STS that is determined to be
work-related or aggravated by occupa-
tional noise exposure, the EPA laboratory
must ensure that the following steps are
taken:
• Employees not using hearing protec-
tion shall be fitted with hearing protec-
tors, be trained in their use and care,
and be required to use them.
• Employees already using hearing pro-
tection shall be refitted and retrained
in their use and provided with different
hearing protection that offers greater
attenuation if necessary.
• If additional testing is necessary,
or if the employer suspects that a
medical pathology of the ear is
caused or aggravated by the wearing
of hearing protection, the employee
shall be referred for a clinical audio-
logical evaluation or an otological
examination, as appropriate.
• if a medical pathology of the ear is
suspected that is unrelated to the use
of hearing protection, the employee
shall be informed of the need for an
otological examination.
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5.0 Medical Recordkeeping
Proper recordkeeping is essential at EPA
laboratories because of the nature of the
work and its risks. OSHA has issued
requirements that must be adhered to at
all laboratories concerning access to
employee medical records in 29 CFR
19 10.1020 and recordkeeping for injuries
and illnesses in 29 CFR 1960, Subpart I,
for federal agency employees.
Medical records pertaining to bloodborne
pathogens must include, among other
items, a copy of the employee’s Hepatitis
B vaccination status and the results of
examinations, tests, and follow-up
procedures.
Medical records for each employee shall
be preserved and maintained in a confiden-
tial file for at least the duration of employ-
ment, plus 30 years (unless a specific
occupational safety and health standard
provides a different time period require-
ment). In addition, whenever an employee
(or designated representative) requests
access to a record, the EPA laboratory
must ensure that the record is provided
in a reasonable place, manner, and time
(i.e., within 15 working days).
OSHA also requires that, when an
employee first enters into employment
(and at least annually thereafter), each
employer shall inform them of the exis-
tence, location, and availability of:
• Medical records
• The person responsible for maintaining
and providing access to these records
• Each employee’s right to access these
records
Logs of occupational injuries and illnesses
shall be maintained by each EPA labora-
tory. Recordable injuries or illnesses must
be recorded on an OSHA Form 200-F (or
the equivalent) within six working days
after the laboratory has been notified of an
illness or injury case. This log shall be
established on a calendar-year basis and
maintained separate from medical records
in an easily retrievable form. Under the
standard, BBP exposure incidents must
also be documented. However, only expo-
sure incidents that require medical beat-
ment (e.g., AZT prophylaxis, gamma glob-
ulin) and/or result in illness need to be
recorded. A supplemental record of occu-
pational injuries and illnesses must be
completed using the OSHA No. 101 form
(or equivalent).
Each facility must complete an annual
summary of occupational injuries and ill-
nesses. The OSHA Form 200-F annual
summary must be completed no later than
one month after the close of each calendar
year. A copy of this summary shall be
posted in a conspicuous location no later
than February 1 and must remain in place
until March 1.
OSHA Form 200-F and OSHA Form No.
101 shall be maintained for five years fol-
lowing the end of the year to which they
relate.
For more information on recording occu-
pational injuries and illness, refer to
Chapter A of this manual.
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SHE Training Program
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C3. SHE Training
1.0 Introduction
At EPA laboratories, may
encounter various types of hazards—
chemical, physical, biological, and radio-
logical. Laboratory management must
familiarize employees with these hazards
and their associated risks, since individu-
als properly trained in handling hazardous
agents are much better equipped to mini-
mize the risk of exposure to themselves,
their coworkers, and the environment. It is
well known that training plays a critical
role in preventing workplace injuries and
illnesses. A comprehensive training pro-
gram teaches employees the proper use of
safety equipment and the implementation
of related procedures and policies. How-
ever, the success of a training program
depends on how fully management sup-
ports these programs and how employees
use the information they learn in the train-
ing course(s).
The goal of any training program is to
ensure that all individuals at risk are ade-
quately informed about workplace opera-
tions, their risks, control measures, and
what to do if an accident occurs. The train-
ing program should be interactive and
offered regularly, not simply on an annual
basis.
This chapter describes the training require-
ments of those standards that apply to
EPA laboratories, as well as training that
is recommended by industry best practices.
Most of the training programs discussed in
this chapter are mandated by the U.S.
Occupational Safety and Health Adminis-
tration (OSHA) and the EPA. While many
of OSHA’s standards are performance-
oriented, allowing the employers the
flexibility to tailor the particular program
to specific worksite conditions, many of
the training provisions require that particu-
lar categories of information be addressed.
EPA Program Requirements
Each EPA laboratory must:
• Conduct a safety, health, and
environmental (SHE) training needs
assessment.
• Provide each laboratory employee
with the required training, both ini-
tially and periodically, as needed or
required, based on the results of the
needs assessment.
• Document and maintain records of
training.
All EPA laboratory employees must meet
the SHE training requirements specified in
EPA Order 1440 and in regional or
facility-specific programs.
Program Administration
To effectively manage the training of labo-
ratory employees, responsibilities should
be assigned for:
• Conducting a training needs assess-
ment to determine the requirements
for training content and frequency
• Coordinating training by:
— Developing training agendas and
materials and presenting the train-
ing internally
— Arranging for training to be pre-
sented by external resources
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• Tracking training needs (e.g., for
refreshers, new hires, or job changes)
• Maintaining training records as speci-
fied in applicable federal, state, and
local regulations
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SHEMP Operations Manual for Laboratories
CadwrER C
Laboratory SHE Programs
C i SHE Training
2.0 Training Guidelines
OSHA has developed voluntary training
guidelines to assist employers in providing
the safety and health information and
instruction needed for employees to work
with minimal risk to themselves, their
fellow employees, and the public. The
guidelines provide a model for designing,
conducting, evaluating, and revising train-
ing programs. The training model can be
used to develop training programs for a
variety of occupational safety and health
hazards identified in the workplace, as
well as for environmental is sues. It can
also help employers meet the training
requirements of current or future occupa-
tional safety and health standards.
The OSHA training guidelines are
designed to help employers to:
• Determine whether a laboratory prob-
tern can be solved by training.
• Detennine what training, if any, is
needed.
• Identify goals and objectives for the
training.
• Design learning activities.
• Conduct the training.
• Determine the effectiveness of the
training.
• Revise the training program based on
feedback from employees, supervisors,
and others.
Figure C3-l presents a summary of train-
ing guidelines that are presented in this
chapter. Additional training guidelines
can be found in the EPA’s “Risk Manage-
ment Through Training ’ manual.
Figure C3-1: Guidelines for the
Development of a Training Program
Training Guidelines
4 ,
Perform a Needs Assessment
1
Design the Training Program
‘ V
Develop Training Content
4,
Conduct Training
r Evaluate Training
Effec t iveness
‘ I.
Improvethe
Trait Prgra
I
2.1 Perform a Needs Assessment
The first step in the training model is to
determine if a problem can be solved by
training. In situations where employees
are not performing their jobs properly, it
is frequently assumed that training will
solve the problem. However, it is possible
that other approaches (e.g., hazard abate-
ment, engineering controls) might be more
effective in helping employees to perform
their tasks correctly. Problems that can be
addressed effectively by training include
those that arise from lack of knowledge of
a work process, unfamiliarity with equip-
ment, or incorrect execution of a task.
Training may prove to be less effective in
cases where a performance problem is the
result of an employee’s lack of motivation.
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C3. SHE Training
If an employer determines that training is
needed, then the first step is to identify
specific training needs. One method of
determining if additional training may be
required is to conduct ajob hazard analysis
(JHA). A JHA is a method for studying
and recording each step of a job, identify-
ing existing or potential hazards, and
determining the best way to perform the
job in order to reduce or eliminate the
risks. Information generated from this
activity may reveal a need for additional
training. Refer to Chapter 82 of this man-
ual for additional information on JHAs.
As part of the assessment, the audience
needing the training should be defined.
Training is generally needed when there
are:
• New employees
• Transferred employees
• Changes in programs or procedures
• New regulations or requirements
• New equipment or materials
• Needs for improved performance
2.2 Design the Training Program
Once the training need has been identified,
the next step is to design the program by:
• Establishing goals and objectives
• Determining training methods
• Designing learning exercises
• Developing training materials appro-
priate for the audience
Each of these steps is described in the fol-
lowing sections and shown in Figure C3-2.
Figure (13-2: Steps hi Designing a
Training Program
Design the
Training Program
‘ I ,
Establish Training Goals
and Objectives
‘ I ,
Determine
Training Methods
‘ I ,
Deaign
Learning Exercises
I
Develop Training
Ma
2.2.1 Establish Goals and Objectives
After training needs have been identified,
specific goals and objectives for the train-
ing should be designated to ensure the use-
fulness and success of the training. For an
objective to be most effective, it should
identify, as precisely as possible, what
individuals will do to demonstrate that
they have learned the desired material,
or that the training objective(s) has been
reached. Objectives should also describe
the important conditions under which the
employee will demonstrate his or her
competence and define what constitutes
acceptable performance.
In its training guidelines, OSHA advises
that objectives should designate the pre-
ferred practice or skill, and its observable
behavior, using action-oriented language.
For instance, rather than using the state-
ment: “The employee will understand how
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Laboratory SHE Programs
C3. SHE Training
to use a respirator” as an objective, it
would be preferable to say: “The employee
will be able to describe how a respirator
works and when it should be used.”
2.2.2 Determine Training Methods
Once the goals and objectives of the train-
ing are determined, the next step is to
identify the most effective method of train-
ing. Selecting methods and materials for
the training depends on such factors as the
extent of training resources available to the
laboratory and the type of skills or knowl-
edge to be learned. The training may be
group-oriented and include lectures, role
playing exercises, and demonstrations, or
it may be designed for the individual with
self-paced instruction. Usually a combina-
tion of training methods will be used,
since some methods will be more effective
than others, depending on the key concepts
to be presented.
Instructional audio/visual aids may help
the trainer to convey important material.
The following are a few guidelines for
using visuals as training tools:
• Use visuals to summarize or illustrate
main points—not to repeat what is
being said.
• Keep text and diagrams simple.
• Use laboratory photographs or
other representative graphics where
possible.
2.23 Design Learning Exercises
Regardless of the method of instruction,
the learning exercises should be developed
in such a way that the employees can
clearly demonstrate whether they have
acquired the desired skills or knowledge.
The program should be designed to deter-
mine whether the objectives of the learn-
ing exercises are being met (e.g., quiz, oral
questions and answers, instructor observa-
tion of participant demonstration, etc.).
2.2.4 Develop Training Materials
The training materials should be appropri-
ate in content and vocabulary to the
educational literacy and language back-
ground of participants. This ensures that
all employees, regardless of their cultural
or educational background, will receive
adequate training on how to eliminate or
minimize their occupational exposure.
AudiolVisualAids
• Diagrams
• Slides
• Films
• Viewgraphs
• Videotapes
• Flipcharts
• Audiotapes
• Blackboard and chalk
• Any combination of these and
other instructional aids
Training Methods
• Open, interactive discussions
• Demonstrations
• Case studies
• Brainstorming sessions
• Hands-on simulations and drills
• Quizzes
• Videos
• Computer-based training
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C3. SHE Training
Where commercially available programs
are used, ensure that there is an opportu-
nity to provide participants with supple-
mental facility-specific information.
2.3 Develop Training Content
Initial laboratory training should be pro-
vided for all employees. In addition, all
employees working in the laboratory are
required to attend eight hours of SHE
compliance training annually.
Regional and facility laboratory training
requirements are designed to comply with
the OSHA standard “Occupational Expo-
sures to Hazardous Chemicals in Laborato-
ries” in 29 CFR 1910.1450, as well as
EPA Order 1440. Other requirements may
pertain to laboratory employees based on
their duties and responsibilities (e.g., if
they handle hazardous waste).
2.4 Conduct Training
Training should be presented so that its
organization and meaning are clear to the
employees. To become motivated to pay
attention and learn the material that the
trainer is presenting, employees must be
convinced of the importance and relevance
of the material. Trainers are encouraged
to follow the training tips provided as
follows:
• Prepare for the training session:
— Review the material presented.
— Ensure that all materials and
equipment are ready and in good
working order.
— Have backups for essential items
(e.g., spare projector bulbs).
— Check the seating arrangement
and layout of the room (e.g.,
placement of audiovisual tools).
• Explain the goals and objectives of the
session.
• Point out the benefits of the training.
• Provide overviews of the material to
be learned.
• Relate the training to the employees’
interests, skills, and experiences.
• Encourage employee involvement and
interaction.
• Reinforce what the employees learned
by summarizing the objectives and key
points.
• Encourage employee feedback on the
effectiveness of the session.
An effective training program allows
employees to participate in the training
process itself, thereby practicing their
skills or knowledge. Employee involve-
ment in training may include:
• Participating in discussions
• Asking questions
• Contributing their knowledge and
expertise
• Learning through hands-on experience
• Conducting role-playing exercises
2.5 Evaluate Training Effectiveness
Evaluating the effectiveness of the training
program is essential to ensure that the pro-
grain is meeting its goals. The method for
training evaluation should be developed at
the same time the training objectives and
content are developed. Examples of train-
ing evaluation are as follows:
• Questionnaires given to employees
• Informal discussions with employees
• Observations of employees’ behavior
before and after training
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• Changes in the workplace resulting in
reduced injury or accident rates
• Observation of training by an external
reviewer or auditor
2.6 Improve Training Program
If evaluation of the training reveals that it
did not provide employees with the level
of knowledge and skill that was expected,
then it may be necessary to revise the
training program. In this situation, asking
questions of both employees and trainers
may provide useful information. Among
the questions that might be asked are:
• Were parts of the content already
known and, therefore, not necessary?
• What material was confusing or
distracting?
• Was anything missing from the
program?
• What did the employees learn and
what did they fail to learn?
An effective evaluation will identify pro-
gram strengths and weaknesses, establish
whether training goals are being met, and
provide a basis for future program
changes.
3.0 Overview of Training Requirements
The type and content of training required
will vary based on the results of the train-
ing needs assessment. The following
section provides information on topics for
which certain laboratories must provide
training. Figure C3-3 outlines the training
requirements discussed in this section.
3.1 SHE Refresher
The topics covered in the required annual
SHE refresher training for EPA laboratory
employees may be determined by each
laboratory based on the specific risks,
activities, and needs of their employees.
Often, laboratories can meet an OSHA
requirement for annual refresher trainin Y
by covering certaiioiiipliañ ëilirniiits
during the training. For instance, laborato-
ries where employees are designated to
fight incipient fires can meet the require-
ment for annual li iiiiiigby incIudiflgJ-
asessionon the use of portable fire
extinilisbers andissociated emergency
t&edures.
; . Tinin1ñg
: Requirements
— SHE Refresher
I— Chemical Hygiene
— Chemical-Specific
— Fire Safety
Ergonomics
H Occupant Emergency Plan
b Environmental Compliance
DOT
Figure C3-3: Training Requirements for Typical Programs
— Radiation Safety
— Biosafety
— Protective Clothing and Equipment
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Common topics for the annual SHE
refresher include the following:
• Routes for chemical exposure
• Toxic effects of chemicals
• Means of preventing exposure
• Effective use of ventilation
• Eye, face, and hand protection
• Respiratory protection
• Techniques for reducing health
hazards
• Emergency procedures
• Standard operating procedures
• Safe use of laboratory equipment
• Fire extinguishers
• Eyewashes and safety showers
• Chemical spill procedures
• Waste minimization and disposal
practices
• Other subjects related to EPA labora-
tory facilities
3.2 Chemical Hygiene
EPA laboratories must provide employees
with information and training so that they
will be apprised of both the physical and
health hazards associated with hazardous
chemicals present in the laboratory. The
goal of this training is to ensure that
employees are adequately informed about
their work in laboratory facilities, the
risks, and the appropriate responses in
case of an emergency.
Chemical hygiene training is mandated
by the OSHA Laboratory Standard.
The training provisions of this standard
supersede the training requirements of
substance-specific standards (e.g., ben-
zene, formaldehyde, methylene chloride),
unless otherwise stated by the specific
standard. In addition, the training require-
ments outlined in the laboratory standard
supersede, for laboratory employees, the
training requirements of the Hazard Com-
munication Standard in 29 CFR
1910.1200.
The required training does not necessarily
involve training for each specific chemical
that the employee will use, but rather the
approach may be directed to classes or
groups of hazardous chemicals.
Information and training must be provided
at the time of the employee’s initial assign-
ment and prior to assignments involving
new hazardous chemicals or new exposure
situations. Typically, new exposure situa-
tions include those in which new classes or
groups of chemicals are used, or those in
which new operations introduce different
opportunities for exposure than those per-
formed previously.
The frequency of’ refresher training may
be determined by each laboratory, but the
chemical hygiene plan is a topic generally
covered during the rç red eighj hours of
annual refresher training for EPA 1abora
—
tc*y employees. more frequent
traiiiiiii iaybewaffanted for employees
who work in high-risk areas.
After receiving chemical hygiene training,
laboratory employees should be familiar
with all of the OSHA-required compo-
nents of training and information under
the Laboratory Standard as outlined in
Figure C3-4.
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Figure C3-4: Chemical Hygiene Training Topics
C3. SHE Training
Physical and Health
Hazards of Laboratory
Chenucals
Methods for Detecting
Presence of
Hazardous Chemicals
Measures Employees
Can Take to Protect
Themselves From
Exposure to
Hazardous Chemicals
3.2.1 Physical and Health Hazards of
Laboratory Chemicals
This component covers information on the
physical and health hazards of chemicals,
including those given in the definitions
section of the OSHA Laboratory Standard.
Generic classes include carcinogens,
acutely toxic chemicals, oxidizers, corro-
sives, etc. This information is essentially
the same as that typically provided by
training under the Hazard Communication
Standard.
3.2.2 Methods of Detecting the Pres-
ence of Hazardous Chemicals
This component covers industrial hygiene
monitoring methods and the visual appear-
ance and/or odor of particular chemicals or
groups of chemicals. Training in this cate-
gory may also include ways in which
employees may be alerted to the presence
of hazardous chemicals, such as signs and
symptoms of exposure, continual vigilance
of workplace conditions, and results of
equipment malfunction.
3.2.3 How Employees Can Protect
Themselves from Hazardous
Chemicals
This component includes details of the
customized chemical hygiene plan (CHP)
and virtually all of the standard operating
procedures (SOP) topics. Training in this
category covers specific procedures the
employer has implemented to protect
employees from exposure to hazardous
chemicals, such as appropriate work prac-
tices, use of containment and safety equip-
merit, emergency procedures, and personal
protective equipment.
In addition, certain required information
must be made available and communicated
to the employees for chemical hygiene:
• Contentof29CFR 1910.1450 and its
appendices
• CliP, location, and availability of:
— Exposure limits
— Permissible exposure limits
(PELs) for OSHA-regulated
substances
Chemical Hygiene
I
Details of the CHP
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— Recommended exposure limits for
hazardous chemicals that do not
have OSHA PELs
• Signs and symptoms associated with
exposures to hazardous chemicals
• Location and availability of reference
materials pertaining to chemical haz-
ards; safe handling, storage, and dis-
posal (including, material safety data
sheets [ MSDSs])
This information may be presented as part
of the training program, or made available
to employees by other means (e.g., memo.
electronic mail). Laboratory employees
should be familiar with the “required
information” items, and should know how
to access this information in their work
area or facility.
A sample training outline is provided in
Attachment C3- 1 of this chapter. Commer-
cially available training materials that
address such topics as hazard communica-
tion concepts, interpretation of the OSHA
Laboratory Standard, and use of laboratory
fume hoods, may be an important part of
the chemical hygiene training program;
however, it is strongly recommended that
employers do not rely solely on video-
tapes, slides, etc., to meet OSHA’s training
requirements. “Off-the-shelf” materials are
not sufficient to address the requirement
that employees be trained in the applicable
details of their employer’s CHP. The most
effective training programs are usually
interactive and conducted by a person who
is familiar with the facility’s organization
and operations.
Chapter C4 of this manual provides more
information on chemical hygiene program
requirements. In addition, SFIEM Guide
24 addresses chemical hygiene programs
and training.
3.3 Chemical-Specific
Where a laboratory is working to imple-
ment effective engineering and administra-
tive controls, there may be instances where
employee exposures to chemicals regu-
lated by an OSHA substance-specific stan-
dard exceed the action level or even the
permissible exposure limit. Where this
occurs, specific training is required.
Chemicals with specific training require-
ments include those listed in Table C3-1.
Table C3.-1: Chemical-Specific Training
Chemical
Regulation
Asbestos
29CFR 1910.1001
Formaldehyde
I9CFR 1910.1048
Cadmium
29CFR 1910.1027
Lead
29CFR1910.1025
Methylene Chloride
29 CFR 1910.1052
Arsenic (Inorganic)
29CFR 1910.1018
Acrylonitrile
29 CFR 1910.1045
Methylenedianiline (MDA)
29 CFR 1910.1050
Benzene
29 CFR 19 10.1028
1.3-butadiene
29CFR 1910.1051
Caicinogens
(specific chemicals)
29CFR 1910.1003
1,2-dibromo-3-
chioropropane (DBCP)
29CFR 1910.1044
Vinyl chloride
29CFR 1910.1017
Ethylene Oxide
29 CFR 1910.1047
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Training recommendations for formalde-
hyde and methylene chloride, two chemi-
cals commonly used at the EPA that are
regulated by a substance-specific standard,
are described in the following sections.
3.3.1 Formaldehyde
Appendix A of OSHA’s Formaldehyde
Standard in 29 CFR 1910.1048 provides
information that may be useful in conduct-
ing training, such as information on:
• Chemical properties
• Physical and health hazards
• Emergency and first-aid procedures
• Exposure monitoring
• Protective equipment and clothing
Training recommendations for formalde-
hyde are presented in Table C3-2.
3.3.2 Methylene Chloride
Appendices A and B of OSHA’s Methy-
lene Chloride Standard in 29 CFR 1910.
1052 contain a substance safety sheet and
technical guidelines, as well as informa-
tion on the toxicology, medical signs and
symptoms, and surveillance for methylene
chloride exposure. This information is
helpful when training employees working
with methylene chloride, especially those
exposed above the action level. Training
recommendations for methylene chloride
are presented in Table C3-3.
3.4 Radiation Safety
EPA laboratories must provide adequate
radiation safety training of all EPA person-
nel entering areas of potential radiation
exposure to keep exposures as low as
Table C3-2: Training Recommendations for Formaldehyde
Contents of the formaldehyde MSDS
A description of the potential health hazards associated with exposure to formaldehyde and
a description of the signs and symptoms of overexposure to formaldehyde
Instructions to immediately report the development of any adverse effects, signs, or
symptoms that the employee suspects are attributable to formaldehyde exposure
A description of operations in the laboratory where formaldehyde is present and an explana
tion of the safe work practices appropriate for limiting exposure
The purpose for, proper use of, and limitations of personal protective clothing and equip-
ment for formaldehyde use
Instructions for the handling of formaldehyde spills and emergencies
An explanation of the importance of engineering and work practice controls for employee
protection and any necessary instruction in the use of these controls
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Table C3-3: Training Recommendations for Methylene Chloride
C3. SHE Training
reasonably achievable (ALARA). All
training and dissemination of information
should correspond to an employee’s
duties, workplace assignment, and respon-
sibilities. The goals and requirements of
the EPA’s radiation safety training pro-
gram are provided in the SHEM Guide,
Chapter 38.
A radiation safety orientation is requreci
for all newiinployees EPA laboratories
upon beginning
will work with radioactive materials at
train g course.
RfreshertraininU basic radiation safety
is required at least once every two years
for all
ing and dosimetry program.
The introductory radiation laboratory work
practices course may also be required. This
course may be waived by the radiation
safety officer (RSO) based on a verifiable
record of the employee’s past training and
experience. Additional topics may be
included in the course, or training may be
shortened for EPA employees at Regional
Laboratories, where on-site radioactive
sources are limited to only sealed sources
used in analytical instruments (e.g., Ni-
63). At a minimum, a biennial refresher
course in radiation laboratory work prac-
tices is also required.
Contents of the methylene chloride MSDS
A description of the potential health hazards associated with exposure to methylene
chloride (e.g., cancer, cardiac effects, central nervous system effects, liver effects, and
skin/eye irritation)
A description of the signs and symptoms of overexposure to methylene chloride
instructions to immediately report the development of any adverse effects, signs, or
symptoms that the employee suspects are attributable to methylene chloride exposure
A description of operations in the laboratory where methylene chloride is present and an
explanation of the safe work practices appropriate for limiting exposure to methylene
chloride in each job
The purpose for, proper use of, and limitations of personal protective clothing and
equipment for methylene chloride
instructions for the handling of methylene chloride spills and emergencies
An explanation of the importance of engineering and work practice controls for employee
protection and any necessary instruction in the use of these controls
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All radiation trai igjs sched e an 1
& izedb he RSQ Appropriate train-
ing videos or interactive computer-based
training programs can be useful in course
presentations. All personnel radiation
tralmng records aremajntained by e
RSO or SHEMP Manager and the Labora-
tory Director.
3.4.1 Basic Radiation Safety
The core instructional materials for the
basic radiation safety training course can
be provided by SHEM Division and Office
of Radon and Indoor Air (ORIA), and con-
sist of an instructor lesson plan, student
handbook, videotapes, viewgraphs, and
a question bank, or similar CD-ROM.
Presentation of these materials will be
accompanied by discussion and a question-
and-answer period. EPA laboratories are
encouraged to supplement the core training
material to meet locally identified special
radiation safety training needs. Course
topics for presentation and discussion
include, but are not limited to:
• Comparison of ionizing radiation with
other hazards
• Types of ionizing radiation
• Radiation measurements, dosimetry,
and bioassay
• Types of radiation exposures and
doses, with appropriate units
• ALARA principles and philosophy
• Risk, health effects, and the linear
non-threshold concept
• Internal and external radiation hazards
• Radiation exposure, administrative
limits, action levels, and dose limits
• Radiation exposure during pregnancy*
• The time, distance, and shielding
concept
• Applicable radiation exposure
regulations
• Identification of the standardized radi-
ation labels that indicate types and
quantities of radiation
• Radioactive waste disposal
• Procedures for handling dosimeters
and interpreting the results
* This topic is mandatory in each basic
course presentation.
An examination after the basic radiation
safety course will document the individ-
ual’s comprehension of the course mate-
rial. The examination will be based on the
core instructional materials. A minimum
score of 80 percent correct answers is
required to pass the examination. If an
employee does not earn the minimum
score, remedial training and retesting shall
be provided at the earliest opportunity.
The satisfactory completion of basic and
refresher radiation safety training courses
arid examinations must be documented. A
record of the specific training course com-
pleted, date of completion, and the names
of personnel who have fulfilled the train-
ing requirements must be maintained by
the RSO. Each student should receive a
certificate that indicates the successful
completion of each course.
3.4.2 Introductory Radiation Labora-
tory Work Practices
Copies of training requirements, regula-
tions, and other radiation safety-related
guidance documents should be included
in the material distributed during the
course. The topics in Attachment C3-2
should be included in the course to the
extent that they have not been covered
during the basic radiation safety course.
An examination after the course will
document the individual’s comprehension
t
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of the course material. The examination
will be based on at least 20 questions
selected by the instructor. A minimum
score is required to pass the examination.
if an employee fails to earn the minimum
score, the course instructor will adminis-
ter a review of the material personally,
emphasizing weaknesses identified by
the examination, and the employee will
be retested. The examination will also
be used to judge the effectiveness of the
course presentation and materials used,
and to identify areas that may require
improvement.
As part of the overall training program,
all employees involved in the use of radio-
active materials and radiation-generating
equipment should be familiar with 10
CFR 20, applicable National Institute of
Standards and Technology handbooks,
National Council on Radiation Protection
(NCRP) publications, state and local regu-
lations on radiation control, 29 CFR 1910.
1096 and 29 CFR 1910.97. Employees
should also be familiar with NRC Regula-
tory Guides 8.13, and 8.29.
3.5 Biosafety
Biosafety training topics that are discussed
in this section and shown in Figure C3-5
include general biohazards, bloodborne
pathogens, and laboratory animal research.
Figure C3-5: Biosafety Training Topics
3.5.1 General Biohazard
All EPA laboratory employees must be
trained prior to beginning any work with
biohazardous agents. Training must be
provided on an individual basis at the time
of hire or when job responsibilities
change. A yearly review must be provided
at a general staff meeting.
Technical Staff
Individual training for technical staff
members will include:
• The biology of the organisms used
in experiments, with emphasis on
potential biohazards
• Good aseptic technique
• Proper techniques for
decontaminationldisinfection
• Emergency procedures
• Safety and health procedures
Before laboratory employees can begin
work they must:
• Understand safety and health
procedures.
• Demonstrate to the biological safety
officer (BSO) a working knowledge of
all relevant safety practices, an under-
standing of the research they will do,
and its potential hazards.
Blosafety
Laboratory Animal
Research
General Biohazards
Bloodborne Pathogens
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C3. SHE Training
• Sign a statement that affirms that the
above requirements have been met.
Nontechnical Staff
All nontechnical staff members are to
be familiarized with the potential hazards
associated with recombinant DNA (rDNA)
and biological research in general. As
such, these workers will be instructed to
recognize areas where biohazardous mate-
rials are used (e.g., the meaning of the
universal biohazard sign) and the require-
merits for entry into a laboratory research
area.
In addition to the training, custodians and
glassware washers must be familiar with
the hazards of the areas they must enter to
perform their duties. Therefore, they will
also be instructed in:
• Waste disposal procedures
• Autoclaving methods
• Emergency procedures for handling
spills of bioha.zardous materials
• Safe work practices while in the
laboratory
3.5.2 Bloodborne Pathogens
EPA laboratories must provide all employ-
ees who are occupationally exposed to
bloodborne pathogens (BBP) and other
potentially infectious materials (OPIM)
with training on the hazards associated
with these agents. Effective training is a
critical element in a facility’s exposure
control plan. Such training will ensure that
employees understand the hazards associ-
ated with BBP, the modes of transmission,
and the use of engineering controls, work
practices, and personal protective clothing.
As described in OSHA’s Bloodborne
Pathogens Standard, in 29 CFR 1910.
1030, training must include an explanation
of the elements listed in Attachment C3-3.
BBP training for all employees covered by
the standard must be provided at the time
of initial assignment to tasks where occu-
pational exposure to BBP may take place.
Additional training must be provided when
changes (e.g., modification of tasks or
procedures; institution of new tasks or
procedures) affect the employee’s occupa-
tional exposure. At a minimum, employees
must receive refresher training annually.
The BBP standard also has specific
requirements for documentation of train-
ing. These training records must be main-
tained for at least three years and must
contain the following information:
• Dates of the training sessions
• Contents or a summary of the training
session
• Names and qualifications of the per-
Sons conducting the training sessions
• Names and titles of all persons attend-
ing the training sessions
BBP awareness training is recommended
for supervisors and other general labora-
tory employees not covered under the
scope of the compliance program. This
information can be communicated in any
effective format, including a training ses-
sion, laboratory meetings, bulletins, etc.
Recommended topics include:
at 11tA
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• Types of (and modes of transmission
for) bloodbome pathogens
• Recognition of biohazards (e.g., signs
and labels, examples of situations pos-
ing a risk of exposure)
• Appropriate actions to take in an
emergency involving blood or OPIM
• Procedures to follow in the event of an
exposure incident
• Biohazard signs and labels
BBP awareness training should also
be documented. Employees working in
research laboratories where the Hepatitis B
virus and Human Jrnmunodeficiency virus
are studied, are subject to the following
additional requirements:
• Training and demonstrated proficiency
in standard microbiological practices
and techniques and specific facility
operations
• Experience in handling human patho-
gens or tissue cu’tures, or progressive
training in work activities if the
employee has no prior experience
3.5.3 Laboratory Animal Research
All employees who work with nonhuman
primates (NHPs) must participate in train-
ing that addresses the following topics:
• Overview of laboratory animal
research (LAR) and NHP operations
• Hazards associated with NHP work
• Safety precautions to take when work-
ing with NHPs
• Incident response procedures
• Occupational health and medical sur-
veillance program
3.6 Protective Clothing and Equipment
EPA laboratory employees must be trained
in the use and maintenance of protective
clothing and equipment, as shown in Fig-
ure C3-6. including:
• Personal protective equipment (PPE)
• Respiratory protection
• Safety showers and eyewash stations
• Fire extinguishers
3.6.1 Personal Protective Equipment
Training must be provided for each
employee required to use PPE. Employees
must be able to demonstrate understanding
of the topics covered in the training ses-
sion before being allowed to perform
any work requiring PPE. Many facilities
administer a quiz to ensure adequate
employee understanding: others use fre-
quent workplace inspections as a means to
check that employees are properly using
and maintaining PPE.
Figure C3-6: Protective Clothing and Equipment Training
Protective Clothing
and Equipment
Personal Protective I
Equipment I R 5PfltOTY OtCLtIOn
Emergeucy Eyewash Unit
and Safety Shower
a ma
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PPE training must include:
• When PPE is necessary
• What PPE is necessary
• How to properly put on, remove,
adjust, and wear PPE
• Limitations of PPE
• Proper care, maintenance, useful life,
and disposal of PPE
Retraining must occur when:
• Changes to the workplace make previ-
ous training obsolete.
• Changes to the PPE make training
obsolete.
• The employee has not retained the req-
uisite understandina or skill.
Laboratories must certify in writing that
the training was carried out and was under-
stood by employees. Training records must
include:
• The name of the employee trained
• The date of the training
• The subject of the training (e.g., types
of PPE)
• The name of the trainer
3.6.2 Respiratory Protection
The quality and quantity of training pro-
vided to respirator users are critical in
determining the level of protection
afforded in a given situation. At a mini-
mum. the laboratory should offer appropri-
ate training on initial assignment, and
whenever the potential for exposure
changes. The American National Stan-
dards Institute (ANSI) recommends, in
its standard on respiratory protection
(ANSI Z88.2-1992), that each respirator
wearer be retrained annually.
Training requirements for respiratory pro-
tection include:
• Functional components of a respirator
• Pre-use inspection
• Air-purifying element selection
• Donning instructions
• Positive/negative-pressure fit checks
• Limitations
• Typical use situations
• Emergency instructions
• Care and maintenance
• Storage locations
OSHA mandates a number of training
topics, which are briefly outlined above.
In addition to the OSHA requirements,
ANSI has recommendations on training
topics. Specific contents of training can
vary depending the laboratory hazards,
but should include:
• The reasons for the need of respiratory
protection
• The nature, extent, and effects of
respiratory hazards to which the per-
son may be exposed
• An explanation of why engineering
controls are not being applied, or are
not adequate, and of what effort is
being made to reduce or eliminate the
need for respirators
• Regulations concerning respirator use
• An opportunity to handle the
respirator
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• Proper fitting of the respirator, with
each wearer receiving fitting instruc-
tions that include demonstrations and
practice in how the respirator should
be worn, how to adjust it, and how to
determine if it fits properly
• A long familiarizing period of wearing
it in normal air, allowing the wearer to
assess comfort; then wearing the respi-
rator in a test atmosphere
• Explanation of why a particular type
of respirator has been selected
• Discussion of the respirator’s capabili-
ties and limitations
• Instruction, training, and actual use of
the respirator
• Explanation of maintenance and stor-
age practices
• Discussion of how to recognize and
handle emergencies
Supervisors who oversee the work activity
of respirator wearers should have a com-
prehensive knowledge of respirators and
respirator protection practices. Their train-
ing should include:
• Basic respiratory protection practices
• Selection and use of respirators to pro-
tect workers against every hazard to
which they may be exposed
• Nature and extent of the hazards to
which the workers may be exposed
• Structure and operation of the entire
respiratory protection program
• The legal requirements pertinent to the
use of respirators
3.6.3 Emergency Eyewash Unit and
Safety Shower
Laboratory employees who may need to
use eyewashes or safety showers in emer-
gency situations should be instructed on
their proper use and operation, as well as
on any inspection or testing procedures
required. ANSI recommends, in its Emer-
gency Eyewash and Shower Equipment
Standard (ANSI Z358.l-1998), that all
employees with a potential exposure to
chemical splash be instructed on the topics
outlined below:
• Location(s) of eyewashes and showers
relative to the user
• Importance of immediate drenching
and flushing
• Operation of, and components of, the
type of eyewashes and showers in the
user’s area
• Proper procedures for drenching and
flushing, including instructions on
how to aid a co-worker
• Testing and maintenance requirements
3.7 Ergonomics
When designing ergonomics training pro-
grams, ensure that the following informa-
tion is included:
• Knowledge of anatomy and musculo-
skeletal disorders
• Procedures for early reporting of
symptoms
• Potential causes of work-related mus-
culoskeletal disorders (WMSDs)
• Personal responsibility for preventing
injuries
• Impact of personal habits and work
procedures
• Material handling techniques
• Work postures
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CHAPTER C
Laboratory SHE Programs
C3. SHE Training
• Simple workplace modifications and
adjustments
• Treatment of WMSDs
3.8 Fire Safety
Fire safety training that is discussed in this
section, and presented in Figure C3-7, coy-
ers fire extinguishers and fire brigades.
Fire Extinguishers
When portable fire extinguishers are pro-
vided for employee use in fighting
incipient-stage fires, OSHA requires in
29 CFR 1910.157 that an educational pro-
grain be provided to familiarize employees
with the general principles of fire extin-
guisher use and the hazards involved with
incipient-stage fire fighting. Both initial
and annual refresher training is required.
Refer to Chapter D of this manual for
more information on fire safety and Chap-
ter G of this manual for more information
on fire emergency response.
The content of the training is not outlined
in the OSHA standard; however, training
recommendations for EPA laboratories
where portable extinguishers are used for
incipient fires include the following topics:
• Basic elements of fire
• Methods for stopping the combustion
process
• Classes of fires
Figure C3-7: Fire Safety Training
• Types of portable fire extinguishers
and extinguishing agents
• Review of emergency procedures and
notification
• Fire extinguisher use
• Precautions for fighting incipient fires
In addition, “hands-on” training is encour-
aged for all personnel designated to use
portable fire extinguishers.
Fire Brigade
For EPA laboratories that have in-house
fire brigades, OSHA requires additional
training. Fire brigade team members must
be provided with training and education
commensurate with the duties and func-
tions they are expected to perform. In addi-
tion, fire brigade leaders must be given
training that is more comprehensive than
the general fire brigade training. For spe-
cific training requirements under this stan-
dard 1 refer to OSHA 29 CFR 1910.156(c).
3.9 Occupant Emergency Plan
All EPA laboratories are required to pre-
pare an Occupant Emergency Plan (OEP)
outlining procedures for evacuation, haz-
ardous material spills, and other emergen-
cies. All laboratory employees must be
trained on the facility-specific emergency
procedures outlined in the OEP. Refer to
Chapter 0 for more information on OEPs.
Fire Safety
Fire Extinguishers
Fire Brigade
1
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Laboratory SHE Programs
C3. SHE Training
Training must include those parts of the
OEP that employees need to know to pro-
tect themselves in the event of an emer-
gency, as well as any special duties or
responsibilities. Therefore, the specific
content of the training will be dictated by
the OEP itself, as well as the response
organization of the laboratory. In general,
training should include the following
elements:
• Emergency escape procedures and
emergency escape route assignments
• Procedures to be followed by employ-
ees who remain to operate critical
operations before they evacuate
• Procedures to account for all employ-
ees who remain to operate critical
operations before they evacuate
• Procedures to account for all employ-
ees after emergency evacuation has
been completed
• Rescue and medical duties for those
employees who are to perform them
• Preferred means of reporting fires and
other emergencies
• Any special response duties or
responsibilities
Training must be conducted initially,
whenever the employees’ responsibilities
or designated actions under the OEP
change, and whenever the OEP itself is
changed.
3.9.1 Emergency Response
Any laboratory employees designated to
respond to an emergency situation must
receive training adequate for their duties
and responsibilities. Refresher training
must be provided at least annually.
Laboratory employees may respond to an
incipient spill of a material, which is not
considered an emergency, as long as it
does not pose a safety or health hazard and
can be safely contained and cleaned-up by
employees or maintenance in the area.
3.10 Environmental Compliance
Some laboratory employees may need to
have additional environmental compliance
training, depending on their duties and
responsibilities. Training requirements for
hazardous waste and for stormwater best-
management practices are discussed in the
following sections and shown in Figure
C3-8.
3.10.1 Hazardous Waste
Hazardous waste training is required
for all generators of hazardous waste,
including personnel involved in waste
management at any laboratory that meets
the criteria for a large-quantity generator.
Providing this training to small-quantity
generator staff is a good management
practice.
The training program should be designed
to teach personnel how to perform their
hazardous waste management duties in
accordance with regulatory requirements.
The training may be either classroom in-
struction or on-the-job training or both.
The program must be directed by a person
trained in hazardous waste management
procedures, and must include instruction
that teaches laboratory personnel hazard-
ous waste management procedures
(including contingency plan implementa-
tion) relevant to the positions in which
they are employed.
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Laboratory SHE Programs
Figure C3-8: Environmental Compliance Training
Environmental
Compliance
C3. SHE Training
At a minimum, the training program
must ensure that laboratory personnel
can respond effectively to emergencies.
The program must teach employees about
emergency procedures, emergency equip-
ment, and emergency systems,
including, where applicable:
• Procedures for using, inspecting,
repairing, and replacing laboratory
emergency and monitoring equipment
• Key parameters for automatic waste-
feed cutoff systems
• Communications or alarm systems
• Response to fires or explosions using
appropriate safety equipment
• Response to groundwater contamina-
tion incidents
• Shutdown of operations
Personnel must successfully complete
the initial training program within six
months of the date of their employment
or assignment to a laboratory, or to a new
position at a laboratory, whichever is later.
Personnel must not work in unsupervised
positions until they have completed the
training requirements. An annual review
of training must be provided to personnel.
In addition to the regulatory requirements,
a thorough training program should
include training in proper operating
procedures for the management of hazard-
ous waste under normal conditions, such
as those identified in 40 CFR 262.34 and
265.16:
• Understanding the hazardous proper-
ties of laboratory wastes
• Container handling and management
• Manifesting
• Pre-transport procedures
• Recordkeeping
• Contingency planning
The laboratory must maintain the follow-
ing written descriptions of the training
program:
• The job title for each position related
to hazardous waste management, and
the name of the employee filling each
job
• For each job title, a written job
description that includes the requi-
site skill, education (or other qualifi-
cations), and duties of personnel
assigned to each position
Hazardous Waste
Stonuwater
spcC
I
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Ca i rER C
Laboratory SHE Programs
C3. SHE Training
• A written description of the type and
amount of both introductory and con-
tinuing training that will be given to
each person filling a job title
The laboratory must maintain records to
document that the training or job experi-
ence requirements have been fulfilled.
The records on current employees must
be kept until closure of the laboratory.
Training records on former employees
must be kept for at least 3 years from
the date the employee last worked at the
laboratory.
3.10.2 Stormwater
Where laboratory facilities are permitted
to discharge stormwater, the permit also
requires implementation of best manage-
ment practices. Employees with responsi-
bility for preventing stormwater pollution
should receive training. Suggested topics
include the following:
• Spill control committee
• Material inventory
• Material compatibility
• Reporting and notification procedures
• Visual inspections
• Preventive maintenance
• Housekeeping
• Security
3.103 SPCC Plan
Any laboratory required to develop and
implement a Spill Prevention, Control,
and Countermeasures (SPCC) plan, due to
quantities of oil on-site, must also ensure
that affected personnel are trained on their
duties and responsibilities under that plan.
Periodic refresher training sessions should
be conducted at intervals frequent enough
to ensure adequate understanding of the
SPCC plan for that laboratory.
To prevent the discharges of oil, all
laboratory employees involved in petro-
leum management should be trained on
the operation and maintenance of oil-
using equipment as well as on applicable
pollution control laws, rules, and regula-
tions. This information can be communi-
cated during the annual laboratory safety
training. Such briefings should highlight
and describe known spill events or fail-
ures, any malfunctioning components,
and any recently-developed precautionary
measures.
3.11 DOT
U.S. Department of Transportation (DOT).
Training is mandatory for all employees
involved in the transport of hazardous
materials (i.e., hazmat employees) as spec-
ified in HM 126F. The training program
must ensure that hazmat employees are
familiar with the general provisions of
DOT hazardous material regulations found
in 49 CFR 172 and 173. The employees
must be able to recognize and identify haz-
ardous materials, and have knowledge of:
• Specific employee performance
requirements
• Emergency response information
• Self-protection measures
• Accident-prevention methods and
procedures
OSHA or EPA training conducted
to comply with the hazard communi-
cation program (29 CFR 1910.1200
or4O CFR 311.1) maybe used to
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Laboratoiy SHE Programs
C3. SHE Training
satisfy DOT training requirements if the
training addresses the above mentioned
requirements.
4.0 Training Resources
SHEMD has developed a number of train-
ing programs available on CD-ROM. In
addition, training assistance may be avail-
able through regional offices for some lab-
oratory locations.
Assistance with training programs or the
identification of training resources is avail-
able from organizations such as:
• Local safety councils (i.e., Association
of System Safety Engineers [ ASSEJ
chapters)
• Local industrial hygiene associations
(i.e., American Industrial Hygiene
Association [ AIHA] chapters)
• OSHA full-service area offices
• State agencies that have their own
OSHA-approved occupational safety
and health programs
• OSHA’s Office of Training and
Education
• OSHA-funded New Directions
grantees
5.0 Training Records
EPA laboratories must maintain training
records for all SHE compliance training.
Generally, the records should contain the
following information:
• Topic of training
• Names of employees attending the
session
• Name(s) of instructor(s)
• Date of the training session
Some topics may have additional training
documentation requirements that must be
followed (e.g., BBP training records as
described in section 3.5 of this chapter).
Training records will help to ensure that
all employees who need training receive it,
that refresher courses are provided at regu-
lar intervals, and that documentation is
available should it be needed.
The laboratory should maintain training
documentation in the facility’s central
SHE files according to the standard-
specific requirements (e.g., three to five
years). Some laboratories may have a
training database used to maintain and
track training by the individual employee
as well as the topic. Records should be
secure to ensure privacy yet still permit
employees to see their files.
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3-1: Outline for Chemical Hygiene Training Program
Purpose: To provide a sample chemical hygiene training program that meets regula-
tory requirements.
Instructions: Use this outline as a guide for developing a training program or for updating
current training programs.
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3-l: Outline for Chemical Hygiene Training Program
Training Modules
I The OSHA Laboratory Standard
2 Physical and Health Hazards
3 Evaluating Chemical Hazards
4 Controlling Chemical Hazards
5 Maintaining Compliance
Module 1: The OSIIA Laboratory Standard
1.0 Scope and Application
Laboratory use/laboratory scale
2.0 Protective Practices
• Administrative controls
• Engineering controls
3.0 Chemical Hygiene Plan
• Procedures/practices for using hazardous chemicals, including safety and health
SOPs
4.0 Training and Information
• Identification of physical and health hazards
• Proper work procedures
• Using exposure control measures
5.0 Medical Consultation and Exams
• Provision of medical resources
• Employee’s right of confidentiality
Module 2: Physical and Health Hazards
1.0 Physical Properties
• Solubility
• Density, specific gravity
• Boiling and melting points
• Flashpoint
• Explosive, flammable limits
2.0 Physical Hazard Categories
• Combustible, flammable. liquids and solids
• Explosives, pyrophorics
• Compressed gases
• Oxidizers, peroxides
• Water reactives
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SHEMP Operations Manual for Laboratories
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Attachment C3- 1: Outline for Chemical Hygiene Training Program
3.0 Health Hazard Categories
• Carcinogens
• Highly toxic materials
• Irritants, corrosives, sensitizers
• Materials with target organ effects
4.0 Chemical Hazards
• Individual
• Multiple
Module 3: Evaluating Chemical Hazards
1.0 Determinants of Exposure
• Concentration
• Duration
• Frequency
2.0 Methods and Observations for Detection
• Signs of the presence of chemicals
• Symptoms of exposure
3.0 Industrial Hygiene Monitoring Methods
4.0 Exposure Limits
• Permissible exposure limit (PEL)
• Short-term exposure limit (STEL)
• Action level
5.0 Material Safety Data Sheets (MSDSs)
• Maintenance
• Requirements
• Elements
6.0 Labeling Requirements
7.0 Hazard Identification and Communication
Module 4: Controlling Chemical Hazards
1.0 General Principles
• Avoid underestimation of risk
• Assume toxicity
2.0 Transporting Hazardous Chemicals
• Containers
•Carts
• Notification
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3-l: Outline for Chemical Hygiene Training Program
3.0 Storage of Hazardous Chemicals
• Containers
• Identity
• Incompatibility
• Chemical inventory policy
4.0 General Chemical Hygiene Practices
• Preventing chemical ingestion
• Decontamination
• Working alone
5.0 Housekeeping
6.0 Personal Protective Equipment
• Policy
• Types of eye protection
• Respirators
• Glove selection and use
7.0 Laboratory Fume Hoods and Exhausted Enclosures
• Use and function
• Monitoring
• Safe practices
8.0 Safety Equipment
• Types
• Responsibilities
• Inspections
9.0 Proper Handling of Hazardous Chemicals
• Review of hazard classes
• Particularly hazardous chemicals
• Substitution for less-toxic chemicals
10.0 Waste Handling
• Segregation
• Storage
• Removal
11.0 Emergency/Contingency Planning
• Types of emergencies and responses
• Spill response
• Accidents and injuries
• Medical response
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SIJEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3- 1: Outline for Chemical Hygiene Training Program
Module 5: Maintaining Compliance
1.0 Roles and Responsibilities
• Chemical hygiene officer/committee
• Laboratory supervisors
• Laboratory employees
2.0 Chemical Hygiene Plan Reviews and Updates
3.0 Compliance Jnspections
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CHAPTER C
Attachment C3-2: Introductory Radiation Laboratory Work Practices Course
Purpose: To provide a sample trainmg program for radiation laboratory work practices
that meets regulatory requirements.
Instructions: Use this outline as a guide for developing a training program or for updating
current training programs.
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3-2: Introductory Radiation Laboratory Work Practices Course
Training Topic
Basic Principles of
Radiation Protection
• Definition of basic terms and concepts
— Reduction of external exposure to ionizing radiation
— Tune, distance, and shielding
ALARA concepts and principles
— Reduction of internal contamination
— Modes of entry: ingestion, inhalation, absorption
— Respiratory protection review
— Personal protective clothing
— Contamination control
Radiation Monitoring
Equipment
• Types of radiation
• Principles of detection
• Survey equipment: inspection and use
Radiological Surveys
• Direct reading surveys
- Dose rate
- Contamination (fixed and removed)
• Analysis of wipe samples (removable contamination)
• Survey forms and results
• Contamination action levels
Radiation Dosimetry
• Dose liimts
— NRC, Presidential Recommendations for Federal Employees
- EPA Administrative Limits and Action Levels
- Personal dosimetry
- External (Thermoluminescent Dosimeters)
- Internal (Bioassay)
• Reports of personal monitoring results
General Laboratory
Practices
• Sample receiving and screening procedures
- Receipt
- Classification by activity
— Sample transfers and spill minimization
- Anaiysis
• Safety procedures
— Location of sakty equipment
— Protective equipment use
— Safety apparel
• Radioactive waste policy
— Waste collection/compaction
- Determination of discharge limits
- Packaging for off-site disposal
— Applicable DOT regulations (overview)
• Accident procedures
— Spills involving radioactive materials
— Proper notification
— Documentation
Risks Associated with
Occupational Radiation
Exposure
• Review of radiation protection for pregnant workers
• Review of Nuclear ReguJatory Commission Guidance Documents
- Reg. Guide 8.29, “Instruction Concerning Risks From Occupational Radiation
Exposure”
— Reg. Guide 8.13, “Instruction Concerning Prenatal Radiation Exposure”
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SHEMP Operations Manual for Laboratories
CHAFFER C
Attachment C3-3: Training Requirements for Bloodborne Pathogens
Purpose: To provide a sample bloodborne pathogens training program that meets
regulatory requirements.
Instructions: Use this outline as a guide for developing a training program or for updating
current training programs.
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C3-3: Training Requirements for Bloodborne Pathogens
Training Requirements for Bloodborne Pathogens
Contents and availability of the BBP standard
Epidemiology and symptoms of bloodborne diseases
Modes of transmission of BBP
Contents and availability of the facility exposure control plan
Appropriate methods for recognizing tasks and other activities that may involve exposure
to blood and OPIM
Use and limitations of methods that will prevent or reduce exposure to such materials,
including appropriate engineering controls, work practices, and PPE
Types, proper use, location, removal, handling, decontamination, and disposal of PPE
Hepatitis B vaccine, including information on its efficacy, safety, method of administra-
tion, the benefits of being vaccinated, and a declaration that the vaccine and vaccination
will be offered free of charge
Appropriate actions to take, and persons to contact, in an emergency involving blood or
OPIM
Procedure to follow if an exposure incident occurs, including the method of reporting the
incident and the medical follow-up that will be made available
Post-exposure evaluation and follow-up that the employer is required to provide for the
employee following an exposure incident
Signs and labels and/or color coding used to communicate biohazard infonnation
Questions and answers with the instructor
GEPA June 1998 C3-32
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C4. Chemical Hygiene Program
1.0 Introduction
Effective management of occupational
safety and health at EPA laboratories
requires the preparation and implementa-
tion of a chemical hygiene plan (CHP)
as part of the chemical hygiene program.
Developing an accurate and up-to-date
CHP offers numerous benefits. In addition
to satisfying regulatory requirements, the
development of a CHP is a useful exercise
in hazard identification, evaluation, and
control. A CHP is also a valuable resource
and reference for all persons protected
by provisions of the CHP. If developed
according to the steps outlined in this
chapter, a CliP can demonstrate a positive
and preventive approach to safety and
health, and reflect a laboratory’s commit-
ment to employee safety and health. In
addition, a CHP can ensure uniformity of
work practices within and between Labora-
tories. This chapter provides an overview
of the Occupational Safety and Health
Administration (OSHA) Laboratory Stan-
dard, and describes the steps necessary to
prepare a CliP that meets these regulatory
requirements.
Program Administration
To effectively implement a laboratory
chemical hygiene program, responsibilities
should be assigned for the following:
• Developing a written CHP
• Complying with the OSHA Laboratory
Standard and EPA Orders
• Determining employee exposure
levels
• Providing medical surveillance, when
required
• Providing employees with training and
information on the hazards in their
work areas
• Reviewing and updating the program
on an annual basis
• Ensuring that proper controls are in
place and are functioning
EPA Program Requirements
In order to realize the benefits described in
the introduction to this chapter, each EPA
laboratory must:
• Prepare a CHP.
• Comply with the OSHA Laboratory
Standard.
• Comply with EPA Order 1440.
• Perform employee exposure
determination.
• Provide medical surveillance, when
required.
• Provide training.
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C4. Chemical Hygiene Program
2.0 Overview of Standards and
Regulations
The following sections outline the require-
ments of the two regulations related to
laboratory chemical hygiene: EPA Order
1440 and the OSHA Laboratory Standard,
29CFR 1910.1450.
2.1 EPA Order 1440
EPA Order 1440, “Occupational Health
and Safety Manual,” establishes the
requirements for the Agency-wide Safety,
Health, and Environmental Management
Program (SHEMP) and prescribes the
basic policy, responsibilities, authority,
and general operational instructions for the
program.
2.2 OSHA Laboratory Standard
The OSHA Laboratory Standard (29 CFR
1910.1450), titled “Occupational Exposure
to Hazardous Chemicals in Laboratories,”
applies to all employers engaged in the
laboratory use of hazardous chemicals, as
defined by the standard. The standard is
intended to protect laboratory personnel
from exposure to hazardous chemicals,
and to ensure that any exposures do not
reach or exceed acceptable limits.
The federal standard supersedes require-
ments of all other OSHA health standards
found in 29 CF.R 1910, subpart Z (e.g.,
Benzene, Lead, Hazard Communication),
except the permissible exposure limits
(PELs) and where the action level (or in
the absence of an action level, the PEL) is
routinely exceeded for an OSHA-regulated
substance. Generally, the Laboratory Stan-
dard exempts laboratories from complying
with detailed requirements of the
substance-specific standards that were
originally designed to protect workers in
industrial, not laboratory, settings. How-
ever, in histology, anatomy, and pathology
laboratories, the use of formaldehyde is
still covered under the OSHA Formalde-
hyde Standard in 29 CFR 1910.1048. AU
other uses of formaldehyde in laboratories
are covered by the Laboratory Standard.
The Laboratory Standard includes the fol-
lowing requirements:
• Determining which types of work are
covered
• Determining employee exposure
• Developing and implementing a
written program
• Performing medical surveillance
• Providing training and information
Each of these is described in greater detail
later in this chapter.
2.2.1 Scope and Application
The OSHA Laboratory Standard applies
to workplaces in which the use of hazard-
ous chemicals occurs on a laboratory scale.
Section (b) of 29 CFR 19 10.1450 defines
hazardous chemical and contains defini-
tions of other terms that appear in the
standard.
Laboratory use means the handling or use
of hazardous chemicals where all of the
following conditions are met:
• Chemical manipulations are per-
formed on a laboratory scale.
• Multiple chemical procedures or
chemicals are used.
• Procedures are not part of (and do not
simulate) a production process.
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Laboratory SHE Programs
C4. Chemical Hygiene Program
• Protective laboratory practices and
equipment are available and com-
monly used.
Laboratory scale refers to work with haz-
ardous chemicals in which the containers
used for reactions, transfers, and other
handling arc designed to be easily and
safely manipulated by one person.
OSHA has allowed laboratory facilities
that fall under the scope of the Laboratory
Standard, such as research facilities that
conduct large-scale studies, to apply the
standard to the entire facility, including
non-laboratory work areas (e.g., cage
wash, shipping/receiving), as long as the
non-laboratory work areas support the
research activities. However, the employer
may also elect to apply the Hazard Com-
munication Standard and other health
standards (instead of the Laboratory Stan-
dard) to these non-laboratory work areas.
In all cases, other OSHA non-health stan-
dards (e.g., respiratory protection, fire pro-
tection) also apply.
1.2.2 Relationship Between the
OSHA Laboratory and Hazard
Communication Standards
The applicability of OSHA’ s Laboratory
and Hazard Communication Standards is
summarized in Figure C4-l. OSHA’s Haz-
ard Communication Standard in 29 CFR
1910.1200 fonnalized an employees’ right
to know about the hazards of the chemi-
cals with which they work. Figure C4-2
provides a summary of the requirements of
the standard.
Figure C4-1: Application of Standards to Facilities
Laboratory Standard
Laboratory Facilities
OSHA
Hazard Communication
Standard
Non-Laboratory
Workplaces
Non-Laboratory
use in Facilities with
Some Laboratory
Activities
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Laboratory SHE Programs
C4. Chemical Hygiene Program
Figure C4-2: Hazard Communication Responsibilities
Chemical Manufacturers
and Distributors
As laboratories began to implement the
Hazard Communication Standard, it
became clear that aspects of the regulation,
such as the requirement that employers
obtain material safety data sheets (MSDSs)
for all hazardous chemicals used in the
workplace, were more burdensome for
laboratories than for general industry. For
this reason, OSHA modified requirements
for laboratories to encompass the elements
presented in Figure C4-3.
OSHA adopted these laboratory-specific
portions of the Hazard Communication
Standard in the Laboratory Standard. In
the Laboratory Standard, OSHA recog-
nized that laboratory employees should
have the same degree of protection and
right to know about workplace hazards
as employees in general industry.
Therefore, when determining the applica-
bility of the Laboratory Standard, employ-
ers must ensure that employees receive
training and information on hazard
communication concepts, whether the
training is provided under the Laboratory
Standard or the Hazard Communication
Standard.
3.0 Chemical Hygiene Program
Elements
A chemical hygiene program compnses
the following elements:
• Hazard identification and maintaining
MSDSs
• Employee exposure determination
• CHP development and
implementation
• Exposure controls
• Training and information
• Medical surveillance
Hazard
Communication
Standard
Train
Personal
Protection
I
Provide MSDSS
to Chemical Users
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Laboratory SHE Programs
C4. Chemical Hygiene Program
Figure C4-3: Modified Hazard Communication Requirements for Laboratories
Labeling
Laboratory Hazard
iunication Requirem
Retention of MSDSs
Received with
Chemicals
I
Training and
Information
I
Each of these program elements is dis-
cussed in the following sections and
depicted in Figure C4-4.
3.1 Hazard Identification and
Maintaining MSDSs
Because the Laboratory Standard reflects
key hazard communication provisions, it
contains several requirements pertaining
to hazard identification and maintaining
MSDSs.
3.1.1 Hazard Identification
Hazard identification involves the use of
a labeling system for containers of hazard-
ous chemicals. According to the Labora-
tory Standard, labels should:
• Not be defaced or removed from
incoming containers of hazardous
chemicals
• Be legible and prominently displayed
• Indicate the identity of the contents at
least on secondary containers
Labels are not required for portable con-
tainers that chemicals are transferred into
from labeled containers as long as it is for
immediate use by the employee perform-
ing the transfer.
3.1.2 Maintaining MSDSs
The Laboratory Standard requires that
employers retain, maintain, and ensure the
employee accessibility of MSDSs that are
received with incoming shipments of haz-
ardous chemicals. If a laboratory decides
to computerize the MSDS system, hard
copies must also be maintained in the
event that the computer system fails and
to ensure that all employees have access to
the information (including those without a
computer).
If a chemical is developed in a laboratory,
there are additional hazard identification
and communication requirements outlined
in the Laboratory Standard. if a chemical
is produced in a laboratory for another user
outside the laboratory, the employer must
comply with the Hazard Communication
Standard. For most situations, the producer
must label containers and provide MSDSs
to the user(s).
3.2 Employee Exposure Determination
If there is reason to believe that employee
exposure levels for a hazardous chemical
routinely exceed the action level or PEL,
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Figure C4-4: Elements of a Chemical Hygiene Program
C4. Chemical Hygiene Program
I
I I
Exposure Training and
Controls Information
Medical
Surveillance
the OSHA Laboratory Standard requires
the employer to measure the employee’s
exposure to the chemical.
For all laboratory workplaces covered
under the Laboratory Standard, a chemical
hygiene program (including a written
CHP) must be developed and imple-
merited, regardless of the outcome of the
employee exposure determination.
The following question has to be answered
before the chemical hygiene program
development process can proceed:
To answer this question, follow the steps
presented in Table C4-l.
If this evaluation reveals that employee
exposures have not routinely exceeded the
action level or PEL, then the employee
exposure determination is complete. How-
ever, if employee exposures have routinely
exceeded the action level or PEL, the
employer must:
Perform initial exposure monitoring
of employees and operations for which
exposures may routinely exceed the
action level or PEL. An industrial hy-
gienist or other qualified occupational
health specialist has to conduct this
part of the employee exposure deter-
mination.
Continue periodic monitoring in
accordance with the exposure moni-
toring provisions of the relevant stan-
dard, if the initial monitoring reveals
that employee exposure has exceeded
the action level or PEL.
Notify the monitored employee(s) of
any results within 15 days after receiv-
ing the results. The notification must
be written, either to employees indi-
vidually or posted in an appropriate
location accessible to the affected
employees.
However, it is prudent to document the
exposure determination process to demon-
strate that an evaluation was completed.
Chemical Hygiene Program
Are there any operations in the
laboratory workplace that may
cause employee exposures to
OSHA-regulated substances that
may routinely meet or exceed the
action level or PEL for the
substance(s) in question?
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C4. Chemical Hygiene Program
Table C4-1: Methods to Identify Exposure Potential of an Operation
Step
Desciiption
Establish a chemical inventory.
Use the information available in the MSDSs and reference
mazerials. Record which hazardous chemicals are present in
the laboratory. Classify their associated physical and health
hazards.
Identify any “particularly hazardous
substances.”
Make a hst of these substances, and ensure that the final
CHP contains all provisions necessary for additional
employee protection.
Identify any OS}4A-regulated substance(s)
used routinely in the laboratory.
Compare the chemical inventory to the list of OSHA-
regulated chemicals in 29 CFR 1910.1000.
Identify and assess the operation(s) in which
the OSHA-regulated chemical(s) is used.
Observe the operation(s), inspect the work environment,
and evaluate ventilation systems or other engineering con-
trols to assess whether the operation is likely to produce
airborne contaminants at significant levels. A job hazard
analysis may also be useful at this stage.
OSHA uses the word “routinely” to
describe a situation in which the airborne
concentration of a hazardous chemical
may be expected to remain at a certain,
characteristic level, because of the nature
of the workplace environment and the
operations performed. Potential overexpo-
sures may be indicated by employee com-
plaints or demonstration of signs and
symptoms of exposure. Although not
required by the OSHA Laboratory
Standard, a routine or baseline industrial
hygiene survey can also be used to identify
potential overexposures.
The EPA’s Laboratory Exposure Assess-
ment Program (LEAP) was designed to
help laboratories evaluate personnel expo-
sures to chemical, physical, and biological
hazards encountered in the laboratory.
SHEM Guide 43 provides information on
planning, implementing, and assessing the
EPA’s LEAP.
Refer to Chapter C5 of this manual for
information on exposure limits and indus-
trial hygiene monitoring.
3.3 CHP Development and
Implementation
The OSHA Laboratory Standard requires
that laboratory employers covered by the
standard develop and implement a written
CliP. The CHP must outline the specific
work practices and procedures that are
used in the laboratory to control occupa-
tional exposures. Implementation of the
CHP must:
• Protect employees from the health
hazards associated with the hazardous
chemicals used in their laboratory.
• Keep exposures below the OSHA
PELs.
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33.1 Elements of a CHIP
The CHP must include the following
elements:
• Circumstances under which particular
laboratory operations require prior
management approval
• Provisions for medical consultation
and exams
• Designation of personnel responsible
for implementing the CHP, including
a chemical hygiene officer (CHO)
and/or a chemical hygiene committee
(CHC)
• Additional protection provisions for
work with particularly hazardous
substances
• Standard operating procedures (SOPs)
relevant to employee safety and health
for work with hazardous chemicals
• Criteria that the employer will use to
implement control measures to reduce
exposures; these control measures can
include engineering controls, indus-
trial hygiene practices, and protective
equipment
• A requirement that laboratory hoods
and other protective equipment func-
tion properly and adequately
• Provisions for employee information
and training
The ClIP must be reviewed and evaluated
at least annually and updated as necessary.
A sample table of contents for a CHP is
provided in Attachment C4-l to this chap-
ter. It contains all of the elements required
by OSHA, as well as some additional
information.
33.2 Assembling a CHP
To assemble a CHIP, the following steps
should be completed:
• Review and revise existing SHEMP
documents to reflect current and pro-
dent practice.
• Document any informal policies and
practices that support the goals of the
chemical hygiene program.
• Develop and write additional SOPs, as
needed.
• Integrate the required elements into a
comprehensive, laboratory-specific
CHP.
• Review the CHIP for accuracy and
thoroughness.
• Delete details of the draft ClIP that
do not apply to the workplace(s) for
which the CHP is being customized;
add other details as necessary.
• Coordinate a critical review of the
CHP by staff who are developing and
implementing the chemical hygiene
program, Include representatives of
upper management and/or legal coun-
sel, if appropriate.
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3.4 Exposure Controls
The OSHA Laboratory Standard states that
for work with particularly hazardous sub-
stances, specific consideration must be
given to the following:
• Establishing a designated area
• Using containment devices, such as
hoods or glove boxes
• Removing contaminated waste
• Decontaminating facilities and
equipment
The term particularly hazardous sub-
stances includes select carcinogens,
reproductive toxins, and chemicals with
high acute toxicity, as defined in the text
of the OSHA Laboratory Standard. At
some laboratories, test substances and pos-
itive controls are considered particularly
hazardous. The many controls for han-
dling these chemicals (e.g., barner system
design, balance enclosures) satisfy OSHA
requirements for additional protection.
EPA laboratories should also ensure that
any non-test chemicals that can be consid-
ered particularly hazardous by OSHA
are handled using additional protective
measures.
3.5 Training and Information
The OSHA Laboratory Standard requires
that employees be provided with informa-
tion and training to ensure that they are
aware of the hazards of the chemicals in
their work areas. Training must be
provided upon initial assignment to
the work area, and prior to assignments
involving new exposure situations. The
employer is required to determine the
frequency of refresher information and
training. Refer to Chapter C3 of this man-
ual for more information on designing a
chemical hygiene training program.
3.6 Medical Surveillance
Under the OSHA Laboratory Standard, the
employer must provide employees with the
opportunity to receive medical attention,
including follow-up exanunations. For all
medical consultations and examinations,
the employer must provide specific infor-
mation concerning potential hazards to
the physician. The examining physician
should provide a written opinion to the
employer that does not reveal specific
findings or diagnoses unrelated to occupa-
tional exposure.
The laboratory standard also requires
that employers establish and maintain an
accurate record of any measurements taken
to monitor employee exposures and any
medical consultation and examinations,
including any tests or written opinions.
Additional specific information on
chemical-specific medical surveillance is
included in Chapter C2 of this manual.
4.0 Chemical Hygiene Program
Implementation
Laboratories that are developing and
implementing a chemical hygiene program
for the first time often train employees
before the program is fully developed. For
new programs, the steps in Figure C4-5
should be completed before employee
training is conducted.
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C4. Chemical Hygiene Program
Figure C4-5: Chemical Hygiene
Program Implementation
Step 1
Obtain
Step2
Management Participation and Approval
4
Designate the CHO and CRC
J
Step 3
1
Perform Employee Exposure Determination
Step 4
Asses
StepS
s Existing Practices, Policies, Documents
4
Develop a Corrective Action Plan
Step 6
Select and
Establish Necessary Program Eleme
ntsJ
Step7
‘I ,
WritethecHP
I
StepS
4 ,
Train Employees
I
Existing chemical hygiene programs
should also be evaluated according to
these steps. However, additional emphasis
would be placed on assessing the strengths
and weaknesses of the current program
and correcting identified deficiencies.
Each of these steps are discussed in the
following sections.
can help to ensure that the chemical
hygiene program is compatible with the
philosophy of the laboratory, as well as its
activities and other compliance programs.
Securing management approval also adds
legitimacy to the program. Key staff who
will be responsible for implementing the
chemical hygiene program should partici-
pate in developing the program, so that
they will have “ownership” of the project.
4.2 Step 2: Designate the CHO and
CHC
The OSHA standard requires that employ-
ers designate the personnel responsible for
implementing the CHP. Designated per-
sonnel include the CHO, whose role is to
provide technical guidance in the develop-
ment and implementation of the CHP. The
CHO must be qualified by training or
experience to assume this responsibility.
A CHC, composed of laboratory manage-
ment, employees, and other key staff, may
also be established to develop and imple-
ment the chemical hygiene program.
4.3 Step 3: Perform Employee Exposure
Determination
Performing an employee exposure deter-
mination is the next step in implementing
a chemical hygiene program. Section C4-
3.2 of this chapter discusses this in greater
detail.
4.1 Step 1: Obtain Management
Participation and Approval
For a chemical hygiene program to be suc-
cessful, laboratory management should
participate in the process of developing
and approving the program. This approach
4.4 Step 4: Assess Existing Practices,
Policies, and Documents
Next, assess how well existing practices,
policies, and documents serve the goals of
the program (i.e., to protect employees
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C4. Chemical Hygiene Program
from health hazards associated with the
chemicals they handle, and to keep expo-
sures below OSHA PELs).
The best way to do this is to conduct a
walk-through of the work area(s) to
evaluate:
• Work practices
• Use of containment, safety, and per-
sonal protective equipment
• Storage and handling of hazardous
chemicals
• Use and function of engineering
controls
If the work area is complex, an industrial
hygienist or other qualified specialist may
assist with this activity. The assessment
step should include a review of all aspects
of the laboratory safety and health pro-
gram, including the following:
• Administrative control systems
• Engineering controls
• General industrial hygiene and chemi-
cal hygiene practices
• Chemical storage, handling, and
disposal
Refer to the survey and assessment tools
described in Chapter B of this manual for
more information.
4.5 Step 5: Develop a Corrective
Action Plan
An action plan to correct the deficiencies
identified should be developed based on
the outcome of assessing existing prac-
tices, policies, and documents. The correc-
tive actions may include, for example, any
of the following:
• Disposal of obsolete/expired
chemicals
• Purchasing flammable-storage
cabinets
• Installing eyewashes and safety
showers
• Removing clutter from within labora-
tory hoods
• Obtaining appropriate chemical-
resistant gloves
• Updating documentation
If the list of program deficiencies is exten-
sive, it may be necessary to prioritize the
corrective actions, so that items directly
and significantly affecting the laboratory’s
compliance status are addressed first.
4.6 Step 6: Select and Establish
Necessary Program Elements
To achieve and maintain compliance with
the OSHA Laboratory Standard, the man-
agement systems presented in Table C4-2
may have to be established as part of the
chemical hygiene program.
5.0 Chemical Hygiene Program
Maintenance
Once the chemical hygiene program has
been developed, it must remain a living
document. It should be maintained to
ensure that it captures all changes to labora-
tory operations that may occur. This is ac-
complished by evaluating its effectiveness
and implementation through periodic pro-
gram evaluations. By reviewing the pro-
gram as a whole, the laboratory will be able
to determine whether established goals and
objectives have been met. Necessary up-
dates should be made to the program and
revisions forwarded to appropriate persons.
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Table C4-2: Management Systems as Part of a Chemical Hygiene Program
Element
Description
Chemical Hygiene Officer
• Develops and implements the CHP
Provides technical guidance
Chemical Hygiene Committee
• Develops and implements the CHP
Monitoring Systems for Adminis-
trative and Engineering Controls
(e.g., inspection and testing)
• Measure and track performance
Recordkeeping
• Demonstrates performance and completion
activities
• Includes minutes of the CHC meetings, results of
inspection and testing programs, maintenance
records, and employee training rosters
Other Provisions for Special
Laboratory Activities
• Requires prior management approval
• Require review of purchases
Training and Medical
Surveillance
• Coordinate programs with appropriate staff
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Attachment C4-l: Sample Chemical Hygiene Plan Outline
Purpose: To provide a sample outline of a chemical hygiene plan that contains the
information required by OSHA.
Instructions: Use this outline to determine if a chemical hygiene plan meets OSHA
requirements. It can also be used as a guide to develop a chemical hygiene
plan.
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Attachment C4-1: Sample Chemical Hygiene Plan Outline
1.0 Introduction
1.1 Policy
1.2 Coverage
1.3 Availability
1.4 Organization, roles, and responsibilities
1.4.1 Chemical Hygiene Committee
1.4.2 Chemical Hygiene Officer
1.4.3 Laboratory Management
1.4.4 Laboratory Employees
2.0 Management Systems Policies
2.1 Hazard identification, characterization, and control
2.1.1 Chemical Hygiene Committee review
2.1.2 Employee exposure detennination
2.2 Employee information and training
2.3 Medical consultation and examinations
3.0 Laboratory Practice Policies
3.1 General chemical hygiene practices
3.2 Housekeeping
3.3 Inspections
3.4 Glassware handling
4.0 Labeling and Material Safety Data Sheets
4.1 Maintaining MSDSs
4.2 Signs and labels
5.0 Procurement, Receipt, Distribution, and Storage of Hazardous Chemicals
5.1 Chemical procurement, receipt, and distribution
5.2 Chemical storage
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Attachment C4-l; Sample Chemical Hygiene Plan Outline
6.0 Handling and Transport of Hazardous Chemicals
6.1 Handling hazardous chemicals
6.2 Handling compressed gases
6.3 Transporting hazardous chemicals
Note: include additional SOPs pertaining to particular chemicaLc or classes of
chemicals as appropriate.
7.0 Facility Design
7.1 General laboratory ventilation
7.2 Access and security
8.0 Laboratory Containment and Safety Equipment
8.1 Monitoring laboratory fume hoods and exhausted enclosures
8.2 Inspecting and maintaining safety equipment
9.0 Personal Protective Equipment
9.1 Eye protection
9.2 Respirators
9.3 Glove selection and use
9.4 Special personal protective equipment
10.0 Waste Management
10.1 Waste handling
10.2 Waste storage and monitoring
10.3 Waste disposal
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Attachment C4-1: Sample Chemical Hygiene Plan Outline
11.0 Emergency/Contingency Planning
11.1 Spill response
11.2 Accidents 1 injuries, and illnesses
11.3 Emergency medical response
11.4 First aid for chemical exposures
11.5 Notification procedures
12.0 Recordkee ma
12.1 Medical surveillance
12.2 Exposure records
12.3 Chemical inventory
Figures
Request for Approval of New Chemicals
Chemical Hygiene Inspection Checklist
Chemical Compatibility Chart
Ventilation Inspection Records
Eyewash Inspection Form
Safety Shower Inspection Form
Resistance of Common Glove Materials to Chemicals
Glove Physical Properties Chart
Training Session Attendance Form
Appendices
Chemical Inventory
Chemical Toxicology
Glossary
References
OSHA Laboratory Standard
&EPA June 1998 C4-16
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Industrial Hygiene Program
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SHEMP Operations Manual for Laboratories
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C5. industrial Hygiene Program
1.0 Introduction
An effective industrial hygiene program
must be an integral part of an EPA labora-
tory’s Safety, Health, and Environmental
Management Program (SHEMP). An
effective industrial hygiene program is
a valuable resource that can help:
• Ensure that employees are not overex-
posed to hazardous agents.
• Support management goals.
• Verify the effectiveness of control
measures.
• Ensure compliance with permissible
exposure limits.
In addition, minimization or elimination of
employee exposure to hazardous agents
can improve morale and productivity, and
reduce lost time.
Table CS-i: Physical States of Chemicals
Laboratory operations may create a variety
of exposure risks. Often the physical,
chemical, and toxicological properties of
samples are unknown. Commonly used
laboratory reagents may also present
exposure risks that require evaluation.
Chemicals requiring air monitoring exist
in different physical states as described in
Table C5-l.
Airborne contaminants are monitored to
ensure that employee exposures are being
effectively controlled. Chemical exposure
monitoring provides data on whether man-
agement systems, engineering controls,
and work practices are effective in mini-
mizing employee exposure to hazardous
chemicals. Exposure monitoring requires
identifying and evaluating sources of
exposure and subsequently measuring
Gases
Laboratory chemicals may exist as compressed gases under normal testing conditions.
Inhalation is the primary route of exposure to gases.
Vapors
‘
Vapors result from the volatilization of a liquid or solid chemical. Inhalation is the
primary route of exposure to vapors, while skin absorption of vapors is a secondary
exposure mute.
Mists
.,
Mists are the aerosolized droplets of a liquid chemical usually created by some
mechanical action in a testing procedure. Inhalation and skin absorption are the
primary routes of exposure to mists.
Fumes
‘
Fumes are aerosolized solid particulates created by the condensation of a solid that has
been heated to form a vapor and then cooled. Inhalation is the primary route of
exposure to fumes.
Dusts
‘
Dusts are generally created and dispersed by mechanical action during an analysis of a
solid. The size of the dust particle determines the extent of dispersion, and whether it
can be inhaled and retained in the respiratory tract. The size of the dust particle also
determines where it will be deposited in the respiratory tract. Inhalation and ingestion
are the primary routes of exposure to dusts. However, chemically contaminated dust,
in some cases, may be absorbed by the skin.
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Laboratory SHE Programs C5. Industrial Hygiene Program
exposure concentrations. Measured • Implementing control, where
concentrations may then be compared necessary
to chemical exposure guidelines published • Communicating results to
by the American Conference of Govern- employees
mental Industrial Hygienists (ACGIH), • Maintaining required documentation
the National Institute for Occupational of results
Safety and Health (NIOSH), and the Occu-
pational Safety and Health Administration
(OSHA). The industrial hygiene program
must be administered in accordance with
the EPA’s “Laboratory Exposure Assess-
ment Program (LEAP)” as described in
SHEM Guide 43.
EPA Program Requirements
The main objective of an industrial
hygiene program is to prevent occupa-
tonal disease and injury through the
anticipation, recognition, evaluation,
and control of occupational health
hazards. To effectively manage an
industrial hygiene program, EPA
laboratories must consider the
following key components:
• A written program and policy
statement
• Hazard recognition
• Hazard evaluation and exposure
assessment
• Hazard control
• Employee training
• Employee involvement
• Program evaluation
• Recordkeeping
• Compliance with LEAP requirements
Program AdmiuLciration
Within the industrial hygiene program,
responsibilities should be assigned for:
• Performing an employee exposure
assessment
• Evaluating sample results
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CS. Industrial Hygiene Program
2.0 Overview of Standards and
Guidelines
This section describes standards and
guidelines that apply to industrial hygiene
activities in the laboratory.
2.1 OSHA Standards
Under the OSHA Laboratory Standard,
EPA laboratories are not required to com-
ply with all provisions of the substance-
specific standards (e.g., formaldehyde,
benzene, etc.). The process used to deter-
mine which requirements apply is dis-
cussed as follows and is summarized in
Figure C5-1. EPA laboratories must:
Determine if employee exposures to
hazardous substances may exceed the
permissible exposure limits (PELs)
specified by OSHA in 29 CFR 1910,
Subpart Z. Many of OSHA’s legally
enforceable PELs were adopted from
ACGIH threshold limit values (TLVs)
and NIOSH recommended exposure
limits (RELs).
• Conduct initial monitoring to measure
employee exposure to any substance
regulated by an OSHA standard and
that requires monitoring (if there is
reason to believe that exposure levels
for that substance routinely exceed the
action level, or in the absence of an
action level, the PEL).
• If initial monitoring reveals that
employee exposure exceeds the action
level or the PEL, the exposure moni-
toring provisions of the relevant stan-
dard must be observed.
Figure CS-i: Regulatory Decision
Process
Determine if the
potential to exceed
PELs exists (based on
quantities and work
practices).
‘I,
Conduct initial
monitoring for
potential
overexposures.
4,
p No Co 1 with OSHA
+ Laboratory Standard.
Observe substance-
specific monitoring
requirements (refer to
OSFIA standards for
specific chemical).
2.2 ACGIH and NIOSH Guidelines
Exposure guidelines developed by ACOIII
and NIOSH are based on the concept that
there is a “threshold” dose or concentra-
tion for a particular chemical below which
no adverse effects will occur. Figure C5-2
demonstrates this in a dose-response
curve. These exposure guidelines, ex-
pressed as TLVs by ACGIH and RELs by
NIOSH, denote airborne concentrations of
substances and represent conditions under
which, it is believed, that nearly all work-
ers may be repeatedly exposed, day after
day, without adverse effects.
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C5. Industrial Hygiene Program
Figure C5-2: Hypothetical Dose-Response Curves for Chemical Agents (A and B)
Administered to Test Mice
I
100
50
5
0
Dose
3.0 Exposure Assessment Process
Two approaches may be used to evaluate
exposures. The first approach is to com-
pare the maximum expected exposure to
PELs or TLVs. ‘Fhis is a “worst case”
approach to provide conservative estimates
of potential exposures. This evaluation
uses a maximum number of homogeneous
exposure groups (discussed in Section 7.2
of this chapter). To evaluate peak expo-
sures, the 95 percent exposure value is
used because only 5 percent of exposures
are expected to exceed this value. The
second approach compares the average
exposure in a group to a PEL or TLV.
4.0 Types of Exposure Monitoring
There are four major types of exposure
monitoring:
• Personal sampling
• Area air monitoring
• Wipe sampling
• Biological monitoring
Personal sampling, area air monitoring,
and wipe sampling are commonly used
in toxicology laboratories; biological
monitoring is used less frequently unless
mandated in a specific OSHA standard.
Selection of the correct category depends
on assessments that were made when
exposures were initially identified.
0 for chemical agent B
for chemical for chemical
agent B agent A
for chemical agent A
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C5. industrial Hygiene Program
4.1 Personal Sampling
Personal sampling of an employee’s
breathing zone is the best method for
estimating actual chemical exposure
from inhalation. Therefore, if the goal
of sampling is to measure an employee’s
inhalation exposure, then the laboratory
should use the breathing zone sampling
method. There are four methods of per-
sonal monitoring that can be applied to
breathing-zone sampling, as described in
Table C5-2. These are often used in com-
bination to evaluate an employee’s chemi-
cal exposure.
Regardless of the monitoring method
chosen, it is important to collect enough
samples to ensure that exposures can be
Table C5-2: Methods of Personal Monitoring
accurately determined within statistical
confidence limits. Typically, a 95 percent
confidence limit is considered satisfactory.
A minimum of four personal and four
area samples should be collected for each
homogeneous exposure group, if possible.
For chemicals with a TLV of 50 ppm or
less, a minimum of six samples is
recommended.
4.2 Area Air Monitoring
Area air monitoring is a technique that can
provide a general idea of potential expo-
sures. Sampling devices are placed around
the exposure source and areas where
employees may work and/or congregate.
The results are then used to characterize
Personal Monitoring
Category
Application
Full-period single
• Samples the concentrations of a chemical over a full shift
Provides a representative assessment of an employee’s TWA daily
exposure
Full-period consecutive
• Evaluates peak exposures during a full shift with samples taken
consecutively -
• Often used for acutely toxic chemicals when the collection capacity
precludes a single, longer sample
• Creates a larger sample size, resulting in improved statistical analy-
sis of the exposure data
Partial-period
consecutive
• Used when an employee’s exposure will remain reasonably con-
stant over a full shift
• Estimates an employee’s daily exposure if enough sample is col-
lected to meet the detection limit
Grab
• Provides a “snapshot” of the chemical’s airborne concentration
• Identifies task-related exposures and areas of highest concentration
• Determines whether exposure control methods are effective
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how source emissions behave. Use caution
when characterizing employee exposure
with this method. Studies have shown that
this technique may significantly underesti-
mate or overestimate personal exposures.
This is especially true when environmental
conditions (e.g., air currents) fluctuate
significantly.
43 Wipe Sampling
Wipe sampling is a method used to inves-
tigate chemical dispersion from an expo-
sure source. Surface area wipes are used
to determine if a particular chemical has
been significantly dispersed throughout
the work area. This method can also be
used to assist in determining whether an
employee’s protective equipment has
been contaminated.
4.4 Biological Monitoring
Laboratories may use biological monitor-
ing to determine whether an employee
has received a significantly acute or
chronic chemical exposure. For example,
cholinesterase levels may be measured to
determine exposure to certain organophos-
phate and carbamate compounds.
Biological monitoring is useful in cases
where air sampling is inappropriate (e.g.,
when the route of exposure is through
skin absorption) and in determining
whether medical treatment is necessary.
It is important that the laboratory obtain
an employee’s baseline of potential con-
taminant prior to exposure, so that signifi-
cant changes resulting from work-related
exposures can be identified.
5.0 Equipment and Instrumentation
Numerous sampling methods, including
those developed by OSHA, are available
for monitoring a wide variety of chemical
concentrations and/or exposures. Some
involve sampling with an air pump, which
is used to draw contaminated air through
a sampling train (e.g.. personal pump, air
tube, and sorbent tube or filter cassette) at
a constant flow rate.
An investigator may collect chemical
contaminants for analysis by filtration,
absorption, or using a preselected sam-
pling medium. When in doubt about a
specific sampling technique, an AIHA-
accredited laboratory (one that has been
formally approved by the American Indus-
trial Hygiene Association) should be con-
tacted for guidance.
It is important that the investigator select
the correct sampling medium and calibrate
the air pump flow rate both before and
after monitoring. After collection, the
investigator should calculate the volume
of air sampled, and once the quantity of
analyte collected on the sampling medium
has been measured, the concentration of
analyte in the air can be calculated. Figure
C5-3 outlines the sampling procedure.
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C5. Industrial Hygiene Program
Figure C5.3: Sampling Procedure
Select Sampling
Medium
Calibrate Pump
4,
Collect Data
-1 ’
Recalibrate Pump
4,
Calculate Air
Volume Sampled
4 ,
Measure Analyte
Quantity From Sample
4,
Calculate Analyte
Concentration
I
• Possible routes of exposure and
expected airborne concentrations
of the chemical
• Physical, chemical, and toxicological
properties of the agent to be monitored
• A representative sample size, and
whether the need to measure peak
exposures (e.g., a short-term
exposure limit [ STELJ or a ceiling
limit [ C] exists for the agent)
• The environmental conditions that
could affect the sampling methods,
such as temperature, humidity, air
currents, and other operations in the
area, and the physical and time con-
straints on sampling the operation
• The range of possible exposure levels
• Potential interferences, and the
method’s detection limit, range,
precision, and accuracy
Passive dosimeters can be used to collect
gaseous contaminants in the air by diffus-
ing the analyte through a membrane onto
a sorbent. Passive monitoring devices do
not require any calibration prior to or after
use, and they have the advantage of being
easily transportable and simple to use.
Numerous passive-dosimetry products that
can measure a variety of specific gases are
available on the market.
6.0 Selecting a Monitoring Technique
Laboratories selecting a monitoring tech-
nique should consider the following:
The manufacturer’s information for
the analyte will be a useful resource to
identify factors that may compromise
results (e.g., environmental conditions,
interferants, etc.).
7.0 Sampling Plan
The plan should be concise, clearly
written, and include, at a minimum,
the following basic components:
Background information collected
when monitoring priorities were
assessed
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• Objectives and goals of the exposure
monitoring
• Sampling methods to be used, includ-
ing equipment needs, procedures, and
sample containment and preservation
• Justification for selected methods and
procedures
• Sample locations and the number and
types of samples to be collected at
each location
• Sampling frequency
These sampling plan components may be
changed, or others added, depending on
the specific needs of the laboratory. A plan
of action should be developed to ensure
that the objectives of exposure monitoring
activities are being met.
7.1 Monitoring Priorities
Before beginning exposure monitoring,
laboratories should assess monitoring
priorities. Ideally, a laboratory should
monitor all its operations and personnel;
however, this is usually impractical.
Therefore, the laboratory must specify
monitoring priorities for highly hazardous
chemicals or for those employees who may
be highly prone to chemical exposure.
A planning committee (e.g., a chemical
hygiene committee) should conduct a pre-
liminary wallcthrough survey of the labora-
tory to identify and prioritize operations
and chemicals that present the greatest
health risk potential. After the operations,
chemicals, and affected personnel have
been identified, the committee should
structure homogeneous exposure groups
and a sampling strategy.
7.2 Homogeneous Exposure Groups
Homogeneous exposure groups (HEGs)
are selected based on job description or
activity and potential for exposure. The
industrial hygienist chooses HEG partici-
pants on the basis of a walkthrough,
noting the various operations, chemicals
used, and potential for exposure.
Determinations may also be random. The
number of persons monitored should take
into account the total number of people in
a given area and the number of people per
job description in order to ensure uniform
representation.
7.3 Sampling Strategy
A sampling strategy should encompass,
prioritize, and balance need, resources,
implementation, and cost. Sampling
programs may be baseline, routine, or
compliance-oriented. The majority of
sampling is compliance-oriented, evaluat-
ing one or two processes, and then never
repeated unless a concern arises, such as
a process change.
Ideally, for each job task and work pro-
cess, a sampling strategy should include
personal and area samples. Once expo-
sures or potential exposures have been
identified, routine monitoring can then
be conducted on a periodic basis to detect
changes from the baseline or initial survey.
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The primary purpose of the sampling
program should be considered. This will
determine whether personal, area, or both
types of samples should be collected. Per-
sonal sampling identifies exposures based
on a given job task or work process, while
area sampling is useful in evaluating the
effectiveness of control measures such as
ventilation.
Work procedures are also important to
consider when developing sampling
strategies. A walkthrough survey must
be conducted to determine differences in
procedures or staffing. All procedures
should be monitored in an initial survey
unless there are no discernible differences.
Then, during routine surveys, the monitor-
ing should be rotated through each shift.
Additional information can be found in
SHEM Guide 43, “Laboratory Exposure
Assessment Programs.”
8.0 Potential Difficulties in Sample
Collection
A number of difficulties may be encoun-
tered in performing chemical exposure
assessments. These include, but are not
limited to, the following:
• Sampling equipment calibration
errors
• Sample contamination
• Varying environmental conditions
• Lack of sample homogeneity
• Absorption of analyte onto sample
container walls
• Use of improper sampling medium or
method
• Incomplete desorption of analyte from
sampling medium
• Channeling of analyte on the collec-
tion medium
• Degradation of analyte prior to
analysis
• Mechanical defects in sampling
equipment
• Partial vapor pressure effects of gases
• Reactivity of the analyte with sam-
pling medium
• Volumetric errors and sampling rate
errors
• Temperature and pressure effects dur-
ing sampling
• Improper packaging and shipping
• Analytical errors
• Calculation errors
• Personnel not professionally compe-
tent to conduct the sampling
• Inadequate replicate samples
Listing the variety of precautions that
should be taken to avoid these difficulties
is beyond the scope of this manual; how-
ever, the person conducting the sampling
should consider whether these sampling
pmblem may affect the specific chemical
monitoring technique being used. Typi-
cally, methods published by NIOSH and
OSHA give information on common prob-
lems (e.g., appropriate ranges, interfer-
ences, etc.).
9.0 Evaluation of Sample Results
Once the sampling has been completed,
several steps should be taken depending on
the outcome of the testing. If the sampling
results are negative (i.e., below the action
level or PEL), and are representative of
employee exposures, the results should be
reported to the employees sampled, and
documented and filed for future reference.
I A
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If the sampling results are positive (i.e.,
exposure is above the action level or PEL),
then both immediate and long-term steps
should be implemented. In cases of highly
toxic compounds, the operation should be
discontinued until additional controls can
implemented. In situations involving less-
toxic compounds, various types of per-
sonal protective and engineering controls
should be implemented to provide both
immediate and long-term protection to the
employees.
Finally, after implementing permanent
controls, further sampling should be con-
ducted to verify their effectiveness.
10.0 Communication of Sample Results
As required by the OSHA Laboratory
Standard and OSHA’s standard concern-
ing access to employee exposure and
medical records in 29 CFR 1910.1020,
employees must be notified of monitoring
results within 15 working days after the
laboratory receives the results. The notifi-
cation must be made in writing, either on
an individual basis, or by posting results
in a location that is accessible to all
employees. In addition, whenever an
employee, or designated representative,
requests access to a record, access must
be provided in a reasonable time, place,
and manner.
If access to the record cannot be reason-
ably provided within 15 working days,
OSHA requires that the delay be explained
to the requestor within 15 working days.
The explanation must include the earliest
date the record can be made available.
11.0 Recordkeeping
Laboratories must also establish and
maintain an accurate record of any mea-
surements taken to monitor exposures
for each employee. OSHA requires that
each employee’s exposure record be
preserved and maintained for at least 30
years. However, background data on work-
place monitoring or measuring, such as
laboratory reports and worksheets, need
to be retained for only one year. This ex-
ception applies as long as the sampling
results, sampling plan, a description of the
analytical and mathematical measurements
used, and a summary of other relevant
background data are retained for at least
30 years. In addition, OSHA specifies that
biological monitoring results designated
as exposure records by specific OSHA
standards must be preserved and main-
tained as required by the specific standard.
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C7. Biosafety Program
1.0 Introduction
EPA laboratories working with micro-
organisms, recombinant DNA (rDNA)
technologies, laboratory animals, or
bloodbome pathogens are special, and
often unique, work environments. The
materials being used may pose special
risks to persons working in or near the
laboratory if the material should escape
the containment procedures established
for the laboratory. It is the responsibility
of the Biosafety Officer (BSO) or Safety,
Health, and Environmental Management
Program (SHEMP) Manager to work with
researchers and technical staff to reduce
the potential for personnel exposure or
environmental release.
An effective biosafety program involves
the control of a variety of biohazards to
which laboratory employees may be
exposed. These hazards include the
following:
EPA Program Requirements
Each EPA laboratory must conduct an
assessment to identify employees with
biohazard exposure potential, as well
as procedures that pose an exposure risk.
For employees and identified procedures,
laboratories must:
• Develop a biological safety plan.
• Train each employee included under
the plan.
• Apply appropriate controls, including
engineering, protective equipment,
work procedures, and housekeeping
techniques.
• Ensure that biohazardous materials are
properly labeled, and that employees
are familiar with the labeling system.
• Develop and implement
decontamination procedures.
• Biological agents used in in vitro
testing laboratory research
• Infectious agents carried by laboratory
animals, particularly rodents and
primates
• The potential of infection caused by
exposure to blood or other potentially
infectious material (OPIM) that may
contain bloodborne pathogens (BBP)
This chapter provides guidance for EPA
laboratories on the design and implemen-
tation of a biosafety program to control
these hazards.
• Ensure that requirements of the U.S.
Occupational Safety and Health
Administration (OSHA) Bloodborne
Pathogens Standard in 29 CFR
1910.1030 are met if exposures
involve blood or OPIM.
Program Administration
To effectively manage the laboratory
biosafety program, responsibilities should
be assigned for:
• Identifying employees with exposure
potential and procedures posing an
exposure risk
• Training employees in the elements of
the biological safety plan
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• Selecting and implementing
appropriate exposure controls
• Evaluating the effectiveness of
control techniques
• Ensuring the integrity of contain-
ment and decontamination pTocedures
• Maintaining required records
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2.0 Overview of Guidelines and
Standards
The Centers for Disease Control/National
Institutes of Health (CDCINIH) have pub-
lished guidelines that apply to laboratories
involved in work with infectious micro-
organisms and rDNA. In addition, guide-
lines for laboratory animal research (LAR)
have been developed by the National
Research Council (NRC). OSHA has pro-
mulgated the BBP Standard to protect
workers who may be exposed to blood and
OHM. These guidelines and standards are
outlined in the sections that follow and
summarized in Figure C7-l.
2.1 CDC/NIH
The guidelines published by the CDCINIH
were developed to reduce employee expo-
sure to potentially hazardous agents, and to
prevent escape of these agents into the
atmosphere. The guidelines describe four
biosafety levels, or levels of containment,
that consist of combinations of:
• Standard and special microbiological
practices
• Safety equipment
• Facility design criteria appropriate for
operations and infectious agents
Section 7.0 of this chapter addresses these
guidelines in more detail.
2.2 NIH Guidelines for rDNA
Recombinant DNA molecules are defined
as:
• DNA molecules that result from the
replication of those molecules
• Molecules constructed outside living
cells by joining natural or synthetic
DNA segments to DNA molecules
that can replicate in a living cell
All laboratories working with rDNA must
comply with applicable federal, state, and
local guidelines and regulations. The fed-
eral guidelines are outlined by NIH, in
the publication entitled “Guidelines for
Research involving Recombinant DNA
Molecules.”
23 NRC Animal Research Laboratory
The NRC has published the Guide for
the Care and Use of Laboratory Animals.
This guide assists laboratories in caring
for and using animals in ways judged
to be scientifically, technically, and
humanely appropriate.
2.4 OSHA Standards
OSHA has increased efforts to protect
workers who may be exposed to blood and
OPIM that may harbor BBP and tuberculo-
sis (TB) in the workplace. The following
sections discuss the OSHA BBP Standard
and proposed TB Standard.
2.4.1 BBP
The BBP Standard in 29 CFR 1910.1030
applies to any workplace where employees
have reasonably anticipated skin, eye, mu-
cous membrane, or parenteral contact with
blood or OPIM (e.g., human body fluids),
regardless of the frequency of exposure.
Potentially infectious materials refers
to those materials that may carry
organisms capable of causing disease
in humans.
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Figure C7-1: Biosafety Guidelines and Standards
osafety
C7. Biosafety Program
TB
The standard contains various require-
ments for a BBP management program,
including the development of an exposure
control plan. Section 9.0 of this chapter
discusses the specific requirements of the
BBP standard in more detail.
2.4.2 TB
On October 17, 1997, OSHA published
the proposed standard on occupational
exposure to Th. EPA laboratories may be
subject to this standard if any handling or
analysis of TB-contaminated specimens is
performed. Under the proposed standard,
employers of a covered facility would be
required to:
• Develop and implement a written
exposure control and response plan
• Offer all employees a free TB skin test
at a time and place convenient to the
employee, with the test results read
and analyzed by a trained professional
• Train employees in recognizing the
signs and symptoms of infection,
modes of transmission, prevention,
identifying tasks or areas that might
increase exposure risk, isolation pro-
cedures for suspected cases, and the
link between HIV infection and TB
Control exposure to staff where there
are higb-risk groups with stays of long
duration
2.5 Local Regulations
In addition to the NIH guidelines gov-
erning research with rDNA, local reg-
ulations exist to ensure their proper use.
Local ordinances outline permit require-
ments, restrictions, and penalties associ-
ated with research involving rDNA.
3.0 Biosafety Responsibilities
The biosafety program organization is
shown in Figure C7-2. Responsibilities
for each of these positions are discussed
in the following sections.
Guidelines
Standards
V I
CDC/NIH NIH NRC OSHA
Biosafety rDNA LAR BBP
OSHA
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3.1 Principal Investigators
Developing and maintaining a healthful
and safe work environment depends on
the day-to-day supervision of research by
personnel with a positive safety attitude.
The principal investigator (P1) is responsi-
ble for complying fully with federal, state,
and local regulations and/or standards. The
PT must:
• Deterniine the known or potential
biohazards associated with the pro-
posed experiments.
• Submit a biohazardous research
checklist to the BSO or SHEMP
Manager.
• Provide supervised personnel with
knowledge of biohazards to which
they may be exposed and safety
procedures to be followed.
• Report (in writing) to the BSO any
accident, personnel exposure, sus-
pected illness, escape of biohazardous
agents, and significant problems per-
taining to the operation and imple-
mentation of containment practices
and procedures.
• Arrange for physical examinations and
other medical surveillance of person-
nel when required by the nature of the
experiments.
• Ensure the integrity of the physical
containment (e.g., biological safety
cabinets) and biological containment.
EPA Laboratory
Biosafety Program
.1.
Laboratory j - -
Management J
J r
Jr
I .
Biosafety Officer or — —
SHEMP Manager i— —
Principal
Investigator — —
1
Maintain knowledge of, and adhere to,
the permit requirements of federal and
state agencies for interstate and inter-
national movement of biohazardous
agents.
3.2 Biosafety Committee
The institutional biosafety committee
(IBC) serves to advise the laboratory’s
management on policies pertaining to
biohazardous research. The committee
recommends standards under which
biohazardous activities should be con-
ducted, and reviews projects for compli-
ance with appropriate federal guidelines
and regulations. Other specific responsi-
bilities include:
Figure C7-2: Biosafety Program
Organization
Institutional Biosafety
Committee
Staff
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• Reviewing the appropriateness and
adequacy of containment levels and
safety measures proposed and/or used
in research
• Assessing the adequacy of contain-
ment facilities for biosafety level 3
(BL3) agents and rDNA molecules,
as required by NIH or regulatory
agencies
• Developing informational and
training seminars and workshops
on biohazards
• Periodically reviewing current
biohazardous research to ensure
that requirements are being fulfilled
• Recommending appropriate sanctions
for noncompliance with biosafety
standards, guidelines, or regulations
• Adopting emergency plans covering
accidental spills and personnel con-
tarnination resulting from biohazard-
ous research
The minimum composition of the IBC, as
specified by NIH, includes:
• Five members with expertise and
experience in SHE issues related to
rDNA technology
• Two members who are not affiliated
with public health or the environment
• Two members who are not otherwise
affiliated with the laboratory
In addition, when experiments using ani-
mals or plants require prior IBC approval,
there must be at least one scientist with
expertise in plants or pathogens or plant
pest containment and one scientist with
animal containment expertise on the JBC.
3.3 BSO or SHEMP Manager
The EPA laboratory’s BSO or SHEMP
Manager has responsibility for the daily
administration of standards set by the
IBC and acts on behalf of the committee
in their implementation. Other responsibil-
ities may include:
• Perfonning preliminary screening of
biohazardous research checklists and
assigning them to the IBC for review
• Arranging for initial and periodic
inspections of laboratories used in
biohazardous research
• Providing technical advice to PIs
and to the IBC on research safety pro-
cedures
• Organizing and conducting training on
biohazards
• Arranging for appropriate medical sur-
veillance of personnel working with
certain biohazardous agents
• Providing technical advice regarding
biohazard safety needs and require-
ments for projects involving the reno-
vation or construction of laboratory
or other facilities where biohazardous
agents will be used
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3.4 EPA Laboratory
The EPA laboratory and its managers are
ultimately responsible for the following:
• Developing and maintaining appropri-
ate policies regarding biohazardous
research
• Developing mechanisms for ensuring
adherence to biosafety policies
• Providing the resources necessary to
implement the biosafety program
4.0 Types of Biohazards
Biohazards found in EPA laboratories
can be in the form of biohazardous agents,
animals, and plants as shown in Figure
C7-3.
4.1 Biohazardous Agents
A biohazardous agent is biological in
nature, is capable of self-replicating,
and can cause disease in susceptible
organisms, particularly humans.
Biohazardous agents can be found in a
variety of environments, such as laborato-
ries and indoor air, and can be harbored in
a number of different media, including:
Figure C7-3: Biohazards at EPA Laboratories
• Experimental tissues and cells
• Human blood and OPIM
• Laboratory animals
• Human and animal wastes
This section describes two types of
biohazardous agents: infectious and
rDNA.
4.1.1 Infectious Agents
Infectious agents generally fall into one
of six types: viral, bacterial, parasitic, fun-
gal, rickettsial, and protozoan. Each are
described in the following sections, and
Table C7-l presents examples of diseases
caused by each type.
Viral Agents
Viruses are pathogens that depend on other
organisms to survive and reproduce. There
are many different types and strains that
can cause a wide range of diseases. Since
few medications are effective in treating
viral infections, the body’s immune system
serves as the primary mechanism for elim-
inating these pathogens. To fight a viral
infection, the body’s white blood cells pro-
duce antibodies that attack the specific
Blohazards
Biohazardous Agents
Athma
DNA
Plants
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Table C7-1: Types of Infectious Agents
C7. Biosafety Program
Agent Type
Diseases
Viral
• HepatitisAandB
• Herpes
• HIV Infection
• Influenza
• Lymphocytic choriomeningitis
• Poliomyclitis
• Rabies
Bacterial
,‘ :/
/
.‘ /
• Tuberculosis
• Bacterial Meningitis
• Typhoid
• Cholera
•
• Shigellosis
• Strep Throat (Streptococcus)
• Food Poisoning
Parasitic
:
• Hookworms
• Tapeworms
• Giardia
Fungal
—
-q
.
• Dermatomycosis
• Ringworm
• Blastomycosis
• Coccidioidomycosis
Rickettsial
• Rocky mountain spotted fever
• Typhus
• Q Fever
Protozoan
/
/
• Malaria
• Amoebic dysentery
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pathogen and weaken and destroy it. How-
ever, some viral pathogens can overtake
the body’s immune system and result in
death.
BBP refers to pathogenic microorganisms
that are present in human blood and in
OPIM and can cause disease in humans,
including:
• Hepatitis B (HBV), the causative
agent of Hepatitis—a serious liver
disease
• Human immunodeficiency virus
(HIV), the causative agent of acquired
immunodeficiency syndrome (AIDS)
OPIM may include:
• Semen
• Vaginal secretions
• Cerebrospinal fluid
• Synovial fluid
• Pleural fluid
• Pericardial fluid
• Peritoneal fluid
• Amniotic fluid
• Saliva
• Any body fluid that is visibly contanii-
nated with blood
• Unfixed human tissue or organ (other
than intact skin)
• HJV-containing cell, tissue, or organ
cultures
• HIV/HB V-containing culture media or
other solutions
Bacterial Agents
Bacteria are present everywhere and,
unlike viruses, do not depend on other
organisms for life. Although most
bacteria do not infect humans, those
that do can cause serious illness.
Bacterial infections are difficult to fight
with the body’s own immune system, and
often must be treated with prescription
medication, such as antibiotics (e.g., peni-
cillin, erythromycin).
Parasitic Agents
Parasites, such as hookworms, rely on the
host to survive and reproduce. Symptoms
of a parasitic infection may include
abdominal pain, diarrhea, anemia, and
respiratory and circulatory complications.
Fun gal Agents
Fungi, which include yeasts, molds, and
mushrooms, can cause numerous diseases
in humans, usually by skin contact or by
inhalation of spores.
Ricketisial Agents
Rickettsia are a type of bacteria that occur
as parasites in lice, fleas, ticks, and mites.
These organisms can be transmitted to
humans and animals.
Protozoan Agents
Protozoa are single-celled organisms that
are mostly free-living. They can be trans-
mitted to humans through infected animals
and insects (e.g., mosquitoes), or through
ingestion.
4.1.2 Recombinant DNA
Laboratory-acquired
seroconversions (i.e., antibody
production) from rDNA-derived
proteins or sensitization to crude
or purified microbial proteins
(or glycoproteins) have been
reported. Therefore, rDNA
require special handling precautions to
address these risks.
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Laboratory SHE Programs
C7. Biosafety Program
4.2 Vertebrate Animals
Laboratory animal research (LAR), and
ongoing care of animals, carries some
inherent risks for injury to the staff
involved, including employee injury
(e.g., bites and scratches) and the trans-
mission of disease preventing cross-
infection is of prime importance.
Animals, particularly nonhuman primates
(NHPs), have the potential to carry and
transmit diseases that can be pathogenic to
humans. Those diseases that are of particu-
lar concern to laboratory employees (e.g.,
Herpes simiae, tetanus, bacterial infec-
tions, Hepatitis and tuberculosis) are
described in the following sections.
4.2.1 Herpes Simiae
The Herpes simiae virus is one of the more
pathogenic viruses to humans; however,
the overall risk of transmission appears to
be low. Macaque monkeys are natural
hosts to the Herpes simiae (i.e., Herpes B)
virus, and can be infected without initially
showing any symptoms. NHPs infected
with this virus eventually suffer only a
mild clinical disease similar to Herpes
simplex in humans; however, humans, if
infected, suffer catastrophic consequences.
During periods of viral shedding, trans-
mission to humans can occur by several
means. Exposure to infected saliva by
bites or scratches, or injuries where
equipment contaminated with body fluids
break the skin or mucosa, are considered
to carry risk of infection. Deep penetrating
wounds, such as cuts from cages or sca]-
pels and punctures with needles, carry the
greatest risk. Aerosol transmission may be
possible, but the risk is low. Although
clinical infection in humans is uncommon,
once it develops, infection nearly always
results in severe or fatal disease. Clinical
signs that may occur two to 54 days fol-
lowing exposure are shown in Table C7-2.
4.2.2 Tetanus
Tetanus is caused by a toxin produced by
Clostridium tetanii (e.g., tetanus bacillus),
and can be found in the intestines of ani-
mals, or in soil or dirt that has been con-
taminated with animal or human feces.
The tetanus bacillus can be introduced to
humans at the Site of a contaminated injury
such as a cut or an animal bite. if the
wound closes over the bacillus and no air
can enter the site, the bacillus then grows
anaerobically (i.e., without oxygen). Deep
wounds that are difficult to clean carry the
greatest risk.
The bacteria invade the nervous system,
causing progressive muscle spasms. Case
fatality rates range from 30 to 90 percent.
However, tetanus vaccines have been
proven effective in preventing the disease.
4.23 Bacterial infections
A large number of bacterial species reside
in the mouths of NHPs and other animals
and can be transmitted to humans through
bites. Some of these bacteria are patho-
genic, others are not. For example,
Eikinella corrodens is quite virulent and
can cause severe cellulitis (i.e., skin infec-
tion). Streptococcal bacteria are also
among some of the potential pathogerts.
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Table C7-2: Clinical Signs of Herpes Simiae Infection in Humans
C7. Biosafety Program
Sig
ns of Infection
•
•
Vesicular eruptions or ulcerations at or near the exposure site
Severe pain or itching at the exposure site
•
Fever
•
Numbness and/or tingling at or near the exposure site that progresses
toward the torso
•
Muscle weakness or para]ysis in the exposed extremity
•
•
Paralysis or numbness and tingling on either side of the body
Neck stiffness
•
•
•
Headache lasting more than 24 hours
Nausea and vomiting
Altered mental state
•
Other signs of central nervous system impairment
Thorough wound cleaning is essential to
preventing bacterial infections following a
bite or scratch, as is evaluation by medical
personnel for additional cleaning and treat-
ment with antibiotics.
4.2.4 Hepatitis
Hepatitis A and E are both enteric (i.e.,
located in the intestines), and can be
carried by monkeys. Since these viruses
are transmitted by ingestion of fecal-
contaminated water or food, they are not
a significant risk to laboratory personnel
if proper work practices are followed.
Hepatitis B, C, and D are bloodbome
viruses and are not carried by monkeys;
however, monkeys can be a susceptible
host. Therefore a blood-to-blood exposure
involving a sick monkey could pose a risk
(e.g., needlestick, laceration, or splash of
monkey blood onto a caretaker’s mucous
membranes). Universal precautions and
vaccination can prevent infections.
4.2.5 Tuberculosis
Tuberculosis is caused by the Mycobacte-
rium tuberculosis bacillus which can cause
disability or fatal disease, usually of the
respiratory system. This bacteria is gener-
ally not found in monkeys, but can be
transmItted to the monkeys from humans
and then spread among the other animal
population.
4.3 Plants
Plants used in laboratory research may
contain biohazardous agents such as
rDNA. Their release into the environment
is prevented using biosafety containment
measures for plants.
5.0 Routes of Infection
Pathogens must have access into the body
through a specific route of exposure for
biohazardous agents to be transmitted.
Some of the most common mutes include
skin contact, ingestion, inhalation, and
injection. Some blohazardous agents can
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enter the body by any one of these routes,
while others can only be transmitted by
one or two modes of entry. In addition,
vector transmission is a route of exposure
that can occur when handling laboratory
animals. The following sections briefly
describe each of the more common routes
of entry for biohazardous agents. Figure
C7-4 presents a summary of these routes
of entry.
5.1 Skin Contact
Skin is an excellent barrier. However,
depending on the pathogen, biohazardous
agents can be transmitted through intact
Figure C7-4: Routes of Infection
and non-intact skin, as well as through the
mucous membranes of the eyes, nose, or
mouth.
Some pathogens, including many para-
sites, can penetrate intact skin to cause
disease, while others, such as lily and
Hepatitis, can be transmitted only from
blood-to-blood contact with infectious
body fluids (e.g., semen). However, these
infectious pathogens can enter the blood-
stream through breaks in the skin such as
open wounds, scratches, insect bites,
rashes, bums, and shaving nicks.
In addition to direct contact, biohazardous
agents can be indirectly transmitted
through the skin or mucous membranes.
For example, handling contaminated
objects or equipment and then rubbing
eyes, nose, or skin creates an entry route
for biohazardous agents.
5.2 Ingestion
Accidental ingestion of a biohazardous
agent can occur from the following:
• Ingestion of contaminated food and
water
• Indirect transfer of the agent from
hand to mouth by contaminated fin-
gers or gloves
• Mouth pipetting
Examples of biohazardous agents that are
often transmitted from accidental ingestion
include parasites (e.g.. tapeworms and
giardia), Hepatitis A, and agents causing
food poisoning (i.e.. bacterial infection).
Ingestion
Inhalation
Skin Contact
Accidental
Injection
Vector i_, —
Transmission
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5.3 Inhalation
Airborne transmission of a biohazardous
agent takes place when the pathogen is
inhaled. In a laboratory, aerosols can be
produced by a number of operations and
practices involving biohazardous materi-
als. For example:
• Animal inoculation
• Centrifugation
• Blending, vigorous shaking, or mixing
• Sonic disruption
• Opening containers of infectious
materials
• Harvesting infectious tissues from ani-
mals or eggs
• Handling or shaking contaminated
animal cage litter and bedding
Microorganisms can proliferate in the
water used for humidification or cooling
and be distributed by the air heating, venti-
lation and air conditioning system
(HVAC) system.
Examples of diseases that are caused by
the inhalation of biohazardous agents
include tuberculosis, bacterial meningitis,
coccidioidomycosis, and influenza.
5.4 Accidental Injection
Accidental injection of a pathogen into the
bloodstream is a significant route of expo-
sure, especially for laboratory workers
handling hypodermic needles, syringes,
and intravenous (IV) sets. Personnel may
also be at risk of infection from broken
glass, needles, or other sharp objects when
handling wastes or responding to accidents
or emergencies.
Biohazardous agents that can be transmit-
ted from accidental injection include FIIV,
Hepatitis, and tetanus.
5.5 Vector Transmission
Vector transmission can occur when an
infected human, animal (e.g., dog or rac-
coon), or insect (e.g., tick or mosquito)
transmits the pathogen into the body
through a bite. Rabies, tetanus, and Lyme
disease are examples of vector-transmitted
conditions.
The risk of vector-borne transmission is
low for most EPA laboratory staff. How-
ever, personnel should be aware of this
hazard when working in laboratories
where animals are handled, and during
emergency situations.
6.0 Risk Assessment
The classification and evaluation of organ-
isms should be based on a thorough risk
assessment of the agent and activity. This
risk assessment and subsequent selection
of the appropriate hazard class and
biosafety level must take into account
several factors, including:
• Virulence of the organism
• Pathogenicity of the organism
• Stability of the organism
• Communicability of the organism
• Function of the laboratory and the pro-
cedures to be used
• Quantity and concentration of agent
used
• Availability of effective vaccines
For example, when examining the classifi-
cation of HBV it is important to know that
it is:
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C7. Biosafety Program
• Among the most ubiquitous of human
pathogens
• The most prevalent of laboratory-
associated infections
• Identified in a variety of body secre-
tions and excretions, including blood
and saliva
However, it is of equal importance that the
primary risk of HBV infection is only
through accidental inoculation, exposure
to broken skin or the mucous membranes,
or ingestion of infectious body fluids.
Since these risks are adequately controlled
by biosafety level two (BL2) containment
practices (see section 7.0 of this chapter
for information on containment levels),
HBV could be considered a Class 2 micro-
organism under certain conditions of use.
The CDCINIH guidelines contain agent
summary statements that provide agent-
specific hazard information that should
be used in selecting biosafety levels. A
comprehensive list of the suitable organ-
isms for each of the biosafety levels is pre-
sented in Attachment C7- I.
7.0 Biosafety Containment
The basic strategy behind biosafety is con-
tainment, which is the use of safe methods
to reduce exposure to potentially hazard-
ous agents, and to prevent the escape of
biohazardous agents into the atmosphere.
Primary containment protects personnel
and the inside environment from exposure,
and is achieved by both adhering to safe
work practices and good microbiological
techniques and by using appropriate safety
equipment.
Secondary containment protects the out-
side environment from exposure to infec-
tious agents, and is accomplished through
the design of the laboratory itself and the
proper management of operations.
The elements of containment and biosafety
are discussed below.
7.1 Biosafety Levels of Containment for
Biohazardous Agents
Biosafety levels describe the degree of
containment (or the combinations of stan-
dard and special practices, safety equip-
ment, and facility design criteria) appropri-
ate for the operations performed and the
biohazardous agents used within the labo-
ratory. Each biosafety level is discussed
as follows, with a summary of recom-
mended practices and techniques pre-
sented in Table C7-3. In addition, Attach-
ment C7-2 presents a very detailed discus-
sion of these practices.
Biosafely Level 1 (BLI)
BLI is suitable for work with micro-
organisms not known to cause disease
in healthy adult humans. Work is gen-
emily performed on open benchtops. Spe-
cial containment equipment and
devices are not usually needed.
Biosafely Level 2 (BL2)
BL2 applies to work with microorganisms
of moderate potential hazard to employees
and the environment. These agents can
usually cause disease in healthy individu-
als. For BL2 laboratories, access is usually
limited and work may be conducted in
biological safety cabinets (BSCs) if
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aerosols may be produced. Additional
information on BSCs, including mainte-
nance, is included in Chapter D4 of this
manual.
Biosafety Level 3 (BL3)
BL3 is used to work with indigenous or
exotic agents where the potential for infec-
tion is real, and the disease may have seri-
ous or lethal consequences. Almost all
work with these agents is conducted in
BSCs and the laboratory may have specific
design features, such as airlock entrance
zones.
Biosafety Level 4 (BL4)
BL4 is required for work with agents
that present a high individual risk of life-
threatening disease. This is the highest
level of containment and requires a con-
tainment facility designed to be com-
pletely isolated from all other buildings.
7.2 Biosafety Levels of Containment for
Vertebrate Animals
When experimental animals are used, the
CDCINIH guidelines describe combina-
tions of laboratory practices, safety equip-
ment, and facilities for experiments with
infected animals. Four combinations, des-
ignated animal biosafety levels (ABSL)
1 to 4, are comparable to the biosafety lev-
els recommended for use with infectious
agents. In general, the animal biosafety
levels have added:
• Specifications for handling and decon-
taminating animal cages and bedding
• Special provisions for personal protec-
tive equipment
• Requirements that floor drains be
filled with disinfectant or water
• Special design criteria for animal
facilities
Table C7-3: Recommended Biosafety Practices and Techniques
Biosafety
Level
‘ “
Practices
‘
Safety Equipment
PadUty
Design
BLI
Standard microbial practices
Standard laboratory practices; open
bench
Basic
BL2
BL1 practices, plus:
• Laboratory coats
• Decontamination of waste
• Lunited access
• Protective gloves
• Warning signs
Partial containment
(i.e., Class I or U BSCs)
Basic
BL3
BL2 practices, plus:
• Special laboratory
clothing
• Controlled access
Partial containment equipment for all
handling procedures
Containment
BL4
BL3 practices, plus:
• Entrance through clothes-change
room
• Shower on exit
• All wastes decontaminated
Maximum containment equipment
(i.e., Class UI BSC or partial contain-
ment equipment with hill-body, air-
supplied, positive-pressure suit) for
all activities
Maximum
containment
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C7. Biosafety Program
Table C7-4 presents a summary of recom-
mended practices and techniques for work-
ing with animals and Attachment C7-3 of
this chapter presents a detailed discussion
of these practices.
7.3 Biosafety Containment for Plants
The principal purpose of plant contain-
ment is to avoid unintentional:
• Transmission of rDNA-containing
plant genome, including nuclear or
organelle hereditary material
• Release of rDNA-derived organisms
associated with plants
• Release of nonindigenous species
• Release of plant pathogens or pests
The containment principles are based on
the recognition that the organisms pose no
health threat to humans or the other higher
animals unless deliberately modified to do
so. The intent of containment is to mini-
mize the possibility of unanticipated dele-
terious effects on organisms and ecosys-
tems outside the experimental facility.
Laboratory experiments with biohazardous
plant materials are to be conducted at BL2.
8.0 Administrative Controls
Administrative controls in a biosafety pro-
gram include:
• Biohazard communication
• Training
• Inspections
• Medical surveillance
Each of these are described in the follow-
ing sections and shown in Figure C7-5.
8.1 Biohazard Coimnunication
In addition to the primary and secondary
containment practices used in biosafety
laboratories, EPA laboratory personnel
should be aware of, and be able to identify,
the symbols and labels used for hazard
communication. For biohazardous materi-
als, labels include the universal biohazard
symbol and hazard warning signs, includ-
ing the biosafety level.
8.1.1 Labeling
Where biohazardous agents are used,
stored or handled, most facilities will label
equipment, storage containers, and rooms
with the following label:
These labels are usually
fluorescent orange or
orange-red, with lettering
or symbols in a contrasting _________
color.
Labeling with the universal
biohazard symbol is
required for regulated
waste, bags, and containers
of contaminated laundry;
refrigerators and freezers
containing blood or OPIM; and other con-
tainers used to store, transport, or ship
blood or OPIM.
In some cases, the use of red
bags or containers may be sub-
stituted for labels.
BIOHAZARD
I NOr0000RDRIIIX
I TO UC STORED IN
REFRIGERATOR
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Table C7-4: Biosafety Levels for Work with Vertebrate Animals
C7. Biosafety Program
Practices
Safety
Equipment
Facilities
Standard animal care and
management practices, includ-
ing appropnate medical sur-
veillance programs
As required for normal care of
each species
• Standard animal
facility
• No recirculation of
exhaust air
Directional air flow
recommended
ABSLI practices, plus:
• Limited access
• Biohazard warning signs
• Sharps precautions
• Biosafety manual
• Decontamination of all
infectious wastes and all
animal cages prior to
washing
ABSLI equipment, plus:
• Containment equipment
appropriate for animal
species
• PPE: laboratory coat,
gloves, and face and respi-
ratory protection, as needed
ABSL! facility, plus:
• Autoclave
• Handwashing sink in
the animal room
AHSL2 practices, plus:
• Controlled access
• Decontamination of cloth-
ing before laundering
• Cages decontaminated
before bedding removed
• Disinfectant foot bath as
needed
ABSL2 equipment, plus:
• Containment equipment for
housing animals and dump-
ing cages
• Class I or U BSCs avail-
able for manipulative
procedures (inoculation,
necropsy) that may create
infectious aerosols
• PPE: appropriate respira-
tory protection
ABSL2 facihty, plus:
• Physical separation
from access
• Self-closing, double-
door access
• Sealed penetrations
• Sealed windows
• Autoclave available in
facility
ABSL4
ABSL3 practices, plus:
ABSL3 equipment, plus:
ABSL3 facility, plus:
Entrance through change
• Maximum containment
• Separate building or
room where persona] cloth-
equipment (I.e., Class U
isolated zone
ing is removed and labors-
BSC or partial containment
• Dedicated supplyl
tory clothing is put on;
equipment in combination
exhaust, vacuum, and
shower on exiting;
with full-body, air-supplied
decontamination
• Decontamination of all
wastes before removal
positive-pressure personnel
suit) used for all proce-
systems
• Other requirements
from the facility
dures and activities
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Figure C7-5: Administrative Controls for a Biosafety Program
Administrative
Controls
I I
Comm uni ation Training
Labeling Warning
Signs
I
C7. Biosafety Program
Labeling is not required for containers and
bags that hold the following
• Clinical specimens, if universal pre-
cautions are observed
• Decontaminated (e.g., autoclaved) reg-
ulated waste
• Blood or OPIM placed in secondary,
labeled containers prior to storage,
transport, or disposal
• Blood, blood products, or blood com-
ponents that have been released for
clinical use (e.g., transfusion) because
they have been screened for HBV and
my
8.1.2 Biohazard Warning Signs
In addition to labels, the entrance to a lab-
oratory involved in the manipulation or
storage of biohazardous materials, includ-
ing blood and laboratory animals, is to be
posted with a bioha.zard sign. This sign
may include the universal biohazard sym-
bol, the agent in use, the criteria for entry
(e.g., vaccinations, personal protective
equipment), and one of the four biosafety
levels.
1BIOHAZARD At the entrances to work
I areas in HBV/HW
I j research laboratories and
I production facilities,
t, RLv employers must post a
sign containing the blo-
hazard label, the name of the agent, special
requirements for entering the area (e.g.,
personal protective equipment, vaccina-
tions), and the name and telephone number
of a contact person.
8.2 Training
All EPA laboratory employees must be
adequately trained prior to beginning
any work with biohazardous agents or
NHPs. Requirements include training at
the time of initial assignment and when
changes in work tasks or operations create
new exposure situations. Training must
include instruction by a person knowledge-
able in the subject matter as it relates to
Laboratory
Inspections
Medical
Surveillance
Rccordkceping
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ç7ffiosaf y Program
the laboratory, and must include an oppor-
tunity for questions and answers between
the trainer and employees. In addition,
%- ç her training must be conducted annu-
Refer to Chapter C3 of this manual
for additional specific biosafety training
guidance.
8.3 Laboratory Inspections
To ensure that the biosafety program con-
tinues to be effective and up-to-date, the
program must be periodically reviewed.
As part of this process, work practices
and engineering controls should be mu-
timely evaluated to ensure compliance
with regulatory requirements and labora-
tory procedures, as well as to identify and
correct any potential hazards. This evalua-
tion can be accomplished through a walk-
through of laboratory areas and a visual
inspection of work practices.
The BSO should annually inspect each
BLI and BL2 laboratory areas to observe
the physical containment practices in oper-
ation. Laboratory employees may be
required to demonstrate knowledge of any
appropriate laboratory practices during the
inspection. Such inspections may also
involve members of the IBC.
The results of all inspections will be
reported to the appropriate personnel,
including the members of the IBC, the
SHEMP Manager, and the P1 responsible
for the laboratory.
8.4 Medical Surveillance Program
Recommendations for staff inclusion in a
medical surveillance program should be
made based on the hazards of the work and
the individual needs of the workers. An
exposure control plan for BBP should also
have medical surveillance considerations
for Hepatitis B vaccinations and post-
exposure evaluation and follow-up.
For more information about medical
surveillance requirements for biohazards,
refer to Chapter C2 of this manual.
8.5 Recordkeeping
Records of exposure monitoring, incidents
such as spills or releases, and waste dis-
posal, should be retained at a minimum.
Recordkeeping requirements under the
BBP standard primarily pertain to medical-
and training records. Refer to Chapter C2
of this manual for medical record retention
requirements. Refer to Chapter C3 of this
manual for BBP training recordkeeping
requirements.
9.0 BBP Exposure Control Plan
SHEMP Managers of laboratories that
handle blood or OPIM must:
• Identify all employees with exposure
potential and all procedures that pose
an exposure risk.
• Develop an exposure control plan that
includes the measures to be taken to
minimize the risk of exposure to BBP.
The exposure control plan must be
designed to eliminate or minimize
employee exposure to BBP. The plan
must contain a schedule and methods
of implementation for the elements of the
standard as shown in Figure 0-6.
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CHAFFER C
Laboratory SHE Programs C7. Biosafety Program
Figure C7-6: Components of a BBP Exposure Control Plan
Universal Precautions
Engineering and Work
Practice Controls
• Personal Protective Equipment
• Housekeeping and Laundry
• Biohazard Communication
• Employee Information and
Training
• Recordkeeping
• Medical Surveillance
The plan should provide guidelines and
procedures addressing these elements. The
following sections discuss the first four of
these program elements. The remaining
topics are covered elsewhere in this chap-
ter as part of a biosafety program.
9.1 Universal
I A k Precautions
I The phrase universal pre-
L E J cautions means treating
all blood and OPIM as
potentially infectious materials in order to
prevent contact. Under circumstances in
which differentiation between body fluid
types is difficult or impossible, all body
fluids should be considered potentially
infectious. Personnel should follow uni-
versal precautions and use appropriate
personal protective equipment for all
procedures involving blood and other body
fluids.
9.2 BBP Engineering and Work
Practice Controls
Engineering controls are used to either
remove the pathogenic hazard, or to isolate
the worker from the pathogen. These types
of controls should be used in combination
with safe work practices to provide the
primary means of employee protection.
Work practice controls are modified pro-
cedures and practices that will reduce the
risk of worker exposure to BBP. Table C7-
5 provides a summary of engineering and
work practice controls. Chapter D of this
manual provides more detailed informa-
tion on engineering controls and Chapter F
provides information on work practice
controls.
9.3 BBP Personal Protective
Equipment
If the exposure potential exists, after the
implementation of engineering controls
and work practice controls, then personal
protective equipment (PPE) must also be
used. Appropriate PPE does not permit
blood or OPIM to pass through or reach
the employees’ skin, eyes, mouth, or other
BBP
Exposure
Plsn
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Table C7-5: Engineering and Work Practice Controls
C7. Biosafety Program
mucous membranes under normal condi-
tions. It should be worn when handling,
transporting, decontaminating, or dispos-
ing of materials potentially contaminated
with BBP. PPE typically includes:
• Disposable gloves
• Utility gloves for handling sharp
objects
• Gowns or lab coats
• Face shields, masks, and eye
protection
• Disposable resuscitation masks or
microshields for use during artificial
The CDC guidelines for laboratories make
specific PPE recommendations based on
the biosafety levels of the laboratory. The
CDC also makes recommendations for
PPE for workers in vertebrate animal
research facilities.
These recommendations can be found in
Attachments C7-2 and C7-3 on biosafety
levels. For more information on the use
and maintenance of PPE, refer to Chapter
E of this manual.
9.4 Housekeeping and Laundry
Housekeeping procedures are an important
part of limiting exposure to biohazardous
material. The main function of housekeep-
ing procedures is to prevent the accumula-
tion of wastes that:
Could shelter microorganisms that
threaten the integrity of the systems
under study
• May enhance the survival of microor-
ganisms accidentally released in
experimental procedures
• May retard penetration of
disinfectants
• Could be transferred from one area to
another on clothing and shoes
• Have the potential, with sufficient
buildup, to become a biohazard due to
aerosolization by personnel and air
movement
Engineering Controls
• Sharps containers for storing potentially contaminated needles and
sharp objects
• Mechanical needle recapping devices
• Local exhaust ventilation, including biological safety cabinets
• Secondary containment features
Work Practice
Controls
• Use of adequate handwashing facilities
• Proper handling and storage of contaminated sharps
• Laboratory hygiene (i.e., no eating, drinking, smoking, etc.)
in areas where there is potential of exposure to BBPs
• Cleaning and disinfection of potentially contaminated work
surfaces
• Proper packaging of blood and OPIM for shipping and
transport
respiration
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• Could cause allergic sensitization of
personnel
When performing housekeeping duties
involving floor care, avoid dry sweeping
and dusting to reduce aerosol formation.
Wet mopping or vacuum cleaning with a
high-efficiency particulate air (HEPA)
filter is recommended.
When dry sweeping is the only method
available, use push brooms and dry-dust
mopheads treated to suppress aerosoliza-
tion of dust.
• To manage the wastes in a manner that
protects employees, the public, and the
environment.
BIOHAZARD)
SHARP J
Chapter C14 of this manual provides spe
cific guidance on biohazardous waste
management.
10.0 Decontamination
The objective of decontamination is not
only to protect personnel and the environ-
ment from exposure to biohazardous
agents, but also to prevent contamination
of experimental materials (e.g., stock
cultures of viruses, bacteria, and cells)
by viable, persistent, and unwanted micro-
organisms. This factor should also be
considered in selecting decontamination
materials and methods. Refer to Chapter
F2 of this manual for specific decontanii-
nation procedures.
11.0 Siohazardous Waste Management
Proper handling and management of bio-
hazardous waste is essential to effective
exposure control. In general, a program for
managing laboratory wastes should have
two basic goals:
• To operate the laboratory in compli-
ance with all applicable regulations,
guidelines, and good industry
practices.
120 Emergency Procedures(
Spill Response
Emergency procedures for responding to
an incident involving biohazards are pre-
sented in Chapter G of this manual. Chap-
ter F2 of this manual provides guidelines
to assist the P1 and other responsible mdi-
victuals who may be involved in the
cleanup of biological spills.
BIOHAZARD
A x
DISPOSE OF
PROPERLY
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Attachment C7-1: Classifications of Microorganisms Based on Hazard
Purpose: To provide a list of organisms that have been classified on the basis of their
hazard.
Instructions: Use this list as a means to determine into what hazard class a microorganism
falls.
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CHAPTER C
Attachment C7- 1: Classifications of Microorganisms Based on Hazard
Class 1 Agents Mycoplasma—all species except M.
mycoides and M. agalactiae, which are
All bacterial, parasitic, fungal, viral, rick- in Class 5
ettsial, and chiamydial agents not included Neisseria gonorrhoeae, N. meningitidis
in higher classes. Pasteurella—all species except those listed
in Class 3
Class 2 Agents Salmonella—all species and serotypes
Shigella—all species and all serotypes
Bacterial Agents Sphaerophorus necrophorus
Acinetobacter calcoaceticus Staphylococcus aureus
Actinobacillus—aH species Streptobacillus moniliformis
Aeromonas hydrophila Streptococcus pneumoniae
Arizona hinshawii—all stereotypes Streptococcus pyogenes
Bacillus anthracis Treponema carateum, T. pallidum and
Bordetella—all species T. pertenue
Borrelia recurrcntis, B. vincenti Vibno cholerae
Campylobacter fetus Vibrio parahemolyticus
Campylobacter jejuni Yersinia enterocolitica
Chiamydia psittaci
Chlamydia trachomatis FungalAgents
Clostridium botulinum, Actinomycetes—including Nocardia
Cl. chauvoei, Cl. haemolyticum, species, Acinomyces species, and
Cl. histolyticum, Cl. novyi, Arachnia propionic
Cl. septicum, Cl. tetani Blastomyces dermatitidis
Corynebacterium diphthenae, Cryptococcus neofornians
C. equi, C. haemolyticum , Paracoccidioides braziliensis
C. pseudotuberculosis,
C. pyogenes, C. renale Parasitic Agents
Edwardsiella tarda Endanioeba histolytica
Erysipelothrix insidiosa Leishniania sp.
Escherichia coli—all enteropathogemc, Naegleria gruberi
enterotoxigenic, enteroinvasive and Schistosoma mansoni
strains bearing Ki antigen Toxoplasma gondii
Haemophilus ducreyi, H. influenzae Toxocara cams
Klebsiella—all species and all stereotypes Trichinella spiralis
Legionella pneumophila Trypanosoma cruzi
Leptospira interrogans—all stereotypes
Listeria—all species Viral Rickettsia4 and ChiamydialAgents
Moraxella—all species Adenoviruses—human—--all types
Mycobacteria—all species except those Cache Valley virus
listed in Class 3 Coxsackie A and B viruses
Cytomegaloviruses
Echoviruses—all types
&ER June 1998 C7-24
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-1: Classifications of Microorganisms Based on Hazard
Encephalomyocarditis virus (EMC)
Flanders virus
Hart Park virus
Hepatitus—associated antigen material
Herpes viruses—except Herpes virus
simiae (Monkey B virus) which is in
Class 4
Corona viruses
Influenza viruses—all types except
A/PR8134, which is in Class 1
Langat virus
Lymphogranuloma venereum agent
Measles virus
Mumps virus
Parainfluenza virus—all types except
Parainfluenza virus 3, SF4 strain,
which is in Class I
Polioviruses—all types, wild and
attenuated
Poxviruses—all types except Alastrim,
Smallpox, and Whitepox which are in
Class 5, and Monkey pox which,
depending on experiments, is in Class
3 or 4
Rabies virus—all strains except Rabies
street virus which is in Class 3
Reoviruses—all types
Respiratory syncytial virus
Rhinoviruses—all types
Rubella virus
Simian viruses—all types except
Herpesvirus simiae (Monkey B virus)
and Marburg virus which are in
Class 4
Sindbis virus
Tensaw virus
Turlock virus
Vaccinia virus
Varicella virus
Vesicular stomatitis virus
Vole rickettsia
Yellow fever virus, 17D vaccine strain
Class 3 Agents
Bacterial Agents
Bartonella—all species
Brucello—all species
Francisella tuiarensis
Mycobacterium avium, M. bovis, M.
tuberculosis
Pasteurella rnultocide type B (“buffalo”
and other foreign virulent strains)
Pseudomonas mal lei
Pseudomonas pseudomallei
Yersinia pestis
Fungal Agents
Coccidioides imznitis
Histoplasma capsulatum
Histoplasma capsulatum var. duboisii
Parasitic Agents
None
Vir4 Rickettsial, and ChlamydialAgents
Monkey pox—when used in vitro
Arbaviruses—all strains except those in
Class 2 and 4 (Arboviruses indigenous
to the United States are in Class 3
except those listed in Class 2. West
Nile and Semliki Forest viruses may
be classified up or down depending on
the conditions of use and geographical
location of the laboratory.)
Dengue virus—when used for transmis
sion or animal inoculation experi-
ments
Lymphocytic choriomeningitis virus
(LCM)
Rickettsia—all species except Vole
rickettsia when used for transmission
or animal inoculation experiments
Yellow fever virus—wild—when used
in vitro
&EPA June 1998
C7-25
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SHEMP Operations Manual for Laboratories
CHAFFER C
Attachment Cl-I: Classifications of Microorganisms Based on Hazard
Class 4 Agents
Bacterial Agents
None
Fungal Agents
None
Parasitic Agents
None
Viral Rickeitsial, and ChiamydialAgents
Ebola fever virus
Monkey pox—when used for transmission
or animal inoculation experiments
Hemorrhagic fever agents—including
Crimean hemorrhagic fever, (Congo),
Junin, machupo viruses, and others as
yet undefined
Herpesvirus simiae (Monkey B virus)
Lassa virus
Marburg virus
Tick-borne encephalitis virus complex—
including Russian spring-summer
encephalitis, Kyasanur forest disease,
Omsk hemorrhagic fever, and Central
European encephalitis viruses
Venezuelan equine encephalitis virus—
epidemic strains, when used for trans-
mission or animal inoculation experi-
ments
Yellow fever virus—wild—when used for
transmission or animal inoculation
experiments
&EPA June 1998 C7-26
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Purpose: To provide a detailed discussion of the biosafety level criteria used in a
laboratory.
Instructions: Refer to the detailed instructions for safe use of biohazardous agents to
supplement cun ent programs.
June 1998 C7-27
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level I
Biosafety Level 1 (BL1) is suitable for work involving agents of no known or of minimal
potential hazard to laboratory personnel and the environment. The laboratory is not separated
from the general traffic patterns in the building. Work is generally conducted on open bench
tops. Special containment equipment is not required or generally used. Laboratory personnel
have specific training in the procedures conducted in the laboratory and are supervised by a
scientist with general training in microbiology or a related science.
The following standard and special practices, safety equipment, and facilities apply to agents
assigned to BL1:
A. Standard Microbiological Practices
1. Access to the laboratory is limited or restricted at the discretion of the Laboratory
Director when experiments are in progress.
2. Work surfaces are decontaminated once a day and after any spill of viable material.
3. All contaminated liquid or solid wastes are decontaminated before disposal.
4. Mechanical pipetting devices are used; mouth pipetting is prohibited.
5. Eating, drinking, smoking, and applying cosmetics are not permitted in the work area.
Cabinets or refrigerators designated and used for food storage are to be located outside
of the work area.
6. Persons wash their hands after they handle viable materials and animals and before
leaving the laboratory.
7. All procedures are performed carefully to minimize the creation of aerosols.
8. It is recommended that laboratory coats, gowns, or uniforms be worn to prevent containi-
nation or soiling of street clothes.
B. Special Practices
1. Contaminated materials that are to be decontaminated at a site away from the laboratory
are placed in a durable, leak-proof container that is closed before being removed from the
laboratory.
2. An insect and rodent control program is in effect.
EPA June 1998 C7-28
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 1 (continued)
C. Containment Equipment
Special containment equipment is generally not required for manipulations of agents assigned
toBLi.
D. Laboratory Facilities
1. The laboratory is designed so that it can be easily cleaned.
2. Bench tops are impervious to water and resistant to acids, alkalis, organic solvents, and
moderate heat.
3. Laboratory furniture is sturdy. Spaces between benches, cabinets, and equipment are
accessible for cleaning.
4. Each laboratory contains a sink for hand washing.
5. if the laboratory has windows that open, they are fitted with fly screens.
&ERP.. June 1998 C7-29
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SHEMP Operations Manual for Laboratories
CHAFFER C
Attachment C7-2: Laboratory Bios afety Level Criteria
Biosafety Level 2
Biosafety Level 2 (BL2) is similar to BLI and is suitable for work involving agents of
moderate potential hazard to personnel and the environment. It differs in that (1) laboratory
personnel have specific training in handling pathogenic agents and are directed by competent
scientists, (2) access to the laboratory is limited when work is being conducted, and (3)
certain procedures in which infectious aerosols are created are conducted in biological safety
cabinets or other physical containment equipment.
The following standard and special practices, safety equipment, and facilities apply to agents
assigned to BL2:
A. Standard Microbiological Practices
1. Access to the laboratory is limited or restricted by the Laboratory Director when work
with infectious agents is in progress.
2. Work surfaces are decontaminated at least once a day and after any spill of viable
material.
3. All infectious liquid or solid wastes are decontaminated before disposal.
4. Mechanical pipetting devices are used; mouth pipetting is prohibited.
5. Eating, drinking, smoking, and applying cosmetics are not permitted in the work area.
Cabinets or refrigerators designated and used for food storage are located outside of the
work area.
6. Persons wash their hands after handling infectious materials and animals and when they
leave the laboratory.
7. All procedures are performed carefully to minimize the creation of aerosols.
B. Special Practices
1. Contaminated materials that are to be decontaminated at a site away from the laboratory
are placed in a durable, leakproof container that is closed before being removed from the
laboratory.
EPA June 1998 C7-30
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 2 (continued)
2. The Laboratory Director limits access to the laboratory. In general, persons who are at
increased risk of acquiring infection or for whom infection may be unusually hazardous
are not allowed in the laboratory or animal rooms. The Director has the final responsibil-
ity for assessing each circumstance and determining who may enter or work in the
laboratory.
3. The Laboratory Director establishes policies and procedures whereby only persons who
have been advised of the potential hazard and meet any specific entry requirements (e.g.,
vaccination) enter the laboratory or animal rooms.
4. When the infectious agent(s) in use in the laboratory require special provisions for entry
(e.g., vaccination), a hazard warning sign incorporating the universal biohazard symbol is
posted on the access door to the laboratory work area. The hazard warning sign identifies
the infectious agent, lists the name and telephone number of the Laboratory Director or
other responsible person(s), and indicates the special requirement(s) for entering the
laboratory.
5. An insect and rodent control program is in effect.
6. Laboratory coats, gowns, smocks, or uniforms are worn while in the laboratory. Before
leaving the laboratory for nonlaboratory areas (e.g., cafeteria, library, administrative
offices), this protective clothing is removed and left in the laboratory or covered with a
clean coat not used in the laboratory.
7. Only animals involved in the work being performed are permitted in the laboratory.
8. Special care is taken to avoid skin contamination with infectious materials. Gloves are
worn when handling infected animals and when skin contact with infectious materials is
unavoidable.
9. All wastes from laboratories and animal rooms are appropriately decontaminated before
disposal.
10. Hypodermic needles and syringes are used only for parenteral injection and aspiration of
fluids from laboratory animals and diaphragm bottles. Only needle-locking syringes or
disposable syringe-needle units (i.e., needle is integral to the syringe) are used for the
injection or aspiration of infectious fluids. Extreme caution is used when handling
needles and syringes to avoid autoinoculation and the generation of aerosols during use
&EPA June 1998 C7-3 I
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 2 (continued)
and disposal. Needles a e not bent, sheared, replaced in the sheath or guard or removed
from the syringe following use. The needle and syringe are promptly placed in a
puncture-resistant container and decontaminated, preferably by autoclaving, before
disposal.
11. Spills and accidents that result in overt exposures to infectious materials are immediately
reported to the Laboratory Director. Medical evaluation, surveillance, and treatment are
provided as appropriate and written records are maintained.
12. When appropriate, considering the agent(s) handled, baseline serum samples for labora-
tory and other at-risk personnel are collected and stored. Additional serum specimens
may be collected periodically, depending on the agents handled or the function of the
facility.
13. A biosafety manual is prepared or adopted. Personnel are advised of special hazards and
are required to read instructions on practices and procedures and to follow them.
C. Containment Equipment
Biological safety cabinets (Class I or II) or other appropriate personal protective or physical
containment devices are used whenever:
1. Procedures with a high potential for creating infectious aerosols are conducted. These
may include centrifuging, grinding, blending, vigorous shaking or mixing, sonic disrup-
tion, opening containers of infectious materials whose internal pressures may be different
from ambient pressures, inoculating animals intranasally, and harvesting infectious
tissues from animals or eggs.
2. High concentrations or large volumes of infectious agents are used. Such materials may
be centrifuged in the open laboratory if sealed heads or centrifuge safety cups are used
and if they are opened only in a biological safety cabinet.
D. Laboratory Facilities
1. The laboratory is designed so that it can be easily cleaned.
2. Bench tops are impervious to water and resistant to acids, alkalis, organic solvents, and
moderate heat.
3. Laboratory furniture is sturdy, and spaces between benches, cabinets, and equipment axe
accessible for cleaning.
‘&EPA June 1998 C7-32
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Leve’ Criteria
Biosafety Level 2 (continued)
4. Each laboratory contains a sink for hand washing.
5. If the laboratory has windows that open, they are fitted with fly screens.
6. An autoclave for decontaminating infectious laboratory wastes is available.
&EPA June 1998 C7-33
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SFLEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 3
Biosafety Level 3 (BL3) is applicable to clinical, diagnostic, teaching, research, or production
facilities in which work is done with dangerous or exotic agents that may cause serious or
potentially lethal disease as a result of exposure by inhalation. Laboratory personnel have
specific training in handling pathogenic and potentially lethal agents and are supervised by
competent scientists who are experienced in working with these agents. All procedures
involving the manipulation of infectious material are conducted within biological safety
cabinets or other physical containment devices or by personnel wearing appropriate personal
protective clothing and devices.
The laboratory has special engineering and design features. It is recognized, however, that
many existing facilities may not have all the facility safeguards recommended for BL3 (e.g.,
access zone, sealed penetrations, and directional airflow, etc.). In these circumstances,
acceptable safety may be achieved for routine tasks or repetitive operations (e.g., diagnostic
procedures involving the propagation of an agent for identification, typing, and susceptibility
testing) in laboratories where facility features satisfy BL2 recommendations provided the
recommended “Standard Microbiological Practices” “Special Practices,” and “Containment
Equipment” for BL3 are rigorously followed. The decision to implement this modification of
BL3 recommendations should be made only by the Laboratory Director.
The following standard and special safety practices, equipment, and facilities apply to agents
assigned to BL3:
A. Standard Microbiological Practices
1. Work surfaces are decontaminated at least once a day and after any spill of viable
material.
2. All infectious liquid or solid wastes are decontaminated before disposal.
3. Mechanical pipetting devices are used; mouth pipetting is prohibited.
4. Eating, drinking, smoking, storing food, and applying cosmetics are not permitted in the
work area.
5. Persons wash their hands after handling infectious materials and animals and when they
leave the laboratory.
6. All procedures are performed carefully to minimize the creation of aerosols.
&EJ A June 1998 C7-34
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S HEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 3 (continued)
B. Special Practices
1. Laboratory doors are kept closed when experiments are in progress.
2. Contaminated materials that are to be decontaminated at a site away from the laboratory
are placed in a durable, leak-proof container which is closed before being removed from
the laboratory.
3. The Laboratory Director controls access to the laboratory and restricts access to persons
whose presence is required for program or support purposes. Persons who are at in-
creased risk of acquiring infection or for whom infection may be unusually hazardous are
not allowed in the laboratory or animal rooms. The Director has the final responsibility
for assessing each circumstance and determining who may enter or work in the labora-
tory.
4. The Laboratory Director establishes policies and procedures whereby only persons who
have been advised of the potential biohazard, who meet any specific entry requirements
(e.g., vaccination), and who comply with all entry and exit procedures enter the labora-
tory or animal rooms.
5. When infectious materials or infected animals are present in the laboratory or contain-
ment module, a hazard warning sign incorporating the universal biohazard symbol is
posted on all laboratory and animal room access doors. The hazard warning sign
identifies the agent, lists the name and telephone number of the Laboratory Director or
other responsible person(s), and indicates any special requirements for entering the
laboratory, such as the need for vaccinations, respirators, or other personal protective
measures.
6. All activities involving infectious materials are conducted in biological safety cabinets or
other physical containment devices within the containment module. No work in open
vessels is conducted on the open bench.
7. The work surfaces of biological safety cabinets and other containment equipment are
decontaminated when work with infectious materials is finished. Plastic-backed paper
toweling used on nonperlorated work surfaces within biological safety cabinets facilitates
cleanup.
8. An insect and rodent control program is in effect.
aEPA June 1998 C7-35
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 3 (continued)
9. Laboratory clothing that protects street clothing (e.g., solid front or wrap-around gowns,
scrub suits, overalls) is worn in the laboratory. Laboratory clothing is not worn outside
the laboratory, and it is decontaminated before being laundered.
10. Special care is taken to avoid skin contamination with infectious materials. Gloves are
worn when handling infected animals and when skin contact with infectious materials is
unavoidable.
11. Molded surgical masks or respirators are worn in rooms containing infected animals.
12. Only animals and plants related to the work being conducted are permitted in the
laboratory.
13. All wastes from laboratories and animal rooms are appropriately decontaminated before
disposal.
14. Vacuum lines are protected with high-efficiency particulate air (HEPA) filters and liquid
disinfectant traps.
15. Hypodermic needles and syringes are used only for parenteral injection and aspiration of
fluids from laboratory animals and diaphragm bottles. Only needle-locking syringes or
disposable syringe-needle units (i.e., needle is integral to the syringe) are used for the
injection or aspiration of infectious fluids. Extreme caution is used when handling
needles and syringes to avoid autoinoculation and the generation of aerosols during use
and disposal. Needles are not bent, sheared, replaced in the sheath or guard, or removed
from the syringe following use. The needle and syringe should be promptly placed in a
puncture-resistant container and decontaminated, preferably by autoclaving. before
disposal.
16. Spills and accidents that result in overt or potential exposures to infectious materials are
immediately reported to the Laboratory Director. Appropriate medical evaluation,
surveillance, and treatment are provided and written records are maintained.
17. Baseline serum samples for all laboratory and other at-risk personnel are collected and
stored. Additional serum specimens may be collected periodically, depending on the
agents handled or the function of the laboratory.
18. A biosafety manual is prepared or adopted. Personnel are advised of special hazards and
are required to read instructions on practices and procedures and to follow them.
&EPA June 1998 C7-36
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 3 (continued)
C. Containment Equipment
Biological safety cabinets (Class I, II, or III) or other appropriate combinations of personal
protective or physical containment devices (e.g., special protective clothing, masks, gloves,
respirators, centrifuge safety cups, sealed centrifuge rotors, and containment caging for
animals) are used for all activities with infectious materials that pose a threat of aerosol
exposure. These include: manipulation of cultures and of those clinical or environmental
materials that may be a source of infectious aerosols; the aerosol challenge of experimental
animals; harvesting of tissues or fluids from infected animals and embryonated eggs, and
necropsy of infected animals.
D. Laboratory Facilities
I. The laboratory is separated from areas that are open to unrestricted traffic flow within the
building. Passage through two sets of doors is the basic requirement for entry into the
laboratory from access corridors or other contiguous areas. Physical separation of the
high-containment laboratory from access corridors or other laboratories or activities may
also be provided by a double-doored clothes change room (showers may be included),
airlock, or other access facility that requires passage through two sets of doors before
entering the laboratory.
2. The interior surfaces of walls, floors, and ceilings are water resistant so that they can be
easily cleaned. Penetrations in these surfaces are sealed or capable of being sealed to
facilitate decontaminating the area.
3. Bench tops are impervious to water and resistant to acids, alkalis, organic solvents, and
moderate heat.
4. Each laboratory contains a sink for hand washing. The sink is foot-, elbow-, or automati-
cally operated and is located near the laboratory exit door.
5. Windows in the laboratory are closed and sealed.
6. Access doors to the laboratory or containment module are self-closing.
7. An autoclave for decontaminating laboratory wastes is available, preferably within the
laboratory.
&EPA June 1998 C7-37
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 3 (continued)
8. A ducted exhaust air ventilation system is provided. This system creates directional
airflow that draws air into the laboratory through the entry areas. The exhaust air is not
recirculated to any other area of the building, is discharged to the outside, and is dis-
persed away from occupied areas and air intakes. Personnel must verify that the direction
of the airflow (into the laboratory) is proper. The exhaust air from the laboratory room
can be discharged to the outside without being filtered or otherwise treated.
9. The HEPA-filtered exhaust air from Class I or Class 11 biological safety cabinets is
discharged directly to the outside or through the building exhaust system. Exhaust air
from Class I or Class II biological safety cabinets may be recirculated within the labora-
tory if the cabinet is tested and certified at least every 12 months. If the HEPA-fihtered
exhaust air from Class I or 11 biological safety cabinets is to be discharged to the outside
through the building exhaust air system, it is connected to this system in a manner (e.g.,
thimble unit connection) that avoids any interference with the air balance of the cabinets
or building exhaust system.
ER June 1998 C7-38
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SHEMP Operations Manual for Laboratories
Cltol’mR C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4
Biosafety Level 4 (BL4) is required for work with dangerous and exotic agents that pose a
high individual risk of life-threatening disease. Members of the laboratory staff have specific
and thorough training in handling extremely hazardous infectious agents, and they understand
the primary and secondary containment functions of the standard and special practices, the
containment equipment, and the laboratory design characteristics. They are supervised by
competent scientists who are trained and experienced in working with these agents. Access to
the laboratory is strictly controlled by the Laboratory Director. The facility is either in a
separate building or in a controlled area within a building, which is completely isolated from
all other areas of the building. A specific facility operations manual is prepared or adopted.
Within work areas of the facility, all activities are confined to Class ifi biological safety
cabinets or Class I or Class H biological safety cabinets used along with one-piece positive-
pressure personnel Suits ventilated by a life support system. The maximum containment
laboratory has special engineering and design features to prevent microorganisms from being
disseminated into the environment.
The following standard and special safety practices, equipment, and facilities apply to agents
assigned to BL4:
A. Standard Microbiological Practices
I. Work surfaces are decontaminated at least once a day and immediately after any spill of
viable material.
2. Only mechanical pipetting devices are used.
3. Eating, drinking, smoking, storing food, and applying cosmetics are not permitted in the
laboratory.
4. All procedures are performed carefully to minimiz .e the creation of aerosols.
B. Special Practices
1. Biological materials to be removed from the Class Ill biological safety cabinet or from
the maximum containment laboratory in a viable or intact state are transferred to a
nonbreakable, sealed primary container and then enclosed in a nonbreakable, sealed
secondary container which is removed from the facility through a disinfectant dunk tank,
fumigation chamber, or an airlock designed for this purpose.
&ERA June 1998 C7-39
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4 (continued)
2. No materials, except for biological materials that are to remain in a viable or intact state,
are removed from the maximum containment laboratory unless they have been
autoclaved or decontaminated before they leave the facility. Equipment or material that
might be damaged by high temperatures or steam is decontaminated by gaseous or vapor
methods in an airlock or chamber designed for this purpose.
3. Only essential personnel are authorized to enter a BL4 laboratory. Those who may be at
increased risk of acquiring infection or for whom infection may be unusually hazardous
are not allowed in the laboratory or animal rooms. The supervisor has the final responsi-
bility for assessing each circumstance and determining who may enter or work in the
laboratory.
Laboratory access is limited by means of secure, locked doors. Accessibility is managed
by the Laboratory Director, biosafety officer, or other person responsible for the physical
security of the facility. Before entering, persons are advised of the potential biohazards
and instructed as to appropriate safeguards for ensuring their safety. Authorized persons
comply with the instructions and all other applicable entry and exit procedures. A
logbook, signed by all personnel, indicates the date and time of each entry and exit.
Practical and effective protocols for emergency situations are established.
4. Personnel enter and leave the facility only through the clothing change and shower
rooms. Personnel shower each time they leave the facility. Personnel use the airlocks to
enter or leave the laboratory only in an emergency.
5. Street clothing is removed in the outer clothing change room and kept there. Complete
laboratory clothing (e.g., undergarments, pants and shirts or jumpsuits, shoes and gloves)
is provided and used by all personnel entering the facility. Head covers are provided for
personnel who do not wash their hair during the exit shower. When leaving the labora-
tory and before proceeding into the shower area, personnel remove their laboratory
clothing and store it in a locker or hamper in the inner change room.
6. When infectious materials or infected animals are present in the laboratory or animal
rooms, a hazard warning sign incorporating the universal biohazard symbol is posted on
all access doors. The sign identifies the agent, lists the name of the Laboratory Director
or other responsible person(s), and indicates any special requirements for entering the
area (e.g., the need for vaccinations or respirators).
EPA June 1998 C7-40
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4 (continued)
7. Supplies and materials needed in the facility are brought in by way of the double-doored
autoclave, fumigation chamber, or airlock, which is appropriately decontaminated after
each use. After securing the outer doors, personnel within the facility retrieve the
materials by opening the interior doors of the autoclave, fumigation chamber, or airlock.
These doors are secured after materials are brought into the facility.
8. An insect and rodent control program is in effect.
9. Only materials related to the experiment being conducted are permitted in the facility.
10. Hypodermic needles and syringes are used only for parenteral injection and aspiration of
fluids from laboratory animals and diaphragm bottles. Only needle-locking syringes or
disposable syringe-needle units (i.e., needle is integral part of unit) are used for the
injection or aspiration of infectious fluids. Needles should not be bent, sheared, replaced
in the needle guard, or removed from the syringe following use. The needle and syringe
should be placed in a puncture-resistant container and decontaminated, preferably by
autoclaving, before disposal. Whenever possible, cannulas are used instead of sharp
needles (e.g., gavage).
11. A system is set up for reporting laboratory accidents and exposures and employee
absenteeism, and for the medical surveillance of potential laboratory-associated illnesses.
Written records are prepared and maintained. An essential adjunct to such a report-
ing/surveillance system is the availability of a facility for the quarantine, isolation, and
medical care of personnel with potential or known laboratory-associated illnesses.
C. Containment Equipment
All procedures within the facility with agents assigned to biosafety level 4 are conducted in a
Class 111 biological safety cabinet or in Class I or II biological safety cabinets used in
conjunction with one-piece positive-pressure personnel suits ventilated by a life support
system. Activities with viral agents (e.g., Rift Valley fever virus) that require biosafety level 4
secondary containment capabilities and for which highly effective vaccines are available and
used can be conducted within Class I or Class II biological safety cabinets within the facility
without the one-piece positive-pressure personnel suit being used if: (1) the facility has been
decontaminated, (2) no work is being conducted in the facility with other agents assigned to
biosafety level 4, and (3) all other standard and special practices are followed.
I&EPA June 1998 C741
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4 (continued)
D. Laboratory Facility
1. The maximum containment facility consists of either a separate building or a clearly
demarcated and isolated zone within a building. Outer and inner change rooms separated
by a shower are provided for personnel entering and leaving the facility. A double-doored
autoclave, fumigation chamber, or ventilated airlock is provided for passage of those
materials, supplies, or equipment that are not brought into the facility through the change
room.
2. Walls, floors, and ceilings of the facility are constructed to form a sealed internal shell
that facilitates fumigation and is animal- and insect-proof. The internal surfaces of this
shell are resistant to liquids and chemicals, thus facilitating cleaning and decontamination
of the area. All penetrations in these structures and surfaces are sealed. Any drains in the
floors contain traps filled with a chemical disinfectant of demonstrated efficacy against
the target agent, and are connected directly to the liquid waste decontamination system.
Sewer and other ventilation lines contain HEPA filters.
3. Internal facility appurtenances, such as light fixtures, air ducts, and utility pipes, are
arranged to minimize the horizontal surface area on which dust can settle.
4. Bench tops have seamless surfaces that are impervious to water and resistant to acids,
alkalis, organic solvents, and moderate heat.
5. Laboratory furniture is of simple and sturdy construction, and spaces between benches,
cabinets, and equipment are accessible for cleaning.
6. A foot-, elbow-, or automatically-operated handwashing sink is provided near the door of
each laboratory room in the facility.
7. If there is a central vacuum system, it does not serve areas outside the facility. In-line
HEPA filters are placed as near as practical to each use point or service cock. Filters are
installed to permit in-place decontamination and replacement. Other liquid and gas
services to the facility are protected by devices that prevent backflow.
8. If water fountains are provided, they are foot-operated and are located in the facility
corridors outside the laboratory. The water service to the fountain is not connected to the
backflow-protected distribution system supplying water to the laboratory areas.
9. Access doors to the laboratory are self-closing and lockable.
10. Any windows are breakage resistant.
&EE3 1 June 1998 C7-42
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SFIEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4 (continued)
11. A double-doored autoclave is provided for decontaminating materials passing out of the
facility. The autoclave door that opens to the area external to the facility is sealed to the
outer wall and automatically controlled so that the outside door can only be opened after
the autoclave “sterilization” cycle has been completed.
12. A pass-through dunk tank, fumigation chamber, or an equivalent decontamination
method is provided so that materials and equipment that cannot be decontaminated in the
autoclave can be safely removed from the facility.
13. Liquid effluents from laboratory sinks, biological safety cabinets, floors, and autoclave
chambers are decontaminated by heat treatment before being released from the rooms.
Toilets may be decontaminated with chemical disinfectants or by heat in the liquid waste
decontamination system. The procedures used for heat decontamination of liquid wastes
is evaluated mechanically and biologically by using a recording thermometer and an
indicator microorganism with a defined heat susceptibility pattern, If liquid wastes from
the shower rooms are decontaminated with chemical disinfectants, the chemical used is
of demonstrated efficacy against the target or indicator microorganisms.
14. An individual supply and exhaust air ventilation system is provided. The system main-
tains pressure differentials and directional airflow as required to ensure flow inward from
areas outside of the facility toward areas of highest potential risk within the facility.
Manometers are used to sense pressure differentials between adjacent areas maintained at
different pressure levels, If a system malfunctions, the manometers sound an alarm. The
supply and exhaust airflow is interlocked to ensure inward (or zero) airflow at all times.
15. The exhaust air from the facility is filtered through HEPA filters and discharged to the
outside so that it is dispersed away from occupied buildings and air intakes. Within the
facility, the filters are located as near the laboratories as practical in order to reduce the
length of potentially contaminated air ducts. The filter chambers are designed to allow in
situ decontamination before filters are removed and to facilitate certification testing after
they are replaced. Coarse filters and HEPA filters are provided to treat air supplied to the
facility in order to increase the lifetime of the exhaust HEPA filters and to protect the
supply air system should air pressures become unbalanced in the laboratory.
16. The treated exhaust air from Class I and II biological safety cabinets can be discharged
into the laboratory room environment or to the outside through the facility air exhaust
system. If exhaust air from Class I or H biological safety cabinets is discharged into the
laboratory, the cabinets are tested and certified at six-month intervals. The treated
exhausted air from Class III biological safety cabinets is discharged, without recircula-
lion, through two sets of HEPA filters in series, via the facility exhaust air system. if the
treated exhaust air from any of these cabinets is discharged to the outside through the
&EPA June 1998 C7-43
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-2: Laboratory Biosafety Level Criteria
Biosafety Level 4 (continued)
facility exhaust air system, it is connected to this system in a manner (e.g., thimble unit
connection) that avoids any interference with the air balance of the cabinets or the facility
exhaust air system.
17. A specially designed suit area may be provided in the facility. Personnel who enter this
area wear a one-piece positive-pressure suit that is ventilated by a life-support system.
The life support system includes alarms and emergency backup breathing air tanks. Entry
to this area is through an airlock fitted with airtight doors. A chemical shower is provided
to decontaminate the surface of the suit before the worker leaves the area. The exhaust air
from the suit area is filtered by two sets of HEPA filters installed in series. A duplicate
filtration unit, exhaust fan, and an automatically starting emergency power source are
provided. The air pressure within the suit area is lower than that of any adjacent area.
Emergency lighting and communication systems are provided. All penetrations into the
internal shell of the suit area are sealed. A double-doored autoclave is provided for
decontaminating waste materials to be removed from the suit area.
EPA June 1998 C7-44
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment 0-3: Laboratory Animal Biosafety Level Criteria
Purpose: To provide a detailed discussion of the animal biosafety level criteria used in
a laboratory.
Instructions: Refer to the detailed instructions for safe use laboratory animals to supple-
ment cunent progra ms.
June 1998 C7-45
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 1
Animal biosafety level I (ABSLI) is suitable for work involving agents of no known or of
minimal potential hazard to laboratory personnel and the environment. Special containment
equipment is not required or generally used. Laboratory personnel have specific training in
the animal handling and experimental procedures and are supervised by a scientist with
appropriate training.
The following standard and special practices, containment equipment and facilities apply to
animals assigned to ABSL1:
A. Standard Practices
I. Doors to animal rooms open inward, are self-closing, and are kept closed when experi-
mental animals are present.
2. Work surfaces are decontaminated after use or after any spill of viable materials.
3. Eating, drinking, smoking, and storing food for human use are not permitted in animal
rooms.
4. Personnel wash their hands after handling cultures and animals and before leaving the
animal room.
5. All procedures are carefully performed to minimize the creation of aerosols.
6. An insect and rodent control program is in effect.
B. Special Practices
1. Bedding materials from animal cages are removed in such a manner as to minimize the
creation of aerosols, and are disposed of in compliance with applicable institutional or
local requirements.
2. Cages are washed manually or in a cagewasher. Temperature cif final rinse water in a
mechanical washer should be 180°F.
3. The wearing of laboratory coats, gowns, or uniforms in the animal room is recom-
mended. It is further recommended that laboratory coats worn in the animal room not be
worn in other areas.
&EPA June 1998 C7-46
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SHElVE ] ’ Operations Manual for Laboratories
CHAFFER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level I (continued)
C. Containment Equipment
Special containment equipment is not required for animals infected with agents assigned to
ABSLI.
D. Animal Facilities
1. The animal facility is designed and constructed to facilitate cleaning and housekeeping.
2. A handwashing sink is available in the animal facility.
3. If the animal facility has windows that open, they are fitted with fly screens.
4. It is recommended, but not required, that the direction of airflow in the animal facility is
inward and that exhaust air is discharged to the outside without being recirculated to
other rooms.
SEAt June 1998 C7-47
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratoiy Animal Biosafety Level Criteria
Animal Biosafety Level 2
Animal biosafety level 2 (ABSL2) is similar to level I and is suitable for work involving
agents of moderate potential hazard to personnel and the environment. It differs in that (I)
access to the laboratory is limited when work is being conducted, (2) laboratory personnel
have specific training on handling infectious animals and are directed by competent scien-
tists, and (3) certain procedures in which infectious aerosols are created are conducted in
biological safety cabinets or other physical containment.
The following standard and special practices, containment equipment, and facilities apply to
animals assigned to ABSL2:
A. Standard Practices
I. Doors to animal rooms open inward, are self-closing, and are kept closed when infected
animals are present.
2. Work surfaces are decontaminated after use or spills of viable materials.
3. Eating, drinking, smoking, and storing of food for human use are not permitted in animal
rooms.
4. Personnel wash their hands after handling cultures and animals and before leaving the
animal room.
5. All procedures are carefully performed to minimize the creation of aerosols.
6. An insect and rodent control program is in effect.
B. Special Practices
I. Cages are decontaminated, preferably by autoclaving, before they are cleaned and
washed.
2. Surgical-type masks are worn by all personnel entering animal rooms housing nonhuman
primates.
3. Laboratory coats, gowns, or uniforms are worn while in the animal rooms. This protec-
tive clothing is removed before leaving the animal facility.
EPA June 1998 C7-48
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 2 (continued)
4. The Laboratory Director or Animal Facility Manager limits access to the animal rooms to
personnel who have been advised of the potential hazard and who need to enter the room
for program or service purposes when work is in progress. In general, persons who may
be at increased risk of acquiring infection or for whom infection might be unusually
hazardous are not allowed in the animal rooms.
5. The Laboratory Director or Animal Facility Manager establishes policies and procedures
whereby only persons who have been advised of the potential hazard and meet any
specific requirements (e.g., vaccination) may enter the animal room.
6. When the infectious agent(s) in use in the animal room requires special entry provisions
(e.g., vaccination), a hazard warning sign incorporating the universal bioha.zard symbol is
posted on the access door to the animal room. The hazard warning sign identifies the
infectious agent, lists the name and telephone number of the animal facility supervisor or
other responsible person(s), and indicates the special requirement(s) for entering the
animal room.
7. Special care is taken to avoid skin contamination with infectious materials. Gloves
should be worn when handling infected animals and when skin contact with infectious
materials is unavoidable.
8. All wastes from the animal room are appropriately decontaminated, preferably by
autoclaving, before disposal. Infected animal carcasses are incinerated after being
transported from the animal room in leakproof, covered containers.
9. Hypodermic needles and syringes are used only for the parenteral injection or aspiration
of liquids from laboratory animals and diaphragm bottles. Only needle-locking syringes
or disposable needle syringe units (i.e., the needle is integral to the syringe) are used for
the injection or aspiration of infectious fluids. Needles are not bent, sheared, replaced in
the sheath or guard or removed from the syringe following use. The needle and syringe
are promptly placed in a puncture-resistant container and decontaminated, preferably by
autoclaving, before disposal.
10. if floor drains are provided, the drain traps are always filled with water or a suitable
disinfectant.
11. When appropriate, considering the agents handled, baseline serum samples from animal
care and other at-risk personnel are collected and stored. Additional serum samples may
be collected periodically, depending on the agents handled or the function of the facility.
&EPA June 1998 C7-49
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 2 (continued)
C. Containment Equipment
Biological safety cabinets, other physical containment devices, and/or personal protective
devices (e.g., respirators, face shields) are used whenever procedures with a high
potential for creating aerosols are conducted. These include necropsy of infected animals,
harvesting of infected tissues or fluids from animals or eggs, intranasal inoculation of
animals, and manipulations of high concentrations or large volumes of infectious
materials.
D. Animal Facilities
1. The animal facility is designed and constructed to facilitate cleaning and housekeeping.
2. A handwashing sink is available in the room where infected animals are housed.
3. If the animal facility has windows that open, they are fitted with fly screens.
4. It is recommended, but not required, that the direction of airflow in the animal facility is
inward and that exhaust air is discharged to the outside without being recirculated to
other rooms.
5. An autoclave capable of decontaminating infectious laboratory waste is available in the
building with the animal facility.
June 1998 C7-50
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 3
Animal biosafety Level 3 (ABSL3) is applicable to clinical, diagnostic, teaching, research, or
production facilities in which work is done with dangerous or exotic agents that may cause
serious or potentially lethal disease as a result of exposure by inhalation. Laboratory person-
nel have specific training in handling pathogenic and potentially lethal agents and are
supervised by competent scientists who are experienced in working with these agents. All
procedures involving the manipulation of infectious material are conducted within biological
safety cabinets or other physical containment devices or by personnel wearing appropriate
personal protective clothing and devices.
The animal facility also has special design features such as: automatically operated hand-
washing sinks, exhaust air ventilation system, and HEPA-filtered exhaust air from primary
containment devices.
The following standard and special safety practices, containment equipment, and facilities
apply to animals assigned to animal ABSL3:
A. Standard Practices
1. Doors to animal rooms open inward, are self-closing, and are kept closed when work
with infected animals is in progress.
2. Work surfaces are decontaminated after use or spills of viable materials.
3. Eating, drinking, smoking, and storing of food for human use are not permitted in the
animal rooms.
4. Personnel wash their hands after handling cultures and animals and before leaving the
laboratory.
5. All procedures are carefully performed to minimize the creation of aerosols.
6. An insect and rodent control program is in effect.
B. Special Practices
1. Cages are autoclaved before bedding is removed and before they are cleaned and washed.
2. Surgical-type masks or other respiratory protection devices (e.g., respirators) are worn by
personnel entering rooms housing animals infected with agents assigned to ABSL3.
SEPA 1 June 1998 C7-5 1
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 3 (continued)
3. Wrap-around or solid-front gowns or uniforms are worn by personnel entering the animal
rooms. Front-button laboratory coats are not suitable. Protective gowns must remain in
the animal rooms and must be decontaminated before being laundered.
4. The Laboratory Director or other responsible person restricts access to the animal rooms
to personnel who have been advised of the potential hazard and who need to enter the
rooms for program or service purposes when infected animals are present. In general,
persons who may be at increased risk of acquiring infection or for whom infection might
be unusually hazardous are not allowed in the animal rooms.
5. The Laboratory Director or other responsible person establishes policies and procedures
whereby only persons who have been advised of the potential hazard and meet any
specific requirements (e.g., vaccination) may enter the animal rooms.
6. Hazard warning signs incorporating the universal biohazard warning symbol are posted
on access doors to animal rooms containing animals infected with agents assigned to
biosafety level 3. The hazard warning sign should identify the agent(s) in use, list the
name and telephone number of the animal room supervisor or other responsible per-
son(s), and indicate any special conditions of entry into the animal room (e.g., the need
for vaccinations or respirators).
7. Personnel wear gloves when handling infected animals. Gloves are removed aseptically
and autoclaved with other animal room wastes before being disposed of or reused.
8. All wastes from the animal rooms are autoclaved before disposal. All animal carcasses
are incinerated. Dead animals are transported from the animal rooms to the incinerator in
leakproof covered containers.
9. Hypodermic needles and syringes are used only for gavage or for parenteral injection or
aspiration of fluids from laboratory animals and diaphragm bottles. Only needle-locking
syringes or disposable needle syringe units (i.e., the needle is integral to the syringe) are
used. Needles are not bent, sheared, replaced in the sheath or guard, or removed from the
syringe following use. The needle and syringe are promptly placed in a puncwre-resistant
container and decontaminated, preferably by autoclaving, before disposal. Whenever
possible, cannulas are to be used instead of sharp needles (e.g., gavage).
10. If floor drains are provided, the drain traps are always filled with water or a suitable
disinfectant.
11. If vacuum lines are provided, they are protected with HEPA filters and liquid disinfectant
traps.
June 1998 C7-52
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CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 3 (continued)
12. Boots, shoe covers, or other protective footwear and disinfectant footbaths are available
and used when indicated.
C. Containment Equipment
1. Personal protective clothing and equipment and/or other physical containment devices
are used for all procedures and manipulations of infectious materials or infected animals.
2. The risk of infectious aerosols from infected animals or their bedding can be reduced if
animals are housed in partial containment caging systems, such as open cages placed in
ventilated enclosures (e.g., laminar flow cabinets), solid-wall and -bottom cages covered
by filter bonnets, or other equivalent primary containment systems.
I). Animal Facilities
1. The animal facility is designed and constructed to facilitate cleaning and housekeeping
and is separated from areas that are open to unrestricted personnel traffic within the
building. Passage through two sets of doors is the basic requirement for entry into the
animal room from access corridors or other contiguous areas. Physical separation of the
animal room from access corridors or other activities may also be provided by a double-
doored clothes change room (showers may be included), airlock, or other facility access
requiring passage through two sets of doors before entering the animal room.
2. The interior surfaces of walls, floors, and ceilings are water resistant so that they may be
easily cleaned. Penetrations in these surfaces are sealed or capable of being sealed to
facilitate fumigation or space decontamination.
3. A foot-, elbow-, or automatically-operated handwashing sink is provided near each
animal room exit door.
4. Windows in the animal room are closed and sealed.
5. Animal room doors are self-closing and are kept closed when infected animals are
present.
6. An autoclave for decontaminating wastes is available, preferably within the animal room.
Materials to be autoclaved outside the animal room are transported in a covered
leakproof container.
GEPA June 1998 C7-53
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 3 (continued)
7. An exhaust air ventilation system is provided. This system creates directional air that
draws air into the animal room through the entry area. The building exhaust can be used
for this purpose if the exhaust air is not recirculated to any other area of the building, is
discharged to the outside, and is dispersed away from occupied areas and air intakes.
Personnel must verify that the direction of the airflow (into the animal room) is proper.
Animal room exhaust air that does not pass through biological safety cabinets or other
primary containment equipment can be discharged to the outside without being filtered or
otherwise treated.
8. The HEPA-filtered exhaust air from Class I or Class II biological safety cabinets or other
primary containment devices is discharged directly to the outside or through the building
exhaust system. Exhaust air from these primary containment devices may be recirculated
within the animal room if the cabinet is tested and certified at least every 12 months. If
the HEPA filtered exhaust air from Class I or Class II biological safety cabinets is
discharged to the outside through the building exhaust system, it is connected to this
system in a manner (e.g., thimble unit connection) that avoids any interference with the
air balance of the cabinets or building exhaust system.
June 1998 C7-54
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S HEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 4
Animal biosafety Level 4 (ABSL4) is required for work with dangerous and exotic agents
that pose a high individual risk of life-threatening disease. Members of the laboratory staff
have specific and thorough training in handling extremely hazardous infectious agents, and
they understand the primary and secondary containment functions of the standard and special
practices, the containment equipment, and the laboratory design characteristics. They are
supervised by competent scientists who are trained and experienced in working with these
agents. Access to the laboratory is strictly controlled by the Laboratory Director. The facility
is either in a separate building or in a controlled area within a building, which is completely
isolated from all other areas of the building. A specific facility operations manual is prepared
or adopted.
Within work areas of the facility, all activities are confined to Class ifi biological safety
cabinets or in partial containment caging systems used along with one-piece positive-pressure
suits ventilated by a life support system.
The following standard and special safety practices, containment equipment, and facilities
apply to animals assigned to ABSL4:
A. Standard Practices
1. Doors to animal rooms open inward and are self-closing.
2. Work surfaces are decontaminated after use or spills of viable materials.
3. Eating, drinldng, smoking, and storing of food for human use is not permitted in the
animal room.
4. An insect and rodent control program is in effect.
5. Cages are autoclaved before bedding is removed and before they are cleaned and washed.
B. Special Practices
1. Only persons whose entry into the facility or individual animal rooms is required for
program or support purposes are authorized to enter. Persons who may be at increased
risk of acquiring infection or for whom infection might be unusually hazardous are not
allowed in the animal facility. Persons at increased risk may include children, pregnant
women, and persons who are immunodeficient or immunosuppressed. The supervisor has
the final responsibility for assessing each circumstance and determining who may enter
or work in the laboratory. Access to the facility is limited by secure, locked doors.
Accessibility is controlled by the Animal Facility Manager, biohazards control officer, or
June 1998 C7-55
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 4 (continued)
other person responsible for the physical security of the facility. Before entering, persons
are advised of the potential biohazards and instructed as to appropriate safeguards.
Personnel comply with the instructions and all other applicable entry and exit procedures.
Practical and effective protocols for emergency situations are established.
2. Personnel enter and leave the facility only through the clothing change and shower
rooms. Personnel shower each time they leave the facility. Head covers are provided to
personnel who do not wash their hair during the exit shower. Except in an emergency,
personnel do not enter or leave the facility through the airlocks.
3. Street clothing is removed in the outer clothing-change room and kept there. Complete
laboratory clothing (e.g., undergarments, pants and shirts or jumpsuits, shoes, and
gloves), are provided and used by all personnel entering the facility. When exiting,
personnel remove laboratory clothing and store it in a locker or hamper in the inner
change room before entering the shower area.
4. When infectious materials or infected animals are present in the animal rooms, a hazard
warning sign incorporating the universal biohazard symbol is posted on all access doors.
The sign identifies the agent, lists the name and telephone number of the animal facility
supervisor or other responsible person(s), and indicates any special conditions of entry
into the area (e.g., vaccinations and respirators).
5. Supplies and materials to be taken into the facility enter by way of the double-door
autoclave, fumigation chamber, or airlock, which is appropriately decontaminated
between each use. After securing the outer doors, personnel inside the facility retrieve the
materials by opening the interior doors of the autoclave, fumigation chamber, or airlock.
This inner door is secured after materials are brought into the facility.
6. Only materials related to the experiment are permitted in the facility.
7. Hypodermic needles and syringes are used only for gavage or for parenteral injection and
aspiration of fluids from laboratory animals and diaphragm bottles. Only needle-locking
syringes or disposable needle syringe units (i.e., needle is integral part of unit) are used.
Needles should not be bent, sheared, replaced in the guard or sheath, or removed from
the syringe following use. The needle and syringe should be promptly placed in a
puncture-resistant container and decontaminated, preferably by autoclaving, before
disposal. Whenever possible, cannulas should be used instead of sharp needles (e.g.,
gavage).
&EPA June 1998 C7-56
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Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 4 (continued)
8. A system is developed and is operational for the reporting of animal facility accidents
and exposures, employee absenteeism, and for the medical surveillance of potential
laboratory-associated illnesses. An essential adjunct to such a reporting-surveillance
system is the availability of a facility for the quarantine, isolation, and medical care of
persons with potential or known laboratory-associated illnesses.
9. Baseline serum samples are collected and stored for all laboratory and other at-risk
personnel. Additional serum specimens may be collected periodically, depending on the
agents handled or the function of the laboratory.
C. Containment Equipment
Laboratory animals infected with agents assigned to ABSL4 are housed in Class 111
biological safety cabinets or in partial containment caging systems (such as open cages
placed in ventilated enclosures, solid-wall and -bottom cages covered with filter bonnets,
or other equivalent primary containment systems) in specially designed areas in which all
personnel are required to wear one-piece positive-pressure suits ventilated with a life
support system. Animal work with viral agents that require ABSL4 secondary contain-
ment and for which highly effective vaccines are available and used, may be conducted
with partial-containment cages and without the one-piece positive-pressure personnel
suit: (I) if the facility has been decontaminated, (2) no concurrent experiments requiring
ABSL4 primary and secondary containment are being done in the facility, and (3) all
other standard and special practices are followed.
D. Animal Facility
1. The animal rooms are located in a separate building or in a clearly demarcated and
isolated zone within a building. Outer and inner change rooms separated by a shower are
provided for personnel entering and leaving the facility. A double-door autoclave,
fumigation chamber, or ventilated airlock is provided for passage of materials, supplies,
or equipment that are not brought into the facility through the change room.
2. Walls, floors, and ceilings of the facility are constructed to form a sealed internal shell
that facilitates fumigation and is animal- and insect-proof. The internal surfaces of this
shell are resistant to liquids and chemicals, thus facilitating cleaning and decontamination
of the area. All penetrations in these structures and surfaces are sealed.
3. Internal facility appurtenances, such as light fixtures, air ducts, and utility pipes, are
arranged to minimize the horizontal surface area on which dust can settle.
June 1998 C7-57
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SHEMP Operations Manual for Laboratories
CHAFFER C
Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 4 (continued)
4. A foot-, elbow-, or automatically-operated handwashing sink is provided near the door of
each animal room within the facility.
5. if there is a central vacuum system, it does not serve areas outside of the facility. The
vacuum system has in-line HEPA filters placed as near as practical to each use point or
service cock. Filters are installed to permit in-place decontamination and replacement.
Other liquid and gas services for the facility are protected by devices that prevent
backflow.
6. External animal facility doors are self-closing and self-locking.
7. Any windows must be resistant to breakage and sealed.
8. A double-doored autoclave is provided for decontaminating materials that leave the
facility. The autoclave door that opens to the area outside the facility is automatically
controlled so that it can be opened after the autoclave “sterilization” cycle is completed.
9. A pass-through dunk tank, fumigation chamber, or equivalent decontamination method is
provided so that materials and equipment that cannot be decontaminated in the autoclave
can be safety removed from the facility.
10. Liquid effluents from laboratory sinks, cabinets, floors, and autoclave chambers are
decontaminated by heat treatment before being discharged. Liquid wastes from shower
rooms and toilets may be decontaminated with chemical disinfectants or by heat in the
liquid-waste decontamination system. The procedure used for heat decontamination of
liquid wastes must be evaluated mechanically and biologically by using a recording
thermometer and an indicator microorganism with a defined heat susceptibility pattern, if
liquid wastes from the shower rooms are decontaminated with chemical disinfectants, the
chemicals used must have documented efficacy against the target or indicator microor-
ganisms.
11. An individual supply and exhaust air ventilation system is provided. The system main-
tains pressure differentials, and directional airflow is required to ensure inflow from areas
outside of the facility toward areas of highest potential risk within the facility. Manome-
ters are provided to sense pressure differentials between adjacent areas that are main-
tained at different pressure levels. The manometers sound an alarm when a system
malfunctions. The supply and exhaust airflow is interlocked to ensure inward (or zero)
airflow at all times.
EPP , June 1998 C7-58
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Attachment C7-3: Laboratory Animal Biosafety Level Criteria
Animal Biosafety Level 4 (continued)
12. The exhaust air from the facility is filtered by 1-IEPA filters and discharged to the outside
so that it is dispersed away from occupied buildings and air intakes. Within the facility,
the filters are located as near to the laboratories as practical in order to reduce the length
of potentially contaminated air ducts. The filter chambers are designed to allow in Situ
decontamination before filters are removed and to facilitate certification testing after they
are replaced. Coarse filters axe provided for treatment of air supplied to the facility in
order to increase the lifetime of the HEPA filters.
13. The treated exhaust air from Class I or Class II biological safety cabinets can be dis-
charged into the animal room environment or to the outside through the facility air
exhaust system. If exhaust air from Class I or II biological safety cabinets is discharged
into the animal room, the cabinets are tested and certified at six-month intervals. The
treated exhaust air from Class Ill biological safety cabinets is discharged without
recirculation via the facility exhaust air system. If the treated exhaust air from any of
these cabinets is discharged to the outside through the facility exhaust air system, it is
connected to this system in a manner that avoids any interference with the air balance of
the cabinets or the facility exhaust air system.
14. A specially designed suit area may be provided in the facility. Personnel who enter this
area wear a one-piece positive-pressure suit that is ventilated by a life support system.
The life support system is provided with alarms and emergency backup breathing air
tanks. Entry to this area is through an airlock fitted with airtight doors. A chemical
shower is provided to decontaminate the surface of the suit before the worker leaves the
area. The exhaust air from the suit area is filtered by two sets of HEPA filters installed in
series. A duplicate filtration unit and exhaust fan are provided. An automatically starting
emergency power source is provided. The air pressure within the suit area is lower than
that of any adjacent area. Emergency lighting and communication systems are provided.
All penetrations into the inner shell of the suit area are sealed. A double-doored auto-
clave is provided for decontaminating waste materials to be removed from the suit area.
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1.0 Introduction
Ergonomics is the science that addresses
workers’ performance and well-being in
relation to their job tasks, tools, equip-
ment 1 and work environment. It is a com-
plex science that has its basis in several
fields of research. Ergonomics analyses
and solutions consider input from the fol-
lowing sciences and disciplines:
• Biomechanics
• Psychology
• Physiology
• Engineering
• Anthropometry
• Kinesiology
The application of ergonomics to the
workplace is necessary for the following
reasons:
• A more diverse workforce means that
workplace design and job demands
must reflect a wider range of worker
capabilities and limitations (e.g., body
size, strength, etc.).
• Ergonomics provides a means of
accomplishing the goals of total qual-
ity and continuous improvement pro-
grams. Some facilities use ergonomic
analyses to determine the effect of
quality.
• There has been an increase in the
reporting of cumulative trauma disor-
ders related to insufficient iznplemen-
tation of ergonomic practices in the
workplace.
• Regulatory activity has increased
pertaining to ergonomics. Employers
have been cited by the U.S. Occupa-
tional Safety and Health Adrninistra-
tion (OSHA) under the general duty
clause for failure to address ergonom-
ics hazards.
This chapter describes measures that can
be used to reduce exposure to, and in some
cases remove, ergonomic stressors from
the workplace. The measures that are pre-
sented include guidelines, worksite analy-
sis, hazard prevention and control, medical
management, and training. Although each
EPA laboratory does not have its own
ergonomist, many of the core elements of
an ergonomics program (e.g., worksite
analysis, hazard prevention and control)
are already found in the laboratory safety
programs. Thus, many tasks can be com-
pleted, only enlisting the aid of an ergono-
mist on an as-needed basis.
EPA Program Requirements
Each laboratory must:
• Conduct workplace assessments to
identify ergonomic risk factors.
• Establish hazard prevention and con-
trol procedures.
• Ensure that employees have ergonom-
ics training.
Program Administration
To ensure that ergonomics is effectively
implemented, a local ergonomics commit-
tee f “human variation” on product (LEC)
should be established that will be responsi-
ble for the programs’ administration and
maintenance. Appropriate members may
include representatives from the following
departments: facilities; Safety, Health, and
Environmental Management (SHEM); and
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occupational medicine. Once established,
this group should distribute responsibili-
ties for:
• Obtaining funding and staff support
from upper management
• Measuring short- and long-term
success
• Analyzing past OSHA 200 Logs and
medical and safety records
• Developing tools to be used for
worksite analysis
• Training employees on fundamentals
of ergonomics
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2.0 Work-Related Musculoskeletal
Disorders
EPA laboratory employees are exposed to
a variety of ergonomic stressors during the
performance of their work tasks. Continual
exposure to these stressors can result in
a work-related musculoskeletal disorder
(WMSD). Potential WMSD-type injuries
common in laboratory environments
include:
• Tendonitis
• Tenosynovitis
• Thoracic outlet syndrome
• Carpal tunnel syndrome
A WMSD is defined as:
WMSDs develop due to an accumulation
of stress or damage to the body over time.
The body has great recuperative powers if
given the opportunity to repair itself. How-
ever, when recovery time is insufficient
and when repeated movements are com-
bined with forceful and awkward postures,
there is an increased risk that the damage
will lead to injury.
Common characteristics associated
with WMSDs may include pain, limited
motion, soft-tissue swelling, possible
diminished sensation, and the potential
for lasting damage. Although these injuries
require time to develop, their overall cost-
related impact on the employee’s health
and the laboratory can be staggering.
According to National Institute of Occupa-
tional Safety arid Health (NIOSH), the cost
to employers is more than 13 billion dol-
lars annually, and more than 20 billion
dollars annually according to the American
Federation of Labor—Congress of
Industrial Organizations. Figure CS-I
shows this injury cost to business.
The prevalence of ergonomics-related
injuries and illnesses continues to increase.
A 1997 Bureau of Labor Statistics study of
more than two million cases that occurred
in 1995 reported the following:
• One in four cases of back injuries or
illnesses resulted in three to five days
away from work.
• One in two cases of carpal tunnel syn-
drome results in 31 or more days away
from work.
In addition, 25 percent of all lost workday
cases and 30 percent of all workers’ com-
pensation costs were WMSD-related. Fig-
ure C8-2 shows the occurrence of WMSDs
over time.
3.0 Ergonomics Guidelines
Although a regulation regarding ergonom-
ics implementation does not exist, there
are several regulatory groups that have
either defined key program elements or
have offered direction. The following sec-
tions summarize each group’s activities
pertaining to ergonomics.
3.1 OSHA
In 1997, OSHA drafted the “Ergonomic
Program Management Recommendations”
for general industry. Its purpose was to
assist employers in preventing disorders
Bodily injury secondary to mechanical
stresses that results in a physical
condition that has developed as a
result of repeated stress on a
particular body part.
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Figure C8-1: Injury Cost to Business
C8. Ergonomics Program
Medical Payments
Compensation
Downtime
Direct Costs
Overhead $ while work disrupted
Breaking in substitute
Lost efficiency due to
breakup of crew
Supervisor time to investigate
Indirect or Hidden Costs
Loss of production
Loss of good will
Damaged tools/equipment
Overtime to make up production
Hiring costs
Lost time by fellow workers
Failure to meet deadline/fill orders
Figure C8-2: WMSD Occurrence
250 —
200 —
150 —
100-
50— 23
O 1981
223.6
185.4
I46.9
729 i
55 JLJLiLJ
1982 1983 1984 1985 1986 1987 1988 1989 1990 1991
Year
C l )
0
0 1
U
‘SM
0
0
0
t I A
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related to the lack of ergonomics in the
workplace. This, as well as the standards
described in the following section, is being
used as the basis for a regulatory standard.
The regulatory standard may require
employers to address ergonomic hazards
by designing their ergonomics programs
to include the items listed in Figure C8-3.
3.2 ANSI Standards
in 1988, the American National Standard
Institute (ANSI) published a standard for
“Human Factors Engineering of Visual
Display Terminal Workstations,” ANSI!
HFS 100. This voluntary standard is being
updated to include guidelines for the fol-
lowing elements:
• Output devices
• Input devices
• Workstation fixtures
• Environmental considerations
The ANSI standard identifies several
elements that should be included in an
ergonomics program:
Figure C8-3: Ergonomics Program
Management
Leadership
Employe
Involvement
K
Injury
Prevention
Continuous
Improvement
• Health- and risk-factor surveillance
• Job analysis and improvement
• Medical management
• Training
• Program evaluation
hi addition, the ANSI Z-365 “Standard
Control of CTDs,” specifies principles and
practices for the control of cumulative
trauma disorders in the industrial work-
place.
3.3 The Americans with Disabilities
Act—Title I
Title I of the Americans with Disabilities
Act (ADA) protects qualified individuals
with disabilities from employment dis-
crimination. Private employers, state
and local governments, employment
agencies, labor unions, and the joint
labor-management committees must
comply with Title I of the ADA.
Although the ADA is an extensive legal
document requiring employers to set up
policies that comply with the Act, the rela-
tionship between ergonomics and the
ADA falls into three major categories:
Identification of
Problem Jobs
Design/Implementation
of Solutions
Training
Medical
Management
Ergonomics
Pra m
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• Developing job descriptions that
define the essential and marginal
requirements of a job
• Providing reasonable accommodations
for qualified workers with disabilities
• Identifying and addressing issues
related to accessibility within the
workplace
3.4 European Directive on Manual
Handling
A directive on manual handling came into
effect in Europe on January 1, 1993. The
directive is a mandatory standard that
applies to any manual handling operations
that may cause injury at work. It requires
employers to take at least three steps in
reducing hazards:
• Avoid hazardous manual handling
operations where reasonable.
• Assess any hazardous operation that
cannot be avoided.
• Reduce the risk of injury as much as
reasonable.
4.0 Human Capabilities and
Limitations
When implementing ergonomics in any
organization, there needs to be an under-
standing of essential guidelines for use
when addressing human capabilities and
limitations. The guidelines in the follow-
ing sections should be considered when
designing for human interactions.
4.1 Anthropometry
analysis of dimensions and proportions
of the human body in relation to worksta-
tion design, equipment, furniture, and
tools. Figure C8-4 shows a workstation
not designed to account for workers of
various sizes. Such a poorly designed
workstation can result in awkward reach-
ing and bending movements.
Figure C8-4: Human Proportions in
Relation to Workstation Design
If a workstation is designed for the average
person (e.g., the 50th percentile), only a
small percentage of the population is
accommodated. As such, workstations
should be designed for 90 percent of the
population, since the “average” person
does not exist. Figure C8-5 shows the dis-
tribution of the majority of the population.
When designing for human beings, it
is important to know their dimensions.
Anthropometric data help to determine
these dimensions. Anthropometry is the
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Figure C8-5: Distribution of the
Majority of the Population
0
Cs
0
4.2 Occupational Biomechanics
In the design or evaluation of safe, effi-
cient, and productive workplaces the
interaction between workers and their
tools, machines, and materials should be
optimized. This will enhance the workers’
performance while minimizing the risk of
repetitive strain injuries.
Occupational biomechanics is the science
that investigates and describes movement
of the body segments (e.g., fingers, hands,
arms, back) and the forces acting on those
segments because of work being per-
formed. The interaction of lever systems
and torque in occupational biomechanics
is presented in the following sections.
4.2.1 Lever Systems
The muscles and bones that make up the
musculoskeletal system function as a sys-
tem of levers to accomplish tasks such as
holding a tool, assembling, and lifting.
Figure C8-6 presents examples of three
classes of lever systems.
4.2.2 Torque
Torque is the rotation caused by the
application of a perpendicular force at
some distance from its axis. To counteract
this rotation, the muscles react and create
opposing forces. The resultant torques
generated cause the muscles to contract
and enable the human being to do mechan-
ical work.
When a muscle’s force is inadequate to
counteract movement created by a load,
the object falls. When a muscle’s force is
equal to the movement created by a load
Percentile
Figure CS-6: Classes of Lever Systems
1 St Class Lever System 2 Class Lever System 3 rd Class Lever System
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in the hand, the object is held steady.
When a muscle’s force is greater than the
movement created by a load in the hand,
the object is raised.
Figure C8-7 shows three examples of the
effect torque has on muscular contraction.
Figure C8 -7: Effect of Torque on Mus-
cular Contraction
Object
Raised
5.0 Relevance to Job and Workplace
Design
The goal of occupational biomechanics in
job design is to minimize the reactive
force that muscles must exert to counteract
movement by controlling the weight load
and distance.
Figure C8-8 demonstrates three lifting
techniques, and indicates the total forward-
bending moments on the lumbar spine,
with the variations in resistance lever arms
for the load (Lu) and the upper body mass
(Lb).
Moving the object closer to the body’s
center of gravity reduces the forward-
bending moment and results in less
stress on the back and shoulder muscles.
Position (a) in Figure C8-8 is analogous
to the low lifting of sheet material. Posi-
tion (b) is similar to lifting over a vertical
obstruction. Position (c) shows the recom-
mended posture for lifting, but it assumes
that the load can fit between the legs dur-
ing the lift, which often is not possible.
While worker training in lifting techniques
can be beneficial, often the most effective
approach is to promote recommended lift-
ing positions through workplace and job
design.
6.0 Worksite Analysis
Worksite analysis is a systematic method
to control work-related injuries and ill-
nesses and prevent future occurrences.
Analysis tools used in the process will
allow:
• Identification of “problem” jobs
• Determination of the risk associated
with those jobs
• Initiation of problem-solving efforts
Object
Falls
Object
Steady
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Figure C8-8: Lifting Techniques
C8. Ergonomics Program
(a) Total
Forward-Bending
Moment = 212 Nm
*N=Newton
(b) Total
Forward-Bending
Moment = 192 Nm
(c) Total
Forward-Bending
Moment= 151 Nm
This process will also provide baseline
documentation on each job or job category
in the laboratory. This can then be used to
measure the results of ergonomics imple-
mentation on a case-by-case basis or to
conduct department audits. The worksite
analysis contains four steps as shown in
Figure C8-9, each of which is discussed
in the following sections.
6.1 Step 1: Data Review
The first step is to review injury data. This
review should result in a detailed summary
of past and current reported injury experi-
ences. The most accurate sources of injury
data include the OSHA 200 Log and medi-
cal and safety records.
Employees can provide accurate informa-
tion, usually in the form of complaints of
discomfort associated with certain jobs.
Every complaint should be recorded and
followed up on to identify ergonomics
concerns before a more serious condition
develops. A sample employee complaint
log is provided in Attachment C8- 1.
This step represents a “reactive” but criti-
cal part of the overall worksite analysis
process.
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Figure C8-9: Steps in Worksite Analysis
Step 1
Data
Review
‘I ,
Step2
Screening
Surveys
Step 3
Job Hazard
Analysis
Step 4
Periodic
Surveys
6.2 Step 2: Screening Surveys
Screening surveys are an important part of
the worksite analysis process. Although
the depth of analysis found in a screening
survey is less than a detailed job hazard
analysis, the results can be used when tar-
geting certain areas of the body (e.g.,
hands/wrists, back, shoulder, etc.).
There are many types of screening surveys
available (e.g., objective scales, checklists,
etc.). One appropriate means for targeting
body area discomfort involves the use of a
“body map,” where specific body areas can
be circled or shaded and the level of dis-
comfort or pain can be identified. A sam-
ple “body map” is provided in Attachment
C8-2.
This step also represents a “reactive”
approach because it can quickly identify
the presence of pain or discomfort. When
combined with the results of the data
review, the severity and magnitude of
exposure to ergonomic stressors can be
identified.
6.3 Step 3: Ergonomic Job Hazard
Analysis
Ergonomic job hazard analysis (JHA) is a
crucial step for determining stressor pres-
ence (e.g., sharp edges, large force projec-
tion, small handles) and level of exposure
(e.g., high, medium, low).
Many times, the ergonomic JIiA can be
completed by using a checldist or other
easily completed form. Although there
are many factors that cause WMSDs, it
is essential to emphasize those that occur
for longer duration or those that are per-
formed for a large portion of the task
cycle. One example of a JHA checklist is
provided in Attachment C8-3.
6.4 Step 4: Periodic Surveys
Periodic surveys are used to determine
the success of ergonomics implementation.
Although decreases in severity and inci-
dence rates may occur as a result of imple-
mentation, the correlation to ergonomics
implementation can be hard to justify. A
more accurate survey would include the
resultant risk as well as any decreases in
worker discomfort or pain. Further peri-
odic surveys could include employee
early reporting and job satisfaction, and
decreases in absenteeism and turnover.
7.0 Hazard Prevention and Control
Once hazards have been identified, the use
of controls can aid in their reduction.
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Engineering controls require a physical
change to the work environment through
equipment adjustment or purchase.
Administrative controls often require
changes in work policy, such as increases
in staffing or job rotation.
Work practice controls are used to identify
the “best practices” to employ when per-
forming a task (e.g., instruction in the cor-
rect lifting technique).
The following sections discuss the use
of engineering controls in designing
workstations and tools.
7.1 Workstation Design
For laboratory environments, correctly
designed workstations can reduce expo-
sure to ergonomic stressors. When design-
in,g workstations, perform the following:
• Design the height of the point of oper-
ation to allow neutral shoulder and
wrist positions.
• Provide a height-adjustable
workstation.
• Provide soft, padded armrests to mini-
mize static stress and external trauma.
• Provide arm supports when the visual
distance or control location requires
the point of operation to be above
seated elbow height.
• Place controls or materials within
reach; avoid placement to the sides,
behind, and/or above shoulder height.
• Provide space for objects or materials
to be located 16 to 18 inches in front
of the body and between the elbows
and shoulders.
• Provide clear knee space for seated
workers, and foot rails for standing
workers.
• Provide adequate lighting for detailed
tasks (e.g., 75 foot-candles).
• Provide adjustable seating to accom-
modate workers ranging from 4 feet
8 inches tall and 97 pounds to 6 feet
2 inches tall and 217 pounds.
7.1 Tool Design
The tools used in EPA laboratories can
range from microscopes and pipettes to
tweezers and other small hand tools.
Although these tools can differ in their
function, it is important that they contain
the following features:
• Focusing knobs on the microscope
should have large diameters and
require small manipulation forces.
• Eyepieces and necks on the micro-
scope should be adjustable in tilt, hori-
zontal, and vertical position.
• Joysticks used to manipulate optical
viewing devices (e.g., cameras) should
have a built-in hand-resting surface.
• The gripping surfaces on tweezers and
the barrels on small hand tools should
be compressible and of a sufficiently
large size (i.e., greater than one inch).
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• Triggers on multi-channel pipettes
must allow for at least two fingers and
should not activate by using thumb
pressure.
• Handles on small tools should not
press into the palm or have grooves
and sharp edges.
73 Design of Work Practice Controls
Although engineering controls are the
most effective in eliminating risk factor
exposure, at times they are not justifiable
for economic or practical reasons. When
this is the case, carefully designed work
practice controls can aid in risk factor
reduction.
The major components of work practice
controls include work procedures and job
design. The following guidelines should be
followed when designing work practice
controls:
• Involve all affected employees.
• Train employees in fundamental
ergonomic principles. This will be
the basis for deciding how to perform
each element of a task with a mini-
mum risk to employees.
• Divide the job into subtasks and iden-
tify the best method for performing
each subtask based on ergonomic
principles.
• Create a simple written procedure that
includes photographs describing each
major subtask.
• Use written work procedures when
training new or transferred employees.
8.0 Medical Surveillance
An effective medical surveillance program
for WMSDs is essential to the success
of an ergonomics program. The program
should identify the elements that will
ensure early evaluation, diagnosis, and
treatment of WMSDs, as well as imple-
mentation of preventive measures. For
more information on medical surveillance
requirements, refer to Chapter C2 of this
manual.
8.1 Appropriate Personnel
A certified occupational health nurse
or occupational medicine physician with
appropriate training should be involved
in the development and administration
of the medical surveillance process. Each
EPA laboratory should have access to
health care providers to facilitate treat-
ment, supervise activities, and record
information. Their findings should be a
topic of discussion during safety meetings.
8.2 Components of a Medical
Surveillance Program
The following are the components of a
medical surveillance program designed for
the prevention and treatment of WMSDs.
8.2.1 Workplace Walkthrough
To identify potential restricted-duty tasks
and to maintain contact with employees
Medical surveillance personnel and
SHEMP Managers should remain knowl-
edgeable about current operations and
work practices. This element is essential
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as it demonstrates laboratory manage-
ment’s commitment to employee
well-being.
8.2.2 System Surveys
This method of worksite analysis is used
to determine the existence of ergonomic
problems in the facility, and establish a
baseline for further comparison. Survey
forms should identify the location, dura-
tion, and severity of the discomfort. This
can be facilitated quite easily with body
diagrams. Employee participation can be
encouraged by eliminating potential
worker identifiers (e.g., name, SSN, etc.).
In order for a WMSD to heal, the
employee should be placed in a work
environment in which the muscle-tendon
unit will have time to rest. For this to
occur, the current task and new tasks
being considered should be examined
to determine the risk to the stnsctures
involved (e.g., shoulder tendon).
8.2.3 Early Reporting of Symptoms
Early reporting of potential WMSDs will
allow for timely and appropriate evalua-
tion and treatment without fear of discrim-
ination or reprisal. It is vital that any
potential disincentives for employee
reporting (e.g., limits on the number of
times an employee may visit the health
unit) are eliminated.
8.2.4 Appropriate Medical Care
Once a WMSD has been identified, it
is essential for there to be established pro-
tocols for dealing with evaluation (e.g.,
diagnostic tools), treatment (e.g., anti-
inflanunatory medication and exercise),
and follow-up assessment.
9.0 Employee Information and
Training
Although an effective ergonomics pro-
gram can help detect and prevent WMSDs
through symptom surveys and periodic
walk-throughs, ergonomics training is vital
for recognizing current problems and for
creating a forum for discussing employee
concerns. Refer to Chapter C3 of this man-
ual for more information on ergonomics
training.
10.0 Material Handling Techniques
Material handling has historically led to
many musculoskeletal injuries. By imple-
menting guidelines for material handling,
injuries may be drastically reduced.
10.1 Pushing /Pulling
Basic guidelines for pushing and pulling
include the following:
• Use two hands instead of one.
• Push at waist level instead of at
shoulder or knee level.
• Pull at knee level instead of at waist
or shoulder level.
• Keep machines and equipment well
maintained and lubricated to ease
pushing and pulling.
• Avoid ramps, long distances, and high
repetition.
10.2 Holding
There are some situations in which
the worker holds the object without
any movement, creating a static load.
Employees should use proper posture
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and tipping aids to reduce strain caused
by holding objects. Basic guidelines
include the following:
• Avoid holding objects above shoulder
height and away from the body (espe-
cially to the sides).
• Use tipping aids to counterbalance
drums when pouring.
10.3 Carrying
There are many different ways to carry
objects, each associated with different
stresses and strains. Methods for carrying
objects should be appropriate for the spe-
cific task performed.
103.1 Carrying With the Back and
Shoulders
Guidelines for carrying with the back and
shoulders include the following:
• Keep the load close to the body.
• Carry light loads often instead of large
loads occasionally.
• Use mechanical assistance where
possible.
10.3.2 Hand Carrying
During hand carrying, employees should
avoid twisting, bending, and excessive
loads all of which may stress the back.
The use of mechanical aids to move
objects should be encouraged. Appropriate
postures, such as using the proper wrist
position, are important in reducing stress
as well.
10.4 Lifting
Proper lifting techniques should be part
of an overall program of hazard prevention
and control that focuses on eliminating the
source of potential ergonomic problems
through engineering change. Many guide-
lines that often include complex calcula-
tions may be used for lifting analysis, but
employees should focus on the following
basic guidelines:
• Bend at the knees instead of at the
waist.
• Lift the load slowly.
• Pivot or move feet instead of twisting
at the waist.
• Use materials handling equipment
whenever possible.
• Make more trips with less weight.
• Maintain a good grip on the object by
using as many fingers as possible.
• Keep the load close to the body.
• Lift and carry items between the waist
and shoulders.
• Ask for assistance when carrying large
or bulky loads.
11.0 Work Postures
To reduce the occurrence of WMSDs,
employees should use appropriate work
postures. The following guidelines should
be imniemented:
• Avoid awkward positions for extended
periods of time (e.g., arms away from
the side or behind the body, wrists
bent).
• Set the work height at two inches
below the elbow.
• Adjust chair control levels to obtain
correct heights.
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Attachment C8- 1: Employee Complaint Log
Purpose: To provide an example of an employee complaint log form.
Instructions: Use this form to record employee complaints related to ergonomic stressors.
J\ June 1998 C8-15
-------
Employee Complaint Log
Complaint
Employee
Job!
Injury Type,
Date
Name
Task
Dept.
Body Area
Severity, Duration
Follow-up Action
Follow-up Date
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C8-2: Body Map
Purpose: To provide an example of a form that can be used to map locations of ergo-
nomic stressors on the body.
Instructions: Use this form to identify how the body responds to the demands of ajob task.
In each section, answer the first question. If the answer is “No,” go to the next
column.
&EI June 1998 C8-17
-------
Body Map: Response to Work Demands
Question
• in the past 12 months, have
you experienced any
discomfort, fatigue,
numbness, or pain that
relates to your Job?
• How often do you
experience discomfort,
fatigue, numbness, or pain
in this region of the body?
• On average, how severe is
the discomfort, fatigue,
numbness, or pain in this
region of the body?
1. ibs ci No ci
If “No,” go to Q.stlon4
3. Mid
Moderate
Severe
2. Daily
Weekly
Monthly
ci
ci
ci
Hands/Wr lstslArms
4. bs ci No ci
W”N4 ”gotoOtMsUon 7
6. Mild
Moderate
Severe
5. DaIly
Weekly
Monthly
ci
ci
ci
7. ‘ibs ci No ci
If ”No , ”goto Question 10
9. Mild
Moderate
Severe
ci
ci
ci
ci
ci
ci
8. Daily
Weekly
Monthly
10. bs ci No ci
If ,“go to QuestIon 13
11. Daily
Weekly
Monthly
12. Mid
Moderate
Severe
U
c i
ci
ci
ci
ci
Head/Eyes
13. Yes ci No ci
14. Daily
Weekly
Monthly
15. Mild
Moderate
Severe
ci
ci
ci
c i
ci
ci
Shoulder/Neck
Back/Torso
Leg Fest
-------
SHEMP Operaüons Manual for Laboratories
CHAPTER C
Attachment C8-3: Ergonomics Checklist
Purpose: To pmvide an example of an ergonomics checklist.
Instructions: Use this checklist when analyzing a job task for risk factors.
&EI 1 June 1998 C8-19
-------
Ergonomics Checklist
X<10% J10 5O% L5O%>X
0 J 2
Solution Opportunities Group
or wrist rest on
Attach a compressible surface to
the workstation edge.
continually held in
Provide a holding device or
clamp.
require projecting
pounds of repeated
Increase the object’s surface
area to allow for a larger contact
area.
subjected to tool
vibration?
Provide azitivibration gloves or
tool wraps, and attach compress-
ible surfaces to workstation
edges.
by a single-
Adapt trigger for multiple
fingers.
heavier than 52
lifted?
Use materials handling equip-
ment or alternative material
delivery methods for heavy
objects.
handling require
or careful
alignment?
Consider providing transfer
devices or carts to hold, place,
or control objects.
have to be car-
than five steps?
Provide a can or hoist, or move
the start and end locations closer
together.
movement require
floor to above
height?
Place frequently lifted objects at
least 20 inches off the floor and
lift objects no higher than 60
inches.
to push because
or bearings?
Ensure that wheels and bearings
are rated for the load capacity.
inhibited by
shape, or location?
Use tubular handles that are 1.5
to 1.8 inches in diameter and are
41 inches from the ground.
-------
Ergonomics Checklist (continued)
Risk Factors JX<1O%
j0
10-50%
S0%>X
SolulionOpportuniliesGroup
2
3
Position
I Are awkward body positions
repeatedly held for more than
10 seconds during the task’
Raise or lower the object so
that a neutral body position is
possible.
2 Does the object movement
require forward or sideways
bending and/or twisting of
more than 15°?
Raise the object so that it is
higher than 20 inches and place
the start/end locations next to
each other.
Does the employee have to
repeatedly reach above shoal-
der height or behind the body
to get parts or supplies?
Place objects or items below the
individual’s shoulder height and
in front of the body.
Are the elbows positioned corn-
fortably at the sides?
Place the object so that the
elbows are positioned comfort-
ably at the sides; provide upper-
limb supportive devices (e.g.,
padded work surfaces, arm
rests).
Are the cart’s contents placed
lower than 19 inches?
Provide carts with higher
shelves; place light objects on
lower shelves.
Does the task require unsup-
ported holding of tools weigh-
ing more than five pounds?
Provide supportive surfaces for
the upper Limb or the tool.
Do tool handles for precision
tasks have compressible
urf a ce
Attach compressible surfaces so
that the barrel diameter is at
least 1.5 inches.
Does the tool handle design or
its use require awkward upper
limb positions?
Modify the tool handle to allow
for proper orientation, or reposi-
non objects to allow for more
neutral positioning.
Does the tool handle have
sharp edges?
Attach compressible surfaces to
the handle or provide gloves.
Position Total
-------
Ergonomics Checklist (continued)
Risk Factors
Xc10%
1O—5O%
5O%>X
Solution Opportunities Group
0
2
3
Frequency
I
Are the worker’s hands
exposed to cold
temperatures?
Provide gloves or redirect
exhaust away from hands.
2
Are similar wrist, elbow, or
shoulder motions repeated
every task cycle?
Provide job variety or rotation
opportunities to allow for rest.
Frequency Total
Risk Factors
Totals
Force
___________
Position
Frequency
Overall Task Subtotal
Overall Task
I I
— Total Possible
Score
I I
x 100=
Overall Risk
I I
-------
c9.
Pollution Prevention
Program
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
1.0 Introduction
The EPA defines pollution prevention (P2)
as source reduction and other practices that
reduce or eliminate the creation of pollut-
ants through increased efficiency in the
use of raw materials, energy, water or
other resources, and protection of natural
resources by conservation. The following
Executive Orders drive current federal
facility requirements for P2:
Order 12856: “Federal Compliance with
Right-to-Know Laws and Pollution
Prevention”
Order 12873: “Federal Acquisition, Recy-
cling, and Waste Prevention”
Order 12902: “Energy Efficiency and
Water Conservation”
One of EPA’s goals is to ensure that
P2 becomes part of the environmental
ethic at every level of the federal govern-
ment; a related goal is that federal workers
integrate environmental considerations
into their work.
EPA Program Requirements
To assist the integration of P2 techniques
as set forth in the Agency’s Code of Envi-
ronmental Principles (CEMP), EPA labo-
ratories must:
• Develop a P2 plan.
• Apply source reduction to facility
management and to acquisition
practices.
• Establish a voluntary goal to reduce
total releases and off-site transfers of
toxic chemicals and pollutants.
• Establish a plan to reduce or eliminate
the acquisition and procurement of
products containing extremely hazard-
ous substances or toxic chemicals.
To apply energy conservation, EPA labo-
ratories must:
• Develop a program to reduce energy
consumption.
• Develop a program to increase energy
efficiency.
• Develop a program to reduce petro-
leum use.
• Conduct surveys and audits based
on facility priorities in energy
conservation.
• Meet facility construction and leasing
requirements.
Program Admintctnuion
P2 opportunities exist in all aspects of lab-
oratory management. To effectively man-
age a P2 program, responsibilities should
be assigned for:
• Identifying sources and amounts of
laboratory pollutants
• Targeting process or material changes
that will result in pollution reduction
• Determining the potential for cost sav-
ings related to specific pollution
reduction techniques
• Evaluating the effectiveness of the P2
program annually
To effectively manage energy conservation
at EPA laboratories, responsibilities
should be assigned for:
• Defining laboratory goals for energy
conservation
SEPA June 1998
C9-l
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs C9. Pollution Prevention Program
• Identifying high-priority areas for
improving energy consumption
• Organizing energy teams
• Providing incentives for energy
conservation
• Measuring effectiveness of energy-
conservation techniques
June 1998 C9-2
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
2.0 P2 Program
Executive Order 12856 requires the
federal government to apply source reduc-
tion to the management of its facilities.
The Order requires each federal agency,
including the EPA, to:
Develop a written P2 strategy and
policy statement emphasizing source
reduction as the primary method of
environmental protection.
• Submit Toxic Release Inventory
(TRI) reports for all releases or trans-
fers of toxic chemicals for all agency
facilities that exceed thresholds for
manufacture, use, or processing of
toxic chemicals, as defined under the
Emergency Planning and Community
Right-to-Know Act (EPCRA) Section
313, without regard to Standard Indus-
try Code (SIC) limitations.
• Comply with the emergency planning
and response provision under EPCRA
Sections 302 and 312.
• Develop voluntary goals to reduce
total releases and off-site transfers of
TRJ chemicals by 50 percent by 1999.
• Establish a plan and goals for elimi-
nating or reducing the unnecessary
procurement of products containing
extremely hazardous substances or
toxic chemicals.
The EPA also requires that each covered
facility develop their own P2 program.
This program must include a plan that sets
forth the laboratory’s contribution to the
agency-wide 50-percent reduction goal.
A successful P2 program involves:
• Calculating a P2 baseline
• Conducting an opportunity assessment
• Preparing a P2 Plan
• Developing a procurement strategy
• Implementing P2 initiatives
The following sections, and Figure C9- 1,
outline a methodology for EPA laborato-
ries to develop a successful P2 program.
Figure C9-1: Development of a P2 Pro-
gram
Obtain Management
S pport
Compile Baseline
Infonnation
Perform an Opportunity
Assessment
‘Jr
PrepareaPlan I
Establish Procurement
Strategies
Implement Strategies
• Revise speciiications and standards, and
identify opportunities, to eliminate or
reduce procurement of extremely haz-
ardous substances or toxic chemicals.
2.1 Obtain Management Support
The EPA is committed to fulfilling both the
spirit and letter of Executive Order 12856.
Therefore, laboratory Safety, Health, and
&EPA June 1998
C9-3
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
Environmental Management Program
(SHEMP) managers should document their
commitment of resources to properly
implement a P2 program. This includes
designating roles and responsibilities
throughout the laboratory, appointing a P2
coordinator to serve as a focal point for
program implementation, and communicat-
ing the importance of P2 to employees.
2.2 Compile Baseline Information
To properly develop a P2 program, labora-
tories must identify and compile baseline
information on material usage, release pro-
files, and environmental impacts related to
laboratory operations. Hazardous chemi-
cals, waste streams, and water and energy
consumption should all be quantified to
the fullest extent possible. Major labora-
tory processes should be diagrammed and
mass balances of pollutants developed.
Such an accounting allows laboratories to
prioritize the emphasis of their P2 strategy.
The P2 Coordinator must develop a con-
sistent method for documenting informa-
tion and may need to organize a team to
collect the necessary data. Information
necessary for developing a baseline in-
cludes:
• Quantities of chemicals used and
disposed of
• Raw material costs
• Disposal costs
• Procurement practices
• Process requirements
Most of this information can be gathered
by reviewing purchasing records, inven-
tory quantities, disposal and transfer data,
and on-site treatment data. Interviews with
people from various organizations or spe-
cialty areas will also help the coordinator
or team members understand the specific
practices occurring in the laboratory.
23 Perform an Opportunity
Assessment
A P2 opportunity assessment is a system-
atic analysis that identifies operational
characteristics that create environmental
impacts, such as waste generation, toxic
chemical releases, power and water con-
sumption, and ecosystem damage. The
overall goal of the assessment is to identify
which laboratory processes and operations
are best suited for P2 projects. Assess-
ments therefore should target the processes
and materials having the highest probabil-
ity of yielding significant reductions in
pollution. Some facilities form teams con-
sisting of operations, maintenance, envi-
ronmental, and engineering personnel to
identify the most promising P2 opportuni-
ties.
During the data collection phase of the
assessment, the team must be careful to
ensure that information is gathered in a
consistent and accurate manner, possibly
through the use of a uniform data collec-
tion worksheet.
Interviews should be conducted with per-
sonnel involved in each process to under-
stand the operability of the process and
whether any improvements to the process
can be implemented to accomplish pollu-
tion reduction. Information for each pro-
cess should include the following:
A characterization of all aspects of the
process or operation, including pro-
cess flow, waste generation patterns,
&EPA June 1998
C9-4
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
material and energy consumption,
costs, manpower, and reliance on toxic
chemicals
• Impacts that the process and related
wastes have on the air, water, and land
• Associated impacts and wastes with
specific unit operations
• Related costs and liabilities of specific
waste streams
• Cost-effective technical and proce-
dural options that will minimize waste
and pollution
Once each process is defined, the assess-
ment team should meet to discuss the
results. The purpose of this meeting should
be to identify possibLe P2 projects and to
target areas requiring further investigation.
For each potential project, the degree of
pollution reduction, cost, and process per-
formance should be documented to aid the
decision process. Relevant factors to con-
sider when evaluating a project include:
• The impact of the project on regula-
tory compliance
• How the project effects critical turn-
around times arid quality
• The actual reduction of pollutants the
project will achieve
• What resources will be required to
implement the project
• The economic implications of this
project
P2 projects that use source reduction con-
cepts (e.g.. raw material substitutions, in-
ventory control, equipment modifications,
and process changes) should be the labora-
tory’s top priority for implementation
where possible.
EPA facilities have numerous P2 projects
in progress. Many of these projects repre-
sent innovative approaches to P2. A sam-
ple of these projects is provided in Attach-
ment C9-l.
2.4 Prepare a P2 Plan
Executive Order 12856 requires all cov-
ered facilities to develop and implement
written P2 plans to ensure that the quantity
of toxic chemicals released into the envi-
ronment is reduced as quickly and effi-
ciently as possible through source reduc-
tion, recycling, etc. Each facility needs to
develop a plan to set goals and targets for
pollution reduction and P2 projects.
To maintain consistency across the
Agency, EPA laboratories should create
a plan that includes, at a minimum, the
elements described below:
• Purpose: Outlining the specific goals
of the laboratory and establishing a
link with the overall goals of the
Agency
• Mission: Describing the relationship
of the program to the laboratory’s
overall mission
• Roles and Responsibilities: Defining
the laboratory personnel’s roles and
responsibilities for fulfilling the objec-
tives of the plan (the team coordinator
should have responsibility for ensuring
implementation of the plan)
• Baseline: Establishing parameters
to be monitored
EPA June 1998
C9-5
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
• Summary of Ongoing and Planned
Initiatives: Identifying projects that
will achieve the laboratory’s goals
• Performance Metrics: Discussing the
methodology the laboratory will use to
track its progress against its goals
• Training: Addressing any training
planned to educate facility personnel
about P2 (this training may be aware-
ness training, training at the opera-
tional level, or training for select
groups)
The P2 plan represents the environmental
road map for reducing waste generation,
reducing worker exposure to hazardous
materials, protecting natural resources,
and minimizing environmental impacts
caused by facility operations. It should be
reviewed yearly and updated as necessary.
For further information on developing a P2
plan, consult EPA’s Facility Management
and Service Division (FMSD) Guidance
Manual for developing P2 plans. Copies of
all P2 plans completed by facilities are
available from SHEMD.
2.5 Establish Procurement Strategies
Under Executive Order 12873, each fed-
eral agency must establish goals and a plan
for eliminating or reducing the unneces-
sary acquisition of products containing
extremely hazardous substances or toxic
chemicals. This Executive Order recoin-
mends guidelines for federal agencies to
follow when detemtining which
environmentally-friendly substitutes to
purchase.
Executive Order 12873 defines these
“environmentally-preferable products
and services” as those that “have a lesser
or reduced effect on human health and the
environment when compared with compet-
ing products and services that serve the
same purpose.” EPA laboratories should
review purchasing and acquisition prac-
tices in order to maximize use of these
products and, in turn, minimize the
amount of waste generated by their
operations.
Laboratories should also refer to the
EPA’s final Comprehensive Procurement
Guideline (CPG) that designates 19 items
for priority use, based on their recovered-
material content. Laboratories should
choose these materials whenever possible,
and purchasing personnel should work
with the P2 coordinator to order smaller
amounts of chemicals.
Another successful component of procure-
ment strategy is the chemical adoption
program. Laboratories, facilities, or offices
enter information describing partially used
or excess products into a data-tracking
system. The system then posts the avail-
able products in an accessible location or
on a network. Organizations can access the
system to request products in the necessary
quantity instead of purchasing new materi-
als. Several EPA laboratories even require
written verification that the system was
checked before any new chemicals are
purchased. This system can significantly
reduce the amounts of chemicals requiring
disposal and it acts in tandem with a suc-
cessful procurement strategy.
&EPA June 1998
C9-6
-------
S}IEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
Although this system is primarily used by
laboratories requisitioning chemicals, the
process can be extended to include mainte-
nance cleaning supplies, surplus furniture,
or laboratory and office equipment.
2.6 Implement Strategies
After the laboratory calculates a baseline,
conducts opportunity assessments, pre-
pares a P2 plan, and develops procurement
strategies, it must implement the P2 pro-
jects it has selected. By developing a strat-
egy for program implementation, the
laboratory’s P2 coordinator can quickly
integrate P2 activities into the laboratory’s
daily operations. Strategies may include
technology transfer and employee training.
Technology transfer essentially involves
borrowing implementation techniques
from other laboratories and modifying
them to fit the needs of the target facility.
Information on similar programs can be
attained from other EPA facilities through
conferences, meetings, and training ses-
sions. Placing requests for information
sharing on bulletin boards or in newsletters
is another way of sharing technology.
Another strategy for implementing
P2 projects is through employee training.
Laboratories can create specific P2 train-
ing courses or they can modify existing
courses to include short segments on P2.
Existing courses in hazardous waste
minimization and hazard communication
provide good forums for providing P2 in-
formation. Also, the EPA Learning Insti-
tute offers a P2 awareness course for all
employees. The EPA SHEMD multimedia
library also offers a module on P2. An
adequately informed and trained workforce
will more readily integrate P2 initiatives
into daily operations at the laboratory.
3.0 Recycling
The Source Separation for Materials
Recovery Guidelines found in 40 CFR Part
246 require federal facilities to implement
recycling programs for high-grade paper,
newspaper, and corrugated cardboard if
they exceed the thresholds in Table C9-l.
Table C9-1: Thresholds for Implement-
ing Recycling Programs
Recycling
Material Program
Required if
High-grade paper
More than 100
office workers
Newspapers
\ 5i\
More than 500
families reside
Corrugated cardboard
More than 10 tons
per year gener-
ated
States have recently begun to require recy-
cling programs for non-hazardous waste
through such regulatory actions such as
banning certain wastes from landfills.
Regardless of regulation, federal facilities
r&EPA June 1998
C9-7
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
are encouraged to establish recycling pro-
grams to reduce disposal costs.
In addition to encouraging collection of
wastes for recycling, federal regulations
require the procurement of goods made
from recycled material, provided they are
equivalent in quality and price to goods
made from virgin stock. The categories of
products containing recycled materials
include building insulation products; ce-
ment and concrete that contains fly ash;
lubricating oils that contain re-refined oil;
paper and paper products; and retread tires.
In addition to the requirements identified
in Table C9-2, other solid waste manage-
ment regulations favor recycling over dis-
posal by providing, in some cases, regula-
tory relief. For example, certain used-oil
management techniques and some storage
practices for used lead-acid batteries are
exempt from hazardous waste regulations.
The following sections discuss the devel-
opment and implementation of a recycling
program.
Table C9.2: Recycling Regulations and Guidelines
3.1 Recycling Program
Factors critical in maximizing the effi-
ciency of a recycling program include:
• Defining a program that maximizes
recovery of recyclables and return on
program investment
• Optimizing the collection strategy
based on facility layout and targeted
recyclables
• Selecting target recyclables based on
economics and waste generation
• Communicating recycling results to
stakeholders
• Evaluating recycling program
performance and adjusting program
attributes
• Marketing collected materials to off-
set program costs
REUSE
REDUCE
RECYCLE
- ‘
-
Name
6901 et seq
Solid Waste Disposal Act, as amended by the Resource
Conservation and Recovery Act, as amended
Federal Acquisition, Recycling, and Waste Prevention
Guidelines for Source Separation for Materials Recovery
Guidelines for Procurement of Products That Contain Recycled
Material
EPA June 1998
C9-8
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
A commonly overlooked element of a suc-
cessful recycling program is the recycling
plan. A recycling plan should include the
elements summarized in Figure C9-2 and
discussed in the following sections.
3.1.1 Policy and Management
Commitment
It is important to have a clear policy that is
linked to the overall mission of the facility
as well as to federal requirements pertain-
ing to P2. Federal facilities have an advan-
tage over commercial concerns in that
there are a number of executive orders and
department directives that emphasize recy-
cling over disposal.
For example, Executive Order 12088 “P2
at Federal Facilities,” requires agencies to
prevent environmental pollution at their
facilities. Executive Order 12873 “Federal
Acquisition, Recycling, and Waste Preven-
tion,” broadens and strengthens the role of
the federal government in the procurement
of recycled and environmentally preferable
products.
Figure C9-2: Elements of a Recycling
Program
— Policy and Management
Commitment
— Goals and Objectives
— Resources
— Roles and Responsibilities
— Communication and
A ware ness
— Training
Program Eva’uation and
Oversight
The commitment of laboratory manage-
ment is necessary to demonstrate to all
employees that the recycling program is a
priority for the facility. Laboratory man-
agement commitment is typically demon-
strated through approval of the recycling
program plan as well as through involve-
ment in the communication of the plan.
For large facilities, integrating the labora-
tory management into an introductory
training video is a good method of demon-
strating commitment. For smaller facili-
ties, periodic memoranda from senior
management work well. One of the biggest
demonstrations of commitment from labo-
ratory management is allocation of re-
sources. Adequate funding is crucial to
prove to employees that a laboratory is
serious about recycling.
3.1.2 Goals and Objectives
The recycling program should set goals
and objectives that are easily evaluated.
Numerical recycling goals can be difficult
to evaluate if they are not expressed as a
percentage of total materials recovered.
One method of establishing numerical
goals and objectives for recycling involves
measuring performance against a baseline
year. The problem with this approach is
that changes to the laboratory’s mission
can dramatically affect the amount and
type of solid waste generated, rendering
any comparison to previous recycling per-
formance a meaningless exercise.
It can be more effective to express goals
and objectives in terms of more subjective
accomplishments. Some examples include:
• Complying with federal, state, and
local regulations and requirements
Recycling
Program
&EPA June 1998
C9-9
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C9. Pollution Prevention Program
• Fostering a philosophy to conserve
resources and minimize waste and
pollution
• Reducing the amount of waste requir-
ing disposal
Some laboratories have increased the suc-
cess of recycling programs by donating the
proceeds from material sales to a local
charity or employee activity fund. This
approach, while not the most attractive
from a revenue-generation standpoint, usu-
ally increases recovery of recyclables. It
can also be effectively applied to selected
materials in the solid waste stream. For
example, proceeds from aluminum can
sales could be donated to charity while
proceeds from office paper recycling
could be used to offset some costs of the
recycling program.
3.13 Resources
Resources necessary to administer the
recycling program include labor, equip-
ment, and supplies. The recycling program
plan should specify the program budget
and means of accounting. Large facilities
can establish discrete charge numbers for
recycling to allow accurate tracking of
resource use. Smaller facilities will need to
determine a means to track labor so that
the true cost of recycling can be calculated.
A typical federal facility draws resources
from its environmental or maintenance
organization to operate an effective recy-
cling program.
The most important equipment used in a
recycling program are the containers that
form the collection network. If the contain-
ers are convenient to use, then material
recovery will increase. For example, an
office paper recycling program with col-
lection bins in every office will be more
successful than one with a single bin in the
corridor. However, this increased conve-
nience also increases the cost of materials
and labor.
The material to be recycled dictates the
design of the collection system. Office
paper recycling is best accomplished with
small bins in individual
offices and larger bins
near photocopy machines
Maintenance or janitorial
personnel should periodically
empty the bins into a larger container for
ultimate transport to a central storage loca-
tion (e.g., a dumpster).
Collection bins for aluminum cans and
glass should be placed next to vending
machines and in break areas.
Pallets and corrugated cardboard are gen-
erally stockpiled in dumpster-sized con-
miners stationed near warehouses and
shipping/receiving areas. Some large facil-
ities use hydraulic compactors for these
materials to conserve space.
For collection networks, durable bright-
colored containers and labels are effective.
Labels are particularly important for office
paper programs due to the various grades
of office paper that must be sorted (e.g.,
GB C-bound, stapled, and glued reports;
glossy paper; color printing,
etc) For aluminum and glass
containers, a plastic trash bar-
rel with a hole cut in the center
provides an adequate and inex-
pensive collection receptacle
Plastic reusable containers can
be used for nickel-cadmium
&EPA June 1998
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CHAPTER C
Laboratory S1{E Programs
C9. Pollution Prevention Program
batteries and toner cartridges.
3.1.4 Roles and Responsibilities
The plan must clearly define roles and
responsibilities for administration and
implementation of the recycling program.
Roles and responsibilities should be
defined for the Laboratory Director, pro-
gram administrator, collection personnel,
and all employees.
The Laboratory Director should
review and approve the recycling
program plan; review program prog-
ress; commit and allocate the necessary
resources to effectively implement the
program; and assist with comniunicat-
ing and promoting awareness.
• The program administrator should
develop and maintain the recycling
program plan; implement the program
as specified in the plan; identify pro-
gram deficiencies and corrective
actions; evaluate recycling program
performance; and coordinate program
communications.
• Laboratory management should ensure
implementation of the recycling pro-
gram in laboratories under their
control.
• All employees should participate in the
recycling program and work to identify
opportunities to minimize the amount
of waste requiring disposal.
3.1.5 Communication and Awareness
There arc a number of ways to communi-
cate progress on recycling and to promote
participation and awareness. The conven-
tional way of communicating recycling
program progress is through regular fea-
tures in newsletters or bulletin board
postings. These features usually report the
quantity of material recycled, the amount
of money generated by the sale of recy-
clables, and comments on noteworthy as-
pects of the program. Some laboratories
track the amount of waste recycled within
each building and provide a small reward
or recognition for the building with the
highest recovery rate. Remember that the
goal of the communication program is to
increase recovery and sustain the recycling
program. Therefore, it is important to por-
tray these competitions in a way that does
not discourage recycling.
3.1.6 Training
SHE training for all personnel should pro-
vide an introduction to the recycling pro-
grain, thereby teaching a new employee
about the program.
Staff with additional responsibilities for
collecting and accumulating recyclables
should be instructed on what materials
should be removed from office paper recy-
cling bins (e.g., colored paper) before
dumping the bins into collection barrels or
dumpsters. Typically this training can be
integrated with existing training programs
as discussed in Chapter C3 of this manual.
3.1.7 Program Evaluation and
Oversight
This program element is important in fos-
tering continuous improvement. The pro-
gram administrator should track the types
and amounts of materials recycled and
maintain this information on a spreadsheet
to allow analysis and presentation of the
data. Quarterly progress reports are sent
to laboratory management. Articles in
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CHAFrER C
Laboratory SHE Programs
C9. Pollution Prevention Program
newsletters or posted on bulletin boards
should also be issued quarterly. Useful
statistics to present graphically include
the amount of each material reàycled and
a total recycling rate for the current quar-
ter, year to date, and a comparison to pre-
vious years.
In addition to quantifying recovery rates,
it is important to obtain feedback from
employees. The recycling program
administrator should periodically survey
selected individuals to identify possible
areas for program improvement. Janitorial
staff can often identify whether the collec-
tion system is effective in ensuring appro-
priate recyclable quality.
3.2 Procurement of Recycled Materials
The EPA has established requirements for
procuring products containing recycled
materials. EPA laboratories must require
that vendors:
• Certify that the percentage of
recovered materials to be used in
performing the contract is at least
the amount required by applicable
specifications or other contractual
requirement
• Estimate the percentage of recovered
materials used for the performance of
the contract
EPA laboratories are required to establish
a program to purchase items containing
recovered materials to the maximum ex-
tent practicable. The program must contain
the following four elements:
• Preference programs for purchasing
designated items
• Promotion program
• Procedures for obtaining estimates and
certifications of recovered material
content and for verifying the estimates
and certifications
• Annual review and monitoring of the
effectiveness of the program
Individual laboratories are encouraged to
coordinate this effort with the EPA SHEM
Division to promote consistency and shar-
ing of lessons learned.
4.0 Energy Conservation
By investing in energy-efficient techniques
to heat or cool a building, heat and circu-
late water, operate lights, run appliances,
and run ventilation fans and motors, EPA
laboratories can save both energy and
money. Energy conservation requires a
total-systems approach. The requirements
for energy conservation at federal facilities
(as well as guidelines for meeting these
requirements) are set forth in Executive
Order 12902.
4.1 Reduction Coals
By practicing energy conservation tech-
niques, EPA laboratories can cut costs
and assist the Agency in reaching its goals
of reducing consumption. Reducing con-
sumption can help achieve the following
Agency goals as set forth in Executive
Order 12902:
• Reduction of energy consumption by
30 percent by the year 2005
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C9. Pollution Prevention Program
• Increase of energy efficiency by at
least 20 percent by the year 2005
• increase of the use of solar and other
renewable energy sources
The executive order also requires agencies
to develop and implement programs to
reduce the use of petroleum by switching
to less-polluting non-petroleum-based
energy sources, such as natural gas or solar
energy sources. Where alternative sources
are not practical, agencies are required to
strive towards improving the efficiency of
systems that currently use petroleum.
4.2 Programs for Energy Conservation
In order to reach the goals of the executive
order, EPA must develop a program to
introduce cost-effective and energy effi-
cient technologies into its facilities.
By conducting surveys and audits, a labo-
ratory can determine the effectiveness of
energy conservation improvements and
target new areas where improvements can
be made. Each federal facility must have a
10-year plan to conduct or obtain compre-
hensive facility audits. These audits should
also include a review of the energy conser-
vation program in order to assess areas for
energy conservation.
4.3 Guidelines for Facility
Construction and Leasing
New facilities should be designed and con-
structed to meet or exceed any applicable
energy conservation standards. The life-
cycle cost of the facility can be conserved
by using energy-efficient technologies.
New facilities should adopt active solar
technologies whenever they are cost-
effective.
When leasing facilities, the energy con-
sumption of the facility and any provisions
that will minimize the cost of energy
should be identified, while maintaining
or improving occupant safety and health.
Negotiations on the cost of the lease
should consider the reduced energy costs
during the term of the lease.
4.4 Reporting Requirements
Laboratories should maintain all wiitten
programs, records, and documentation to
confirm that the requirements of Executive
Order 12902 are being met. This informa-
tion must be available upon request.
4.5 Implementing Energy Conservation
Techniques
There are many techniques that laborato-
ries can apply to reduce energy consump-
tion. These techniques include:
• Gaining employee involvement
• Using energy efficient equipment
• Implementing energy management
techniques
• Instituting best-practice technologies
4.5.1 Employee Involvement
Laboratories should strive to involve
employees and management in energy
conservation programs. Useful techniques
for gaining commitment and involvement
include:
• Forming an energy team to help edu-
cate and motivate fellow employees
• Offering incentives for the best energy-
saving strategy
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• Reporting to employees how much
energy costs decreased through their
efforts
Energy teams, or environmental project
teams, are useful in implementing energy
efficiency. The Department of Energy
offers training and support to help project
teams develop expertise in energy savings.
4.5.2 Energy Efficient Equipment
Laboratories may also consider other
energy-saving techniques. For example,
they may ask electric utilities
about rebates for energy-
efficient lighting equipment.
Motors are often oversized for
jobs and can be replaced with
smaller motors that use less energy. Office
and laboratory equipment can often be
replaced with equipment that runs more
efficiently.
4.5.3 Energy Management Techniques
There are many specific techniques for
energy-management that can be applied to
reduce the amount of energy used in an
EPA laboratory. These techniques fall un-
der three categories: cooling, heating, and
water heating, as discussed below.
Cooling
Ensure air condition-
ers are the proper
size for areas being
cooled. (Regular
maintenance, includ-
ing a filter check,
ensures efficient operation).
• Verify that windows are closed while
air conditioning is in
operation.
• Use automatic thermostats to adjust
temperatures during off-work hours.
• Use drapes, shades, and awnings to
reduce cooling costs by shielding win-
dows from the hot sun.
• Install energy-efficient windows to
help keep cool air in and hot air out
during summer months.
Heating
• Install energy-efficient windows to
help prevent warm air from escaping.
• Insulate walls, ceilings, and floors to
retain heat within the building.
• Caulk or weather-strip cracks in walls,
floors, windows, and doors to avoid
heat loss.
• Allow sunlight to enter
laboratories by opening
curtains, blinds, and
shades. These should be
re-closed during off-
hours (evenings) to help retain heat.
Water Heating
• Lower the temperature of the water
heater on weekends and holidays.
• Insulate water-heating systems and
pipes to maintain warmth.
• Immediately repair leaks in pipes or
faucets to conserve energy.
• If more than one boiler is used to
heat the same area, sequence the boil-
ers so only one is used when half the
heating capacity is needed.
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4.5.4 Best-Practice Technologies
in accordance with Department of Energy
guidelines, all federal agencies must strive
to purchase approved energy-efficient
products. The guidelines that can be used
specify practices to increase energy
efficiency in federal agencies. Lists of en-
ergy efficient products are updated annu-
ally and agencies must increase, to the ex-
tent possible, purchases that are in the up-
per 25 percent of energy efficiency for all
similar products, or products that are at
least 10 percent more efficient that the
minimum level that meets federal stan-
dards.
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Attachment C9-1: Example P2 Projects
Purpose: To provide a sample of P2 projects for EPA laboratories.
Instructions: Compare current P2 program projects to the list to determine if there are
additional P2 opportunities for the laboratory.
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Attachment C9-1: Example P2 Projects
Facility
Example of P2 Projects
Laboratory
• Control sample sizes
• Practice pH neutralization
• Increase laboratory automation and implement new extraction
techniques
• Implement microanalytical techniques to reduce chemical
quantities
• Replace chemical-based methods with physical methods
• Implement solid-phase extraction and high-pressure extraction
practices to reduce amount of solvent purchased, used, and dis-
posed of
• Develop individual chambers to reduce gases used in inhalation
techniques
• Improve ventilation controls with fume hoods, biological safety
cabinets, and clean benches
• Eliminate excess ordering of animals
Offices and
Regional Centers
• Compost lunch waste and coffee grounds
• Substitute vinyl siding for wooden siding to reduce painting
Field
Activity
• Send only required amount of analytes for analysis
• Use biodegradable soap to clean field equipment
Aft Facilities
• Establish a heat reclamation process to harness the incinerator’s
excess energy for heating water
• Landscape with indigenous plants, use mechanical means of
weed control, use beetle bags instead of insecticide, use environ-
mentally benign fertilizers, and increase mulching to decrease
water use
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1.0 Introduction
This chapter presents air quality regula-
tions that may be applicable to an EPA
laboratory assuming that it is not a “major
source” of air pollutants. However, an
EPA laboratory may still be subject to
other regulatory requirements based on the
air emissions sources present and/or the
types of air emissions that they produce.
EPA Program Requirements
To ensure that it meets the applicable reg-
ulatory requirements, an EPA laboratory
must consider whether, based on its design
and operation, it is subject to the require-
ments for air quality outlined in this chap-
ter relative to:
• Steam-generating units
• Radionucide emissions
• Federal operating permit program
• Ozone-depleting substances
• Asbestos
Program Adminutration
To effectively manage an air quality pro-
gram, an EPA laboratory should assign
responsibility for the following items, as
applicable:
Management of Change
• Assessing the regulatory implications
of changes in laboratory design and/or
operation
• Tracking changes to regulatory
requirements that could potentially
affect a laboratory
Permitting and Permit Requirements
• Ensuring that air emissions sources are
permitted as required by governing
regulatory requirements
• Ensuring compliance with the require-
ments established in the laboratory’s
air permit(s)
Air Emissions Monitoring
Monitoring quantities of nitrogen oxides,
sulfur dioxide, particulate matter, and
radionuclides.
Recordkeeping and Reporting
• Establishing and maintaining a
recordkecping system for information
required by the governing regulations
and/or air permit(s)
• Preparing and submitting notifications
and report(s) to the EPA, as required
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2.0 Management Systems
An EPA laboratory should thoroughly
assess the actual and potential impacts that
its air emissions have on the environment.
Therefore, it can ensure that it does not
allow the release of a substance in an
amount, concentration, level, or rate of
release that causes, or may cause, an
exceedance of established air emission
limitations and/or a significant adverse
effect on the environment. In order to
completely understand and effectively
manage its air quality program, an EPA
laboratory should perform an air emissions
inventory, design programs and practices
to control or minimize air emissions and
perform air emissions prevention. Each are
discussed in the following sectthns.
2.1 Air Emissions Inventory
Each EPA laboratory should perform an
air emissions inventory. This involves pre-
paring and maintaining a comprehensive
listing of actual and potential air emissions
(e.g., fume hoods, local vent pipes and
stacks, drains) that includes the sources
and locations of emission points, as well
as analytical data characterizing the nature
and volume of emissions. Sufficient docu-
mentation (i.e., process or equipment in-
formation) should be maintained so that
the applicability of air permit requirements
can be made. This determination should be
made through the regulatory review pro-
cess where the applicability of federal and
state requirements is assessed.
2.2 Program and Practice Design
EPA laboratories should design and imple-
ment programs and practices for control-
ling and minimizing air emissions. This
should include the full range of laboratory
operations generating air emissions, such
as sampling, equipment maintenance,
start-up, and shutdown. Where feasible,
the laboratory should consider establishing
a program to apply appropriate technology
(e.g., installation of air pollution control
equipment on laboratory hoods, carbon
canisters) to minimize or reduce the effects
from emissions that cannot be otherwise
eliminated.
2.3 Air Emissions Prevention
EPA laboratories can eliminate or reduce
air emissions from their operations by con-
sidering emission control during process
change, change of process scale, or modi-
fication of engineering controls.
3.0 Regulatory Requirements
This section addresses the regulatory
requirements that are likely to apply to an
EPA laboratory. There may be additional
requirements that apply based on the na-
ture of its processes, operations, etc. These
requirements should be identified through
a management of change process. In
addition, this section addresses the EPA’s
proposal to regulate hazardous air pollut-
ant (HAP) emissions from major research
and development sources.
3.1 Federal Regulations
An EPA laboratory is not likely to be con-
sidered a “major source” of air pollution
under the governing federal regulations
based on its potential to emit less than
100 tons per year of a regulated pollutant.
Therefore, it would not be subject to Pre-
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ClO. Air Quality Program
vention of Significant Deterioration (PSD)
or New Source Review (NSR) require-
ments. However, other federal regulatory
programs that are potentially applicable to
an EPA laboratory are summarized in Fig-
ure Cl 0-1 and discussed in the following
sections.
NSPS
The New Source Performance Standards
(NSPS) in 40 CFR 60 establish require-
ments for new stationary sources of air
pollution according to industry or emission
source (e.g., steam generating units). This
program is discussed in greater detail in
section 4.0 of this chapter.
NESHAPs
The National Emission Standards for Ha.z-
ardous Air Pollutants (NESHAPs) in 40
CFR 61 contains requirements governing
emissions of specific pollutants (e.g.,
radionuclides, asbestos), regardless of
source, process, or industry. These stan-
dards apply to both existing and new
sources. This program is addressed in
greater detail in section 5.0 of this chapter.
Specific requirements related to asbestos
are addressed in section 8.0 of this chapter.
Operating Permit Program
The operating permit program established
under Title V of the 1990 Clean Air Act
Amendments in 40 CFR 70 and 71 applies
to major sources, as well as sources that
are subject to NSPS or NESHAPs. This
program is addressed in section 6.0 of this
chapter.
Protection of Stratospheric Ozone
Program
The Protection of Stratospheric Ozone
Program established under 40 CFR 82 fo-
cuses on banning nonresidential uses
of chlorofluorocarbons (CFCs), labeling
containers that store Class I and II ozone-
depleting substances, and certifying indi-
viduals who perform work on systems and
equipment that contain CFCs. This pro-
gram is addressed in section 7.0 of this
chapter.
Even though all of the programs are fed-
eral programs, many states have been dele-
gated regulatory authority for these pro-
grams by the EPA.
3.2 State and Local Regulations
In addition to the federal requirements,
many states have established air-emission
source requirements that may affect an
EPA laboratory (e.g., permitting, state haz-
ardous air pollutant inventory, and regis-
tration requirements). As such, an EPA
laboratory should determine whether there
are additional state and/or local require-
ments that may apply to its sources.
3.3 Proposed Regulations
The EPA has submitted a proposal to regu-
late HAP emissions from major research
and development sources. As stated previ-
ously, an EPA laboratory is not likely to be
considered a major source. However,
based on the potential regulatory implica-
tions, an EPA laboratory should track the
status of the EPA’s proposal. The advance
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ClO. Air Quality Program
Figure C10-1: Summary of the Applicable Air Emissions Regulations
Protection of
Stratospheric Ozone
Program
notice of proposed rulemaking was pub-
lished in the May 12, 1997 Federal Regis-
ter. Possible regulatory requirements asso-
ciated with EPA’s proposal include:
Maintaining records of chemical
usage, inventory, and emissions for
individual laboratories
• Installing air pollution control equip-
ment on laboratory hoods
• Modifying laboratory procedures to
minimize emissions
• Developing and implementing plans
to reduce the usage of target chemi-
cals (i.e., HAPs)
4.0 Steam Generating Units
A steam generating unit is an example of
an air emissions source that may be pres-
ent at an EPA laboratory. This section dis-
cusses the applicable regulatory require-
ments for the management of steam gener-
ating units.
4.1 Description of Steam Generating
Units
There are three types of steam generating
units that are discussed in the following
sections: Subpart Db Units, Subpart A
Units, and Subpart Dc Units.
4.1.1 Subpart Db Units
A steam generating unit for which con-
struction, modification, or reconstruction
commenced after June 19, 1984, that has
a heat input capacity from fuels combusted
in the unit of greater than 29 megawatts
(i.e., 100 million British thermal units
[ Btu] per hour) is subject to NSPS,
Subpart Db “Standards of Performance for
lndustria l—Commercial-lnstitutional
Steam Generating Units.”
4.1.2 Subpart A Units
Steam generating units that meet the
criteria of Subpart Db are also subject to
NSPS, Subpart A “General Provisions.”
This subpart includes specific require
FederaL Air
NSPS
Sulfur dioxide
Particulate matter
Ninogen oxide
• Asbestos
Radionuclides
‘—CFCs
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ments relative to notifications; record-
keeping and reporting; monitoring; perfor-
mance tests; and control devices. It also
addresses more general information per-
taining to defrnjtions, modification and
reconstruction, and compliance with stan-
dards and maintenance requests.
4.1.3 Subpart Dc Steam Generating
Units
A small steam generating unit for which
construction, modification, or reconstruc-
tion commenced after June 9, 1989,
that has a maximum design heat input
capacity of 29 megawatts or less, but
greater than or equal to 2.9 megawatts
(i.e., 10 million Btu per hour) is subject to
NSPS, Subpart Dc, “Standards of Perfor-
mance for Small Industrial-Commercial-
Institutional Steam Generating Units.”
4.2 Sulfur Dioxide Emissions
Standards for sulfur dioxide emissions are
set forth in 40 CFR 60.42b. Sulfur dioxide
emission limitations vary based on the date
of construction of the unit, the pollution
control devices in place, and the fuel mix-
ture. Affected EPA laboratories should
determine if the emission limitations that
apply to them.
4.2.1 Subpart Db Units
In the absence of such variations, sulfur
dioxide emissions must be less than 10
percent of the potential sulfur dioxide
emission rate, and less than the combined
calculated emissions from the combustion
of coal and oil for the Subpart Db units.
The sulfur dioxide emission limitation
for coal is 1.2 pounds per million Btu
(lbs/MMBtu) and for oil is 0.8 lbs/
MMBtu.
Note that only the heat input supplied to
the unit from the combustion of coal and
oil is counted. No credit is given for the
heat input from the combustion of natural
gas, wood, municipal-type solid waste, or
other fuels, or heat input from exhaust
gases from other sources such as gas tur-
bines, kilns, etc. This standard applies to
the unit during all phases of operation (i.e.,
startup, shutdown, etc.).
4.2.2 Subpart Dc Units
Sulfur dioxide emissions for a unit that
burns only coal, such as Dc units, must be
less than 10 percent of the potential sulfur
dioxide emission rate, and less than 1.2 lb/
MMBtu.
4.3 Particulate Matter Emissions
Particulate matter emission limits vary
according to the fuel used. Table C 10-I
presents the limits for particulate emis-
sions from Subpart Db units that burn
coal; oil or mixtures of oil with other fu-
els; and wood or mixtures of wood with
other fuels (except coal). Table C 10-2
presents limits for Subpart Dc Units.
The particulate matter and opacity stan-
dards apply at all times, except during pe-
riods of startup, shutdown, or malfunction.
The annual capacity factor is determined
by dividing the actual heat input to the unit
during the calendar year from the combus-
tion of coal, wood, or other fuels, as appli-
cable, by the potential heat input to the
unit if the unit had been operated for 8,760
hours at the maximum design heat input
capacity.
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4.4 Nitrogen Oxide Emissions
Standards for nitrogen oxide emissions
that pertain to Subpart Db units are set
forth in 40 CFR 60.44b. Nitrogen oxide
emission limitations vary based on the fuel
mixture. An affected EPA laboratory
should ascertain the emission limitations
that specifically apply to it.
4.5 Emission Monitoring
Emission monitoring requirements vary
depending on the size of the unit and,
in some cases, the governing state regula-
tory requirements. Some EPA laboratories
may be allowed to calculate emissions
based on process data and emission factors
while others must install and maintain
Table C1O-1: Limits for Particulate Emissions from Subpart Db Units
Fuel
Heat Input
( lb/MMRtu)
Discussion
Coal-fired
units
0.05
If the unit burns only coal, or if the unit burns coal and other fuels and has
an annual capacity factor for the other fuels of 10 percent or less.
0.10
If the unit burns coal and other fuels and has an annual capacity factor for
the other fuels greater than 10 percent, and is subject to a federally en-
forceable requirement (limiting operation of the unit to an annual capacity
factor greater than 10 percent for fuels other than coal)
0.20
If construction of the unit commenced after June 19, 1984, and before
November 25, 1986, and the unit burns coal or coal and other fuels and
has: 1) an annual capacity factor for coal or coal and other fuels of 30
percent or less; 2) a maximum heat input capacity of 250 MMBw/hr or
less; and 3) a federally enforceable requirement limiting operation of the
unit to an annual capacity factor of 30 percent or less for coal or coal and
other solid fuels.
Oil or mix-
tures of oil
with other
fuels
0.10
None
Wood or mix-
tures of wood
with other
fuels (except
coal)
0.10
If the unit has an annual wood capacity factor greater than 30 percent
0.20
If the unit: I) has an annual capacity factor for wood of 30 percent or less;
2) is subject to a federally enforceable requirement limiting operation of
the unit to an annual wood capacity factor of 30 percent or less; and 3) has
a maximum heat input capacity of 250 MMBtu/hr or less.
Coal, oil,
wood, or mix-
tures of these
fuels with any
other fuels
c20 percent
opacity
(6-minute
average)
Except for one 6-minute period per hour of not more than 27 percent
opacity.
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Table C1O-2: Limits for Particulate Emissions from Subpart Dc Units
Fuel
Heat Input
(lb/MMBtu)
Discussion
Coal-fired
units that have
a heat input
capacity of 30
MMBtu/hror
greater
0.05
If the unit burns only coal, crlf the unit burns coal aith other fuels and has
an annual capacity factor for the other fuels of 10 percent or less.
0.10
If the unit combusts coal with other fuels, has an annual capacity factor for
the other fuels greater than 10 percent. and is subject to a federally en-
forceable requirement limiting operation of the unit to an annual capacity
factor greater than 10 percent for fuels other than coal.
Wood or mix-
turns of wood
with ocher
fuels (except
coal) that
have a heat
input capacity
of 30
MMBtU/hr or
greater
0.10
If the unit has an annual wood capacity factor that is greater than 30
percent, or 0.30 lb/MMBtu heat input if the unit has an annual wood
capacity factor of 30 percent or less and is subject to a federally enforce-
able requirement limiting operation of the unit to an annual capacity factor
for wood of 30 percent or less.
Coal, wood,
or oil that
have a heat
Input capacity
of 30
MMBtu/hr or
greater
<20 percent
opacity
(6-minute
average)
Except for one 6-minute period per hour of not more than 27 percent
opacity.
continuous emissions monitoring systems
(CEMS). As such, an EPA laboratory’s air
permit should provide more detailed guid-
ance regarding the emission monitoring
requirements specifically applicable to the
unit.
4.6 Reporting and Recordkeeping
The following sections discuss reporting
and recordkeeping requirements for steam
generating units.
4.6.1 Subpart Db Units
An EPA laboratory with unit(s) that are
subject to Subpart Db is also subject to
the NSPS, Subpart A “General Provi-
sions.” This subpart includes specific
requirements relative to notification;
recordkeeping and reporting; monitoring;
performance tests; and control devices.
An EPA laboratory with unit(s) subject to
Subpart Db should provide the following
information to the EPA:
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• The date of con siruction within 30
days after such date
• The anticipated date of initial startup
between 30 to 60 days prior to such
date
• The actual date of initial startup
within 15 days after such date
EPA laboratories must maintain records
of the amounts of each type of fuel burned
during each day. Also the annual capacity
factor must be calculated individually for
coal, distillate oil, residual oil, natural gas,
wood, and municipal-type solid waste for
each calendar quarter. The annual-capacity
factor is determined on a 12-month rolling
avenge basis with a new annual-capacity
factor calculated at the end of each calen-
dar month.
Records of fuel nitrogen content and nitro-
gen oxide emissions are required for cer-
tain units. Excess emissions reports are
required and must be submitted semiannu-
ally or for every calendar quarter and
include information required under 40
CFR 60.7(c), such as:
• The magnitude of excess emissions
• The date and time period of each
excess emissions event
• The nature and cause of each malfunc-
tion leading to excess emissions, and
the corrective actions taken
• The date and time that the CEMS was
not operating
In general, an EPA laboratory should
retain any process data that is required to
demonstrate compliance with established
emission limits.
4.6.2 Subpart Dc Units
An EPA laboratory with unit(s) subject to
Subpart Dc should provide the following
information to the EPA:
• Date of construction within 30 days
after such date
• Anticipated date of initial startup be-
tween 30 to 60 days prior to such date
• Actual date of initial startup within 15
days after such date
• Design heat input capacity
• Fuels to be burned
• Any federally enforceable requirement
that limits the annual capacity factor
for any fuel or mixture of fuels
• Annual capacity factor at which the
owner or operator anticipates operat-
ing the affected facility
An EPA laboratory that has a unit subject
to the sulfur dioxide emission limits under
40 CFR 60.42c, or the particulate matter or
opacity limits under 40 CFR 60.43c, shall
submit the performance test data from the
initial (and any subsequent) performance
tests and, if applicable, the performance
evaluation of the CEMS to the EPA.
Laboratories that have a coal-fired, resid-
ual oil-fired, or wood-fired unit subject to
the opacity limits under 40 CFR 60.43(c)
shall submit excess-emission reports to
the EPA for any calendar quarter for which
there are excess emissions. If there are no
excess emissions during the calendar quar-
ter, the owner or operator shall submit a
report semiannually stating that no excess
emissions occurred during the semiannual
reporting period. The time frames for
reporting are listed as follows:
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• The initial quarterly report must be
postmarked by the 30th day of the
third month following the completion
of the initial performance test, unless
no excess emissions occur during that
quarter.
• The initial semiannual report must
be postmarked by the 30th day of the
sixth month following the completion
of the initial performance test, or fol-
lowing the date of the previous quar-
terly report, as applicable.
• Each subsequent quarterly or semi-
annual report must be postmarked by
the 30th day following the end of the
reporting period.
• An EPA laboratory that has a unit
subject to the sulfur dioxide emission
limits, fuel oil sulfur limits, or
percentage-reduction requirements
under 40 CFR 60.43c shall:
— Submit quarterly reports to the
EPA. (The initial quarterly report
shall be postmarked by the 30th
day of the third month following
the completion of the initial per-
formance test. Each subsequent
quarterly report shall be post-
marked by the 30th day following
the end of the reporting period.)
— Keep the required records and
submit quarterly reports as speci-
fied in this section.
• An EPA laboratory should also record
and maintain records of the amounts
and types of fuel burned during each
day.
In general, an EPA laboratory should
retain any process data that is required
to demonstrate compliance with estab-
lished emission limitations.
5.0 Radionuclide Emissions
In general, radionucide emissions are reg-
ulated by the Nuclear Regulatory Commis-
sion (NRC) or NRC Agreement State.
Emissions specific to the laboratory may
be listed in a laboratory’s NRC radioactive
materials license, if an EPA laboratory
does not have an NRC license, then its
radionuclide emissions are subject to
NESHAPs, 40 CFR 61, Subpart!,
“National Emission Standards for Radio-
nuclide Emissions from Federal Facilities
Other than Nuclear Regulatory Conunis-
sion Licensees and Not Covered by
Subpart H.”
5.1 Emission Limits
Emissions of radionuclides, excluding
iodine, into the ambient air must not
exceed those amounts that would cause
any member of the public to receive in
any year an effective dose equivalent of
10 millirem per year. Emissions of iodine
to the ambient air from a facility regulated
under this subpart shall not exceed those
amounts that would cause any member
of the public to receive in any year an
effective dose equivalent of 3 millirem.
5.2 Monitoring
Compliance with the emission standard
must be determined with either the EPA
computer model COMPLY or alternative
requirements in 40 CFR 61, Appendix E
that requires an inventory of radioactive
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materials. Facilities emitting radionuclides
not listed in COMPLY or Appendix E
shall contact the EPA to receive the infor-
mation needed to determine the dose.
Facilities may demonstrate compliance
with the emission standard through the use
of computer models that are equivalent to
COMPLY, provided that the model has
received prior approval from EPA head-
quarters. Any facility using a model other
than COMPLY must file an annual report.
The EPA may approve an alternative
model in whole or in part and may limit its
use to specific circumstances.
53 Reporting
An annual report to the EPA is required
covering the radionudide emissions of a
calendar year by March 31 of the follow-
ing year. It must include the following in-
formation:
• The name of the facility
• The name of the person responsible
for operating the facility and the name
of the person preparing the report (if
different)
• The location of the facility, including
suite and/or building number, street,
city, county, state, and zip code
• The mailing address of the facility, if
different from the facility location
• A list of the radioactive materials used
at the facility
• A description of radioactive materials
handling and processing at the facility
• A list of the stacks, vents, or other
points where radioactive materials are
released into the atmosphere
• A description of the effluent controls
that are used on each stack, vent, or
other release point and an estimate of
the efficiency of each device
• Distances from the point of release to
the nearest residence, school, busi-
ness, or office, and the nearest farms
producing vegetables, milk, and meat
• The effective dose equivalent calcu-
lated using the COMPLY model
• The physical form and quantity of
each radionuclide emitted from each
stack, vent, or other release point, and
the method(s) by which these quanti-
ties were determined
• The volumetric flow, diameter, efflu-
ent temperature, and release height for
each stack, vent or other release point
where radioactive materials are emit-
ted, and the method(s) by which these
were determined
• The height and width of each building
from which radionuclides are emitted
• The values used for all other user-
supplied input parameters (e.g., mete-
orological data) and the source of the
data
• A brief description of all construction
and modifications that were com-
pleted in the calendar year for which
the report is prepared, but for which
the requirement to apply for approval
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to construct or modify was waived
under 40 CFR 61.106. and associated
documentation developed by the li-
censee to support the waiver
Each report must be signed and dated by
a corporate officer or public official in
charge of the faciLity and contain the fol-
lowing declaration immediately above the
signature line:
Facilities emitting radionucLides in an
amount that would cause less than 10 per-
cent of the dose standard are exempt from
the reporting requirements. Facilities must
annually determine whether they are ex-
empt from reporting.
5.4 Recordkeeping
EPA laboratories must keep records that
document the source of input parameters,
including the results of all measurements
on which they are based, the calculations
and/or analytical methods used to derive
values for input parameters, and the proce-
dure used to determine compliance. This
documentation should be sufficient to
allow an independent auditor to verify
the accuracy of the determination made
concerning the facility’s compliance with
the standard, and, if claimed, qualification
for exemption from reporting. These
records must be kept at the site of the
facility for at least five years and must
be made available for inspection upon
request.
6.0 Federal Operating Permit Program
The Federal Operating Permit Program
established under Title V of the 1990
Clean Air Act Amendments in 40 CFR
70 and 71 applies to major sources, as
well as sources that are not major sources
but are subject to certain subparts of the
NSPS or NESHAPs regulations. However,
an EPA laboratory that is subject to any of
the NSPS or NESHAPs subparts addressed
above is required to be considered in the
Title V permit program. This program will
be administered either by the EPA, via the
regulations established in 40 CFR 71, or
a state agency that has been delegated
authority for the program by the EPA,
via the state air permittinE regulations.
7.0 Ozone-Depleting Substances
An EPA laboratory that has processes or
equipment that contain CFCs should:
• Compile and maintain a sitewide
inventory of CFCs used in the labora-
tory’s air conditioning and refrigera-
tion systems and other processes.
• Maintain records to demonstrate
that personnel, including contractors,
who perform maintenance on the
laboratory’s air conditioning and re-
“1 certify, under penalty of law, that 1
have personally examined and am
familiar with the information submit-
ted herein and, based on my inquiiy of
those individuals immediately respon-
sible for obtaining the information, I
believe that the submitted information
is true, accurate, and complete. I am
aware that there are significant penal-
ties for submitting false information,
including the possibility of fine and
imprisonment.”
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frigeration systems have been trained
and certified to perform this work,
and, if applicable, that they
use certified recycling and recovery
equipment.
• Maintain records related to certified
refrigerant recycling equipment, for at
least three years, that include the
name and address of any facility to
which refrigerant is sent.
• For equipment containing 50 pounds
or more of refrigerant, maintain ser-
vice records for at least three years,
that document the date and time of
service as well as the quantity of
refrigerant added, or, in cases where
the EPA laboratory adds its own
refrigerant, records of the refrigerant
purchased.
8.0 Asbestos
Specific asbestos activities are subject
to NESHAPs, 40 CFR 61, Subpart M,
“National Emission Standard for Asbes-
tos.” The federal standards governing
asbestos activities (e.g.. manufacturing,
demolition and renovation, spraying, fabri-
cating, and insulating) that may pertain to
an EPA laboratory are in 40 CFR 61.140
through 61.148. Jf an EPA laboratory en-
gages in any of these activities, it should
refer to the regulatory requirements speci-
fied in 40 CFR 61.150 through 61.153 that
address waste disposal, air cleaning, and
reporting. Refer to Chapter C14 of this
manual for more information on waste
management.
An EPA laboratory that meets the criteria
of Subpart M is also subject to NESHAPs,
40 CFR 61, Subpart A, “General Provi-
sions.” This subpart includes specific
requirements relative to notifications,
monitoring, and emission tests, and also
addresses more general information per-
taining to definitions, construction or mod-
ification, and compliance with standards
and maintenance requests.
&ER June 1998
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EPCRA Program
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laboratory SHE Programs
Cli. EPCRA Program
1.0 Introduction
The Emergency Planning and Community
Right-To-Know Act (EPCRA) was
designed to inform emergency planners
and the public of potential chemical haz-
ards. The regulations were developed to
provide the following information about
hazardous chemicals or extremely hazard-
ous substances:
• The quantity of regulated chemicals at
the laboratory
• The specific hazards presented by the
chemicals
• The fate of chemicals (i.e., used, dis-
charged, sold, etc.)
• Any unplanned releases
Under the emergency planning provisions,
state emergency response commissions,
and local emergency planning committees
(LEPCs) must be established. These
authorities are mandated to develop and
implement plans for responding to emer-
gencies. Laboratories subject to the emer-
gency planning provisions are required
to inform the state and local emergency
response authorities that extremely hazard-
ous substances are on-site. They must
also work with the LEPC on planning
for emergencies.
The regulations require a variety of re-
ports, which are discussed in this chapter:
• Tier LlTier II Reporting
• Release Reporting
• Toxic Release Inventory Reporting
• Material Safety Data Sheets
EPA Program Requirements
To ensure that reporting requirements of
EPCRA are met, EPA laboratories must
evaluate the mandates for applicability of:
• Tier I /Tier II Reporting
• Release Reporting
• Toxic Release Inventory Reporting
• Material Safety Data Sheets
Program Administration
To effectively manage an EPCRA pro-
gram, responsibilities should be assigned
for the following:
Tier Iflier 11 Reporting
• Identifying all chemicals regulated
under EPCRA, with average as well
as maximum amounts on-site
• Determining if any reporting thresh-
olds have been exceeded
• Submitting required reports
Release Reporting
• Filing appropriate reports for any
release of toxic substance(s)
• Notifying community emergency coor-
dinators in areas that may be affected
by a release
• Providing a follow-up notice if an
emergency notice has been filed
Toxic Release Inventory (TRI) Reporting
• Determining if TRI reporting is appli-
cable to the laboratory
• Determining and documenting the
amount of regulated toxic substance(s)
in air and water effluents, waste, and
byproducts
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SHEMP Operations Manual for Laboratories
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• Developing and maintaining required
records
• Filing reports to the EPA when
necessary
Material Safety Data Sheets (MSDSs)
• Determining if MSDSs for the hazard-
ous chemicals on-site must be submit-
ted to local agencies
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CII. EPCRA Program
2.0 Tier I/Tier II Reporting
Figure Cli -1 provides a summary of the
Tier I and Tier II inventory form submis-
sion determination process as required by
40 CFR 370.20.
A Tier I form requires a certification
statement, information on the maximum
amount of chemicals at the laboratory
during the year, the daily average amount
on-site, number of days on-site, and
information on hazard type and storage
location for all chemicals subject to the
requirements.
The Tier U inventory reporting form con-
tains more detailed information on hazard-
ous chemicals and extremely hazardous
substances. Figure Cl 1-2 provides a sum-
mary of the information required on both
the Tier I and Tier II forms. EPA laborato-
ries may complete the simpler Tier I form,
unless the EPA or state agencies request a
Tier II form.
Emergency planning agencies may request
information for hazardous chemicals that
may occur on-site below the reporting
thresholds.
Each EPA laboratory should identify all
of the chemicals on-site that are regulated
under EPCRA and maintain a detailed
inventory of the average and maximum
amounts present. The items presented in
Table C 11-1 are exempt from hazardous-
chemical reporting requirements of 40
CFR 370.20.
At the end of the year, laboratories must
examine the inventory and determine if
any of the reporting thresholds have been
exceeded. The basis for the decisions
should be documented and maintained
with supporting documentation.
Figure Cli - !: Tier I and II Inventory Form Submission
Hazardous Chemicals
10,000 pounds
(>4,540 kilograms)
Tier I or II Form
Must Be
Submitted If There
are. .
L
Extremely Hazardous
Substances
> 500 pounds
(>227 kilograms)
or
> 55-gallons
Or
Threshold Planning
Quanti y*
*(whichever is lower)
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SHEMP Operations Manual for Laboratories
CHAPTER C
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Figure C11-2: Summary of Infonnation Required on Inventory Reporting Forms
Information Required on I
Tier l Tierli
— Certification statement — Maximum amount of chemicals
in each hazard category at the
— Maximum amount of chemicals at laboratory during the year
the laboratory during the Y — Average daily amount of chemi-
— Number of days chemicals cals in each category on-site
on-site — Physical and health hazards
associated with the chemical
— Hazard type and storage location
for all chemicals subject 10 Storage location of all chemicals
requirements in each category
— Number of days chemicals are
on-Site
Table Cu-i: Items That Are Exempt From Hazardous-Chemical Reporting
Requirements
Item
Description
HAZCOM-Excluded
Substances
Substances excluded from the coverage of the OSHA Hazard
Communication Standard (HAZCOM)
FDA-Regulated
Substances
Any food or food-color additive, drug, or cosmetic regulated by
the Food and Drug Administration (FDA)
Articles
Substances present as a solid in any manufactured item as long as
exposure to the substance does not occur under normal conditions
of use (e.g., asbestos insulation and polychlonnated biphenyls
[ PCBsJ in transformers)
Household Products
Substances used for personal, family, or household purposes or
present in the same form and concentration as products packaged
for distribution and use by the general public
Research Laboratory
Substances
Substances used in a research laboratory, hospital, or under the
direct supervision of a technically qualified individual
Agricultural
Substances
Substances used in routine agricultural operations, or fertilizers
held by a retailer for sale to the ultimate customer
&EPA June1998 CIl-4
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The Tier I/li reporting forms are available
from the EPA. Examples of the forms are
included in Attachment Cu-I. The labora-
tory must submit an inventory form to the
Agency, the committee, and the fire de-
partnient with jurisdiction over the labora-
tory before March 1 of the following year.
The laboratory must allow on-site inspec-
tion upon request of the fire department
having jurisdiction over the laboratory,
and must provide the location of hazard-
ous chemicals at the laboratory to the de-
partment.
3.0 Release Reporting
This section applies to any laboratory
where a hazardous chemical is produced,
used, or stored and at which there is a
release of a reportable quantity of any ex-
tremely hazardous substance listed in 40
CFR 355 or any hazardous substance as
defined in 40 CFR 302.
This section does not apply to:
• Any release that is continuous and sta-
ble in quantity and rate under the defi-
nitions in 40 CFR 302.8(b)
• Any release that results in exposure to
persons solely within the boundaries
of the laboratory
• Any release that is a “federally permit-
ted release” as defined in section 101
(10) of the Comprehensive Environ-
mental Response, Compensation, and
Liability Act (CERCLA)
If the laboratory experiences a release of
a toxic substance, a report should be filed
immediately, even if the amount of the
release is undetermined. The notification
can be retracted later if investigations
show that the release is below the report-
ing threshold. Figure C11-3 summarizes
the notification of emergency officials.
The notice must include the following
information to the extent known at the
time of notice and provided that no delay
in notice or emergency response results:
• The chemical name or identity of any
substance involved in the release
• An indication of whether the sub-
stance is an extremely hazardous sub-
stance
• An estimate of the quantity of the sub-
stance that was released into the envi-
ronment
• The time and duration of the release
• The medium or media into which the
release occurred
• Any known or anticipated acute or
chronic health risks associated with
the emergency and, where appropriate,
advice regarding medical attention
necessary for exposed individuals
• Proper precautions to take as a result
of the release, including evacuation,
unless this information is readily
available to the LEPC
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Figure C 11-3: Toxic Substance Release Notification
File Report Immediately
4 ,
Provide Information
On Any Areas Likely
to Be Affected by the
Release to...
Cli. EPCRA Program
ConlTntmlty Response
Coordinator for LEPC
or
Relevant Local
Emergency Response
Personnel
Provide Follow-Up Notice(s) to
Update information
State Emergency
Response Commission
• The names and telephone number of
the person or persons to be contacted
for further information
The laboratory must then provide a written
follow-up notice(s), as soon as possible.
These follow-ups update the information
required in the notice and include addi-
tional information on:
• Actions taken to respond to, and con-
tain, the release
• Any known or anticipated acute or
chronic health risks associated with
the release
• Advice regarding medical attention
necessary for exposed individuals,
where appropriate
4.0 TRI Reporting
A laboratory that meets all of the follow-
ing criteria for a calendar year is a covered
laboratory for that calendar year and must
comply with TRI reporting requirements in
40 CFR 372:
The laboratory has 10 or more full-
time employees
• The laboratory is in Standard Indus-
trial Classification Codes 20 through
39.
• The laboratory manufactured,
imported, processed, or otherwise
used a toxic chemical in excess of an
applicable threshold quantity of that
chemical
Thresholds for reporting are as follows:
a For a toxic chemical manufactured
(including imported) or processed at
a laboratory—25,000 pounds of the
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Cli. EPCRA Program
chemical manufactured or processed
for the year
• For a chemical otherwise used at a
laboratory—lO,000 pounds of the
chemical used for the applicable cal-
endar year
EPA laboratories may qualify for an
exemption for TRI reporting.-If a toxic
chemical is manufactured, processed, or
used in a laboratory under the supervision
of a technically qualified individual, the
quantity of the particular chemical does
not have to be considered when determin-
ing whether an applicable threshold has
been met, or in determining the amount of
release to be reported.
This exemption does not apply in the fol-
lowing cases:
• Specialty chemical production
• Manufacture, processing, or use of
toxic chemicals in pilot plant—scale
operations, where the product is dis-
tributed into commerce (that is, if the
pilot plant is solely for research and
development, then the laboratory
exemption still applies)
• Activities conducted outside the
laboratory
If the laboratory does not qualify for this
exemption, then it should evaluate the
applicability of other exemptions (e.g.,
de minimus, articles, uses) by refemng
to 40 CFR 372.38.
The TRI regulations can be viewed as
a mass balance for all hazardous and
extremely hazardous substances manufac-
tured, processed, or otherwise used by the
laboratory. Thus it is important to docu-
ment the amount of a regulated toxic sub-
stance in air and water effluents, waste,
and byproducts. The regulations do not
specify minimum requirements for data
accuracy but it is sometimes necessary to
sample effluents to determine the amount
of material emitted through any given
pathway.
The laboratory must develop and maintain
the documentation listed in Table Cl 1-2
for three years.
For each toxic chemical manufactured,
imported, processed, or otherwise used in
excess of an applicable threshold quantity,
the laboratory must file a completed EPA
Form R (EPA Form 9350-1) in accordance
with the instructions referred to in 40 CFR
372, Subpart E. An example of EPA Form
R is included in Attachment Cl 1-2. Note
that, in the case of mixtures of toxic chem-
icals with other chemicals, only the
amount of the toxic chemical present in
the mixture needs to be included.
The report must be submitted on or before
July 1 of the followIng year.
5.0 Material Safety Data Sheets
The following requirements apply to any
facility required to p or have avail-
able an MSDS for a hazardous chemical
under the Occupational Safety and Health
Act (OSHA) of 1970 and regulations pro-
mulgated under that Act. Each laboratory
must identify, and submit an MSDS for,
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Table C11-2: Till Documentation
TEl Documentation Required to be Developed and Maintained
the following substance:
• All extremely hazardous substances
present at the laboratory at any one
time in amounts greater than, or equal
to, 500 pounds or the threshold plan-
ning quantity (TPQ) listed in the Ap-
pendix to 40 CFR 355, whichever is
less (An excerpt from this Appendix is
included as Attachment ClI-3 to this
manual)
• All hazardous chemicals (for which
MSDSs are required) present at the
laboratory at any one time in an
amount greater than or equal to 10,000
pounds.
MSDSs for hazardous chemicals present at
the laboratory above the applicable thresh-
old must be submitted to the LEPC, the
state emergency response commission, and
the fire department with jurisdiction over
the facility.
Alternatively, the laboratory may submit
the following:
• A list of the hazardous chemicals for
which MSDSs are required, grouped by
hazard category
• The chemical or common name of each
hazardous chemical as provided on the
MSDS
• Any hazardous component of each haz-
ardous chemical as provided on
the MSDS
• A revised MSDS to the committee, the
commission, and the fire department
within three months after discovery of
new information on the chemical
• TRI reports submitted and supporting documentation
• Detennination that laboratory is a covered facility
• Documentation of an allowable exemption
• Determination of whether a threshold under $372.25 applies for each toxic chemical
• Calculation of the quantity of each toxic chemical released to the environment or
transferred to an off-site location
• Supporting information for use indications and quantity on-site reporting for each
toxic chemical (e.g., dates of manufacture, processing, or use)
• Basis for estimate used in developing any release or off-site transfer estimates for each
toxic chemical
• Receipts or manifests associated with the transfer to off-site locations of each toxic
chemical in waste
• Estimates of waste treatment efficiency for each toxic chemical such as: reported
waste treatment methods, estimates of treatment efficiencies, ranges of influent
concentration to such treatment, sequential nature of treatment steps, and actual
operating data
a
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cl i -1: Sample Tier I/ I l Forms
Purpose: To provide an example of Tier 1/il inventory reporting forms.
Instructions: Obtain the appropriate form from the EPA and submit it to the Agency, the
committee, and the fire department with jurisdiction over the laboratory.
SEPA June1998 C11-9
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EM DENCY
At40
HAZARDOUS
CHEMICAL
INVENTORY
I —
b Civmw&
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II
R
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cl 1-2: Sample EPA Form R
Purpose: To provide an example of EPA Form R, which serves as a report of the
laboratory’s toxic chemicals manufactured, processed, or used in excess of
threshold quantities.
Instructions: Obtain the form from the EPA, and complete it in accordance with 40 CFR
372, Subpart E.
jEP4 June1998 C11-13
-------
-
t FA FORM R TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
United States Section 313 ol the Emergency Planning and Community
Environmental election Rtght-to4(now Act Of 1986, also known as Title III of the Supeifund
Agency Amendments and Reauthonzatcn Act
II EnherXflereIImIsi
WHERETO SEP 10 COMPLETED FORMS: 1 X k ’9 APPRomIAI! STATE OF CE isa revision
PO& A3 3 4 6 ISwcalt35wsh ceClzF)
ATTN 1 HEk0 L RELEASE I VENTQRY FcI EPA
Msntaa .VA 22116.33iB
IMPORTANT: See insiniclions to determine when Not Applicable (NA)” boxes should be checked.
PART L FACILITY IDEPITIFICXTION INFORMATION
SECTION 1. REPORTiNG YEAR 19 —
SECTION 2. TRADE SECRET INFORMATION
1 iey ij ciciming in. toxic chemical ld&flThSd ca psgo2t,adi SICISI? I :- , Q 0 Unsinltlzsd
zi Yes (Aniwu, quesdon o No Do not insww 2.2; 2.2
I Attach ssths n2isIIOn go to SactIon 3 (Anwuer only 8 YES In 2.1)
I fomlal
SECTION 3. CERTIFICATION (impoitint: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and thai, to the best of my knowledge and beliet, the
submitted information is true end complete and that the amounts and values in this report are accurate based on
reasonable estimates using data available to the preparers of thus report
risea. of i l Ie of ni ......,....4 of 5 nis
SECTION 4. FACILITY IDENTIFICATION
fFaeeyaIE.* h 0 .4I4sre I
.chtcr & iicisrsd Natie or Mails Ad&e$s (if otlemit foci tInot aeleast I
i J
MailgAniessl
nWDrWThcod
wfoSW ce I
42
IicSIioOtonSIISSIIOITISIIO ifDI Mew s
aea . , 1We es aeb,d ’nicuipplcabIe) a 0 I 0 PatoIs 0
4 ,3
“
Tscts*slctlwss
lreiemem NaSIer I c e area de1 I
I
ITeleliac. t (I aiA eec d .1 I
I
46
NC Cede(s) (4 N I I . I I
wu D e e visas Seisisis
Latitude Len tude
4?
Dun & Bredatreet
Numbsi(e)(9d Ia)
EPA Identification Iluanb.r(s) Facility NPVES Psmiit
48 (R RALD.Noj(l2cliimctjts g ijm s(scharictess)
UuIditWnUAd IflIection Will Cods
410 (UIC)LO.Nimiber(s)(t2dIglta)
a
a a
a
it
b. it
it
SECTION 5. PARENT COMPANY INFORMATION
. —
5.2
NameolPatmnICcl1 any I
Parent Company’s Dun A Biadstreet Ninniter NA J (9dtssj
Foss Aptisiod OMBNarfler 50700093
(IMPORTANT T$se or pit . read Thstnictptrs befopt owijifetinp form) Appmvil Espires 093000
Page 1 of ti
EPAFonI1 93501 (R . 041971. p eni.ss50 5 iie i*ie
-------
Page 2 of 5
I I u i .i cmI OI )
. —. —— —.
fl —v
ThI FAOLJTYIDMJ SER
EPA FORM K
PART II. CHEMICAL- SPECIFIC INFORMATION Ta*Ct.n i. Caieqoiy. o,G i10cN ye
SECTION 1 TOXIC CHEMICAL IDEN1TTY (Impo.tlnI Do iioy coinplut. ihi suctian II you
Coinpistsd Sictlon S bIb ..)
SECTION 2. MIXTURE COMPONENT (bnpcdant: CO NOT compu IIU• suction ii you
conipt.to Suction I ovs)
Gsuuric Ox ncuI Ns Pio . sd by (t. uoxt MIsuun 0170 Ui. ruvesn. 11001 e,
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY (b .,..JbIh. Chuck ill that iptyj
3.1 J Manufacture the toxic chainlcil:
3.2 Pre sas the toxic chemlc .J:
3.3 foatun’ti.. ui. the toxic otienilcab
a. Produce b. llnpofl
• As a reactant
b. As a formulation component
a. As an artide component
d. Repackaging
As a chemical processing aid
b. As a manufacturing aid
c. Ancillary or other use
0 oiodteo oi imnoit
C For On-site use/processing
d. For sale/disinbution
.. c: As a byproduct
I. As an impurity
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME DURING THE
CALENDAR YEAR
4.1 [
I I (Enter two-digit code from instruction paCkage.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
I Teal Polish (pmr .afl( .her
i.gs Wmhe%doisarlckIalel
[ s.
(ereeroithi
c. %FmII
!
Fugitive or non-point
ai i st
5 2
Slack or point o
aIr emissions
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
Underground Injection on-site
to Class I Wells NA
Underground Injection on-site
54.2 to Class Il-V Wells NA
If addItional pages of Part U, Section 5.3 are attached, Indicate the total number of pages In thIs box
and IndIcate whIch Part II, Section 5.3 page thIs Is, here (example: 1,2,3. etc.)
EPA FOITO g350-l (Rev 0457)- Prescue editions ale obsolete
RangeCodes AnI.l0pO8.ll -499pCUnd Cn50O.999 OiJUb
-------
Page 3 of 5
1 FAWTY m -S R
EPA FORM R
PART ii. CHEMICAL..SPEC IFIC INFORMATION (CONTINUED)
SECTIONS. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
A. TQ I RNais (pounds# eaz) (enter rwi 5. BasIs c( EstImate
NA de from rns bons orestmala) (e nte r code)
5-
Disposal to bnd on site
5.5.1A
RCRASubtitleClandfilis
0
5.5.15
Other landfills
0
5.5.2
Land treatment/application
farming
—
5.5.3
Surface inipoundment
0
5.5.4
Other disposal
0
SECTIONS. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF.SITE LOCATIONS
6.1 DISCNAROES TO PUBLICLY OWNED TREATMENT WORKS (POTWa)
6.1.A. Total Quantity Transferred to POTWs and Basis of Estimate
6.1 .A.I.Totat Transfers (pounds/year) 6.1.A.2 Basis of Estimate
(enter range code or estimate) (enter code)
IpoiwNa m
6.1.5. —
P01W Address
City J State J Countyj I I
as
6.1.5. —
P01W Address
City State County I I
If additional pages of Part II, Section 6.1 are attached, Indicate the total number of pages
In this box I I and indicate which Part fl, Section 8.1 page thIs Is here I 1 (example: 1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OThER OFF-SITE LOCATIONS
62 ........OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
Off-Site Location Namef
Ott-Site Address
City State County J Zip
Is location under control of reporting facility or parent company? Yes No
EPA Form 9350-t tR, ’ GUS?)- Pseveus edema eve b5Cl.te
Rar ecodes 1- 1bpoin . B it -4t9pcwtde. C 500- S SSpo.mds.
-------
..___ A _A S
EPA FORM A
PART IL CHEMICAL-SPECIFIC INFORMATION (CONTINUED) T F1 JY M&OER
— A..?s
SECTION 6.2 TRANSFERI
TO OTHER OFF-SITE LOCATiONS (con iued)
. TcSI 1 w i lpau eaI)
escreal ca .eri5e)
B hea
4 4 )
1 IF4q (e4er e}
1.
1
IN
2
2.
2M
3
3.
3M
•
4
4 .M
6.2 — OFF-SITE EPA IDENTIFICATION NUMBER (ACRA ID NO.)!
Off-Silo L.ocaton Name
Oil-Site Address
cityJ fstatej countyJ 1z o 1
Is location under control of reporting facility or parent company? Yes ( J No
A. TsstTi.st.s bont i.)
(s!eer n oreaiese1
LB 6
(stera
C.Ty WI TPIS NIUD IpISIV
1a, d.)
1.
1.
1.M
2.
2.
2.M
3.
3.
3.M
4.
4.
4.M
SECTION 7& ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (NA) - Check here If no on-site waste treatment Is applied to any
waste stream cont .InInaIho IpvIe chemical or hemlcaicatneory.
a Ou ii
w— . 8 W Tiesrel IWedCs) Sacom
U1W 3 dWIaV (I)j
c. a.gs.nneai
1ji
a wst.i es
a B edm
Opst*ç0aa’
TAle
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II —I I
Si 1 7 j
J
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7A.ld
TA le
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7A2a
‘
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6! 171
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1
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51 I
1
7A.2c
7A.2d
?A.2e
y
c 0
7A.3a
1
a
I I ij
I
1
J
2
B
T
7A .3d
7A .3o
%
Y i
Do
TA.4a
1 2
141 I s
I. al
7A.4c
TA.4d
IA.4.
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y
D 0
.5a
7A-Sb I 2
31 1 I
61 171 1 SI I
7A.5c
7A.5d
7A.5e
,
E] c::i
II additional pages of Part II, Sections 6.217A are attached, Indicate the total number of pages In this
box and IndIcate which Part II, Sections 6.217A page thIs Is, here. (example: 12.3. etc.)
EPA FOrD 93504 (Rev OS 7) - Previous edbais axe obsolete Raxige Code As 1.10 pounds, Bl1- 499 poimds Cs 500- 999 pounds
-------
pee. SOt S
R FAcLWf MJ 5an
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) (_VeCCII.W C L Ca .uar. otO tome
SECTION 70. ON-ORE ENERGY RECOVERY PROCESSES
D Not Applicable (NA). Check her. I i no on-site energy recovery is epplied to any waste
efream containing the toxic chemical or chemical catsgory.
Energy RecOverY Methods entev 3d a,act.i code ($)
ii 121 1 3 [ 1 41 I
SEC11ON7C OP4SI1E RECYCLING PROCESSES
D Not applicable (NA)- Check here If o on-situ recycling Is applied to any waste
stream containing the toxic chamical or chemical category.
Recycling Me (erder3charscter code(a))
I 21 I 31 141 151
81 I 71 I at I 9! I tot
SECTION 8. SOURCE REDUCTION AND RECYCLING
ACTIVITIES
All quantity utlniafoc can hecapwfed
using i p to rev significant figures
us o
B
‘
Coeam c
‘, ‘
C.Uiu D
5 ei uP Yur
sT
Quantity
Quantity used for esorgy recovery
‘n-aft.
8.3
Quantity used for energy recovsry
Quantity recycled on-sit.
8.5
Quantity recycled off-site
es
Quantity bested on-site
8.8
Quantity Vested off-el.
Quantity r.laassd to the snvlronmant isa sult of iwselal actions.
cntaitrophic events, or one-time event. not associated with production
(poun ear)
8.9
Production ratio or activity index
S . IO
Did your facility engage In any source reduction activities for this chemical during the reportIng year? It not,
snterHA In SectIon 8.10.1 end answersectlon 8.11.
Source Reduction Activities
[ enter code(s)]
Methods to Idoniwy Activity (eider codes)
8. 10.11
a.
b.
C.
8.10.2
a.
b.
r.
a.
b.
c.
8.104
a.
b.
C.
8.11
is edditiocal optional information on sowue reduction, recycling, or pollution control activIties ] NO
indudid with this report? (Chock on. box) 1=1
• Report releases pulsuate to EPCRA SectIon 329(8) IncludIng any rpliing, iealdng, pumping, pouring, emitting, empt 4ng, dIscharging,
miocting, eacapu%g. leaching, dumping, or disposing into the eriwoiiment. Do nol include any quantity treated on.site or olf.slte.
EPA Fore 9 0•1 (Rev. 04191)- Francis adOrns are starlet.
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cl 1-3: Excerpt from 40 CFR 355 Appendix A
Purpose: To demonstrate threshold planning quantities (TPQs) for extremely
hazardous substances.
Instructions: Consult this list to determine threshold quantities for reporting hazardous
materials to regulatory agencies.
6EPA June1998 C11-19
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cl 1-3: Excerpt from 40 CFR 355 Appendix A
Appendix A: The List of Extremely fl Mous Substances and Their Threshold Plpnning Quantities
Appendix A to Part 355—The List of Extremely Hazardous Substances
and Their Threshold Planning Quantifies
CAS
Number
Chemical Name
Notes
Reportable
Quanlity*
(pounds)
Threshold
Plnnnlng
Quantity
(pounds)
75-86-5
Acetone Cyanohydrin
10
1,000
1752-30-3
Acetone Thiosemicarbazide
1,000
1,000/10,000
107-02-8
Acrolein
1
500
79-06-1
Acrylamide
1
5,000
1,000/10,000
107-13-1
Acrylonitrile
1
100
10,000
814-68-6
Acrylyl Chloride
h
100
100
111-69-3
Adiponmile
1
1,000
1,000
116-06-3
Aldicarb
c
1
100/10,000
309-00-2
Aidrin
1
500/10,000
107-18-6
Allyl Alcohol
100
1,000
107-11-9
Allylamine
500
500
20859-73-8
Aluminum Phosphide
b
100
500
54-62-6
Aminopterin
500
500/10,000
78-53-5
Anüton
500
500
3734-97-2
Ainiton Oxalate
100
100/10,000
7664-41-7
Ammonia
1
100
500
300-62-9
Amphetamine
1,000
1,000
62-53-3
Aniline
1
5,000
1,000
88-05-1
Aniline, 2,4, 6-Trimethyl
500
500
7783-70-2
Antimony Pentafluoride
500
500
1397-94-0
Anumycin A
c
1,000
1,000/10,000
86-88-4
ANTU
100
500/10,000
1303-28-2
Arsenic Pentoxide
1
100/10,000
1327-53-3
Arsenous Oxide
h
1
100/10,000
&EPA June 1998
Cl 1-20
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cl 1-3: Excerpt from 40 CFR 355 Appendix A
CAS
Number
Chemical Name
Notes
Reportable
Quantfty*
(pounds)
Threshold
Planning
Quantity
(pounds)
7784-34-I
Arsenous Trichloride
1
500
7784-42-1
Arsine
100
100
2642-71-9
Azinphos-Ethyl
100
100/10,000
86-50-0
Azinphos-Methyl
I
10/10,000
98-87-3
Benzal Chloride
_____
5,000
500
98-16-8
Benzenamine, 3-(Trifluoromethyl)
500
500
100-14-1
Benzene, I-(Cliloromethyl)-4-Niuo
500
500/10,000
98-05-5
Benzenearsonic Acid
10
10110,000
3615.21-2
Benzimidazole, 4, 5-Dichloro-2-(Trifluoromethyl)
g
500
500/10,000
98-07-7
Beezotrichioride
10
100
100-44-7
Benzyl Chloride
100
500
140-294
Benzyl Cyanide
h
500
500
15271-41-7
Bicyclo [ 2 2.1] }Ieptane-2-Carbonitrile, 5-Chloro-6-
(Methylanñno, Carbonyl, Oxy lniino,-ls-1-alpha,
2-beta, 4-alpha, 5-alpha, 6E)
500
500/10,000
534-07-6
Bis (Chioromethyl) Ketone
10
10/10,000
4044-65-9
Bitoscanate
500
500/10,000
10294-34-5
Boron Trichloride
500
500
7637-07-2
Boron Trifluoride
500
500
353-42-4
Boron Tri±luoride Compound with Methyl Ether
(1:1)
1,000
1,000
28772-56-7
Broinadiolone
100
100/10,000
7726-95-6
Bromine
1
500
500
1306-19-0
Cadmium Oxide
100
100/10,000
2223-93-0
Cadmium Stearate
c
1,000
1,000/10,000
7778-44-1
Calcium Arsenate
1
500/10,000
8001-35-2
Camphechlor
1
500/10,000
56-25-7
Cantharidin
100
100/10,000
&EPA June1998 C1l-21
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment Cli -3: Excerpt from 40 CFR 355 Appendix A
CAS
Number
Chemical Name
Notes
Reportable
Quantity*
(pounds)
Threshold
Planning
Quantity
(pounds)
5 1-83-2
Carbachol Chloride
500
500/10,000
26419-73-8
Carbamic Acid, Methyl-, O-(2, 4-Dimethyl-1, 3-
Dithiolan.2-yI Methylene Amino)
d
1
100/10,000
1563-66-2
Carbofuran
10
10/10,000
75-15-0
Carbon Disulfide
1
100
10,000
786-19-6
Carbophenothion
500
500
57-74-9
Chlordane
I
I ,ooo
470-90-6
Chiorfenvinfos
500
500
7782-50-5
Chlorine
10
100
24934-91-6
Chiormephos
500
500
999-81-5
Chlonnequat Chloride
h
100
100/10,000
79-11-8
Chloroacenc Acid
100
100/10,000
107-07-3
Chloroethanol
500
500
627-11-2
Chloroethyl Chloroformate
1,000
1,000
67-66-3
Chloroform
I
10
10,000
542-88-1
Chloromethyl Ether
h
10
100
107-30-2
Chloromethy] Methyl Ether
C
10
100
3691-35-8
Chlorophacinone
100
100/10,000
1982-47-4
Chloroxuron
500
500 1 10,000
Only the statutory or final RQ is shown. For more mfonnauon. see 40 CFR Table 3014.
Notes:
a.
b.
C.
d.
C.
1.
8•
h.
J.
k.
L
This cheuucai does not meet acute toxicity criteria. Its 1YQ is set at 10.000 pounds.
This material is a reactive solid. The 11’Q does not default to 10,000 pounds for nonpowder, noninolten, nonsolution form.
The calculated ‘TPQ changed after technical review as described in the technical support document.
Indicates that the RQ is subject to change when the assessment of potential carcinogenicity and/or other toxicity is completed.
Statutory reportable quantity for purposes of notification under SARA section 304(a)(2).
Reserved.
New chemicals added that were not pan of the original list of 402 substances.
Revised TPQ based on new crre.evaluated toxicity data.
1PQ is revised to its calculated value and does not change due to technical review as in proposed rule.
The TPQ was revised after proposal due to calculation error.
Chemicals on the original list that do not meet toxicity cliterra but because of their high production volume and recognized toxicity are
considered chemicals of conoern COther Chemicals”)
&EPA June 1998
Cl 1-22
-------
C12.
Wastewater Program
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C12. Wastewater Program
1.0 Introduction
This chapter discusses wastewater regula-
tions that may apply to an EPA laboratory.
During both normal and experimental
operations, a variety of wastewater will be
generated. This wastewater can be a source
of pollution if it contains contaminants
(e.g., metals, radionuclides) or exhibits
potentially hazardous properties (e.g.,
acidity, temperature). Therefore, an EPA
laboratory should characterize its waste-
water before discharging it directly into a
navigable waterway or into a publicly-
owned treatment works (PO1’W), to
determine whether any restrictions on its
discharge apply. The sections in this chap-
ter address the federal regulations that
govern wastewater discharges.
• Monitoring wastewater discharges
for prohibited pollutants
• Reporting requirements
Program Administration
To effectively manage a wastewater
program, an EPA laboratory should
assign responsibility for the following
items, as applicable:
Management of Change
• Assessing the regulatory implica-
tions of changes in laboratory
design and/or operation
• Tracking changes to regulatory
requirements that could affect the
laboratory
EPA Program Requirements
To ensure that it meets the applicable fed-
eral regulatory requirements, an EPA labo-
ratory must consider whether, based on its
design and operation, it is subject to the
following requirements for water pollution
control:
• The National Pollutant Discharge
Elimination System (NPDES) Pro-
gram for wastewater discharges and
point-source discharges into a naviga-
ble waterway
• A pretreatment/POTW program for
point-source discharges to a POTW
• Operating and maintaining wastewater
systems
Permitting and Permit Requirements
• Ensuring that wastewater
discharges are permitted as
required by governing regula-
tory requirements
• Ensuring compliance with the
requirements established in the
laboratory’s wastewater discharge
permit(s)
Wastewater System Maintenance
• Ensuring that appropriate
wastewater system measures
(e.g., treatment and/or control)
are in place, and that they are
operating effectively
Wastewater Discharge Monitoring
• Monitoring quantities of pollutants
in wastewater discharges
&EPA June 1998
C12-I
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs C12. Wastewater Program
Recordkeeping and Reporiing
Establishing and maintaining a rec-
ordkeeping system for information
required by the governing regulations
and/or wastewater discharge permit(s)
Preparing and submitting, as required,
notifications and report(s) to the EPA
&EPA June 1998 C 12-2
-------
SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C12. Wastewater Program
2.0 Management Systems
An EPA laboratory should assess the
actual and potential impacts that its
wastewater discharges have on the envi-
ronment. The release of a pollutant in an
amount, concentration, level, or rate of
release that causes, or may cause, an
exceedance of established wastewater dis-
charge limit and/or a significant adverse
effect on the environment must not be
allowed. To completely understand and
effectively manage its wastewater pro-
graIn, an EPA laboratory should consider
implementing management systems as
described in the following sections.
2.1 Wastewater Discharge Inventory
EPA laboratories should maintain a
comprehensive listing of wastewater
discharges that includes the sources and
Locations of the discharges, as well as ana-
lytical data characterizing the nature and
volume of the discharges. Consideration
should be given to the following:
Points where normal or unusual dis-
charges of wastewater or contaminated
surface water leave or may leave the
boundary of the laboratory (e.g., floor
and sink drains, discharge outfall
pipes)
• Manufacturing operations, domestic
wastewater, noncontact cooling water,
etc., that contribute to the laboratory’s
effluent
• Contaminant contributions to the labo-
ratory’s effluent, such as manufactur-
ing/storage area runoff, dredge and fill
solids, drainage water, leachates, sep-
tic tank discharge areas, wastewater
treatment plant effluent, lagoons,
surface impoundments, and process
wastewater
Points where flow from adjacent
property or surface water runoff
may affect the quality of the labora-
tory’s effluent
[ Note: An EPA laboratory should
also maintain sufficient documenta-
tion (i.e., process or equipment
information) to help determine the
applicability of wastewater dis-
charge permit requirements.)
2.2 Programs and Practices
EPA laboratories should design and
implement programs and practices
for controlling and minimizing waste-
water discharges during the full range
of operations. Where feasible, the labo-
ratory should consider establishing a
program to apply appropriate technol-
ogy to minimize or reduce the effects
from discharges that cannot otherwise
be eliminated (e.g., the installation of
acid neutralization chip tanks, contami-
nant recovery units, collection sumps).
23 Wastewater Discharge
Prevention
EPA laboratories should establish a pro-
gram to reduce or eliminate wastewater
discharges from its operations and/or
consider discharge prevention objec-
tives in the design of new or modified
facilities and processes.
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3.0 Regulatory Applicability
3.2 PretreatmentlPOTW
Depending on its design and operations,
an EPA laboratory that has wastewater or
stormwater discharges may be subject to
the permit programs as described in the
following sections. Many states have
wastewater discharge legislation and regu-
lations that require permitting similar to
the NPDES Program (i.e., these states have
been delegated authority by the EPA to
administer the NPDES Program). How-
ever, this is not always the case. Some
states have chosen not to administer the
NPDES Program, and instead issue a state
permit; however, this does not preclude
participation in the federal NPDES Pro-
gram. As a result, an EPA laboratory
located in such a state would have two
permits. Local agencies may also develop
enforceable limit on wastewater discharges
to POTWs for items such as pH, tempera-
tore, and concentrations of various con-
taminants.
3.1 NPDES
NPDES is the primary regulatory program
governing wastewater discharges. The
fundamental concept of this program is
that a facility may not discharge pollutants
to the navigable waters of the United
States without a permit. The NPDES Pro-
gram regulates “point source” wastewater
discharges from various sources directly
into a navigable waterway, including
wastewaters from industrial and commer-
cial sources and POTWs. To obtain an
NPDES permit, an EPA laboratory must
complete a permit application.
Industrial and commercial facilities and
POTWs that receive off-site wastewater
are usually required to develop and
implement a pretreatment program that
regulates the characteristics of the influ-
ent that they receive. It is likely that an
EPA laboratory that sends out any con-
taminants in lab packs, and/or dis-
charges directly to the sanitary sewer
system, would be subject to these
requirements.
3.3 Stormwater
Under 40 CFR 122.26, the EPA
requires NPDES permits for specific
types of stormwater discharges. Those
categories that could potentially apply
to an EPA laboratory include discharges
associated with an “industrial activity”
as defined in the governing regulations;
discharges having NPDES permits
issued as of February 1987; and any
other discharges deemed by the EPA to
“contribute to a violation of a water
quality standard or is a significant
contributor of pollutants to water of the
United States.” Refer to section 8.0 of
this chapter for more information on
storrnwater.
4.0 Permit and Program
Requirements
An NPDES permit is required if the
laboratory discharges treated or
untreated wastewater into a navigable
waterway (i.e., surface water). If an
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EPA laboratory discharges treated or
untreated wastewater to a POTW, it
must receive approval from the POTW
under the POTW’s Pretreatment Program.
To obtain a permit, an EPA laboratory
must prepare and submit an application
to the EPA and/or state environmental
agency that contains information pertain-
ing to the laboratory’s discharges, sources
of contaminants, flow rates, treatment pro-
cesses, etc. The responsible agency will
then act on the application by preparing a
draft permit for public comment prior to
issuing the final permit.
In general, NPDES permits contain the
specific effluent limits designated by the
regulatory agency as necessary to protect
surface water quality (e.g., pH, tempera-
tare, flow, oil and grease, ammonia,
biological oxygen demand [ BOD], total
suspended solids [ TSS]). However, an
EPA laboratory should also review the
“Effluent Guidelines” established in 40
CFR 403 through 471 to identify possible
applicable requirements not explicitly
identified in the laboratory’s permit(s).
NPDES permits typically include the fol-
lowing general conditions (refer to 40 CFR
122.41):
• Operation and maintenance
• Monitoring and recordkeeping
• Planned changes
• Noncompliance
• Bypass condition
• Upset condition
An EPA laboratory that is covered by an
NPDES permit, or equivalent, must com-
ply with all of the conditions of the permit.
Any pennit noncompliance constitutes a
violation of the Clean Water Act, and may
result in an enforcement action; termi-
nation, revocation, and reissuance of
the permit; modification of the permit;
and/or denial of a permit renewal
application.
4.1 Operation and Maintenance
An EPA laboratory’s systems of treat-
ment and/or control that are necessary
to achieve compliance with the condi-
tions of its permit must be properly
operated and maintained. Proper opera-
tion and maintenance includes adequate
laboratory control, appropriate quality
assurance procedures, and sufficiently
trained personnel. The operation and
maintenance provision also requires the
operation of backup or auxiliary facili-
ties (or similar systems that are installed
by a perniittee) only when the operation
is necessary to achieve compliance.
4.2 Monitoring and Recordkeepmg
All samples and measurements that are
taken for the purpose of monitoring, in
accordance with established analytical
procedures, must be representative of
the monitored activity.
43 Planned Changes
An EPA laboratory should, as soon as
possible, notify the regulatory agency
of any planned physical alterations or
additions to the laboratory when the
alteration or addition:
• Meets one of the criteria for deter-
mining whether a laboratory is con-
sidered a new source under 40 CFR
122.29(b)
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• Could significantly change the
nature or increase the quantity of pol-
lutants discharged
• Results in a sIgnificant change in
sludge use or disposal practices, and
such alteration, addition, or change
may justify the application of permit
conditions that are different or absent
from those conditions in the existing
permit
44 Noncompliance
An EPA laboratory representative must
report all instances of noncompliance to
the regulatory agency within 24 hours of
becoming aware of the noncompliance. In
some cases, this report may be deferred
until the time that the laboratory’s moni-
toring report is submitted. Refer to section
6.0 of this chapter for a description of the
reporting process.
4.5 Bypass Condition
Bypass of an EPA laboratory’s wastewater
treatment equipment may only occur if
it does not cause effluent limits to be
exceeded, and only if it is for essential
maintenance to ensure efficient operation
of the system. An EPA laboratory must
communicate anticipated bypasses to the
regulatory agency prior to such an event,
and for unanticipated bypasses, the labora-
tory must notify the agency within 24
hours of the event.
4.6 Upset Condition
An upset condition constitutes an affirma-
tive defense to an action brought for non-
compliance with technology-based permit
effluent limitations if the following
threc conditions are met:
The EPA laboratory can identify the
cause of the upset.
• At the time of the event, the system
was being properly operated.
• Notice of the upset was communi-
cated to the regulatory agency
within 24 hours of the event.
5.0 Monitoring
NPDES permits, and many Pretreat-
mentIPOTW Programs, require
monitoring of wastewater effluent.
Depending on the analytical para-
meter and the complexity of the efflu-
ent, monitoring samples may be either
grab samples or composite samples.
Grab samples are instantaneous samples
usually taken by dipping a sample con-
miner or bucket into the effluent stream.
Composite samples are taken over a
specified time (usually 24 hours). This
is usually performed by an automated
sampler, although it may also be ac-
complished manually.
An EPA laboratory must use the test
procedures established in 40 CFR 136
when sampling and analyzing waste-
water effluent In addition, the current
edition of the Standard Methods for the
Examination of Water and Wastewater
is the most commonly accepted meth-
odology for sampling and analyzing
wastewater.
If any pollutant is monitored more
frequently than required by the permit,
test procedures approved under 40 CFR
136 are used. In the case of sludge use
or disposal, test procedures approved
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Cl 2. Wastewater Program
under 40 CFR 136, or as specified in the
permit, are used. The results of this mom-
toring must be included in the calculation
and reporting of the data submitted in the
discharge monitoring report or sludge
reporting form specified by the regulatory
agency.
If an EPA laboratory’s pennit requires that
samples be taken on a monthly basis, and
the laboratory elects to sample on a more
frequent basis (i.e., weekly), the results of
all of the samples must be reported if they
were:
• Representative of the monitored
activity
• Obtained using an approved standard
method
• Analyzed using established analytical
procedures
6.0 Reporting
Reporting under the NPDES regulations
can be divided into two categories: routine
and nonroutine. Each are discussed in the
following sections.
6.1 Routine Reporting
For NPDES permits, a monthly discharge
monitoring report (DMR) that documents
monitoring results and demonstrates the
EPA Laboratory’s level of compliance
with effluent limitations is usually required
by the regulatory agency. DMRs must be
signed by an officer of the company or
his/her duly authorized representative.
Routine reporting can also be specified by
the POTW as part of the pretreatment pro-
grain authorization.
6.2 Nonroutine Reporting
Nonroutine reporting is required when-
ever an event causes an exceedance of
effluent limits, including bypasses,
upsets, pollutant exceedances, or other
emergency events. Any noncompliance
event that may endanger human health
or the environment shall be orally
reported to the regulatory agency within
24 hours from the time the EPA labora-
tory becomes aware of the event.
The EPA laboratory must also provide
a written submission to the regulatory
agency within five days of the time the
event is identified. The written submis-
sion must contain:
• A description of the noncompliance
and its cause
• The period of noncompliance,
including the exact dates and times
• The anticipated duration of the
event (if the noncompliance had not
yet been corrected)
• The steps taken or planned to
reduce, eliminate, and prevent
reoccurrence of the noncompliance
(Note: The regulatory agency may
waive the written report requirement
on a case-by-case basis.J
7.0 Recordkeeping
Monitoring records must include the
following:
• The date, exact place, and time of
sampling or measurements
• The individual(s) who performed
the sampling or measurements
• The date(s) that analyses were
performed
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• The individual(s) who performed the
analyses
• The analytical techniques or methods
used
• The results of such analyses
Records of all monitoring must be main-
tained for a period of at least three years
from the date of the sample, measure-
ment, report, or application (e.g., calibra-
tion and maintenance records and strip
chart recordings for continuous monitoring
instrumentation, copies of reports required
by the wastewater discharge permit, and
records of data used to complete the permit
application).
(Note: Records of any required monitoring
information related to sewage sludge use
and disposal must be retained for a period
of at leasifive years (or longer as required
by 40 CFR 503).J
8.0 Stormwater
At EPA laboratories there may be spill
containment barriers around outdoor tanks
or storage areas. These containment barri-
ers can collect rainwater. Because this
water can pick up contaminants, its
discharge must be closely monitored.
The discharge of stormwater from certain
industrial activities is regulated by the
EPA as part of the NPDES Program under
40 CFR 122.26.
Each laboratory component or system must
be examined for its potential for causing a
release of pollutants due to equipment fail-
ure (e.g., a tank overflow or leakage), im-
proper operation, or natural phenomena
(e.g., rain or snowfall, etc.).
Where experience indicates a reason-
able potential for such a release, the
plan should predict the direction, rate of
flow, and total quantity of the pollutants
that could be released from the facility
as a result of each condition or circum-
stance.
8.1 Applicability
The EPA has delegated authority for
administration of the stormwater pro-
gram to the states. Depending on how
stormwater is managed at an EPA labo-
ratory, the laboratory may be subject to
an individual permit or a general per-
mit, or it may not be required to obtain
a permit.
Laboratories that discharge stormwater
associated with industrial activity are
required to:
• Apply for an individual permit
• Apply for a permit throug i a group
application
• Seek coverage under a promulgated
general permit
8.2 Permit Conditions
Individual and general permits typically
contain provisions related to operation
and maintenance of the stormwater
management system. Monitoring
requirements may also be imposed with
sampling required during certain storm
events. An EPA laboratory may be
required to prepare and implement a
Best Management Practices (BMP)
Plan, otherwise known as a Stormwater
Pollution Prevention Plan (SWP 3 ), to
reduce its potential to discharge pollut-
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ants to stormwater. This plan may be a
stand-alone plan, or integrated into an EPA
laboratory’s Spill Prevention Control and
Countermeasures (SPCC) Plan. Refer to
Attachment C12-1 for an example of the
BMP requirements imposed by a state in
an NPDES permit that it issued.
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Attachment Cl 2-1: Best Management Practices for NPDES Permitting
Purpose: To serve as an example of Best Management Practices that may be imposed
on an EPA laboratory.
Instructions: Refer to the example to make improvements to the laboratory’s current
permit management system.
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Attachment C 12-1: Best Management Practices for NPDES Permitting
General Conditions
1. Applicability
These conditions apply to all pennittees who use, manufacture, store, handle, or discharge
any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act; oil, as defined in
Section 31 1(a)(l) of the Act; and any pollutant listed as hazardous under Section 311 of the
Act, and who have ancillary manufacturing operations that could result in the release of a
hazardous substance, pollutant, or contaminant (hereafter referred to as the “BMP pollut-
ants”) in a reportable quantity; or an environmental emergency. These operations include
material storage areas; plant site runoff; in-plant transfer, process, and material handling
areas; loading and unloading operations; and sludge and waste disposal areas.
2. BMP Plan
The permittee shall maintain a Best Management Practices (BMP) plan that prevents, or
minimizes the potential for, the release of BMP pollutants from ancillary activities through
plant site runoff; spillage or leads; sludge or waste disposal; or drainage from raw material
storage.
3. Implementation
The plan shall continue in effect and shall be modified as necessary.
4. General Requirements
The BMP plan shall:
a. Be documented in narrative form, and shall include any necessary plot plans, drawings.
or maps.
b. Establish specific objectives for the control of toxic and hazardous pollutants.
1. Each facility component or system shall be examined for its potential for causing a
release of BMP pollutants due to equipment failure, improper operation, natural
phenomena such as rain or snowfall, etc.
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2. Where experience indicates a reasonable potential for equipment failure (e.g., a tank
overflow or leakage), natural condition (e.g., precipitation), or other circumstances
that could result in a release of BMP pollutants, the plan should include a prediction
of the direction, rate of flow, and total quantity of the pollutants that could be released
from the facility as result of each condition or circumstance.
c. Establish specific best management practices to meet the objectives identified under
paragraph b of this section, addressing each component or system capable of causing a
release of BMP pollutants.
d. Include any special conditions.
e. Be reviewed by engineering staff and the laboratory manager.
5. Specific Requirements
The plan shall be consistent with the general guidance contained in the publication entitled
“NPDES Best Management Practices Guidance Document” and must include the following
baseline BMPs as a minimum.
a. BMP committee
b. Reporting of BMP incidents
c. Risk identification and assessment
d. Employee training
e. Inspections and records
f. Preventive maintenance
g. Good housekeeping
h. Materials compatibility
i. Security
j. Materials inventory
6. SPCC Plans
The BMP plan may reflect requirements for Spill Prevention Control and Countermeasure
(SPCC) plans under Section 311 of the Act and 40 CFR Part 151, and may incorporate any
part of such plans into the BMP plan by reference.
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Attachment C 12-1: Best Management Practices for NPDES Pennitting
7. Hazardous Waste Manaaement
The permittee shall ensure the proper management of solids and hazardous waste in accor-
dance with the regulations promulgated under the Solid Waste Disposal Act, as amended by
the Resource Conservation and Recovery Act of 1978 (RCRA) (40 U.S.C. 6901 et seq).
Management practices required under RCRA regulations shall be referenced in the BMP
plan.
8. Documentanon
The permittee shall maintain a copy of the BMP plan at the facility and shall make the plan
available to representatives of the Division of Water upon request. Copies of modified BMP
Plans shall be submitted within thirty (30) days of completion.
9. BMP Plan Modification
The permittee shall amend the BMP plan whenever there is a change in the facility (or change
in the operation of the facility) that materially increases the potential for the ancillary
activities to result in the release of “BMP pollutants.”
10. Modification for Ineffectiveness
If the BMP plan proves to be ineffective in achieving the general objective of preventing the
release of BMP pollutants then the specific objectives and requirements under Paragraphs b
and c of Section 4, the permit and/or the BMP plan shall be subject to modification to
incorporate revised BMP requirements. If, at any time following the issuance of this permit,
the BMP plan is found to be inadequate pursuant to a state or federal site inspection or plan
review, the plan shall be modified to incorporate such changes necessary to resolve the
concems.
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1.0 Introduction
The EPA’s regulations on oil pollution
prevention became effective on December
11, 1973, and were designed to prevent oil
pollution of the waters of the United
States. One mechanism established for
accomplishing this is the Spill Prevention
Control and Countermeasure (SPCC) Plan.
The regulations that govern the prepara-
tion, issuance, amendment, and implemen-
tation of an SPCC plan are contained in
40 CFR 112. The federal oil pollution pre-
vention regulations focus on prevention
and planning specifically related to oil,
and do not address or require the prepara-
tion of a plan for chemicals or hazardous
substances. However, an EPA laboratory
should consider expanding the scope of
its SPCC Plan to include materials other
than oil.
[ Note: In some cases, an EPA laboratory
may be required to prepare and implement
a Best Management Practices (BMP)
Plan, otherwise known as a Stormwater
Pollution Prevention Plan, to reduce its
potential to discharge certain Clean Water
Act pollutants to stormwater. This plan
may be a stand-alone plan, or integrated
into an EPA Laboratory’s SPCC Plan.
Refer to Chapter C12 of this manual for
more information.]
EPA Program Requirements
To ensure that it meets the applicable fed-
eral regulatory requirements, an EPA labo-
ratory must consider whether, based on its
design and operation, it is subject to the
following requirements for oil pollution
prevention:
• Preparing, maintaining, and imple-
menting an SPCC Plan
• Training employees on the pollution
control laws and regulations that apply
to the laboratory and the proper opera-
lion and maintenance of equipment to
prevent discharges of oil
Program Administration
To effectively manage an SPCC pro-
gram, an EPA laboratory should assign
responsibility for the following items, as
applicable:
• Determining whether the laboratory is
subject to SPCC Plan requirements
• Preparing and issuing an SPCC Plan
• Implementing the requirements con-
tained in the SPCC Plan (e.g., contain-
ment, inspections, training)
• Amending the SPCC Plan as required
(e.g., whenever there is a change to the
laboratory design, construction, opera-
tion, or maintenance that may affect
the laboratory’s oil discharge poten-
tial; if the laboratory experiences two
spill events in any 12-month period;
or if the laboratory has a single spill
event that results in the discharge of
more than 1,000 gallons)
• Reviewing, revising, and recertifying
the SPCC Plan every three years
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2.0 Applicability of SPCC Plan
Requirements
An EPA laboratory that meets the follow-
ing conditions is required to prepare and
implement an SPCC Plan:
AND
An EPA laboratory that does no: meet both
of the above conditions is not required to
prepare and implement an SPCC Plan.
There are two items that an EPA labora-
tory should take into consideration when
making an SPCC Plan applicability
determination. The first is the definition
of “oil” - which includes a wide variety
of substances, including:
• Crude oils
• Transformer oils
• Vegetable oils
• Lacquer-base paints and varnishes
Refer to Attachment Cl 3-1 for EPA Guid-
ance on the Clean Water Act Definition of
Oil.
The second consideration when making
an SPCC plan is related to the total above-
ground storage capacity of a laboratory
which includes containers, drums, tanks,
etc., that contain oils. Based on this defini-
tion, it does not take that many 55-gallon
drums to exceed the threshold. Further,
the applicability threshold is based on the
potential to contain, and not the actual
quantity of material contained. So, even
if a laboratory routinely stored only 10
gallons of oil in a 55-gallon drum, for the
purpose of the applicability determination,
this drum would still be considered to con-
tribute 55 gallons to the total quantity of
oil stored. As such, it may be relatively
easy for some EPA laboratories to exceed
1,320 gallons of oil stored.
3.0 SPCC Plan
This section addresses the regulatory
requirements that govern the preparation,
implementation, and amendment of an
SPCC Plan.
Condition #1: Storage Capacity
• More than 1,320 gallons of oil
above ground, or
• Oil in a single container with a
capacity greater than 660 gallons
above ground, or
• More than 42,000 gallons below
ground
Condition #2: Location
Located in an area where there is
a potential to discharge oil into a
navigable waterway (as defined in
the Clean Water Act)
(Note: This is determined based on the
location of the laboratory relative to a
navigable waterway, and does con-
sider systems used to prevent releases
(e.g., secondary containment, equip-
ment, etc.).)
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3.1 SPCC Plan Preparation and
Implementation
An EPA laboratory that is subject to
SPCC Plan requirements must prepare
this plan within six months after the date
the laboratory begins operations. The plan
must be reviewed and certified by a regis-
tered professional engineer. This certifica-
tion attests that the SPCC Plan has been
prepared in accordance with good engi-
neering practices. An EPA laboratory must
implement its SPCC Plan as soon as pos-
sible, but not later than one year after the
laboratory begins operations.
(Note: In some cases, the EPA may autho-
rize an extension of time for the prepara-
tion and full implementation of an SPCC
Plan; this extension must be spec flcally
requested by an EPA laboratory.]
3.2 SPCC Plan Contents
The SPCC Plan must be a carefully
thought-out plan, prepared in accordance
with good engineering practices, and have
the full approval of management including
commitment of the necessary resources, If
the plan calls for additional facilities, pro-
cedures, methods, or equipment not yet
fully operational, these items should be
discussed—including the details of instal-
lation and operational start-up.
An SPCC Plan must include a discussion
of the EPA laboratory’s conformance with
the following items:
• Spill event history
• Failure analysis
• Containment and diversionary
structures
In addition, an SPCC Plan should include
a discussion of other applicable regulatory
guidelines noted in 40 CFR 112.7(e).
Refer to section 3.2.4 of this chapter for
more information. Finally, an SPCC Plan
must address requirements relative to:
• Inspections
• Recordkeeping
• Secunty
• Training
These requirements are discussed in sec-
tions 3.2.5 through 3.2.7 of this chapter.
Refer to Attachment C 13-2 for an example
of a table of contents for an SPCC Plan
that addresses regulatory requirements.
An EPA laboratory should be aware of
the fact that the implementation of an
SPCC Plan is a regulatory requirement.
That is, any “self-imposed” programs,
procedures, practices, etc., that are set
forth in the laboratory’s SPCC Plan must
be fully implemented, otherwise the labo-
ratory is technically not in compliance
with the requirement to implement its
plan (i.e., 40 CFR 112.3).
3.2.1 Spill Event History
An EPA laboratory that has experienced
one or more spill events within 12 months
prior to the effective date of 40 CFR 112
should include a written description of
each spill, the corrective action taken, and
plans for preventing recurrence.
A spill event is a discharge of oil into
or upon the navigable waters of the United
States or adjoining shorelines in harmful
quantities, as defined at 40 CFR Part 110
(e.g., a release that causes a sheen on
water).
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3.2.2 Failure Analysis
Where experience indicates a reasonable
potential for equipment failure (such as
tank overflow, rupture, or leakage), the
plan should include a prediction of the
direction, rate of flow, and total quantity
of oil that could be discharged from the
laboratory as a result of each type of major
failure. For an EPA laboratory, consider-
ation should be given to storage tanks
and/or drum storage areas.
3.23 Containment and Diversionary
Structures
Appropriate containment and/or diversion-
my structures, or equipment to prevent
discharged oil from reaching a navigable
waterway, should be provided. One of the
following preventive systems or its equiva-
lent should be used as a minimum:
• Dikes, beams, or retaining walls suffi-
ciently impervious to contain spilled
oil
• Culverting, gutters, or other drainage
systems
• Sorbent materials
• Curbing, drip pans
• Sumps or collection systems
• Spill diversion or retention ponds
3.2 .4 Other Applicable Guidelines
In addition to the items noted in sections
3.2.1 through 3.2.3, the SPCC Plan should
include a complete discussion of compli-
ance with the applicable guidelines noted
in 40 CFR 112.7(e). These guidelines
address the following areas that may
apply to an EPA laboratory:
• Facility drainage
• Bulk aboveground and underground
storage tanks (Refer to Chapter Cl 6
for an overview of the requirements
applicable to underground storage
tanks.)
• Facility transfer operations, pumping,
and in-plant process
• Tank car and tank truck loading/
unloading procedures
The plan should also include a complete
discussion of compliance with other effec-
tive spill prevention and containment pro-
cedures, or if more stringent, with state
rules, regulations and guidelines. Refer to
section 3.4 for a description of state spill
prevention and control programs.
3.2.5 Inspection Procedures and
Recordkeeping Requirements
Inspections required by 40 CFR 112.7
(i.e., bulk storage tank integrity inspec-
tions, stonnwater drainage inspections)
should be in accordance with written
procedures developed by the EPA labora-
tory. These procedures, and a record of
the inspections, signed by the appropriate
supervisor or inspector, should be made
part of the SPCC Plan and maintained for
a period of three years.
Bulk Storage Tank Integrity
Aboveground tanks should be subject
to periodic integrity testing, taking into
account tank design (floating roof, etc.),
and using such techniques as hydrostatic
testing, visual inspection, or a system of
non-destructive shell thickness testing.
Comparison records should be kept where
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C13. SPCC Program
appropriate, and tank supports and
foundations should be included in these
inspections. The outside of the tank should
frequently be observed by operating per-
sonnel for signs of deterioration, leaks
which might cause a spill, or accumula-
tion of oil inside diked areas.
Drainage of Rain water from
Containment Dikes
Drainage of rainwater from a diked area
into a storm drain or an effluent discharge
that empties into an open water course,
lake, or pond may be acceptable if:
• The bypass valve is nonnally sealed
closed
• Inspection of the rainwater runoff
ensures that complies with applicable
water quality standards and will not
cause a harmful discharge as defined
in4O CFR Part 110
• The bypass valve is opened, and
resealed following drainage under
responsible supervision
• Adequate records are kept of such
events
3.2.6 Visual Examinations
An EPA laboratory with aboveground
valves and pipelines should subject this
equipment to regular examinations. The
general condition of items should be
assessed, such as:
• Flange joints
• Expansion joints
• Valve glands and bodies
• Catch pans
• Pipeline supports
• Locking of valves
• Metal surfaces
In addition, periodic pressure testing may
be wananted for piping in areas where
facility drainage is such that a failure
might lead to a spill event.
3.2.7 Security and Lighting
An EPA laboratory that handles, pro-
cesses, and stores oil should be fully
fenced, and entrance gates should be
locked and/or guarded when the labora-
tory is unattended. If applicable:
• Master flow and drain valves and any
other valves that will permit direct
outward flow of the tank’s contents to
the surface should be securely locked
in the closed position when in non-
operating or standby status.
• The starter control on all oil pumps
should be locked in the off position
or located at a site accessible only to
authorized personnel when the pumps
are in a non-operating or standby
status.
• The loading/unloading connections
of oil pipelines should be securely
capped or blank-flanged when not
in service or standby service for an
extended time. This security practice
should also apply to pipelines that are
emptied of liquid either by draining or
by inert gas pressure.
In addition, lighting should be commensu-
rate with the type and location of the EPA
laboratory. Consideration should be given
to:
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CHAFrER C
Laboratory SFIE Programs
C13. SPCC Program
• Discovery of spills occurring during
hours of darkness, both by laboratory
personnel, if present, and by others
(the general public, local police, etc.)
• Prevention of spills occurring through
acts of vandalism
3.2.8 Training
An EPA laboratory is responsible for
properly instructing its personnel in
applicable pollution control laws, rules
and regulations and the operation and
maintenance of equipment to prevent
the discharges of oil. In that regard, the
laboratory should have a designated person
who is accountable for oil spill prevention
and who reports to line management. In
addition, the laboratory should schedule
and conduct spill-prevention briefings for
its operating personnel at intervals fre-
quent enough to ensure adequate under-
standing of the laboratory’s SPCC Plan.
Such briefings should highlight and de-
scribe:
• Known spill events or failures
• Malfunctioning components
• Recently developed precautionary
measures (e.g., floor drain covers to
prevent spills from entering a sewer
system)
Refer to chapter C3 of this manual for
additional information on training.
An amendment to the plan is required whenever a laboratory has discharged more than 1,000 gallons of
oil into or upon the navigable waters of the United States or adjoining shorelines in a single event, or if a
laboratory has experienced two or more spill events within any 12-month period. Within 60 days of such
an event(s), the EPA laboratory must submit to the EPA a report that contains the following information:
• Name of the laboratory
• Name(s) of the owner or operator of the laboratory
• Location of the laboratory
• Date and year of initial laboratory operation
• Maximum storage or handling capacity of the laboratory and normal daily throughput
• Description of the laboratory, including maps, flow diagrams, and topographical maps
• A complete copy of the SPCC Plan with any amendments
• The cause(s) of such spill, including a failure analysis of the system(s) or subsystem(s) in which the
failure occurred
• The corrective actions and/or counrermeasure
ment repairs and/or replacements
• Additional preventive measures taken or contemplated to minimize the possibility of recurrence
• Such other information as the Regional Administrator may reasonably require pertinent to the Plan or
spill event
taken, including an adequate description of equip-
Upon receipt of this information, the EPA may require the laboratory to amend its SPCC Plan.
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OR
C13. SPCC Program
3.3 SPCC Plan Amendments
There are three main reasons why an
SPCC Plan would be amended. Each
of these “scenarios” is discussed
in the following sections.
3.4 State Spill Prevention and Control
Programs
The federal oil pollution prevention regu-
lations provide for the preparation and
implementation of an SPCC Plan in accor-
dance with 40 CFR 112.7. However, an
SPCC Plan should also be designed to
complement existing laws, regulations,
rules, standards, policies and procedures
pertaining to:
• Safety standards
• Fire prevention
• Pollution prevention
Some states have developed overlapping
and/or supplementary programs for spill
prevention and control, secondary contain-
ment standards, inspection requirements,
etc. The following are examples of the
different types of regulatory programs that
have been developed.
Spill Prevention and Control Plan
Requirements
Supplement federal SPCC Plan require-
ments. Examples include:
The Alaska Oil and Hazardous Sub-
stances Pollution Control require-
ments for bulk storage tanks with
capacities greater than 10,000 gallons
• The Michigan Pollution Incident
Prevention Plan
• The Minnesota Prevention and
Response Plan
• The Pennsylvania Storage Tank and
Spill Prevention Act
Scenario #2—Design-Based
An amendment to the plan is required whenever there is a change in laboratory design, construction,
operation, or maintenance that affects the laboratory’s potential to discharge into or upon the navigable waters
of the United States or adjoining shorelines. Such an amendment shall be fully implemented as soon as
possible, but no: later than six months after such change occurs.
This type of amendment must be reviewed and certified by a Registered Professional Engineer.
Scenano #3—Three-Year Review
An amendment to the plan is required at least once every three years from the date the EPA laboratory
becomes subject to the SPCC Plan regulations. As a result of this review and evaluation, the laboratory shall
amend its SPCC Plan within six months of the review to include more effective prevention and control
technology if:
• Such technology will significantly reduce the likelihood of a spill event from the laboratory
• Such technology has been field proven (i.e., demonstrated) at the time of the review
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Tank inspection Program Requirements
Prescribe detailed inspection criteria
and/or reporting practices. Examples in-
clude:
• New York State Code of Rules and
Regulations: monthly inspection
requirements
• Rhode Island Oil Pollution Control
Regulations: inspection report with
annual submission requirements
Fire Prevention Standards
That govern secondary containment
requirements for storage tanks containing
flammable liquids. Examples include:
• New York City Fire Law Handbook
• Commonwealth of Pennsylvania
Flammable & Combustible Liquids
Handbook
• NFPA 30 Flammable and Combusti-
ble Liquids Code
Release-Repo#ing Requirements
That impose more stringent definitions of
oil spills releases that have to be reported.
Examples include:
• California Health and Safety Code
requirements pertaining to the imme-
diate reporting of a release of one
barrel or more of petroleum to land
• Barclays California Code of
Regulations
• State of Texas Oil and Hazardous
Substances Spill Contingency Plan
requirements pertaining to the imme-
diate reporting of releases of harmful
quantities of oil and hazardous sub-
stances
• Texas Administrative Code require-
ments pertaining to releases of 25 gal-
ions or more of petroleum products
and used oil
An EPA laboratory should review its state
environmental regulatory program to
determine whether there are additional
requirements that pertain to it, and as mdi-
cated in section 3.2.4, these requirements
should be reflected in the laboratory’s
SPCC Plan.
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S}IEMP Operations Manual for Laboratories
CHAPTER C
Attachment C13-l: Guidance on Clean Water Act Definition of Oil
Purpose: To provide a reference list of materials considered “oil” under the definition
of oil in the Clean Water Act.
Instructions: Refer to this list when quantifying the oil present in the laboratory.
June 1998 C13-9
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C13-2: Sample SPCC Plan Table of Contents
OH of any Kind, in any Form
Qil Not an Oil ’
Cutting Oils Fuel Oil Sludge Toluene
Transformer Oils Waste Oil Molasses
#2, #5 Fuel Oils, Bunker Oil Mixtures Plating Waste
Fuel Paraffin Wax Stearic Acid
Mix of Benzene, Asphalts Cresol
Toluene, and Xylene Tars (Petroleum) Hexanol
Jet Fuels (JP-4, etc.) Crude Oils Methyl Mercury
Kerosene Naphtha DDT
Diesel Fuel Mineral Spirits Natural Gas Condensate
Gasoline Refinery Petroleum Waste Naphthalene
Motor Oils and Lubricating Lacquer-Base Phenols
Oils PaintsNarnishes Toxaphene
Animal and Vegetable Higb-Temp Heating Oils Butanol
Fats/Oils: (Dowthern, Therminol, Ethanol
Whale Oil etc.) Methanol
Coconut Oil ThA, MTBE (Gasoline
Corn Oil Additives)
Tallow Benzene
Meat Rendering Ketones
Fish Oil Acetone
Tung Oil Propanol
Linseed Oil Glycol
Cottonseed Oil Ethylene
Ethylene/Peopylene
Glycol (Antifreeze)
Coal Tar
* The following conditions will apply if the material is an oil:
I. It is an isomer. An isomer is when a compound is identical to another compound in its formula but
different in its molecular arrangement. An example is xylene, which has 3 isomers; ortho-xylene,
meta-xylene, and para-xylene. The formula C 8 H 4 (CH 3 ) 2 is the same for all of these isomers. The
difference in appearance is due to the different placement of the methyl groups on the benzene
ring.
2. Secondly, by itself, the isomer is a non-oil; however, when combined with 3 or more in a
homologous series, it becomes an oil. Homologous series is a series of compounds where each
successive member has one or more CH 2 group in its molecule than the next preceding member.
In the example of xylene, the homologous series is: Benzene C 8 H , Toluene C 7 H , and Xylene
C 8 H 10 .
&EPA June 1998 C13-1O
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C13-2: Sample SPCC Plan Table of Contents
Purpose: To provide an example of a table of contents for an SPCC Plan that
addresses the governing regulatory requirements.
Instructions: Use this table of contents for an SPCC Plan as a framework for developing
your own plan.
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C13-2: Sample SPCC Plan Table of Contents
1.0 Introduction
2.0 General Site Information
3.0 Facility Description
3.1 Facility Operations
3.2 011 Storage
4.0 Spill Event History
5.0 Potential Spills—Prediction, Control, and Containment
6.0 Facility Drainage
6.1 Diked Storage Areas
6.2 Undiked Storage Areas
7.0 Bulk Storage Tanks
7.1 Tank Materials and Construction
7.2 Secondary Containment
7.3 Drainage of Stormwater from Dilced Areas
7.4 Buried or Partially Buried Metallic Tanks
7.5 Aboveground Storage Tank Integrity Testing
7.6 Internal Heating Coils
7.7 Fail-safe Engineering
7.8 Facility Wastewater Discharges
7.9 Visible Oil Leaks and Mobile Oil Storage Tanks
8.0 Transfer Operations, Pumping, and In-Plant Processes
8.1 Buried Piping
8.2 Out-of-Service Pipelines
8.3 Pipe Supports and Aboveground Pipelines and Valves
9.0 Tank Truck Loading and Unloading
9.1 Department of Transportation Regulations
9.2 Containment in Tank Truck Loading and Unloading Areas
9.3 Vehicular Departure Warning Light or Physical Barrier
9.4 Examination of Tanker Trucks Prior to Departure
10.0 Inspections and Records
11.0 Security
11.1 Fencing Gates
11.2 Flow Valves, Starter Controls, and Pipeline LoadinglUnloading Connections
11.3 Facility Lighting
12.0 Personnel Training and Spill Prevention Procedures
13.0 011 Spill Contingency Plan
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C13-2: Sample SPCC Plan Table of Contents
List of Tables
I Types of Products Stored and Potential Storage Volumes
2 Potential Spills—Prediction and Control
3 Summary of Oil Storage Tank Information
List of Attachments
1 Records of Spills
2 Inspection Procedures/Log
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C14.
Waste Management
Pro9ram
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C14. Waste Management Program
1.0 Introduction
EPA laboratories generate a variety of
wastes that must be properly managed.
This section defines the processes that
should EPA laboratories should develop
and undertaken by EPA laboratories to
manage their wastes and it helps laborato-
ries create systems that will allow them to
maintain compliance with federal regula-
tions. State-specific waste management
regulations may also apply to the laborato-
ries and should be reviewed to determine
requirements. Although state requirements
are not specifically addressed in this
manual, the waste management systems
described within should allow laboratories
to easily integrate the management of state
waste requirements into their overall waste
management program.
Program Administration
To effectively implement a waste manage-
ment program, responsibilities should be
assigned for:
• Characterization of waste
• Verification of appropriate waste stor-
age
• Arranging for waste collection, trans-
port, and treatment/disposal
• Development and maintenance of
required records and reports
• Development and presentation of
employee training information
EPA Program Requirements
To properly handle an EPA laboratory’s
solid waste, the facility must:
• Establish a recycling program.
• Provide appropriate collection, stor-
age, and disposal of non-hazardous
waste.
• Arrange for proper collection, storage,
transport, and disposal of infectious
waste.
• Ensure proper collection, storage,
transport, and treatment/disposal of
hazardous waste.
• Train employees on responsibilities
related to hazardous waste
management.
• Develop and maintain required records
and reports for hazardous waste.
• Ensure suitable waste management
techniques are applied to radioactive
waste.
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C14. Waste Management Program
2.0 Waste Management Process
Overview
All wastes generated by EPA laboratories
should be managed using the same basic
process. This process can be divided into
the following steps:
Step 1
- -
Identify and inventory all labo-
ratory waste streams.
Step2
- ‘
Characterize the composition
of each waste stream.
Step.3..
- I
.
Determine what regulations
govern the management of
each waste stream.
Step4
Determine applicable collec-
tion and storage requirements.
-Step 5:
Detennine applicable transpor-
tation and disposal
requirements
Detailed information on each of these
steps is provided in section 3.0 of this
chapter.
Once the basic waste management process
has been determined, identify and organize
the systems necessary to fulfill waste man-
agement requirements. The EPA has de-
veloped policies that should be considered
when planning waste management strate-
gies. These policies specify the following
strategies, in order of preference, for man-
aging wastes:
Source elimination—remove waste at its
origin by substituting less hazardous alter-
natives, managing inventory to include
only necessary quantities, etc.
Source reduction—decrease consumption
of a waste source by using only the small-
est amount needed to effectively perform
necessary activities; buy bulk source prod-
ucts to eliminate unnecessary packaging;
segregate hazardous wastes from nonhaz-
ardous wastes; etc.
Recycling and reuse—use source
byproducts more than once, reclaim
wastes into reusable materials, etc.
Treatment—process wastes to eliminate
or reduce hazardous components.
Land disposal—if wastes cannot other-
wise be eliminated or reduced, dispose of
them at approved landfills.
2.1 Roles and Resuonsibilities
All laboratory personnel should be respon-
sible for managing wastes according to the
aforementioned waste management strate-
gies. Personnel responsible for establish-
ing laboratory waste management policies,
overseeing waste policy implementation,
and implementing the waste management
process identified in section 2.0 should be
identified and formally notified of their
responsibilities.
Responsibility for developing and main-
taining required and supplementary waste
management documentation (e.g.. waste
stream inventories, waste constituents,
applicable federal and state regulations,
personnel training certifications, waste
accumulation start dates, waste manifests,
etc.) should be formally designated to lab-
oratory personnel.
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C14. Waste Management Program
2.2 Wastes Specific to EPA
Laboratories
The following six general categories of
waste may be found at EPA laboratories:
Nonhazardous waste—waste that
resembles common household waste in
content (e.g., paper, plastic, cans, etc.)
Hazardous waste—waste that is listed by
the EPA as hazardous or that exhibits de-
fined characteristics of flammability, reac-
tivity, corrosivity, or toxicity
Infectious waste—waste that is derived
from work procedures with biological
agents at the occupational medicine clinic
or first-aid treatment center
Radioactive waste—waste that has the
potential for emitting alpha, beta, gamma.
or neutron radiation.
Special waste—waste such as contami-
nated soils, waste oil, batteries, etc.
Polychiorinated biphenyl (PCB)
waste—waste containing PCBs in quanti-
ties above established threshold levels
Specific waste management options for
each of these waste types are described
in sections 4.0 through 9.0.
3.0 Waste Management Process
To ensure that EPA laboratory waste
streams axe appropriately managed, the
five basic steps of the waste management
process should be followed at each labora-
tory. When appropriately evaluated and
applied in their entirety, these steps consti-
tute a comprehensive waste management
process as summarized in Figure C14-1.
Figure C14-1: Waste Management
Process
Step I
Identi1 r and
Inventcny Waste
Step2
characterize
Waste
Step3 J,
Determine Regulatory
Requirements
I
Step4 ,
Determine Collection and
Storage Requirements
Step5
Determine Transportation
and Disposal Requirements
3.1 Step 1: Waste Identification and
Inventory
To identify and inventory laboratory
waste, consider the following questions:
• What are the waste streams generated
at this laboratory?
• How much of each type of waste is
generated?
A list of all specific types of wastes gener-
ated from laboratory activities should be
created for each laboratory. This identifi-
cation of waste streams should include aLl
liquid, semisolid, and solid wastes from
sources such as, but not limited to, the
following:
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Laboratory SHE Programs
C14. Waste Management Program
• Laboratory activity/project wastes
(e.g., experiment waste products,
sample containers, etc.)
• Discarded and unused chemicals
(e.g., outdated chemicals)
• Wastes associated with cleanup activi-
ties (e.g., materials used to clean up
spilled chemicals, contaminated mate-
rials, etc.)
• Operational/maintenance activity
wastes (e.g., used filters removed
from laboratory hoods, etc.)
• Wastes associated with material
receiving areas (e.g., packaging
materials, damaged containers, etc.)
After all waste streams are identified, an
inventory of the approximate amount of
each waste stream generated per month
should be calculated. The process used
to arrive at these calculations (e.g., estima-
tion, data from chemical purchase orders,
process knowledge, etc.) should be
documented.
• Are any laboratory waste streams
exempt from regulations?
• Do any laboratory solid wastes have
specific management
requirements?
All waste streams must be characterized as
“hazardous” or “nonhazardous.” In deter-
mining waste characterization, EPA labo-
ratories should follow these guidelines that
are highlighted in Figure C14-2.
3.2.1 Identify Solid Wastes
Identify those waste streams that are con-
sidered “solid wastes.” According to fed-
cmi regulations in 40 CFR 260, Appendix
I, all materials can be classified as:
1) Garbage, refuse, or sludge; all solid
waste.
2) Solid, liquid, semisolid, or contained
gaseous material; all solid waste
unless they are one of the five exclu-
sions (e.g., spent sulfuric acid used
to produce virgin sulfuric acid).
3) Something else other than solid waste.
Waste stream identification and associated
inventories should be periodically (e.g.,
annually) reviewed and updated, as
appropriate.
3.2 Step 2: Waste Characterization
To characterize laboratory wastes, con-
sider questions such as:
• Which waste streams are considered
“solid wastes?”
• Which waste streams are considered
“hazardous?”
3.2.2 Determine Exempt Wastes
Determine if any laboratory solid wastes
are exempt from hazardous waste regu-
lation. Refer to 40 CFR 261.4(a) for a list
of such wastes.
3.2.3 Determine Hazardous Wastes
Determine which solid wastes are consid-
ered “hazardous.” A solid waste is consid-
ered hazardous if it is listed in Subpart D
of 40 CFR 261 or if it meets certain crite-
ria, identified in Subpart C of 40 CFR 261,
for one of four hazardous waste character-
istics (ignitability, corrosivity,
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CHAPTER C
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Figure C14-2: Waste Characterization Guidelines
C14. Waste Management Program
Identif r Solid Wastes
‘ I ,
Determine Exempt Wastes
‘I
Detennine Hazardous
Wastes
40 CFR 260, Appendix I
40 CFR 261.4(a)
40 FR 261.4(a)
4OCFR 261, SubpartD
40 CFR 261, Subpart C
40 CFR 260.21
State Laws
40 CFR 261.3
reactivity, or toxicity). This determination
can be based on analytical data (see Sub-
part C of 40 CFR Part 261 and 40 CFR
260.2 1) or on knowledge of both the
process and the chemical and physical
properties of the waste generated from
the process.
Staff who understand a process can help to
determine the chemical composition of
waste generated by that process. Such
wastes should be retested annually. All
other wastes should undergo testing to
determine if they are hazardous. Accept-
able test methods are described in “Test
Methods for Evaluating Solid Waste,
Physical/Chemical Methods,” EPA Publi-
cation SW-846.
Solid wastes can also be considered haz-
ardous under state law. For example, PCB
wastes are considered hazardous in certain
concentrations in California, Maryland,
and Washington. Laboratory solid waste
streams should be reviewed against any
applicable state laws to determine whether
they are considered hazardous. Figure
C14-3 outlines the process of determining
if solid wastes are hazardous.
3.2.4 Determine Hazardous Mixtures
Determine whether any solid waste
streams are subject to the federal “mixture
and derived from” rules in 40 CFR 261.3.
Listed hazardous wastes mixed with non-
hazardous wastes, and residues resulting
from the processing or managing of a
listed hazardous waste, are considered
hazardous.
3.3 Step 3: Applicable Regulations
To determine applicable regulations, con-
sider the following questions:
• If hazardous wastes are generated at
this laboratory, which generator regu-
lations apply?
• Which regulations are applicable to
other laboratory waste?
Determine Hazardous
Mixtures
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Figure C14-3: Waste Determination Summary
C14. Waste Management Program
Dehrmlne whether .ofld wistna ganeratod on-ette are hazardous wastes
Is the solid waste exempt from regulation or not considered a solid waste when recycled?
(40 CFR 261.2. .4)
Is it considered a listed state hazardous waste?
1-
Is it listed on the hazardous waste tables?
(40 CFR 261. Subpart D)
‘lrNo
Is it ignitable; flash point 140F?
(40 CFR 261 .21)
Is it corrosive: pH S 2 or 12.5?
(40 CFR 2612,4)
9—
Waste lee
hazardous
waste
Waste Is rosta tta ardaus waste
)
3.3.1 Hazardous Laboratory Wastes
The degree to which a laboratory is regu-
lated by Subpart C of the Resource Con-
servation and Recovery Act (RCRA)
depends upon the amount of hazardous
waste generated and whether the labora-
tory transports, treats, stores, or disposes
of such waste. After identifying and
characterizing waste streams, each EPA
laboratory should add together all of its
approximate monthly individual hazardous
waste stream amounts calculated in Step 1
to determine its generator status.
The maximum amount on-site at any one
time should also be determined. Hazard-
ous wastes that must be included in the
generator calculation are specified in 40
CFR 26 1.5(c).
Generator status is divided into three types
as shown in Table C14-1.
.L.Na
Is it reactive (40 CFR 261.2. .4): unstable, undergoes violent change, reacts with water
to form texic gases, forbidden explosives, etc?
.L.
Is it a ‘TCLP (Toxicfty Charactenstic Leaching Procedure) waste? (40 CFR 261.24)
ContamInant mgfl Contaminant mglt
Senzene 0.5 Arsenic 5.0
Carbon fetrachlonde 0.5 Banum 100.0
Ch lordane 0.03 Cadmium 1.0
Ch lorebenzene 100.0 Chromium 5.0
Chloroform 6.0 Lead 5.0
Methyl ethyl ketone 200.0 Mercury 0.2
Vinyl chloride 0.2 Etc.
Conversions
lb/rn x 0.4536 = kg
kg x 2.2046 = lb/rn
gal (U.S.) x 3.785 = m 3
I lb/rn x 16.02 = kg/rn
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Table C14-l: Types of Hazardous Waste Generators
C14. Waste Management Program
Generator Class
Calendar Month
At Any One Time
Conditionally Exempt Small
Quantity Generator (CESQG)
100 kg hazardous waste
1 kg acutely hazardous waste
< 100 kg contaminated waste
from acutely hazardous waste spilt
<1,000 kg hazardous waste
indefinitely
Small Quantity Generator (SQG)
100 - 1,000 kg hazardous waste
s 1 kg acutely hazardous waste
<6,000kg hazardous waste for up
to 180 days
Large Quantity Generator (LQG)
> 1,000 kg hazardous waste
>1 kg acutely hazardous waste
> 6,000 kg hazardous waste for up
to 90 days
A different but similar set of regulations
applies to each type of generator. Manage-
ment of hazardous wastes is further
described in Section 5.0.
3.32 Other Laboratory Wastes
Applicable federal and state regulations
for other types of EPA laboratory wastes
(i.e., nonhazardous, infectious, radioactive,
special, and PCB wastes) should be fol-
lowed. At a minimum, EPA laboratories
should develop and implement waste
minimization and pollution prevention
activities that eliminate or reduce both
the amount of laboratory waste and the
environmental impacts associated with
of such wastes. These techniques are
discussed further in Chapter C9 of this
manual.
Management of these types of wastes is
further described in Sections 4.0, and 6.0
through 9.0
3.4 Step 4: Collection and Storage
Requirements
To plan for appropriate waste collection
and storage, consider the following
questions:
• How should laboratory wastes be
stored?
• What types of waste collection pro-
grams/activities should be available at
EPA laboratories?
• What are some guidelines for proper
waste container management?
EPA program requirements mandate that
EPA laboratories do the following with
regards to waste collection and storage.
In general, the collection and storage of
laboratory wastes should be consistent
with the following practices:
• Segregate waste streams (to avoid
incompatibility incidents).
• Label each container with the name of
the waste it contains.
Note: Waste containers that are
too small to be labeled can be
collected and packed (by type of
waste) into a larger, compatible,
labeled container.
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• Avoid mixing hazardous and non-
hazardous wastes.
• Ensure that incompatible materials
stored close to each other are sepa-
rated by a dike, berm, wall, or other
device.
• Ensure that wastes are stored so as to
minimize spills, leaks, or ruptures.
• Manage all unidentifiable wastes as
hazardous (until positive identification
is made).
• Close containers during storage.
• Avoid storing/stacking waste contain-
ers in high traffic areas.
• Ensure that storage areas are ade-
quately vented.
• Avoid placing waste in an unwashed
container that previously held an
incompatible material.
In addition, waste accumulation and stor-
age areas should be inspected periodically
(e.g., weekly). Such inspections should be
documented, with any identified deficien-
cies promptly corrected. Attachment C14-
1 includes an inspection checklist.
Specific collection and storage guidelines
for EPA laboratory waste streams are pro-
vided in Sections 4.0 through 9.0.
3.5 Step 5: Transportation and Disposal
Requirements
Consider the following questions related to
transportation and disposal of wastes:
• How should laboratory wastes be
transported off-site?
• What types of disposal options are
available for the identified waste
streams?
• What is the laboratory’s responsibility
after the waste leaves the laboratory?
Laboratories are ultimately responsible for
the wastes they produce. All laboratory
wastes that are removed from the lab for
off-site treatment and/or disposal should
therefore be transported, treated, and/or
disposed of in an environmentally sound
manner. While EPA laboratories do not
typically transport wastes, it is important
that all contractors hired to perform such
services are appropriately trained for such
tasks and use appropriate transportation
vehicles, equipment, and procedures (e.g.,
vehicles should be cleaned at least weekly,
solid waste should be removed from vehi-
cles within 24 hours, etc.). In addition,
knowledgeable laboratory personnel
should be responsible for overseeing such
services.
EPA’s waste management strategies iden-
tified in section 2.0 promote (where feasi-
ble) the use of source elimination, source
reduction, and recycling/reuse over waste
treatment and land disposal. The current
regulatory trend is to reduce the amount of
waste added to landfills by requiring waste
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generators to examine implementing
source elimination/reduction, recycling!
reuse, and treatment options before consid-
ering land disposal.
In determining which waste management
strategy(ies) to employ, EPA laboratories
should consider issues summarized in Fig-
ure C14-4.
• Potential environmental consequences
if wastes are improperly managed
• Cost of implementing management
strategy(ies)
• Short-term costs versus long-term
gains
• Future business opportunities!
objectives
• Community relations
• New/pending environmental
regulations
Additional transportation and disposal
considerations specific to EPA laboratoiy
waste streams are discussed in sections
4.0 through 9.0.
3.6 Other Considerations
Two additional topics—waste minimiz-
ation and documentation—should also
be considered when developing, imple-
menting, and maintaining a waste manage-
ment system.
3.6.1 Waste Minimization
Because of the growing emphasis placed
on source elimination, source reduction,
and recycling/reuse waste management
strategies, waste minimization plays an
increasingly important role in a labora-
tory’s waste management process. Labora-
tories should strive to develop waste
minimization programs that reduce the
amount of wastes generated and/or limit
the types of wastes generated to those that
are less hazardous or nonhazardous.
The checklist in Attachment C 14-2 pro-
vides a listing of techniques that should
be considered in the waste minimization
process.
Figure C14-4: Waste Management Considerations
Establisha I
Recycling Program fu
I.
U
I
I
I
• Ensure Appropriate
4 Collection and —
Storage
— Non-Hazardous
— Hazardous
— Infectious
— Radioactive
— Special
— PCB
Develop Records
andReports
Content Labels
Storage
Inspections
I
I
+ Train Employees
Handling
Storage
Disposal
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3.6.2 Documentation Aspects
Various types of documentation are gener-
ated during, and in support of, the waste
management process. All EPA laboratories
should establish formal systems to orga-
nize and control waste documentation.
Any existing regulatory record retention
time frames should be followed.
Waste management documentation
includes, but is not limited to, the
following:
• Waste identification and inventory
records
• Hazardous waste shipment manifests
• Accumulation and storage area inspec-
tion forms
• Training records for employees!
contractors who handle, treat, trans-
port, and/or dispose of wastes
• Agreements regarding contracted
waste management services
• Chain-of-custody forms for laboratory
samples/off-site waste shipments
• Content labels on waste containers
4.0 Nonhazardous Waste
Nonhazardous wastes ate those wastes that
are not defined as hazardous under federal
or state law. It is important to note that,
while such wastes are not regulated
as hazardous, other regulations governing
their management may apply. For exam-
ple, all nonhazardous wastes may be sub-
ject to waste minimization and pollution
prevention initiatives.
• Food refuse
• Paper-related trash (e.g., packaging
materials, used photocopy paper, etc.)
• Plastic garbage (e.g., used utensils,
packaging materials, etc.)
• Chemical wastes determined to be
nonhazardous
The amounts of such wastes should be
periodically calculated (e.g., monthly),
with results tracked to determine approxi-
mate annual usage. Such data can then be
compared to previous and future data to
determine nonhazardous waste minimiza-
tion trends and opportunities.
4.2 Characterization
Laboratories should determine whether
new/atypical chemical wastes are non-
hazardous through analytical tests or
process knowledge. Wastes characterized
as nonhazardous should be reviewed
annually to ensure that they still meet
non-hazardous criteria.
4.3 Applicable Regulations
The collection and disposal of nonhazard-
ous waste is regulated by Subtitle D of
RCRA. Most states have promulgated
additional regulations governing the con-
struction and operation of nonhazardous
waste disposal facilities, mostly incinera-
tors and landfills. The regulation govern-
ing nonhazardous waste directly applicable
to EPA laboratories is 40 CFR 243.
4.1 Identification and Inventory
4.4 Collection and Storage
Types of nonhazardous waste streams
that may be present at EPA laboratories
include the following:
Nonhazardous waste must be stored in
a manner that neither constitutes a fire,
safety, or health hazard, nor provides
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food or shelter for pests. All solid waste
containing food wastes must be securely
scored in covered or closed containers
that axe nonabsorbent, leakproof, durable,
easily cleanable (if reuseable), and
designed for safe handling. Containers
must be maintained in a clean condition.
Reusable waste containers that are emptied
manually must not exceed 75 pounds
(34.05 kg) when filled, and must be capa-
ble of being serviced without the collector
coming into physical contact with the solid
waste.
In the design of all buildings or other facil-
ities that are constructed, modified, or
leased after the effective date of regulatory
guidelines, there must be provisions for
storage that will accommodate the volume
of solid waste anticipated. Storage areas
must be easily cleaned and maintained,
and must allow for efficient and safe
collection.
4.5 Transportation and Disposal
If nonhazardous wastes cannot be elimi-
nated, reduced, recycled, and/or treated,
the laboratory should properly transport
and dispose of such wastes. While EPA
laboratories do not operate transportation
and disposal facilities, EPA laboratories
are responsible for ensuring that the con-
tracted transportation and disposal facility
has all appropriate permits and approvals.
5.0 Hazardous Waste
Hazardous wasteà must be managed from
“cradle to grave”; that is, specific federal
and, in many cases, state and local laws
require that hazardous wastes be:
• Identified and characterized upon
generation
• Stored in appropriate containment
areas for finite time periods
• Sent to licensed facilities for ultimate
treatment, storage, and/or disposal
5.1 Identification and Inventory
Types of hazardous waste streams that
may be present at EPA laboratories
include, but are not limited to, the
following:
• Spent solvents (e.g., methylene chlo-
ride, tetrachioroethylene, acetone, etc.)
• Petroleum sludges
• Various organic chemical residues
(e.g., distillation bottoms from the
production of acetaldehyde from
ethylene. etc.)
• Certain “off-specification” chemicals
(e.g., acetic acid, benzene, etc.)
EPA laboratories must maintain an accu-
rate inventory of hazardous wastes con-
mined in satellite accumulation areas and
temporary (post satellite) accumulation
areas to determine generator status and to
facilitate accurate reporting.
5.2 Characterization
Federal regulations require generators to
determine if generated wastes are hazard-
ous. 1.1 a laboratory generates solid wastes,
it must determine if such wastes are haz-
ardous using the following method (as
identified in 40 CFR 262.11):
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• Determine if the waste is excluded
from regulation under 40 CFR 261.4.
• Determine whether the waste is listed
as a hazardous waste in Subpart D of
4OCFR 261.
• If it is not listed as a hazardous waste
in Subpart D of 40 CFR 261, deter-
mine whether the waste is identified in
Subpart C of 40 CFR 261 as exhibit-
ing igrntability, corrosivity, reactivity,
or toxicity characteristics.
RCRA regulations in 40 CFR Part 261
list over 100 industrial waste streams as
hazardous (the F- and K-listed wastes).
These wastes are listed because they either
exhibit one or more of the characteristics
of hazardous waste or contain specific
toxic components at levels deemed
hazardous.
The EPA has also designated approxi-
mately 200 discarded commercial chemi-
cal products as acute hazardous wastes
(the P-list wastes), and approximately
450 other chemical products as hazardous
wastes (the U-list wastes). To qualify as
a listed waste under the P or U list, the
chemical product must be disposed of as
a commercially pure grade of the chemical
(any technical grade of the chemical and
all formulations in which the chemical is
the sole active ingredient). However, if
the chemical enters a mixture or a reaction
that is part of a manufacturing process,
the manufacturing process waste is not
considered a listed waste unless either
the manufacturing process itself is listed
(F- or K-listed wastes) or the waste exhib-
its hazardous characteristics as defined
in 040 CFR Part 261, Subpart C (i.e.,
corrosivity, ignitability, reactivity, or tox-
icity characteristics).
Characteristic metal wastes are generated
by academic institutions, industry, nuclear
utilities, and government and medical
facilities. This waste category is domi-
nated by lead and lead shielding, mercury,
cadmium, and chromium. Typical charac-
terislic organic wastes include chloroform,
methanol, and pesticides. Some waste
streams exhibiting the characteristics of
both ignitability and toxicity are also iden-
tified as characteristic organic waste.
The hazardous waste characterization pro-
cess is summarized in Figure 14-5.
Figure C14-5: Hazardous Waste
Charzwtpriz itigin
Step I
53 Applicable Regulations
Subpart D of 40 CFR 261 specifies
the wastes that must be included in the
hazardous waste generator quantity deter-
mination. Wastes that are excluded from
regulation are identified in Subpart C of
40 CFR 261 and include the following:
Determine If Waste F 40 CFR 261.4
Is Excluded
Step2
Determine If Waste 1-40 C 261,
J SubpartD
Step 3
Deta wizie If Waste
Is “Characteristic”
1—40 CFR Part
J 261,SubpartC
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• Waste exempt from regulation under:
—40 CFR 261.4(c) through (f)
in-process material, samples, and
treatability studies
—40 CFR 261.6(a)(3) (reclaimed
industrial ethyl alcohol)
— 40 CFR 261.7(a)(1) (waste left in
an empty container or liner)
—40 CFR 261.8 (PCB wastes regu-
lated under the Toxic Substances
Control Act)
• Waste managed immediately upon
generation only in on-site elementary
neutralization units, wastewater treat-
ment units, or totally enclosed treat-
ment facilities as defined in 40 CFR
260.10
• Waste that is recycled, without prior
storage or accumulation, only in an
on-site process subject to regulation
under 40 CFR 261 .6(c)(2)
• Used oil managed under the require-
ments of 40 CFR 261.6(a)(4) and 40
CFR 279
• Spent lead-acid batteries managed
under the requirements of 40 CFR
266, SubpartG
• Universal waste (cuffently batteries,
pesticides and thermostats) managed
under 40 CFR 261.9 and 40 CFR 273
States may have their own hazardous
waste regulations, which will be at least
as stringent as federal regulations. Labora-
tories should determine whether state reg-
ulations exist and whether such regulations
are applicable to laboratory operations.
A hazardous waste management program
that addresses both the federal and the
state requirements should then be devel-
oped and implemented.
5.4 Collection and Storage
Federal regulations identifying collection
and storage requirements applicable to
generators of hazardous waste are listed
in 40 CFR 262. The extent of regulation
depends on a laboratory’s generator
classification (i.e., conditionally exempt
small quantity, small quantity, or large
quantity). Table C14-1 summarizes these
classifications.
5.4.1 Registering as a Hazardous
Waste Generator
If a laboratory generates hazardous wastes
in any amount, it must register with the
EPA (49 CFR 262.12). The registration
form (“Form 8700-12”) includes a listing
of all wastes generated and a listing of all
hazardous waste activities (i.e., generator,
transporter, treatment, storage, and/or dis-
posal) conducted at the laboratory.
Upon review of the form, the EPA will
issue the laboratory an EPA identification
number. This number should be referenced
in any contact with the EPA concerning
hazardous waste issues.
5.4.2 Hazardous Waste Accumulation
Provisions
Federal regulations delineate two types of
hazardous waste storage areas: satellite
accumulation and 90-day for large quantity
generators (LQGs), 180-day accumulation
areas for small quantity generators
(SQGs).
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Satellite Accumulation
Hazardous wastes or wastes of unknown
compositions or regulatory applicability
may be accumulated at the point of genera-
tion subject to requirements for satellite
accumulation. The key constraint on these
storage areas is the volume of waste that
can be stored in the area. The satellite
accumulation regulations allow generators
to accumulate as much as 55 gallons of
hazardous waste, or one quart of acutely
hazardous waste listed in 40 CFR
261.33(e), in containers at or near any
point of generation which is under the
control of the operator of the process,
provided the container:
• Is maintained in good condition (eg.,
does not leak, is not rusting, etc.)
• Is compatible with the waste it
contains
• Is kept closed during storage, except
when it is necessary to add or remove
waste
• Is labeled either with the words
“Hazardous Waste” or with other
words that identify the contents of
the container
When more than 55 gallons of hazardous
waste or 1 quart of acutely hazardous
waste are accumulated, the generator
must remove the “excess” waste within
3 days either to a temporary accumulation
area, or directly to a licensed treatment,
storage, and disposal facility (TSDF).
The generator must mark the container
holding the excess accumulation of haz-
ardous waste with the date the excess
amount began accumulating.
The phrase “at or near any point of genera-
tion where wastes initially accumulate,
which is under the control of the operator
of the process generating the waste” has
been subject to a wide variety of interpre-
tation by state and federal regulatory agen-
cies. In general, a waste container located
next to laboratory equipment or a process
generating the waste is “at or near the
point of generation.” A container for waste
solvents located in a room that collects
waste from several different laboratories
will not likely be considered “under the
control of the operator of the process gen-
crating the waste.” The main concern of
regulators is mixing the incompatible
waste. Some laboratories install locks on
containers; other require personnel adding
waste to a container to include information
regarding added wastes in a log.
90- or 180-Day Accumulation
LQGs and SQGs that lack permitted or
interim-status TSDFs must accumulate
containers of hazardous waste that are no
longer eligible for satellite accumulation,
in a 90- or 180-day accumulation area. The
key constraint on these storage areas is the
amount of time that waste can be stored.
LQGs are allowed 90 days of accumu-
lation and SQGs are allowed 180 days. For
unknown wastes undergoing sampling and
analysis, the start date of accumulation is
when the waste is generated, not when it is
determined by analysis to be hazardous.
Therefore, it is important to manage an
unknown waste as hazardous until it is
proven otherwise.
Waste accumulation areas have specific
design and operational requirements that
depend on whether the generator is a SQO
or LQG. Once waste is removed from a
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satellite area, it may be managed in con-
tainers, tanks, drip pads, or waste piles.
Note that there are occasions when more
than 55 gallons of waste is generated by a
process when waste will not be managed
in a satellite accumulation area. Rather,
this waste will be directly placed in 90-
or 180-day accumulation.
— A device, such as a telephone
(immediately available at the scene
of operations) or a hand-held two-
way radio, capable of summoning
emergency assistance from local
police departments, fire depart-
ments, or state or local emergency
response teams
Accumulation Practices Applicable to
Both 90- and 180-Day Accumulation
Areas
The following waste accumulation prac-
tices should be established and followed
at 90- and 180-day accumulation areas:
• The date accumulation begins must be
clearly marked and visible for inspec-
tion on each container.
• While being accumulated on-site, each
container and tank must be labeled
“Hazardous Waste” or with an EPA
hazardous waste label.
• The generator must comply with 40
CFR 265, Subpart C (Preparedness
and Prevention), which requires main-
tenance and operations of the facility
to minimize the potential for a release
to the environment. All facilities must
be equipped with the following, unless
none of the hazards posed by waste
handled at the facility could require a
particular kind of equipment specified
below:
— An internal communications or
alarm system capable of providing
immediate emergency instruction
(voice or signal) to facility
personnel
— Portable fire extinguishers, fire
control equipment (including
special ectinguishing equipment,
such as that using foam, inert gas,
or dry chemicals), spill control
equipment, and decontamination
equipment
— Water at adequate volume and
pressure to supply water hose
streams, or foam-producing equip-
ment, or automatic sprinklers, or
water spray systems
• Emergency equipment must be tested
and maintained as required to ensure
that it will work if needed in an
emergency.
• Aisle space must be sufficient to allow
unobstructed movement of personnel,
fire protection equipment, spill control
equipment, and decontamination
equipment to any area of facility oper-
ation in an emergency, unless aisle
space is not needed for any of these
purposes.
The checklist provided in Attachment
C14-3 can be used as a guide for inspect-
ing hazardous waste accumulation areas.
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5.4.3 Large Quantity Generators
(LQGs)
In addition to the waste accumulation
requirements applicable to both 90- and
180-day accumulation areas, LQGs must
comply with the following requirements:
Method of Accumulation
if waste is accumulated in containers,
they must conform to 40 CFR 265,
Subpart I, which requires that containers
be in good condition and compatible with
the waste. Containers must be kept closed
except when adding or removing waste
and they must be managed to minimize
the potential for a leak. Weekly inspec-
tions of containers must be performed
to detect any signs of leaks or container
failure. Incompatible wastes must be
separated by physical means, and flamnia-
ble waste must be accumulated greater
than 50 feet from the property boundary.
There are also air emission standards
defined in 40 CFR 265, Subparts AA,
BB, and CC that may apply.
If waste is accumulated in tanks, then
the provisions of 40 CFR 265, Subpart
J apply, except 40 CFR 265.197 and
265.200. Sub-part J imposes a variety
of requirements including, but not limited
to, integrity testing, secondary contain-
ment, fill/overfill protection, daily inspec-
tions, and air emission standards defined
in 40 CFR 265, Subpart AA, BB, and CC.
EPA laboratories do not accumulate waste
on drip pads, nor accumulate waste in con-
tainment buildings, therefore they are not
addressed in this manual.
Contingency Plan
The laboratory must prepare a contin-
gency plan that documents the laboratory
preparedness and prevention measures
required by 40 CFR 265, Subpart C,
designed to minimize hazards to human
health or the environment from fires,
explosions, or any unplanned sudden or
non-sudden release of hazardous waste
or hazardous waste constituents to air,
soil, or surface water. The plan must
include the following elements (as identi-
fied in 40 CFR 265, Subpart D):
• A description of the actions laboratory
personnel must take in response to
fires, explosions, or any unplanned
sudden or non-sudden release of haz-
ardous waste or hazardous waste con-
stituents to air, soil, or surface water
at the facility (Contingency plan
requirements can be integrated with
another emergency plan such as a Spill
Prevention, Control, and Countermea-
sures (SPCC) Plan. Refer to Chapter
13 of this manual for SPCC plan
requirements.)
• A description of the arrangements
agreed to by local police departments.
fire departments, hospitals, contrac-
tors, and state and local emergency
response teams to coordinate emer-
gency services
• A list of names, addresses, and phone
numbers (office and home) of all per-
Sons qualified to act as emergency
coordinator (this list must be kept
up-to-date. Where more than one per-
son is listed, one must be named as
primary emergency coordinator and
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thers must be listed in the order in
which they will assume responsibility
as alternates)
A list of all emergency equipment
(such as fire extinguishing systems,
spill control equipment, communica-
tions and alarm systems [ internal
and external], and decontamination
equipment), and its location at the
laboratory, a physical description of
each item, and a brief outhne of its
capabilities
• An evacuation plan for laboratory per-
sonnel where there is a possibility that
evacuation could be necessary. (This
plan must describe signal(s) to be used
to begin evacuation, evacuation routes,
and alternate evacuation mutes (in
cases where the primary routes could
be blocked by releases of hazardous
waste or fires.)
Copies and subsequent revisions of the
contingency plan should be maintained
at the laboratory and submitted to local
police departments, fire departments,
hospitals, and state and local emergency
response teams. Refer to Chapter G of
this manual for information on emergency
planning.
Land Disposal Restrictions
If the laboratory is treating waste subject
to the land disposal restrictions (40 CFR
268) in tanks or containers, it must
develop and follow a written waste analy-
sis plan that describes the procedures to
ensure compliance with the treatment stan-
dards. The plan must be kept at the labora-
tory and must include a detailed chemical
and physical analysis of a representative
sample of the prohibited waste(s) being
treated that includes all information neces-
sary to treat the waste(s) in accordance
with the regulations, including the selected
testing frequency. The plan must be filed
with the EPA Regional Administrator (or
a state authorized to implement the land
disposal restriction requirements) a mini-
mum of 30 days prior to the treatment
activity, with delivery verified.
An extension may be granted by the appli-
cable regulatory agency if hazardous
wastes must remain on-site for longer than
90 days due to unforeseen, temporary, and
uncontrollable circumstances. The exten-
sion of up to 30 days may be granted at the
discretion of the Regional Administrator
on a case-by-case basis.
5.4.4 Small Quantity Generators
(SQGs)
An SQG may accumulate hazardous waste
On-Site for 180 days or less (270 days or
less if the waste must be transported over a
distance of 200 miles or more for off-site
treatment, storage or disposal). An exten-
sion of up to 30 days may be granted at the
discretion of the applicable regulatory
agency.
SQGs that accumulate waste in containers
must adhere to the standards set forth in 40
CFR 265, Subpart I except for the air
emission standards and the requirement to
locate ignitable or reactive waste greater
than 50 feet from the property line. For
waste accumulated in tanks, the SQO must
comply with the requirements specified in
40 CFR 265.201 (e.g., daily inspections).
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n addition to the requirements applicable
to both 90- and 180-day accumulation
areas, SQGs must comply with the
following:
• There must be at least one employee
(the emergency coordinator) either on
the premises or on call (i.e., available
to respond to an emergency and arnve
at the laboratory within a short period
of time) with the responsibility for
coordinating all emergency response
measures.
• The following information must be
posted next to the telephone:
— The name and telephone number
of the emergency coordinator
— Location of fire extinguishers and
spill control material, and (if pres-
ent) the fire alarm
— The telephone number of the fire
department, unless the laboratory
has a direct alarm
• All employees must be familiar with
responding to emergencies and proper
waste handling procedures in their
work area.
• The emergency coordinator or his/her
designee must respond to any emer-
gencies that arise.
5.4.5 Personnel Training
LQGs and TSDFs are required to develop
and implement a training program, as
required by 40 CFR 262.34 and 265.16.
SQGs must ensure that their personnel
are familiar with hazardous waste manage-
ment; a training program for SQGs is a
ood management practice. Refer to Chap-
ter C3 of this manual for more information
on training.
5.5 Transportation and Disposal
Most hazardous waste at EPA laboratories
will require shipment to an off-site TSDF.
The EPA requires that all hazardous
wastes be managed from “cradle to grave.”
The hazardous waste regulations place the
burden of compliant shipping on the gen-
erator. Most generators contract for waste
transportation with a professional trucking
company, which assists with ensuring
proper packaging and labeling require-
ments prior to shipment.
5.5.1 Pre-Transport Requirements
The first step in cradle-to-grave tracking
of hazardous wastes is at the pre-transport
stage. In order to ship containers of haz-
ardous wastes off-site 1 generators must
comply with the following pre-transport
requirements, as identified in 40 CFR
262.30 to .33:
• Affix an EPA hazardous waste label to
the container package
• Complete the EPA label with the
required information as specified in
40 CFR 262.32 and 49 CFR 172 (e.g.,
EPA waste II) number, hazard class,
accumulation start date, etc.)
• Identify any land-ban-restricted wastes
• Prepare manifests
• Make placards available to
transporters
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5.5.2 Placarding
Placards that indicate the hazards of the
cargo must be placed on the end and sides
of the transport vehicle. Tables 1 and 2
in 49 CFR 172.504 identify classes of
hazardous materials and placarding
requirements consistent with 40 CFR
262.30 and .31.
5.5.3 Manifest System
The manifest is used to convey hazardous
waste from the generator to the transporter
and then to the TSDF. The form of the
manifest can vary by state. Generators
must complete the manifest form of the
state to which the waste will be trans-
ported. If the receiving state does not have
a manifest, then the manifest for the state
in which the waste is generated should be
completed. If neither the receiving nor the
sending state has a manifest, then the fed-
eral form may be completed.
The manifest is a multiple-copy form. The
generator and the transporter sign and date
the completed manifest and the transporter
retains the form. A representative from the
designated TSDF signs the manifest when
the waste is delivered and returns a signed
copy to the generator. If the generator does
not receive a copy of the manifest from
the TSDF, certain actions are required,
depending on the generator status.
An LQG must contact the TSDF if the
manifest is not received within 35 days
of the date of initial shipment. If the LQG
has not received the manifest copy within
45 days, then the LQG must file an excep-
tion report with the regulatory agency. The
exception report should include:
• A legible copy of the manifest for
which the generator does not have
confirmation of delivery
• A cover letter signed by the generator
or his/her authorized representative
explaining the efforts taken to locate
the hazardous waste and the results
of those efforts
An SQG who does not receive a copy of
the manifest with the handwritten signa-
ture of the owner or operator of the desig-
nated facility within 60 days of the date
the waste was accepted by the initial trans-
porter must submit a legible copy of the
manifest, with some indication that the
generator has not received confirmation
of delivery.
(Note: Conditionally-exempt small quan-
tity generators (CESQGs) are exempt from
manifesting requirements as well as trans-
port requirements in the hazardous waste
regulations. However, U.S. Department of
Transportation regulations for transport-
ing hazardous materials may apply.]
In addition to the manifest, the generator
must notify the TSDF of the status of the
waste with respect to the land disposal
restrictions (LDRs). If the waste does
not meet the applicable treatment standard
in 40 CFR 268, then the generator must
notify the TSDF in writing, If the waste
does meet the applicable treatment stan-
dard, then the generator must certify this
fact. Most commercial TSDFs have a
standard LDR form that contains the
required information.
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The hazardous waste regulations place the
burden of ensuring that waste is properly
packaged, labeled, and placarded on the
generator; 40 CFR 262.30 to .33 contain
specific requirements that are almost iden-
tical to the Department of Transportation
(DOT) regulations.
5.5.4 Treatment
There are two major categories of treat-
ment that are apply to EPA laboratories:
generator treatment and treatment at a
facility with a permit or interim status.
Generator treatment may be performed
on-site in tanks or containers (or contain-
ment buildings) in conformance with the
genera-tor requirements in 40 CFR 262.
Generator treatment commonly includes
gravity separation, elementary neutraliza-
tion, and chemical precipitation. The stan-
dards for generator treatment are the same
as for 90- and 180-day hazardous waste
accumulation operations. Refer to section
5.4 of this chapter for those requirements.
Note that the addition of absorbent mate-
rial to waste in a container or the addition
of waste to the absorbent material in a con-
tainer is allowed, provided:
• These actions occur at the time waste
is first placed in the containers.
• Such mixing does not result in incom-
patible waste reactions.
• The container does not leak.
• The container is compatible with the
mixture.
EPA laboratories typically do not have
permitted or interim status treatment facili-
ties. Rather, they send waste to a licensed
off-site facility. As a good management
practice, EPA laboratories should perform
necessary research on prospective treat-
ment vendors to ensure that EPA labora-
tory waste is managed in accordance with
required regulations.
5.5.5 Storage
On rare occasions some EPA laboratories
may store waste for longer periods than
allowed under the generator regulations
(i.e., 90 days for LQGs and 180 days for
SQGs, with few exceptions). Such storage
is permitted only if the laboratory has
been granted a hazardous waste pennit
or interim status. The standards for manag-
ing a permitted or interim status laboratory
are extensive. In addition to all of the
requirements discussed for LQGs, a stor-
age facility must establish a comprehen-
sive inspection program, design tank or
container storage areas to minimize the
potential for a release, and implement
additional recordkeeping requirements.
The interim status standards for container
and tank storage are discussed in 40 CFR
265, Subparts I and 3, respectively.
5.5.6 Disposal
EPA laboratories do not operate hazardous
waste treatment storage d disposal
facilities. Laboratories who contract with
hazardous waste TSDFs should review
regulatory status and history of vendors
to ensure minimal risk to the EPA. In par-
ticular, the contracted TSDF should treat
EPA waste such that they meet the land
disposal restriction requirements
prior to land disposal.
5.6 Recordkeeping and Reporting
Generators have a number of record-
keeping and reporting requirements that
vary, depending on generator status.
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5.6.1 LQGs
An LQG must maintain the following
records:
• A copy of each manifest signed by the
designated TSDF that received the
waste (If the manifest is not received
signed from the TSDF [ in which case
an exception report would need to be
submitted], then the LQG must keep
the copy of the manifest signed when
the shipment was provided to the
transporter. These records must be
retained for at least three years from
the latest date on the manifest.)
• A copy of each biennial report and
exception report for a period of at
least three years from the due date
of the report
• Any test results, waste analyses, or
other waste determinations for at
least three years from the date that
the waste was last sent to a TSDF
• Training records on current person-
nel (These must be kept until closure
of the laboratory. Training records
on former employees must be kept
for at least three years from the date
the employee last worked at the
laboratory.)
• Copies of all notices, certifications,
demonstrations, waste analysis data,
and other documentation produced
pursuant to the LDRs for at least five
years from the date that the waste that
is the subject of such documentation
was last sent for on-site or off-site
treatment, storage, or disposal
An LQG must prepare and submit a
biennial report due March 1 of each even
numbered year. The biennial report must
be submitted on a form prescribed by the
applicable regulatory agency and must
include the following information:
• The EPA identification number, name,
and address of the generator
• The calendar year covered by the
report
• The EPA identification number, name,
and address for each TSDF in the
United States to which waste was
shipped during the year
• The name and EPA identification
number of each transporter used dur-
ing the reporting year for shipments to
a TSDF within the United States
• A description, EPA hazardous waste
number, DOT hazard class, and quan-
tity of each hazardous waste shipped
off-site for shipments to a TSDF
within the United States
• A description of the efforts undertaken
during the year to reduce the volume
and toxicity of waste generated
• A description of the changes in vol-
ume and toxicity of waste actually
achieved during the year in compari-
son to previous years
5.6.2 SQGs
An SQG must maintain the following
records:
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• A copy of each manifest signed by
the designated TSDF that received
the waste. if the manifest is not
received signed from the TSDF then
the SQO must keep the copy of the
manifest signed when the shipment
was provided to the transporter. These
records must be retained for at least
three years from the latest date on the
manifest.
• Any test results, waste analyses, or
other waste determinations for at least
three years from the date that the
waste was last sent to a TSDF.
5.6.3 CESQGs
Although CESQGs do not have specific
recordkeeping and reporting requirements
in the regulations, it is a good management
practice to maintain copies of waste deter-
minations, shipping papers, and other doc-
umentation necessary to demonstrate that
the laboratory generated and accumulated
wastes in such quantities as to justify the
designation of the laboratory as a CESQO.
6.0 Infectious Waste
EPA laboratories may generate
infectious wastes through both
occupational health and re-
search activities. Information
regarding infectious materials is included
in Chapter C7 of this manual.
6.1 Identification and Inventory
Types of infectious waste streams that may
be present at EPA laboratories include the
following:
• Pathological specimens (e.g., tissues,
blood samples, excreta, secretions
from patients/laboratory animals, etc.)
• Any substance that may harbor or
transmit pathogenic organisms
Although the amounts of such wastes may
vary considerably, depending on the nature
of current laboratory experiments, labora-
tories should attempt to quantify and track
the approximate usage. Several states
require generators to complete annual
reports of the amount of infectious waste
generated.
6.2 Characterization
Laboratories should ensure that infectious
wastes are appropriately characterized and
managed in accordance with applicable
federal and state regulations.
6.3 Applicable Regulations
Federal regulation 40 CFR 243, “Guide-
lines for the Storage and Collection of
Residential, Commercial, and Institutional
Solid Waste,” governs the collection of
infectious waste. The section on radioac-
tive waste discusses management of infec-
tious waste with radioactivity. Typically,
states have specific regulations for manag-
ing infectious waste.
64 Collection and Storage
infectious waste should be
segregated from other
wastes into containers that
prevent contact with infec-
tious agents. Infectious wastes must never
be handled without protective gloves.
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Generally, “sharps” (e.g., bro-
ken glassware, needles) should
4j be contained in rigid plastic
con-tainers displaying the uni-
versal biohazard symbol. Other
infectious wastes may be stored in plastic
bags displaying the universal biohazard
symbol. Containers should be covered and
secured from unauthorized access.
EPA laboratories that employ vendors for
infectious waste treatment and/or disposal
must verify that the vendor has all appro-
priate approvals to manage such waste. In
addition, EPA laboratories should retain
records of any infectious waste disposed.
(Note: Several states require generators
to complete man (fests. I
6.5 Transportation and Disposal
7.0 Radioactive Waste
The majority of infectious waste generated
by EPA laboratories will be transported
off-site by a licensed medical waste ven-
dor for ultimate treatment and disposal.
The vendor will provide instructions on
proper packaging of the waste. Generally,
the container must be labeled with genera-
tor identification information and the blo-
hazard label or equivalent.
Some states require that transporters of
infectious waste maintain certain permits;
each EPA laboratory should consult its
state’s regulations to determine if this
requirement is applicable.
DEPc s I
--J !
Some facilities may operate
an autoclave or other device
to pretreat waste prior to dis-
posal. Autoclaving destroys
biological agents and renders
the resultant waste noninfec-
tious. For facilities that treat
infectious waste, it is important to develop
a procedure describing the specific steps
for operating the treatment system,
including:
• Waste acceptance criteria
• Unit operation
• Unit maintenance program
• Recordkeeping
Although a separate issue from the dis-
posal of hazardous waste, the handling
and disposal of radioactive wastes should
be clearly addressed in all EPA laboratory
waste management programs. Because of
the unique hazards associated with radio-
active materials, this aspect of the waste
management program should be imple-
mented and overseen by the Radiation
Safety Officer (RSO) or other qualified
person with experience in radiation safety.
This section of the manual outlines the
low-level radioactive waste (LLRW)
management guidelines and procedures
in effect at EPA laboratories. For more
information on radiation safety practices
refer to Chapter C6 of this manual. The
radioactive waste generated at EPA
laboratories is primarily managed by
decay-in-storage, sanitary sewer disposal,
and interim storage pending final disposi-
tion (e.g., off-site burial, or incineration).
In the interest of occupational and public
safety and health, as well as maintaining
exposures as low as reasonably achievable
(ALARA). the length of time LLRW is
placed in storage should be kept to a
minimum. Also, radioactive waste should
be treated, either on or off-site, to the
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maximum extent possible, to achieve
maximum volume reduction prior to
landburial.
7.1 Identification and Inventory
Radioactive waste results from the use
of radioisotopes, which can be found
in either liquid or solid form, or from
radiation-generating machines. Waste
is segregated according to physical form
(e.g., liquid, solid, scintillation vials, etc.)
and by radionuclide. Since the cost of dis-
posal will depend directly on the volume
and weight of the radioactive waste pro-
duced, minimization of radioactive wastes
is essential, and requires advanced plan-
ning, facility and equipment design, and
control of work methods. It is essential
to separate ordinary nonradioactive trash
from solid radioactive waste at the point
of origin. For this reason, solid radio-
active waste containers should be clearly
identified with the radiation symbol and
easily distinguishable from ordinary hash
containers.
Radioactive waste streams
generated should be continually
evaluated to ensure that reason-
able waste avoidance tech-
niques are employed. The major
radioactive waste streams produced at
EPA laboratories include solids; liquids;
liquid scintillation vials; and animal car-
casses, parts, or bedding. Each of these
categories are in Table C 14-2.
be initiated, the project officer or branch
chief managing the project must present a
plan for waste disposal to the RSO and
SHEMP Manager. This plan must include:
• A waste volume estimate
• Chemical form(s)
• The anticipated activity of the waste
(specific and total)
• The number and frequency of waste
samples to be analyzed
When historic data are available for a par-
ticular group of samples and the waste
streams have been previously analyzed, it
may be possible to analyze the waste
streams using a representative percentage
of samples to verify previously observed
trends. When these data are not available,
a representative sample from all waste
streams must be collected for analysis.
Sample screening data, obtained after
sample receipt, can be used to select an
appropriate sample for waste stream analy-
sis. Samples suspected of containing the
highest concentrations of radioactive mate-
rials should be selected for waste stream
characterization.
All waste analysis results submitted to
the RSO must be in writing. After evalua-
tion by the RSO, a copy of the results must
be returned to the employee with recom-
mendations for disposal. If the waste
requires off-site disposal, the RSO must
make the appropriate arrangements.
7.3 Applicable Regulations
7.2 Radioactive Waste Characterization
All waste streams must be characterized
to determine an appropriate means of dis-
posal. Before a new project or process can
The Nuclear Regulatory Commission has
regulatory authority over storage and dis-
posal of all LLRW. Regulations require
conformance with minimum acceptable
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Table C14-2: Radioactive Waste Streams
C14. Waste Management Program
Type
Example
Solid
Paper, plastic, gloves, bench covers, Eppendorl tubes
Liquid scintillation vials
Environmental samples (e.g., soil, rock)
Precipitates, resins, residues
Liquid
Acids, solvents, washwater
Environmental samples
Animals
Carcasses, tissues, organs, excreta, bedding
performance criteria for waste manage-
ment activities, while providing for flexi-
bility in technological approach. These
criteria and guidelines are designed to
ensure adequate protection of the public
safety and health, and the environment.
LLRW are commonly buried in near-
surface shallow trenches, usually in their
shipping containers. There is no intent to
recover the wastes once they are buried.
There were once six operating commercial
facilities in the United States licensed to
bury LLRW. Now, only Hanford, Wash-
ington, and Barnwell, South Carolina are
receiving waste for burial. The two cur-
rently operating commercial burial
grounds are located in Agreement States
and are regulated by the states. However,
the NRC licenses special nuclear material
because the quantities received by the
commercial operator exceed those that the
Agreement States may license under their
agreements. The sites are all commercially
operated.
10 CFR 61 of the NRC’s regulations set
forth the procedures, criteria, terms and
conditions for licensing sites for land
disposal of LLRW. These requirements
also provide the basis for Agreement State
regulation, since state rules must be com-
patible with NRC requirements.
7.4 Collection and Storage
Radioactive waste must be collected into
designated receptacles in the laboratory,
depending on the type of waste.
7.4.1 Plexiglass Boxes
The primary containers for collection of
dry solid radioactive waste in the labora-
tory are plexiglass boxes (bins) that are
built into the laboratory cabinets at the
end of the work bench. The boxes are
lined with thick, yellow-striped, clear
plastic bags.
7.4.2 Waste Cans
All laboratories that produce solid radioac-
tive waste must be provided with a clearly
labeled radioactive waste can. Each can
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should be lined with a yellow plastic waste
bag. The bag should be labeled to show
the radionuclides present in the waste, the
dates of waste accumulation, and the labo-
ratory in which it was generated. When the
solid waste bags are filled, or if the expo-
sure rate at the surface of the waste can
exceeds 0.25 milliroentgen per hour
(mR/h), the RSO should be contacted to
remove the waste from the laboratory.
7.4.3 Liquid Waste
It is recommended that liquid waste be
collected in polyethylene bottles (4 to 20
liters in size) whenever feasible. Unlike
glass bottles, these are unbreakable, pro-
duce less secondary radiation, are impervi-
ous to most organic chemicals, and do not
form sharp edges when compacted.
7.4.4 Liquid Scintillation Cocktails
and Animal Carcasses
Liquid scintillation cocktails and animal
carcasses containing hydrogen-3 and
carbon-14 which fall below NRC de mini-
mis level of 0.05 microcuries per gram
( .tCiIg) should be separated from other
non.de minimis wastes. There are gener-
ally other, lower cost disposal options for
these de minimis wastes.
7.4.5 Recordkeeping
A logsheet must be attached to each bin or
step-can for scientific staff to enter the
following disposal data:
• Isotope
• Amount of activity
• Users’ initials
• Disposal date
Waste generated in the laboratory must
be segregated and disposed of according
to physical form and radionucide. All
radio-active material caution tape, as well
as signs and labels, must be obliterated or
defaced prior to deposit in the appropriate
waste receptacle.
In deciding which waste receptacle to
deposit waste contaminated with two
or more radionuclides, the material must
be disposed of according to the longest-
lived component. Generally, hydrogen-3
and carbon-14 may be disposed of in the
same waste container.
When emptying a radioactive waste
receptacle:
• Remove the bag from the waste
receptacle.
• Visually inspect waste for sharp items
and radiation warning labels.
• Mark the bag with the radioisotope.
• Place the bag in a totally-enclosed
lucite cart that is wheeled between
laboratories and augmented with lead
shielding when required.
The cart should then be fransported to the
nearest radioactive waste handling room
for processing or temporary storage.
7.5 Transportation and Disposal
The waste producer is required to provide
documentation of the identity and esti-
mated quantity of radioactivity, and to
ensure that the waste is properly labeled
and contained. Each package of radioac-
tive material, unless excepted, must be
labeled on two opposite sides with a dis-
tinct warning label. The purpose of the
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label is to alert personnel that the package
contains radioactive materials and that
special handling may be required. The
determination of the proper label to use is
based on the criteria contained in 49 CFR
172.403.
Radiation surveys should be conducted
for each container to determine the exter-
nal radiation levels and to detect possible
surface contamination. Radiation limits
for the external dose rate and removable
surface contamination on packaging have
been established by the DOT and can be
found in 49 CFR 173. 11 survey results
are within these regulatory limits, the
waste container may be prepared for
transportation to a waste disposal area.
Waste brokers accept packed waste
drums and transport them to a final
disposal site.
7.5.1 Waste Storage
Radioactive waste in storage must be
housed in rooms exclusively dedicated
for this purpose. These rooms should
be located in areas of the laboratories
designed for low traffic, secured against
unauthorized entry when not continuously
attended, and monitored by surveillance
equipment and security staff during non-
business hours.
Radioactive waste held for decay-in-
storage or interim storage must be pro-
cessed in accordance with ALARA
techniques (as discussed in Chapter
C6 of this manual) and in anticipation
of ultimate disposition.
Solid wastes should be stored on-site in
55-gallon drums until a sufficient volume
has accumulated for a radioactive waste
shipment to a licensed low-level radioac-
tive waste disposal facility. The contents
of the drums must meet NRC and DOT
regulations, as well as the requirements
of the low-level waste disposal facility.
7.5.2 Discharge
Discharge of small quantities of liquid
radioactive waste is allowed by the NRC
in specifically designated laboratory sinks.
The liquid radioactive waste must:
• Be readily soluble or dispersible in
water
• Not contain chemically or biologically
hazardous components
The average concentration disposed of
in this manner must not exceed the limits
specified in Appendix B of 10 CPR 20.
These limits, which must be posted on
each designated sink, are the maximum
daily average quantities that may be dis-
posed of into the laboratory drain. A
record of the nuclide, quantity disposed,
and date of disposal should be recorded
on a logsheet that is collected by radiation
safety staff.
If a liquid waste cannot be
disposed of by discharge to
the sanitary sewer, it may be
precipitated and dried or
evaporated, and treated as a
________ solid waste.
7.5.3 Decay-in-Storage (DIS) Program
An EPA laboratory may be licensed to
perform DIS until the activity decays
if the radionuclide is short-lived. The
NRC considers that materials with half-
lives under 65 days may be managed by
storage-for-decay. The NRC may also con-
sider storage-for-decay for isotopes with
RADIATION
UA OACIWE
WASTE
PRO SBrTEC
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half-lives greater than 65 days on a permit-
by-permit basis. These options may be
im-practical if the half-life is greater than
about 30 days.
After a storage interval of 10 half-lives,
the waste should be surveyed at the con-
tainer surface with a pancake Geiger-
Mueller (GM) survey meter. If no activity
above background is observed, the waste
may be disposed of as nonradioactive.
This waste, now deemed “cold,” is gener-
ally disposed of via shredding and ship-
ment to a landfill, or incineration.
7.5.4 Extended Interim Storage
Radioactive waste not suitable for decay-
in-storage must be prepared, processed,
and stored pending transfer off-site. This
waste is further processed (via super-
compaction or incineration) and ultimately
land-buried. Generally, radio-active waste
containing hydrogen-3 and carbon-14
should be handled in this manner. This
method of storage must also be licensed
by the NRC or an NRC Agreement State.
7.5.5 Radioactive Waste Minimization
Radioactive waste minimization involves
treatment and processing techniques to
either reduce the volume generated or to
render the waste nonhazardous (i.e., no
longer radioactive). Where practical, the
following techniques should be used to
minimize the generation of radioactive
waste:
• Share and reuse radioisotope source
vials that come in larger-than-required
quantities (e.g., stock a supply of mu-
licurie quantities for multiple users)
or pay the extra cost for the smaller
quantity that is generally regarded as
a custom order.
• Plan and practice experimental proce-
dures in advance to ensure that nonra-
dioactive items are not inadvertently
contaminated.
• Use reusable spill trays instead of lay-
ers of absorbent paper to define and
protect the work area.
• Wear reusable protective clothing,
such as cotton laboratory coats that
are laundered instead of discarded as
waste.
• For large items that are partially con-
taminated and cannot be sufficiently
cleaned. cut out and dispose of Only
the contaminated portion as radio-
active waste.
• Decontaminate plastic plates, tips, and
glassware by soaking the items in a
mixture of detergent for a few days to
render the waste nonradioactive. The
cleaning solution can then be disposed
of via the sanitary sewer system.
• Carefully segregate leftover reagents,
boxes, and packing material and dis-
pose of them as nonradioacfive.
Use nonradloactive alternatives.
• Substitute radioactive material with
shorter half-lives (e.g., P-33 for S-35).
The approximate amount of radioactive
waste generated in a given period should
be quantified, with results tracked for
waste minimization purposes.
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7.6 Mixed Waste
Cl4. Waste Management Program
Mixed Waste Management
Some EPA laboratories may generate
mixed waste, or waste containing both
hazardous waste and source, special
nuclear, or byproduct radioactive material.
Such laboratories must satisfy the require-
ments of both the NRC regulations under
the AEA and the EPA regulations under
RCRA.
7.6.1 Radioactive Components
The radioactive component of mixed
wastes is classified as LLRW. Any class
of radio-active waste that contains a haz-
ardous waste, as defined in RCRA, is
considered mixed waste. Categories of
radioactive mixed waste include liquid
scintillation fluid (LSF), waste oil, chlori-
nated fluorocarbons, cadmium, lead,
mercury, and aqueous corrosives. The
liquid scintillation counting (LSC) fluids
category is the largest mixed waste gener-
ated by EPA laboratories. LSC fluids usu-
ally contain toluene and xylene, and may
sometimes contain benzene or
pseudocumene.
7.6.2 Mixed-Waste Management
Program
The NRC and the EPA require mixed-
waste generators to establish a mixed-
waste management program that includes
the following elements:
4
Categorize Hazardous or
Radioactive Waste
Establish Waste
Minimization Practices
4
Obtain Appropriate
Waste Storage Permits
Adhere to Storage-For-
Decay Guidelines
Obtain Approval to Use
Alternative Treatment
Methods for Mixed Use
7.6.3 Source Reduction and
Avoidance Management
Types of source reduction and avoidance
management activities that can be imple-
mented for mixed wastes include the
following:
• Substitution and/or use of biodegrad-
able solvents
• Waste segregation and separation
• Process modifications
• Recycling
• Storage-for-decay
• Administrative controls
Additional information on mixed waste
can be found in the EPA SHEM Guide 41.
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8.0 Special Waste
“Special waste” refers to wastes that are
neither nonhazardous nor hazardous.
These wastes are usually considered
“industrial wastes.” Specific state regula-
tions must be applied to, and followed in,
the management of such wastes.
8.1 Identification and Inventory
Types of special wastes that, depending
on the individual laboratory’s state of
residence, may be present at EPA laborato-
ries include (but are not limited to) the
following:
• Contaminated soils
• Grinding dusts
• Asbestos
• Waste oils
• Antifreeze
• Dried paint wastes
• Wastewater treatment sludges
• Batteries
ff f .J
The approximate amount of special waste
generated in a given period should be
quantified, with results tracked for waste
minimization purposes.
8.2 Characterization
Prior to categorizing wastes as special
wastes, many states require that wastes
are evaluated and determined to be
nonhazardous.
8.3 Applicable Regulations
Special wastes axe regulated at the state
level. As such, an all-inclusive list of
these wastes does not exist. States that
have special waste regulations include, but
are not limited to, the following:
• Connecticut
• Florida
• illinois
• Massachusetts
• Washington
8.4 CollectIon and Storage
General special waste collection and stor-
age practices that should be followed at
EPA laboratories include:
• Storing special wastes in an environ-
mentally safe manner.
• Ensuring that containers are in good
condition (e.g., not leaking, container
materials compatible with waste con-
mined within, etc.)
• Reporting any special waste spills to
the regulating agency, as appropriate.
Specific state regulations should be con-
sulted for additional collection and storage
requirements.
8.5 Transportation and Disposal
General special waste transportation and
disposal practices that should be followed
at EPA laboratories include:
• Using manifests when transporting
special wastes for treatment and/or
disposal, if required
• Using licensed transporters for ship-
ping special wastes
• Disposing of special wastes only at
facilities that are licensed in accor-
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laratory SHE Programs
C14. Waste Management Program
dance with the requirements of the
state where the disposal facility is
located
Selecting and using appropriate dis-
posal options (e.g., landfihling)
Specific state regulations should be con-
sulted for additional transportation and
disposal requirements.
9.0 PCB Waste
• Sludges and slurries
• Dredge materials
• Soils
• Materials contaminated as a result of
spills
• Other chemical substances or
combination of substances
The approximate amount of PCB waste
generated in a given period should be
quantified, with results tracked for waste
minimization purposes.
This section establishes prohibitions of 1
and requirements for, the use, disposal,
storage, and marking of polychiorinated
biphenyls (PCBs) and PCB items (i.e.,
any PCB-containing article, article con-
tainer, container, or equipment that delib-
erately or unintentionally contains PCBs).
Most of the federal provisions apply to
PCBs only if PCBs are present in concen-
trations above a specified level (e.g., at or
above 50 ppm). No provision specifying a
PCB concentration may be avoided as a
result of any dilution, unless otherwise
specifically provided in applicable regula-
tions. Refer to Chapter C15 of this manual
for more information on the regulation and
management of PCBs.
9.2 PCB Waste Characterization
If a waste solution, mixture, or material
is known or suspected to be contaminated
with PCBs, such items must be charac-
terized as PCB-containing (greater than
or equal to 50 ppm PCBs) or as non-PCB-
containing (less than 50 ppm PCBs) prior
to transportation and/or disposal.
9.3 Applicable Regulations
Federal regulations for the handling, stor-
age, disposal, and reporting of materials
containing PCBs in concentrations greater
than 50 ppm are regulated under the Toxic
Substances Control Act (TSCA). Applica-
ble regulations are listed in 40 CFR 761.
9.1 Identification and Inventory
Regulated substances that may be present
at EPA laboratories include, but are not
limited to, the following:
• Dielectric fluids
• Contaminated solvents
• Oils and waste oils
• Heat transfer fluids
• Hydraulic fluids
• Paints
Because states may have additional PCB
regulations, EPA laboratories should con-
sult their specific state regulations for
more information.
9.4 Collection and Storage
Proper PCB waste collection and storage
includes specific marking and storage
requirements as well as the development
of specific spill prevention, control, and
&EP4 1 June 1998
C14-31
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C14. Waste Management Program
countermeasure practices.
9.4.1 Marking Requirements
Any container holding PCBs in a concen-
tration greater than 50 ppm must be
marked with a label stating:
Caution (Note: Any container,
contains piece of equipment, arti-
PCB’s cle, etc., determined to
have PCBs in concentra-
:wns less than 50 ppm
should be marked with a label that reads,
‘ This (container, equipment, article, etc.)
does not contain PCBs.”]
9.4.2 Storage
Containers used for the storage of wastes
containing PCBs in concentrations greater
than or equal to 50 ppm must comply
with the following DOT container specifi-
cations:
• Label the container with a PCB label.
• Mark the container with the dale when
the waste was first added.
• Maintain secondary containment and a
running inventory that lists the date
and amount and type of material being
accumulated.
Wastes with PCBs in concentrations less
than 50 ppm should be placed in a poly-
bottle or smaller container (if possible).
The container should be marked with the
same requirements as previously men-
tioned for wastes containing PCBs in
concentrations greater than or equal to
Any PCB container designated for disposal
must be removed from temporary storage
within 30 days and disposed of within one
year from the date it was first placed in
storage.
Waste storage areas must be provided with
the following:
• Adequate roof and walls to prevent
rainwater from reaching the stored
PCBs and PCB items
• An adequate floor that has a continu-
ous curb at least six inches high and
that provides a containment volume
equal to at least two times the internal
volume of the largest PCB article or
PCB container stored therein, or 25
percent of the total internal volume of
all PCB articles or PCB containers
stored therein, whichever is greater
• A floor designed without drain valves,
floor drains, expansion joints, sewer
lines, or other openings that would
permit liquids to flow from the curbed
area
• Floors and curbing constructed of
continuous smooth and impervious
materials, to prevent or minimize
penetration of PCBs
In addition, storage areas must not be
located at a site that is below the 100-year
flood water elevation.
9.4.3 Spill Prevention, Confrol and
Countermeasure (SPCC) Plan
EPA laboratories that generate PCB
wastes during the course of laboratory
analyses must ensure that their SPCC
50 ppm.
June [ 998
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laboratory SHE Programs
C14. Waste Management Program
plans address the following:
• Securing all PCB-containing materials
in a closed primary container with sec-
ondary containment
• Ensuring that measures are in place
to arrest the spread of a spilled mate-
rial, to clear personnel from the imnle-
diate area of the spill 1 and to notify the
appropriate emergency coordinator
• Disposing of all used decontamination
materials as contaminated PCB waste
• Activating the laboratory hazardous
waste contingency plan in the event
of a spill/release of PCB-contaminated
materials that has the potential to
damage human health or the
environment. Chapter C13 of this
manual provides specific guidance on
SPCC programs
• Providing absorbent material to clean
up spills that occur outside the second-
aiy containment
• Placing spill cleanup materials in PCB
waste containers and disposing of con-
tainers in accordance with applicable
regulations
• Decontaminating all surfaces conta-
minated by spilled PCB-contaming
materials by triple rinsing with a suit-
able solvent (e.g., acetone)
Table C14-3: PCB Waste Disposal Practices
9.5 Transportation and Disposal
All PCB waste materials should be trans-
ported off-site to an approved waste man-
agement facility, in addition, all PCB
waste materials should be disposed of
in accordance with the practices in Table
C14-3. Records of all PCB waste trans-
ports and/or disposals should be
maintained.
, — — ,
Wáste’Type
, -
- DiSp sàl
PCBs of concentrations
Permitted hazardous waste treannent facility
ppm
Approved incinerator at a permitted PCB disposal facility
PCB discharges at concen-
Incineration
concentrations 500 ppm
Incineration
contain only PCBs at a con-
Municipal solid waste disposal
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CH pmR C
Attachment C 14-1: Hazardous Waste Drum Storage Area Inspection Checklist
Purpose: To provide an example of an inspection checklist for a hazardous waste
drum storage area.
Instructions: Use this checklist when inspecting hazardous waste storage areas to help
determine if storage practices are consistent with regulatory requirements.
&EPA June 1998 C14-34
-------
Hazardous Waste Drum Storage Area Inspection Checklist
Date: Hazardous Waste Drum Storage Area:
inspector:
Question Yes No
Container Condition
Is the area free from evidence of leaks and spills?
Are all containers securely closed?
Are all containers marked with the words “Hazardous Waste,” the waste
description, and the date of accumulation?
Are all container dates within the allowed accumulation time frame?
Are all containers free from signs of colTosion or evidence of bulging?
Container Arrangement
Is aisle space sufficient for inspection of all containers?
Are labels on all containers readable?
Are containers properly positioned (i.e., not stacked more than two high, etc.)
Are containers with different labels properly separated?
Can emergency equipment access the area?
Containment
Is any accumulated precipitation free from evidence of ‘eaks and spills?
Are the floor and containment devices free from cracks and other deficiencies?
Is the drain valve locked in the closed position?
Emer gency Equipment
Is the emergency equipment cabinet fully stocked, as per the inventory list?
Is the communication device nearby and functioning?
Are notification procedures posted near the communication device?
Are fire extinguishers readily available?
Are warning signs clearly visible?
Note: Immediately report any “NO” answers to your supervisor.
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SHE!ifF Operations Manual for Laboratories
CHAFrER C
Attachment 04-2: Waste Minimization Tcclmiques
Purpose: To evaluate current waste minimization activities and provide guidance on
how to perform more waste minimization.
Instructions: Answer the questions pertaining to current waste minimization. The ques-
tions that were answered “No” are areas that may need additional waste
minimization.
R4 I June 1998 C14-36
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Waste Minimization Techniques
To reduce excess wastes, do you:
Yes
No
1. Buy and keep on hand only the amount of raw material needed?
2. Use_recyclable_materials when_possible?
3. Use raw materials sparingly so that excess waste is not generated?
4. Use raw materials in correct proportions so that excess waste is not
generated by making defective products/formulations?
5. Ensure that all containers free from signs of corrosion or evidence of
bulging?
6. Check for faulty valves/pipes to ensure that the product is not being lost
from the system or unintentionally contaminated?
7. Ensure that all products and Wastes are inventoried, clearly labeled, and
properly stored?
8. Segregate wastes to assess the potential for recycle, reuse, or resale of the
wastes?
9. Substitute any nonhazardous products for hazardous materials?
10. Use only as much of a hazardous substance as ajob requires?
11. Use an entire product (rather than throw away partially filled containers)?
12. Use existing materials more efficiently (i.e., make double-sided
photocopies)?
13. Encourage the use of technological changes (e.g., changes in the produc-
tion process, use of automation, etc.) that reduce wastes/eliminate ineffi-
ciencies, enhance recovery of recycling options, increase product yields,
and decrease probability of error?
14. Check the optimum settings for certain parameters (i.e., flow rates, resi-
dence times, temperatures, pressures)?
15. Refrain from mixing hazardous Wastes with nonhazardous/different
wastes?
16. Use waste concentration/water conservation to minimize hazardous waste
generation?
17. Avoid producing/transfemng spills and leaks?
18. Conserve energy?
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SHEMP Operations Manual for Laboratories
CHAPTER C
Attachment C 14-3: Hazardous Waste Accumulation Area Inspection Checklist
Purpose: To provide an example of a checklist that can be used to inspect hazardous
waste accumulation areas.
Instructions: Answer the questions based on observations at a hazardous waste accumula-
tion area. Any questions that are answered “No” should be addressed
immediately.
&EPA June 1998 C14-38
-------
HAZARDOUS WASTE ACCUMULATION AREA
INSPECTION CHECKLIST
DATE: INSPECTED BY:
BUILDING: ROOM:
YES NO
I. Aretheareasfreeofevidenceofleaksorspills?
2. Are all containers securely closed?
3. Are containers free of signs of corrosion, leaks, or other deterioration?
4. Are containers compatible with the hazardous waste stored in them and do
they meet DOT standards?
5. Is there adequate aisle space?
6. Are containers handled in a safe way as to prevent leaking or rupture?
7. Are hazardous waste labels present, visible, and readable?
8. Are Accumulation Start Dates present, visible and readable?
9. Are incompatible wastes placed in the different containers?
10. Is the required emergency equipment present?
11. Is the required communication device present and functioning?
12. Are notification instructions posted neaz the communication device?
Remarks:
Signed:
Inspector
Reviewed By:
Date:______________________________
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Cl 5.
TSCA Program
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
1.0 Introduction
The Toxic Substances Control Act
(TSCA) is intended to ensure that “new”
chemical substances are appropriately
evaluated before they are introduced into
commerce in the United States; to collect
information on chemicals that are already
in use; and to control the manufacture,
processing, distribution, use, storage, and
disposal of particular categories of toxic
substances (most particularly polychlori-
nated biphenyls [ PCBs]). Major provisions
of TSCA include:
• Development and maintenance of a
master inventory of all “existing”
chemical substances in commerce in
the United States
• Specification of notification require-
ments for the manufacture, importa-
tion, or processing of “new” chemical
substances (i.e., those not already on
the TSCA inventory)
• Requirements for gathering safety and
environmental data for specific chemi-
cals if the EPA laboratory determines
that they may pose an unreasonable
risk of injury, or when there is poten-
tial for significant environmental or
human exposure
• Regulation of existing chemicals
(including prohibition or limitation
of production) if the laboratory
determines that they pose an unreason-
able risk of injury to health or the
environment
C15. TSCA Program
Prohibition of and requirements for
the manufacture, processing, distri-
bution in commerce, use, disposal,
storage, and marking of PCBs and
PCB items
TSCA applies to United States federal
government agencies, to state and local
government agencies, and to private
business entities. However, virtually all
sections of TSCA apply only to those
entities (private or public sector) that
manufacture, import, process, or distribute
chemical substances for commercial
purposes. Since EPA laboratories are not-
for-profit entities, their activities do not
generate commercial advantage either for
the laboratory or for the agency as a whole.
Therefore, they are not subject to most
TSCA requirements that relate to “new”
chemical substances introduced into
commerce.
In contrast to the TSCA requirements for
“new” chemicals, which apply only to
those entities that manufacture, import, or
process the substances, the PCB require-
ments (40 CFR 761) also apply to any
entity that uses, disposes of, or stores
PCBs or PCB items. Two possible
scenarios under which EPA laboratories
could be subject to TSCA requirements are
listed below:
The laboratory uses small quantities
of PCBs for research and development
purposes, including use as analytical
standards.
&EF t June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs C15. TSCA Program
The laboratory’s infrastructure
incorporates PCB-contaminated
electrical equipment, PCB trans.
formers, or PCB-contaimng items
such as fluorescent light ballasts.
In addition to the PCB scenarios above,
the following activities involving “new”
chemical substances, if undertaken on the
laboratory’s behalf, could trigger some
TSCA obligations:
• Serving as the importer of record for a
new-to-the-United States chemical
substance
• Exporting specific chemicals
EPA Program Requirements
To ensure that requirements are met under
the TSCA, EPA laboratories must:
• Determine the applicability of the
TSCA’s regulations, which are out-
lined in the Table C15-l.
• Label TSCA-regulated materials.
• Store and dispose of applicable
materials as regulated.
• Maintain related records
Program Administration
To effectively manage a program
addressing TSCA requirements,
responsibilities should be assigned for:
• Determining the applicability of
TSCA requirements to the laboratory
• Providing appropriate labeling on
applicable materials
• Ensuring proper storage and disposal
of applicable materials
• Reporting and cleaning spills of
applicable materials
June 1998 C152
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laboratory SHE Programs C15. TSCA Program
Table C15-1: Toxic Substances Control Requirements
Regulailors
Key
Requirements
Ezesupabma
suit?
(YIN)
Chapter 16 Sectioul
CVR Roferewems
Key CharadistiWFeature(s)
TSCA Inventory
Reporting
Y
Small quantities for ressaith and development
(R&D) exemption
16.2140 CFR 710
Premanufacture
Notice
Reporting
V
Exempt if
• Small quantities for R&D
• Extployees notified of potential health risks
• Technically qualified supervisor uses the
substance
16.3/40 CPR 720
Significant New
Use Rule (SNUR)
Repomng
Y
Sante exemption criteria as those for
Premanufacnire Notice
16.4/40 CFR 721
Ptebminary
Assessment
Information Rules
(PAD )
Reporting
V
Exempt if chenucals me used solely for
scientific experunentation, analysis, or R&D.
16.5/40 CFR 712
Allegations
Recordkeeping
and Reporting
N
Laboratories must maintain records for
employee allegations of adverse reaction(s) to
chemicals.
16.6140 CFR 717
Reporting Health
and Safety Studies
Reporting
N
• Unpublished studies for listed substances
must be submiuzed to the EPA.
• Exemptions exist only for certain studies.
167/40 CFR 716
Notice of
Substantial Risk
Reporting
N
Laboratories must notify the EPA of any new
substantial risk regarding chemicals or
mixunes.
16.SI4OCFR 717
In iports /Exports
Y: Importing
N: Exporting
Exempt from Importing Notification
requirements if the exemption criteria for
Premanufacture Notice are met
16.9/40 CFR 707
Chemical-Specific
Test Rules
N
Labosetones must submit certain data for
chemicals or sniatwes listed in Subpart B for a
given testing period.
16.10140 CFR 799
PCB Management
Labeling and
storage of PCB.
containing
equipment
Y
Exemptions exist far
• PCB concentrations <50 ppm
• Small quantities for R&D
16.11.2 /40 CFR 761
PCE Disposal
Notification and
recordkeeping
N
• PCB wastes >50 ppm must be incinerated
• Receiving facility must be approved for
specific waste being shipped.
16.11.3/40 CFR 761
PCB Spill
Procedures for
responding to a
PCBspiIl
N
Specific requirements exist for spills of
materials containing PCB5 with concentrations
>S0pprn
16.1l.4ICFR 761.120
PCB Records
Recordkeeping
and reporting
N
• Labs with a Class Exemption must retain
PCB records for- five years.
16.11.5/40 CFR 761
• Labs prvcessmg/distsibubng more than 22
lbs. of PCBs for R&D iii one year must
notif Sr the EPA.
,EPJfi 1 June 1998 C15-3
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C15. TSCA Program
2.0 Import of “New” Chemical
Substances
If an EPA laboratory imports a chemical
substance into the Customs tethtory of the
United States, it must certify either that
the substance is subject to TSCA anti
complies with all applicable requirements
(positive certification) or that the sub-
stance is not subject to TSCA (negative
certification). As long as the laboratory
does not intend or expect to receive
inunediate or eventual commercial advan-
tage from the substance, it is not subject to
TSCA and the negative certification can be
made. The certification should state:
“I certify that all chemicals in this
shipment are not subject to TSCA.”
3.0 Export of Chemical Substances
An EPA laboratory that intends to export
a chemical substance must first determine
whether any of the following actions have
been taken under TSCA with respect to
that chemical substance:
• Data axe required under TSCA Section
4 or 5(b).
• An order has been issued under TSCA
Section 5.
• A nile has been proposed or promul-
gated under TSCA Section 5 or 6.
• An action is pending or relief has been
granted under TSCA Section 5 or 7.
There is no easy way of making this deter-
mination, and no accessible listing of sub-
stances for which such actions have been
taken. The laboratory is advised to call the
TSCA hot line (1-202-554-1404) or to use
other resources available within the labo-
ratory to make the determination.
For export to a particular country, if the
chemical substance is subject to one of the
TSCA actions listed above, the exporter of
the substance must notify the EPA. Notifi-
cation must take place within one calendar
year and be postmarked within seven days
of “forming the intent” to export, or on the
date of export (whichever is earlier). The
required contents of the notice are:
• Name of the regulated chemical
• Name and address of the exporter
• Country(ies) of import
• Date(s) of export or intended export
• The Section (4.5,6, or 7) of TSCA
under which EPA has taken action
The notice, marked “Section 12(b)
Notice,” is sent to the TSCA Document
Processing Center (TS-790), Office of
Pollution Prevention and Toxics, EPA,
401 M Street, SW, Washington, DC,
20460.
4.0 Poly
Biphenyls (PCBs)
EPA laboratories may use PCBs in small
quantities for the purpose of research and
development (R&D) indefinitely, provided
that:
• Records of their PCB activities are
maintained for a period of five years.
• Sites of PCB activities and the quan-
tity of PCBs to be processed are
reported to the EPA by laboratories
that process more than 100 grams in
a year.
8 1 ft t June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
“Small quantities for research and develop-
ment” means PCBs, in sealed containers of
no more than 5 milliliter volume, that are
used for scientific experimentation or anal-
ysis, or for chemical research on PCBs. It
does not include research and development
(R&D) activities related to developing
PCB products. Also, R&D on disposal
methods using PCBs constitutes “dis-
posal,” under 40 CFR 761.60, and must
comply with these regulations. Such dis-
posal R&D requires approval from the
EPA.
Most waste from R&D activities (e.g.,
used PCB standards, contaminated con-
miners, contaminated laboratory equip-
ment, etc.) is likely to contain less than 50
ppm of PCBs and its disposal is not specif-
ically regulated under TSCA. However, if
EPA laboratories’ R&D activities generate
PCB waste that contains 50 ppm or more
of PCBs, they must use a disposal facility
(incinerator) that is permitted to accept
PCBs and has no outstanding TSCA viola-
tions. Refer to Chapter C14 of this manual
for further discussion on disposal of PCBs.
4.1 PCB Survey and Labeling
EPA laboratories must survey their opera-
tions to determine whether they contain
such items as:
C15. TSCA Program
equipment, other than circuit breakers,
reclosers, and cable, whose PCB con-
tent is unknown, must be assumed to
be PCB-contaminated electrical equip-
ment.)
• PCB Containers—Any packages, cans,
bottles, barrels, drums, tanks, etc.,
used to contain PCBs or PCB articles
and whose surfaces have been in direct
contact with PCBs.
• PCB Articles—Any manufactured
articles, other than a PCB container,
that contain PCBs and whose surfaces
have been in direct contact with PCBs.
If any of the above are present on-site, they
must be marked as illustrated in Figure
C15-1. This label must also be used to
mark areas used for storage of PCB items.
Figure C15-1: Label Example
r oN I
PCBs
IU & & _ - _ aQs pIa
I 76 —F
UA
‘
C Gd P CaIuU ’
I
‘
• PCB-Transformers—Any transformers
containing 500 ppm or more of PCBs
• PCB-Contaminated Electrical Equip-
ment—Any transformers, capacitors,
circuit breakers, voltage regulators,
switches, etc., that contain between
50 and 500 ppm PCBs (Oil-filled
4.2 Storage
PCBs, PCB items, and PCB cleanup debris
over 50 ppm may be stored for up to one
year prior to disposal. Items removed from
service and awaiting disposal must be
stored in areas that have:
• Adequate roof and walls to prevent
infiltration of rainwater
&EPA June 1998
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Laboratory ShE Programs
C15. TSCA Program
• Adequate floors and curbing con-
structed of impervious material
• Secondary containment volume suffi-
cient to hold two times the largest sin-
gle container or 25 percent of the total
• No floor drains or other openings that
would allow release of liquids from
the curbed area
The location must be above the 100-year
flood water elevation. (These requirements
do not apply to temporary [ up to 30 days]
storage of PCB items that are non-leaking,
overpacked, non-liquid, or liquids with
less than 500 ppm PCBs.) PCB storage
areas must be inspected at least every 30
days and records of the inspections must
be maintained.
4.3 Spill Cleanup
Spill requirements vary according to the
size of the spill and the nature of the
receptor. Spills of more than 10 pounds of
PCBs or any spill that directly contami-
nates surface water, sewers, drinking
water supplies, grazing lands, or vegetable
gardens must be reported to the EPA
Regional Office of Prevention, Pesticides,
and Toxic Substances Branch in the short-
est possible time, but never later than 24
hours after discovery. Spills of less than 10
pounds do not need to be reported, but
must be decontaminated within the short-
est possible time after discovery. In sum-
mary, decontamination procedures require:
• Cordoning off the affected area
• Recording and documenting the area
of visual contamination
• Initiating cleanup of all visible traces
• Cleaning of all indoor surfaces to 10
pgIlOO cm 2 , outdoor surfaces to 100
.ig /l00 cm 2 , and soil cleaned to 25
ppm PCBs by weight
This assumes that the spill occurs within a
restricted access area (the laboratory prop-
erty). Other, stricter requirements apply if
the spill reaches areas where people live
or work.
In addition, all other applicable reporting
requirements under the Clean Water Act
and the Comprehensive Environmental
Response, Compensation and Liability
Act must be met. For example, all spills
involving 10 pounds or more by weight
of PCBs must be reported to the National
Response Center (1-800-424-8802). For
additional emergency response informa-
tion, refer to Chapter 02 of this manual.
4.4Recordkecping
Laboratories that use or store, at any one
time, at least 45 kilograms (99.4 pounds)
of PCBs in containers, one or more PCB
transformers, or 50 or more PCB large
(more than 3 pounds of dielectric fluid)
capacitors must maintain records and a
written annual document log. The annual
records must include all manifests and all
Certificates of Disposal received by the
facility during the year. The written docu-
ment log must include the following:
• The name, address, and EPA identifi-
cation number of the laboratory
• The calendar year covered by the log
• The unique number of every manifest
generated during the year
SERk June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs Cl5. TSCA Program
For PCI] items (transformers, capaci-
tors, PCI] containers, etc.), transported
off-site
— A unique identifying number
— A description of the contents (for
containers)
— The total weight (kilograms) of
PCI] in each item
— The date the item (or contents)
was destined for disposal
— The date the item was transported
off-site
— The date of disposal (if known)
For PCB items in service or storage
on-site:
— The total number of items and the
total weight (kilograms) of PCBs
in articles (capacitors or trans-
formers) and containers placed in
storage for disposal during the
calendar year
— The total number of PCI] trans-
formers in service at the end of the
year and the total weight (kilo-
grams) of PCBs in them
— The total number of large PCB
capacitors in service at the end of
the year and the total weight (kilo-
grams) of PCBs in them
— The total weight (kilograms) of
PCBs in containers remaining in
service at the end of the year.
A record of each telephone call or
other method used to confirm receipt
of PCB waste transported by an inde-
pendent transporter
GEPA June 1998 Cl5-7
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Cl 6.
UST Program
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs C16. Underground Storage Tanks
1.0 Introduction
The regulations pertaining to underground
storage tanks (USTs) are designed to pre-
vent spills from overfilled or leaking
tanks. The following guidance will assist
in the management of USTs and UST sys-
tems in accordance with the requirements
under the U.S. Resource Conservation and
Recovery Act (RCRA).
EPA Program Requirements
To ensure that requirements for USTs are
met. EPA laboratories must:
• Ensure that tank designs meet applica-
ble regulations
• Report, investigate, and clean up any
spills
• Submit required reports to the imple-
menting regulatory agency
Program Adminictration
To effectively manage a UST program.
responsibilities should be assigned for:
• Determining if regulations are applica-
ble to the facility
• Ensuring any new tanks meet design
requirements for USTs
• Determining what upgrades may be
necessary on existing tanks
• Providing monitoring for transfer
operations
• Inspecting UST systems
• Submitting reports and maintaining
required records
&ER June 1998 C16-l
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
Cl 6. Underground Storage Tanks
2.0 Applicability of Requirements
A UST is subject to the regulatory require-
ments found in 40 CFR 280 except:
• UST systems holding hazardous
wastes listed, or identified, under
Subtitle C of the Solid Waste Disposal
Act, or a mixture of such hazardous
wastes and other regulated substances
• Wastewater treatment tank systems
that are part of a wastewater treatment
facility regulated under Section 402 or
307(b) of the Clean Water Act
• Equipment or machinery that contain
regulated substances for operational
purposes (e.g., hydraulic lift tanks and
electrical equipment tanks)
• USTs with a capacity of 110 gallons
or less
• USTs that contain a de minimus con-
centration of regulated substances
• Emergency spill or overflow contain-
ment UST system that is expeditiously
emptied after use
UST exemptions vary from state to state.
Specific state regulations for USTs must
be consulted to determine requirements.
3.0 Design and Construction
The regulations define new tanks as USTs
under construction after December 22,
1988. All other USTs are considered exist-
ing tanks. The following sections describe
the design and construction Of both new
and existing USTs.
UST
.1
rother.re
Piping
EPA June 1998
C 16-2
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
Cl 6. Underground Storage Tanks
3.1 New USTs
In order to conform with requirements for
new USTs, EPA laboratories must:
• Submit notification forms to the State
agency certifying the proper installa-
tion of the UST
• Implement procedures and use devices
to prevent releases from USTs
• Design and construct USTs and asso-
ciated piping with corrosion protection
• Check USTs monthly for releases
using approved methods
3.1.1 Installation, Certification, and
Notification
When a new UST is installed at an EPA
laboratory, the laboratory must submit a
notification form certifying one of the fol-
lowing:
• The installer has been certified by the
tank and piping manufacturers or by
the implementing agency
• The installation has been inspected
and certified by a registered profes-
sional engineer
• The installation has been inspected
and approved by the implementing
agency (i.e., EPA or designated
state/local agency)
An example notification form is provided
in Attachment C16-l.
3.1.2 Release Protection
As an owner and operator of a new UST,
EPA laboratories must prevent releases
resulting from USTs by:
• Following proper filling procedures
and ensuring available tank volume
prior to transfer
• Monitoring transfer operations using
electronic or mechanical means
• Use devices such as catchment basins
and automatic shut-offs
3.13 Corrosion Protection
The EPA must also ensure that tanks
and piping for new USTs are designed
and constructed in a way that protects
them from corrosion. Several methods
available include the use of cathodic pro-
tection, noncormdible material, steel with
fiberglass reinforcement, or alternate
methods. Each are described in the follow-
ing sections.
Cathodic Protection
The tank and piping are coated with a
corrosion-resistant material. Sacrificial
anodes or impressed current are used to
reverse the electric current associated with
corrosion.
All UST systems equipped with cathodic
protection systems must be inspected for
proper operation by a qualified cathodic
protection tester in accordance with the
following requirements:
• Test within six months of installation
and at least every three years, or
according to another reasonable time
frame established by the implementing
agency.
• Ensure the criteria that are used to
determine if cathodic protection is
adequate must be in accordance with
a code of practice developed by a
nationally recognized association.
&EPA June 1998
C16-3
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SHE lVE ? Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C16. Underground Storage Tanks
UST systems with impressed current
cathodic protection systems must also
be inspected every 60 days to ensure
the equipment is running properly.
Noncorrodible Material
Tanks and piping are constructed of a
material not susceptible to corrosion
(e.g., fiberglass).
Steel with Fiberglass Reinforcement
Steel tanks have a layer of noncorrodible
material bonded to the outside.
Alternate Method
Other protection methods may be used if
approved by the i mplementing regulatory
agency.
3.14 Leak Detection
UST systems must be provided with a
method, or combination of methods, of
release detection as shown in Figure Cl6-
1, that:
• Can detect a release from any part of
the tank and the underground piping
that routinely contains product
• Is installed, calibrated, operated, and
maintained in accordance with the
manufacturer’s instructions, including
routine maintenance and service
checks for operability or running
condition
• Meets the performance requirements in
40 CFR 280.43 or 40 CFR 280.44,
with any performance claims and their
manner of determination described
in writing by the equipment manufac-
turer or installer and meeting regulatory
performance standards for sensitivity
EPA laboratories must check new USTs
monthly for releases using one or more of
the following methods:
• Inventory control
• Vapor monitoring
• Manual tank gauging
• Groundwater monitoring
• Tank tightness testing
• Interstitial monitoring
• Automatic tank gauging
• Other method approved by regulatory
authority
Some tanks are exempt from these require-
ments. Examples are presented below.
• UST systems that meet the perfor-
mance standards in 40 CFR 280.20 or
280.21, and the monthly inventory
control requirements in 40 CFR
280.43(a) or (b), may use tank tight-
ness testing at least every five years
until December 22, 1998, or until 10
years after the tank is installed or
upgraded, whichever is later.
• UST systems that do not meet the per-
formance standards in 40 CFR 280.20
or 280.21 may use monthly inventory
controls and annual tank tightness test-
ing until December 22, 1998 when the
tank must be upgraded or permanently
closed.
• Tanks with capacity of 550 gallons or
less may use weekly tank gauging.
Underground piping that conveys regu-
lated substances must either have a line
tightness test conducted at least every
three years, or use a monthly monitoring
method conducted in accordance with 40
CFR 280.44(c). No release detection is
SEPIA lune 1998
C16-4
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
Figure C16-1: UST Leak Detection
C16. Underground Storage Tanks
required for suction piping that is designed
and constructed to meet the following
standards:
• Below-grade piping operates at less
than atmospheric pressure
• Below-grade piping is sloped so that
the contents of the pipe will drain back
into the storage tank if the suction is
released
• One check valve only is included in
each suction line
• The check valve is located directly
below, and as close as practical to, the
suction pump
• A method is provided that allows
compliance with paragraphs 40 CFR
280.41(b)(2)(ii)-(iv) to be readily
determined
3.2 Existing UST Systems
USTs and piping installed before Decem-
ber 1988 are subject to the same require-
ments as newer USTs, but with a different
timetable for compliance.
As of December 22, 1998, existing USTs
must be closed unless they meet the sys-
tem performance standards (i.e., corrosion
protection for steel tanks and piping, spill
and overfill [ release] prevention, equip-
ment leak detection), or internal lining or
cathodic protection upgrade requirements.
3.2.1 Internal Lining
A tank may be upgraded by internal lining
if the lining is installed in accordance with
the requirements of 40 CFR 280.33.
Within 10 years after lining the UST, and
every five years thereafter, the lined tank
must be internally inspected and found to
be structurally sound.
Vapor
Monitor
Interstitial • ‘
&EPA June 1998
Cl 6-5
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SHEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs
C16. Underground Storage Tanks
3.2.2 Cathodic Protection
A tank may be upgraded using cathodic
protection that meets the requirements of
40 CFR 280.21 if one of the following
apply:
• Internal inspections and assessments
have be performed to ensure that the
tank is structurally sound and free of
holes prior to installing the cathodic
protection system
• The tank has been installed for less
than 10 years and has been monitored
monthly for releases in accordance
with 40 CFR 280.43(d) through (h)
• The tank has been installed for less
than 10 years and is assessed for holes
by conducting two tightness tests. The
first tightness test must be conducted
prior to installing the cathodic protec-
tion system. The second tightness test
must be conducted between three and
six months following the first opera-
tion of the cathodic protection system
• The tank is assessed for corrosion
holes using a method that is approved
by the implementing agency
Upgrading by combining internal lining
and cathodic protection is acceptable if
requirements in 40 CFR 280.33 and
281.21 are met. Existing USTs must com-
ply with leak detection requirements for
new USTs as required by the phased-in
schedule in Table C16- 1.
Table C16-1: Leak Detection
Requirements
Year
.ii tau :
Musthaveleakdetecfionby -
mber22aL ;
.
1989
1990
1991
1992
1993
Before 1965
or date
unbown
P
P
1965-1969
PIRD
1970-1974
P
1975-1979
P
RD
1980.1988
P
RD
P = pressurized piping
RD = release detection
4.0 Inventory
Laboratories should develop a formal
process for inventory control by conduct-
ing regular measurements of each USTs
contents. These measurements should be
recorded daily on a UST reconciliation
form to keep track of withdrawals from,
and deliveries into, the UST. Refer to At-
tachment C16-2 for an example Under-
ground Storage Tank Daily Reconciliation
Form.
A certain amount of variation is acceptable
depending on the product, water in the
tank, and amount of products removed or
delivered. If records reveal continued
shortages, a leak investigation should be
conducted. Sources of potential discrepan-
cies may include:
• Fuel pump meter calibration error
• Discrepancy of delivery
• Temperature variations
• Measurement error
• Pilferage
EPA June 1998
C16-6
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SHEMP Operations Manual for Laboratories
CHAFFER C
Laboratory SHE Programs C16. Underground Storage Tanks
Investigation guidance is included in Table • A corrosion expert’s analysis of site
Cl 6-2. If the discrepancy is not associated corrosion potential (if corrosion pro-
with the above problems, a leak is likely. tection equipment is not in use)
If leaks are detected, laboratories should
ensure that they are properly reported to • Documentation of UST system
facility personnel and the implementing repairs
agencies.
Recent compliance with release detec-
5.0 Recordkeeping and Reporting tion requirements
Laboratories must maintain the following • Results of the site investigation con-
information, as applicable: ducted at permanent closure
Table C16-2: Leak Investigation Procedures
Unexplained Loss From
Reconciliation Over 30 days
Unexplained Loss From
Two Successive RecondH tlone
Step 1. Notify the people responsible for the mainte-
nance of the equipment and carefully inspect the
readily accessible physical facilities on the premises
for evidence of leakage.
Step 1. Notify the people responsible for the mainte-
nance of the equipment and carefully inspect the
Teadily accessible physical facilities on the premises
for evidence of leakage.
Step 2. If Step 1 does not explain the loss, calibrate
the pumps used with the particular product involved
with the apparent loss. But, first fill a calibrated five-
gallon can from each pump to determine if a pump
calibration is required.
Step 3. If Step 2 does not explain the loss, test the
piping system between the storage tank and dispens-
ers in an acceptable manner to determine if this seg-
ment of the system is leaking. If the tank has are-
mote fill and the variations occur at the time of fill.
ing, also test the remote fill line.
Step 2. if Step I does not explain the loss, test the
piping system between the storage rank and dispensers
as well as the fill lines in an acceptable manner to
determine if this segment of the system is leaking.
Step 3. If Steps I through 3 do not explain the loss,
continue additional reconciliations with an independ-
em verification by a qualified person. Also, conduct
additional surveillance of the facility to ensure against
unauthorized removal of the product.
Step 4. If Step 3 does not explain the loss, leak test
the storage tank.
StepS. If Steps I through 4 do not explain the loss,
continue the daily inventory with an independent
verification by a qualified person. Also, conduct
additional surveillance of the facility to ensure
against unauthorized removal of the product.
EPA June 1998 C16-7
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SI-JEMP Operations Manual for Laboratories
CHAPTER C
Laboratory SHE Programs C16. Underground Storage Tanks
Laboratories with USTs must submit the 6.0 Closing USTs
following information to the implementing
agency: If a UST does not meet the performance
standards for new USTs, or the upgrading
• Notification for all UST systems, requirements for existing USTs, it must be
which includes certification of instal- closed permanently. Procedures for prop-
lation for new UST systems erly closing a UST include:
• Reports of all releases including sus- • Notifying the implementing agency 30
pected releases, spills and overfills, days before initiating closure
and confirmed releases
Emptying and removing the tank or
• Corrective actions planned or taken filling it with inert materials
including initial abatement measures,
initial site characterization, free prod- • Determining whether the system has
net removal, investigation of soil and leaked, and if so, implementing a cor-
groundwater cleanup, and corrective rective action
action plan
• Maintaining records of the results of
• A notification before permanent do- the excavation zone assessment for the
sure or change-in-service UST system for at least three years
after closure
For UST systems using cathodic protec-
tion, records of the operation of the cath-
odic protection must be maintained to
demons ate compliance with the perfor-
mance standards in this chapter. These
records must provide the following:
• The results of the last three inspec-
lions of impressed current cathodic
protection systems
• The results of testing from the last two
inspections of cathodic protection sys-
tems performed by a qualified cath-
odic protection tester
3, P 4 June 1998 C16-8
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SFIEMP Operations Manual for Laboratories
CHAFFER C
Attachment C l 6 -1: Notification of New UST Installation
Purpose: To provide an example of notification requirements for the installation of
new USTs.
Instructions: Refer to the notification form to determine potential notification require-
menu. This is an example of federal notification. State and/or local notifica-
tions may also be required.
GEPA June 1998 C16-9
-------
FeemAXI
EPA u s
Environmental Protection Agency I App ,mat o tqtlrea 301aM
weeN, m DC 20450
NotifIcatIon for Underground Storage Tanks
STATE USE ONLY
I ID NUMBER
I DATE RECEIVED
TYPE OF NOTIFICATION A Date Entered 1 ,50 Conpiter —
o A NEW FACILITY D B. AMENDED DC. CLOSURE B. Data Eftoy Clerk IM a ts
C Dine, W Contacted to CIwffy Ranporwea. Ce,ivnerds
— at f I1ty j — No. at c 5InustIonshelts d.hud
INSTRUcTIONS
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GENERAL INFORMATION —- - -
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-------
‘ DA s
U.iI 1 Environmental Protection Agency
Wuflnpar OCanIeO
Notification for Underground Storage Tanks
CL TYPE OF OWNER
P1. INDIAN LANDS
O
Fedsat Onent Contmerciel
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O
Locat Om .......1
Tanks se located i Iand Wun e Inea Tnbe
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‘IL CONTACT PERSON IN CMARGE OF TANKS
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VIL FINANCIAL RESPONSIBILITY
D I have mat elsucced ucemtyreqiwsnsds
0 emIth4OCFR Si.apst H
check *i cm l A y
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Pie. a c ia
-------
EPA I OMBNO
I FonnAp med
Environmental Protection Agency Appi eo3 31 8
WesIe gt DC te460
Notification for Underground Storage lanka
IX . DESCRIPTION OF UNDERGROUND STORAGE TANKS (Complete for each tank at this location.)
Tonk Identifioslim Niarber
Tw4 No I Task No — I ToNi No._ Tirk No —
1
0 1 0 0 0
0 0 0 0
0 0 0 0
i_ToNi No.. ..._.
—_____
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—-______
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Cah. ,m Prulected
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LkiIsI n 9 0
° • 0 0
0
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-------
D. Engineenng Controls
-------
Dl.
Introduction
-------
D2.
General Laboratory Design
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D2. Laboratory Design
1.0 Introduction
All laboratories should be designed
according to basic principles that will
enhance worker safety and health and
minimize environmental impact. Numer-
ous factors influence the efficient design,
construction, and modification of an EPA
laboratory. These factors include, but are
not limited to:
• Location
• Size
• Type
• Task requirements
• Hazard containment needs
• Decontamination needs
• New construction versus retrofit
• Cost
Effective design requires careful consider-
ation of the functions and activities to
be performed within the laboratory. For
example, proper design must ensure chem-
ical containment. Designers of chemical-
use laboratories must also give special
consideration to the fire safety implica-
tions of barrier and containment features.
Since decisions pertaining to building
design, construction, and laboratory
preparation have far-reaching effects, con-
sultations with an architect, a
structural engineer, an industrial
hygienist, and a quality surveyor are
imperative.
This chapter addresses general design
requirements for several types of engineer-
ing controls. For specific guidance on lab-
oratory design, consult the EPA Facility
Safely, Health, and Environmental
Management Manual as well as federal,
state, local, and EPA standards for the
following:
• Ventilation
• Chemical storage
• Control of biologicals
• Fire safety
• Noise control
• Radiation safety
• illumination
EPA Program Requirements
EPA laboratories must meet the laboratory
design requirements discussed in this
chapter, and are encouraged to follow
the recommendations and best practices
presented. Laboratories should be:
• Sufficient in size to accommodate the
building and outbuildings with ade-
quate setbacks that meet local and
federal Resource Conservation and
Recovery Act (RCRA) requirements
• Located in light-industrial areas with
provisions to contain accidental spills
• Located in areas that have fully staffed
emergency response personnel, includ-
ing hazardous-material response teams
Laboratory design should include:
• Appropriate general ventilation
systems with air intakes and exhausts
located to avoid the intake of contami-
nated air
• Adequate, well-ventilated stockrooms
• Sufficient fume hoods and sinks
D7i June 1998
D2-l
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SHEMP Operations Manual for Laboratories
CHAFFER D
Engineering Controls
D2. Laboratory Design
• Required safety equipment (e.g., eye-
wash and shower units, etc.)
• Arrangements for waste disposal
• Provisions to meet other requirements
and guidelines outlined in Chapters
D3, D4, and D5 of this manual
Laboratories that handle or store hazardous
chemicals, flammable gases, flammable
liquids or explosives, and biological
agents should not be incorporated into
design plans for EPA office buildings or
other buildings that may be leased by the
Agency. Also, laboratory facilities should
not be established or expanded in existing
EPA buildings that are mainly occupied by
office space.
For design assistance for new laboratories
in EPA-owned and EPA-leased facilities,
or the modification of existing laborato-
ries, refer to SHEM Guide 23 and the
EPA Facility Safety, Health, and Environ-
mental Management Manual, which pro-
vide guidelines for laboratory design and
construction, including storage areas and
installation of engineering controls.
Program Administration
To effectively manage the design, con-
struction, and modification of EPA labora-
tories, responsibilities should be assigned
to:
local building and fire prevention
codes must be met as well. The most
stringent criteria will prevail, if con-
flict exists.
• Conduct work-area surveiiance that
includes an assessment of engineering
controls and design features.
• Prepare written standard operating
procedures (SOPs) with reference to
the SHEM Guide 23 section on the
storage of flammables, compressed
gases, and other chemicals.
• Perform and document a safety,
health, and environmental (SHE)
review as part of any laboratory
design, construction, and/or modifica-
tion project.
• Ensure that the design of laboratory
facilities satisfies the requirements
of the EPA; the National Fire Protec-
tion Association (NFPA); General
Services Administration (GSA); and
Occupational Safety and Health
Administration (OSHA). State and
&EPA June 1998
D2-2
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineerng Controls
D2. Laboratory Design
2.0 Design Process
A methodology for designing a laboratory
is presented in Figure D2-1. The designer
can modify this scheme for different types
of laboratories, based on the types of oper-
ations to be performed and the staff who
will be using the space.
To design a laboratory, there is a sequen-
tial process that must be followed. The
steps, summarized below, include con-
ducting a needs assessment, carrying
out a design hazard review, and develop-
ing design criteria.
Figure D2-1: Sequence of Laboratory
Design Process
Step2
Define Functional
Requirements
Step3
Apply Design Criteria
Step4 4
Specify Design
Alternatives
StepS 4 ,
Select Preferred
Alternatives
Step in
Perform Design
Hazard Review
Laboratory Directors, Safety, Health, and
Environmental Management Program
(SH.EMP) Managers, and laboratory staff
should be involved in the design process,
where feasible. Staff participation and
input is especially important in the needs
assessment and when specifying design
alternatives. Laboratory personnel will
likely have unique insight into laboratory
operations as well as facility and equip-
ment use.
2.1 Step 1: Conduct Needs Assessment
To design a laboratory, the first step is
to conduct a needs assessment to gain
an understanding of both the planned
activities and the project requirements.
This initial step should consider the
employees who will be using the labora-
tory, equipment needs, and, most impor-
tantly, the future project needs. Figure
D2-2 summarizes the components of a
needs assessment.
The needs assessment should be a qualita-
tive process review that can also identify
any hazardous operations that should not
be performed in a general-use laboratory.
Once the needs assessment has been
completed, the designer(s) can define the
functional requirements of the laboratory
and perform a design hazard review.
2.2 Step la: Perform Design Hazard
Review
Once the functional needs of the labora-
tory have been identified and understood,
the designer(s) can assess employee risk
and employee protection alternatives. This
type of review is known as a design hazard
review (DHR). For general laboratories,
a DHR should be performed for the labo-
ratory as a whole. if specific projects intro-
duce additional laboratory hazards that
cannot be minimized with existing engi-
neering controls and personal protective
Step 1
Conduct Needs
Assessment
4-
ERJ June 1998
D2-3
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
Figure D2.2: Components of a Needs Assessment
D2. Laboratory Design
List Chenucals
and Other
Hazardous
Agents
I Define the
Design Criteria
I ‘to Meet User and
J Project Needs
equipment, a DHR should be performed as
well. After the initial DHR, the Laboratory
Director or SHEMP Manager should initi-
ate a subsequent DHR if hazards associ-
ated with a new project(s) warrant it.
While performing a DHR for a laboratory
process, the SHEMP Manager should
identify any points of uncontrolled
chemical, biological, and/or radiological
exposure to laboratory staff. Also, the
designer(s) should review each exposure
point to ensure that equipment controls are
adequate to elinunate the hazard. This
review should cover the process from the
receipt to the disposal of the hazardous
agent.
2.3 Step 2: Defme Functional
Requirements
The needs assessment and information
from the DHR must then be used to
define the functional requirements of a
laboratory. For example, based on the
needs assessment, an organic prep labora-
tory used for extractions would require the
following facilities and equipment:
• Solvent storage
• Exhaust ventilation
• Negative pressure
• Sinks
• Eyewash and shower facilities
• Fire protection
It is important to consider insight gained
from the DHR the type of ventilation, fire
protection, etc., will be based on hazards
and risk.
2.4 Steps 3 to 5: Select Design
The laboratory designer(s) can construct
a series of design criteria, based on the
design review and needs assessment. An
excellent source for design specifications
is the Guidelines for Laboratory Design,
by Louis DiBerardinis, et al. A compre-
hensive list of the elements of design for
general laboratories can be obtained from
this source. Some of these elements are
shown in Attachment D2- 1.
Conduct
Interviews With
Laboratory
Personnel
Determine
Activities and
Project
Operations
Information for DHR
• Description of the process
• List of raw materials and products
• Size and type of equipment
• Statement of potential hazards
• Recommendations for risk
reduction
&ERA June 1998
D2-4
-------
SHEMP Operauons Manual for Laboratories
CHAPTER D
Attachment D2- 1: Design Elements for General-Use Laboratories
Purpose: To provide a list of elements to be used for design of general-use
laboratories.
Instructions: Refer to this list when considering what design elements should be included
in a new or renovated general-use laboratory.
&ER June 1998 D2-5
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Attachment D2-l: Design Elements for General-Use Laboratories
1.0 Laboratory Layout
1.1 Staff entry and egress
1.2 Laboratory furniture locations
1.3 Location of fume hoods
1.4 Location of equipment
1.5 Handicapped access
2.0 Laboratory Heating, Ventilation, and Air Conditioning (HVAC)
2.1 Temperawre control
2.2 Laboratory pressure relationship
2.3 Laboratory ventilation systems
— Comfort ventilation supply air for laboratory modules
— Recirculation of laboratory room air
2A Exhaust ventilation for laboratory modules
— Exhaust of general room ventilation air from laboratories
— Air rates for laboratory hoods and other local exhaust air facilities
— Chemical fume hoods
2.5 Exhaust fans and blowers
— Exhaust air cleaning for laboratory effluent air
— Exhaust ducts and plenums
3.0 Loss Prevention and Occupational Safety and Health Protection
3.1 Emergency considerations
— Emergency fuel gas shutoff
— Ground fault circuit intemipters
— Master electrical disconnect switch
— Emergency blowers
— Emergency eyewash
— Chemical spill control
— Emergency cabinet
3.2 Construction methods and materials
3.3 Control systems
3.4 Alarm systems for experimental equipment
3.5 Hazardous chemical disposal
3.6 Chemical storage and handling
3.7 Compressed-gas cylinder racks
Source: D Besardinis. Li.. et aL, Guidelines for L borotoiy Design. 2nd Editrnn. John Wiley and Sons. New Yo , 993.
June 1998 D2-6
-------
D3.
Process Change
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D3. Process Change
1.0 Introduction
There are many methods that can be used
to control a hazard. Some methods of con-
trol have proven to be better than others.
Process change is the first line of defense
against exposure to a hazard. Ideally, a
process change can be made that will
improve quality, reduce production costs,
reduce risk, and offset potential environ-
mental impacts.
As with any type of change, process
changes for controlling hazards and envi-
ronmental impact must also go through the
established channels and systems of the
specific EPA laboratoiy. This will help
ensure that all details of the process
change have been considered, as well as
any potential implications (e.g., impact on
environmental permits). Refer to Chapter
B4 of this manual for further information
on change management. Process changes
specifically related to pollution prevention
are addressed in Chapter C9 of this
manual.
This chapter introduces process change
techniques that can be used to control haz-
ards and environmental impacts.
EPA Program Requirements
Each laboratory must:
• Consider the use of engineering con-
trols (e.g., process change) as the first
step in hazard and environmental
impact control.
• Conduct any process change in accor-
dance with the established laboratory-
specific procedures, as well as the
guidance outlined in Chapter B4 of
this manual and, if applicable, Chapter
C9 of this manual.
• Evaluate the effectiveness of process
changes.
Program Administration
To effectively manage laboratory process
changes, responsibilities should be
assigned to:
• Evaluate the technical applicability
and feasibility of process change
methods for hazard and environmental
impact control.
• Coordinate potential process changes
with all involved parties (e.g., safety,
health, and environmental (SHE)
specialists, maintenance personnel,
researchers, etc.).
• Test and implement any approved pro-
cess changes.
• Evaluate the effectiveness of any
implemented process changes.
• Maintain necessary documentation
associated with process changes.
&EPA June 1998
D3-l
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D3. Process Change
2.0 Overview of Process Change
Methods
There are several process changes that can
be implemented to result in the favorable
conditions mentioned. These changes are
shown in Figure D3-l and discussed in the
following sections.
2.1 Substitution
Substitution is an effective method to
control hazard exposure and potential
environmental impacts, and is generally
considered to be the first method of con-
trol. Substitution can take three forms:
• Substitution of materials
• Substitution of process
• Substitution of equipment
A combination of these forms of substitu-
tion can often be the best method of
control.
2.1.1 Substitution of Materials
A substitute of nontoxic or less-toxic
materials may be as effective as, or better
than, the more hazardous material. Table
D3-l shows some common examples of
material substitutions.
Figure D3-1: Methods for Process Change
Table D3-1: Examples of Material
Substitutions
R rdous Substitute
Material Material
Neat Reagents
Premixed Reagents
Neat Liquids
Pelietized Materials
Carbon Tetrachioride
Aliphatic Petroleum
Hydrocarbons
Benzene
Toluene
Organic Solvents
Detergent-and-Water
Cleaning Solutions
In the case of solvents, a substitution of
water-based materials will generally pro-
vide an even greater level of protection for
laboratory staff. When substituting chemi-
cals, though, it is important to ensure that
an unforeseen hazard or environmental
impact does not occur along with the
substitution.
2.1.2 Substitution of Process
The overall process or procedures within an
operation may be changed to eliminate or
reduce exposure to hazardous materials or
situations and to minimize potential envi-
ronmental impacts. Examples of process
substitutions are shown in Table D3-2.
Substitution I
Change of Scale
M Lcns
I
Enclosure
I
6EPA June 1998
D3-2
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D3. Process Change
Table D3-2: Examples of Process
Substitutions
JTsi,sirdous Substitute
Process Process
Manual Material
Handling
Automated Material
Handling
Open System
Closed System and
Equipment
Batch Processing
Continuous Processing
Carrying Containers
of Toxic Materials
Using Pumping or
Conveying Systems
Substitution of process also involves the
redesign of procedures. This includes
changing how the employee performs
the task or interacts with equipment and
the environment, or changing the fre-
quency or duration of a task. Assessment
tools such as a job hazard analysis can
help identify the need for a change in how
a process is designed. Similarly, an envi-
ronmental audit can help uncover deficien-
cies in laboratory practices and procedures
that may harm the environment.
Human factors engineering can be applied
to the overall process and procedures to
aid in the ergonomic design of laborato-
ries, workstations, and tasks. Chapter C8
of this manual discusses ergonomic hazard
prevention and control in more detail.
2.1.3 Substitution of Equipment
The use of specialized equipment, or
adaptations to current equipment, can
effectively reduce or eliminate exposure
and mitigate environmental impact. Sub-
stitution of equipment includes the follow-
ing examples:
• Use of guarding on existing mechani-
cal equipment
• Use of automated equipment rather
than manual
• Addition of pollution control devices
to current systems
• Use of continuous area air monitoring
for hazardous operations
2.2 Change of Scale—Micro and Mini
Techniques
Changing the scale of the operation can
be an effective engineering control
method. Exposures and potential environ-
mental impacts can often be minimized by
handling and using smaller quantities of a
material.
For instance, when working with volatile
organic compounds or other toxic materi-
als, the lower the quantity present and
involved, the smaller the degree of volatil-
ization and aerosolization. This reduces
the employee inhalation hazard. Further-
more, using fewer compounds that have
specific reportable quantities or thresholds
may reduce the level of effort necessary
for the laboratory to comply with environ-
mental regulations that are triggered by the
quantity of a chemical substance used,
processed or produced (such as Compre-
hensive Environmental Response, Com-
pensation and Liability Act [ CERCLA]
and Emergency Planning and Community
Right-to-Know [ EPCRA]).
2.3 Enclosure
Isolation of potentially hazardous opera-
tions is another hazard exposure control
method. Typically, this isolation is pro-
vided in the form of a physical barner.
&EPA June 1998
D3-3
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls D3. Process Change
Enclosure should be one of the first con-
trol measures considered after attempts to
substitute are not successful. The use of
enclosures is especially useful for jobs
requiring relatively few workers and when
control by other methods is difficult or
impossible. The enclosure will isolate the
hazardous job from the rest of the work
operations, eliminating the exposures for
the majority of the workers. For some
operations, enclosing and isolating is
essential. The process may generate con-
taminants in large quantities that fill
a work area, exposing all workers to the
hazard. Examples of enclosures for hazard
exposure control include:
• Glove boxes
• Soundproof enclosures
• Heat barriers
• Separate, enclosed storage room for
bulk material
• Laboratory fume hoods
&EPA June 1998 D3-4
-------
D4.
Ventilation
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D4. Ventilation
1.0 Introduction
Proper ventilation is an integral part of
Safety, Health, and Environmental Man-
agement Programs (SHEMP) at EPA labo-
ratories. The general ventilation system
should provide air for breathing and for
input to local ventilation devices. Local
exhaust ventilation is used to remove con-
taminants from the air at the point of gen-
eration. In laboratories, these air containi-
nants usually include particulates, vapors,
gases, biohazardous agents, and radionu-
clides. Local exhaust ventilation prevents
air contaminants from entering a worker’s
breathing zone and, for stationary work
operations, is considered to be more reli-
able and protective than personal respira-
tory protective equipment.
Local exhaust ventilation systems can only
be effective if designed and operated prop-
erly. Often, many monitoring and mainte-
nance programs only concentrate on the
visible components of the ventilation sys-
tem (e.g., the hood), and ignore such ancil-
lary equipment as ductwork, fans, fan
stacks, etc.
Over the past 15 years, considerable
research has focused on evaluating labora-
tory ventilation systems. This chapter
summarizes this research and presents per-
formance criteria that have resulted from
new knowledge. The final portion
of the chapter reviews evaluation and
monitoring techniques, and presents infor-
mation on inspection, routine mainte-
nance, and user training. The topics cov-
ered in this chapter include:
• Ventilation systems overview
• Performance requirements
• Work practice guides
• Inspection and maintenance programs
• User training
EPA Program Requirements
Each laboratory must ensure that:
• Local exhaust ventilation systems are
provided where needed for protection
from toxic substances in the labora-
tory.
All laboratory fume hoods:
— Meet the construction and perfor-
mance criteria contained in the
SHEM Guide Manual
— Have an American Society of
Heating, Refrigerating, and Air
Conditioning (ASHRAE) No. 110
standard performance rating as
manufactured (AM)
— Provide 80 to 120 linear feet per
minute (fpm) of air flow
— Are tagged “out of service” and
reported to the building engineer
for corrective action if they do not
meet this criteria
• All local exhaust ventilation equip-
ment is included in an inspection and
maintenance program.
• Records of certification are maintained
on-site.
• Employees are informed of the proper
use and any required testing or inspec-
tion for the local exhaust ventilation
equipment they use.
June 1998
D4-1
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls D4. Ventilation
Program Administration
To effectively manage the laboratory ven-
tilation program, responsibilities should be
assigned to:
Ensure that the design of the ventila-
tion systems satisfies the provisions
of current EPA, National Fire Protec-
tion Association (NFPA), American
National Standards Institute (ANSI),
and Occupational Health and Safety
Administration (OSHA) ventilation
requirements.
• Perform periodic checks of fume
hoods and other ventilated equipment
to ensure they are working properly.
• Coordinate an inspection and mainte-
nance program for ventilation systems.
• Confirm that certification has been
obtained and approved.
• Maintain records of certification.
• Provide employees with information
on the proper use of, and any testing or
inspection requirements for, local
exhaust ventilation equipment.
&EPA June 1998 D4-2
-------
SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D4. Ventilation
2.0 Overview of Ventilation Systems
General ventilation provides room make-
up air. Local exhaust ventilation is the pri-
maiy method of contaminant control in the
laboratory. Examples of exhaust ventila-
tion control include laboratory fume
hoods, biological safety cabinets, clean
benches, and other local exhaust systems.
The following sections provide guidance
on:
• General laboratory ventilation
• Fume hoods
• Biological safety cabinets
• Other exhausted enclosures
Although general laboratory ventilation is
briefly discussed, this chapter is intended
to focus primarily on local exhaust ventila-
tion systems. Each of the examples of
local exhaust ventilation systems are
described in the following sections and
summarized in Table D4-l.
2.1 General Laboratory Ventilation
General room ventilation is the least effec-
tive way to protect personnel from expo-
sure to airborne contaminants such as
gases, vapors, or particulates. This system
should not be relied upon for protection
against toxic substances released into the
laboratory. Laboratory air should be con-
tinually replaced in order to prevent the
increase of airborne concentrations of
toxic substances during the workday.
The airflow into the laboratory should be
directed from non-laboratory areas to the
exterior of the building.
2.2 Laboratory Fume Hoods
A fume hood is the primary hazard control
device for protecting laboratory personnel.
The common laboratory fume hood is sim-
ply an exhausted booth or enclosure that
draws chemicals away from a worker’s
breathing zone. It is typically equipped
Table D4-1: Overview of Local Exhaust Systems
Fihsaust Work Access
- Opening
‘
Minimum Face
Velocity (fpm)
Applicab Ility
Carcinogens
Biohazards
Sliding Sash
100
Yes
N/A
I Open Front
75
No
BSL3
A Open Front
BI Sliding Sash
B2 Sliding Sash
B3 Sliding Sash
100
No
No
Yes
No
BSL3
BSL3
BSL3
BSL3
U I Front Panel With
Gloves
N/A
Yes
BSL4
BSC . boIog ia *yc
BSL - uoIogca1 s My k ci
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
D4. Ventilation
with a rear baffle system to distribute the
airflow evenly across the hood face, and a
horizontal or vertical sash so that the hood
opening can be minimized during use, and
closed when not in use. Make-up air can
be introduced directly to the laboratory
fume hood (termed an “auxiliary air
hood”); however, most often, make-up air
is supplied by the room heating, ventila-
tion and air conditioning (HVAC) system.
For ordinary laboratory operations, a well-
designed and properly-installed fume hood
should provide adequate protection for
laboratory workers against airborne haz-
ards. However, a laboratory fume hood
cannot protect a worker against all materi-
als and processes that may be contained in
the hood. For instance, protection may be
inadequate for materials with extremely
low occupational exposure limits (i.e.,
those in the parts-per-billion range). In
these circumstances, glove boxes or other
totally-enclosing control systems should
be used.
2.3 Biological Safety Cabinets
Three classes of biological safety cabinets
(BSCs) are used in laboratories. In general,
Class I, II, and ifi BSCs are used for work
involving pathogens of low, moderate, and
high virulence, respectively. Class U BSCs
also protect materials handled inside the
cabinet from external contamination. All
BSCs are equipped with high-efficiency
particulate air (HEPA) ti]ters. Although
HEPA filters protect operators from expo-
sure to particulates, including bacteria,
viruses, etc., they do not absorb chemical
vapors and gases. For this reason, BSCs
with recirculating air flow cannot be used
for protection against toxic and/or
irritating gases and vapors. Several types
of BSCs recirculate air within the work
space, and are inappropriate for use with
toxic gases and vapors, since contaminants
may accumulate. The various classes and
types of BSCs are summarized below.
Class I BSCs
Class I BSCs are considered laboratory
fume hoods, but the exhaust air is filtered
through a HEPA filter, and no filtered air
recirculates into the work space. Class I
BSCs are designed to deliver a minimum
face velocity of 100 (pm at the work
access opening.
Class II BSCs
Class II BSCs provide a vertical laminar
airflow into the work space, and also
maintain an inward flow of air at the work
opening. Like Class I, Class 11 BSCs have
face velocities of at least 100 ( pm. There
are four types of Class II BSCs. The
amount of air recirculation and the manner
in which exhaust air is removed from the
work space differs between the various
types. Each of these is described in
Table D4-2.
A typical airflow pattern for a Class II,
Type A BSC is shown in Figure D4-1.
Standard Class U, Type Bi and Type B2
BSCs are illustrated in Figures D4-2 and
D4-3, respectively.
Class III BSCs
Class Ill BSCs, also known as “glove
boxes,” are gas-tight enclosures used for
operations with the highest level of risk.
As illustrated by Figure D4-4, access to
the enclosed chamber is only possible
through rubber gloves and sleeves that are
integrated into the side of the cabinet. Air
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CHAPTER D
Engineering Controls D4. Ventilation
Table D4-2: Types of Class II BSCs
Types of Class II BSCs
Type A
• Recirculate 70 percent of the HEPA-filtered exhaust air back within the cabinet; the remaining
30 percent is exhausted.
• Filtered exhaust air may recirculate into the workroom air.
• Face velocity is at least 100 f pm.
• Meant to control airborne paiticulates only—inappropnate for use with toxic or irritating gases
or vapors.
Type Bi
• Only 30 percent of the exhaust air is recirculated into the cabinet.
• Face velocity is at least 100 fpm.
• Meant to control airborne particulates only—inappropriate for use with toxic or irritating gases
or vapors.
Type B2
• 100 percent exhaust from enclosure; none of the air exhausted from the cabinet is recirculated.
• All of the HEPA-fikered air is discharged either into an appropriate exhaust or back into the
workroom air.
• A second blower (fan) provides the vertical laminar flow.
• Face velocity is at least 100 fpm.
• Appropriate for use with toxic gases and vapors (as well as particulates) when connected to an
exhaust duct with a safe release point outside the facility.
Type B3
• Recirculate 70 percent of the HEPA-filtered exhaust air back within the cabinet; the remaining
30 percent is exhausted.
• Exhausts 30 percent of the air outside the building.
• Face velocity is at least 100 f m.
• Meant to control airborne particulates only—inappropriate for use with toxic or irritating gases
or vapors.
is swept across the work space through • “Elephant trunks” (flexible ducts with
HEPA filters on both the supply and cone or flanged inlet hoods)
exhaust ducts. • Laboratory bench slot hoods
• Extraction hoods
2.4 Other Exhausted Enclosures • Vented balance enclosures
• Glove boxes
Other special systems for laboratory opera-
tions are available. They include:
• Vented benchtop workstations
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
Figure D4-1: Class II, Type A BSC
I I Exhaust FUterFi I
View Screen
Front Access Opening
Supply Filter
D4. Ventilation
Vented benchtop workstations can be used
for pipetting and for housing small centri-
fuges. These units should be equipped
with a rear plenum to eliminate turbulence
that normally occurs in standard hoods,
and should provide laminar flow in the
chamber that directs air away from the
user. Vented benchtop workstations must
not be used for chemical transfers.
“Elephant trunks” with attached cone or
flanged inlet hoods are typically used with
gas chromatographic or other type of spec-
trophotometric analysis equipment.
Also, a vented balance enclosure can be
used for protecting laboratory employees
from inhalation hazards when weighing
toxic or otherwise hazardous materials.
The air capture velocity does not interfere
with the weighing accuracy. In addition,
the balance enclosure has been designed to
provide maximum visibility, manipulation
capacity, and worker comfort.
Note: Recirculating hoods equipped
with charcoal or other filters are not rec-
ommended for protection against toxic
chemicals. Refer to ANSI Z9.5for more
information.
3.0 Ventilation System Design
The design of an effective and efficient
ventilation system is a technically complex
and rigorous process. All designs should
be developed or approved by a certified
industrial hygienist or by a ventilation
engineer experienced with both ventilation
design and laboratory operations. Design
efforts should be coordinated with all
personnel involved, including the user,
maintenance, SHEMP Manager and fire
personnel. In addition to sound knowledge
of ventilation principles, the design pro-
cess requires an in-depth familiarity with
both the range of tasks for which protec-
tion is required, and the variety of agents
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls
Figure D4-2: Class H, Type Bi BSC
D4. Ventilation
t
Exhaust
II Filter (I
b’ ser
Clean
Air
1’ /“
Contaminated
Air
UFiltert-I
Fan P ’
t t
JExhaust Fitterl I
_)
‘ Diffuser
$ View Screen
t Access Opening
Supply Filter
used. ANSI Z9.5 and ASHRAE 110 con-
tain ventilation design criteria. EPA
SHEM Guides must be consulted as well.
In addition, OSHA and NFPA ventilation
requirements must be met.
4.0 Performance Requirements
New exhaust installations should be
inspected and tested prior to use. It is im-
portant to verify that the hood per-
formance is adequate for intended use
before working in the fume hood.
All laboratory fume hoods must meet the
EPA construction and performance crfte-
na, and must also have an ASHRAE 110
standard performance rating of 4.0 AM
0.05. The fume hoods must provide 80 to
120 fpm of air flow and be certified that
they meet this velocity criteria before im-
tial use. A copy of the initial certification
must be forwarded to Safety, Health, and
Environmental Management Division
(SHEMD).
5.0 Work Practice Guides
The following work practice guides are
primarily intended for the use of laboratory
fume hoods, but can also be applied to the
use of BSCs and other exhausted enclo-
sures.
Conduct all operations that release
significant quantities of airborne mate-
rials inside a laboratory fume hood.
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Engineering Controls
D4. Ventilation.
Figure D4-3: Class H, Type B2 BSC
1 Exhaust
t Filter
j
Supply Filter
View Screen
[ :;
Front Access Opening
• Keep all containers and apparatus at
least six inches back from the front of
the indicator marks on the hood base
or side walls.
• Do not extend the head inside the
hood when operations are underway.
• Keep all hazardous waste containers
tightly closed at all times, except when
additions are made to the container.
• Do not store unused chemicals or
apparatus inside the laboratory fume
hood. Instead, store chemicals in
approved storage cabinets.
• Keep the hood sash closed as much as
possible.
• Do not obstruct the slots or baffles in
the rear of the hood.
• Minimize traffic past the hood.
• Keep laboratory doors and windows
closed.
• Except for maintenance or repair, do
not remove the hood sash, horizontal
sliding safety panels, airfoil sill, or
rear baffles.
• Use a safety shield or barricade if
there is possibility of an explosion.
• For hoods that can be turned on and
off in the laboratory, ensure that the
hood is “on” whenever in use.
• Ensure that the laboratory fume hood
system is adequately functioning and
maintained. Do not work in a malfunc-
tioning hood.
Filter
mAir
Air
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SHEMP. Operations Manual for Laboratories
CHAPTER D
Engineering Controls
Figure D4-4: Class III BSC
[
Exhaust Filter
I
.1
Supply Fitter
View Screen
II
f@ .@
D4. Ventilation
Pass Thru
I
6.0 Inspection and Maintenance
Program
Where local exhaust ventilation is the pri-
mary control, regular inspection, testing,
and maintenance of the ventilation systems
are critical to ensure the protection of per-
sonnel from exposures to airborne hazards
in the laboratory. Every monitoring pro-
gram should include:
• Daily visual inspections
• Quarterly testing
• At least annual maintenance
Where applicable, the monitoring pro-
gram for each piece of exhaust equip-
ment should reflect the manufacturer’s
or designer’s recommended operating
practices. A document to use for assist-
ance in hood inspection and testing is the
“Procedure for Certifying Laboratory
Fume Hoods to Meet EPA Standards.”
This document provides step-by-step
procedures and worksheets for initial
and periodic performance evaluations
of laboratory fume hoods.
The following sections provide general
guidance on inspection, testing, and main-
tenance procedures.
6.1 Inspection
Effective ventilation systems should dem-
onstrate the following characteristics:
• Non-disruptive air patterns, including
those inside the enclosure and those in
the environment around the enclosure
• Adequate and appropriate face veloci-
ties and air flow volume
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SHEMP Operations Manual for Laboratories
CHAFFER D
Engineering Controls
D4. Ventilation
• Absence of leaks
• Properly functioning and well-
maintained components
The inspection program should be
designed to identify when these character-
istics are not being met, as well as any
warning signs of a potential problem.
The performance criteria below represent
both quantitative and qualitative methods
of assessing ventilation system perfor-
mance and condition. Attachment D4-l
presents instructions for monitoring labo-
ratory fume hoods and a sample hood
monitoring form.
Before use of an exhaust system, operators
should perform a visual inspection that
includes checks of airflow, monitors and
gauges, and housekeeping. Each are dis-
cussed in the following sections.
6.1.1 Airflow Check
When the exhaust system is operating, a
flow indicator check, such as a ribbon or
tissue paper check, should be performed to
ensure that the exhaust is functional. This
qualitative flow check is conducted by
taping a small piece of tissue paper or
plastic ribbon at the hood opening, and
observing whether it reflects a directional
air flow. For a glove box, the indicator
should be placed inside at the exhaust
slots. These indicators should not be
allowed to escape into the exhaust system,
as they can block the filter and reduce
airflow.
6.1.2 Monitors and Gauges
All pressure gauges and other hood moni-
tors should be checked for proper opera-
tion within a predetermined and indicated
range. For pressure gauges, this range
should be initially determined, for both the
enclosure static pressure and the HEPA
filter pressure drop, by a qualified health
and safety professional or ventilation engi-
neer. The precise range may vary between
systems, and should be defined for each
individual system.
6.1.3 Housekeeping
Any material blocking the hood opening or
exhaust parts should be removed. Simi-
larly, spilled material should be cleaned
up, and soiled or damaged base-liner mate-
rial replaced.
6.2 Testing
Periodic testing (e.g., quarterly) should be
performed on local exhaust systems. For
example:
• Smoke tube tests
• Face velocity measurements
• Additional tests
These tests are used, in conjunction with
the daily inspections, to verify that local
exhaust ventilation systems are working
properly. Each are discussed in the follow-
ing sections.
6.2.1 Smoke Tube Tests
Smoke tube tests should be performed
quarterly to evaluate airflow patterns.
Tests should be performed as follows:
Laboratory Fume Hoods or Class I BSCs
(with or without auxiliary air supply)
The smoke should move from the plane of
the sash directly to the rear exhaust slot,
with the sash in its normal operating posi-
tion. The smoke tube should be placed at
June 1998
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SHEMP Operations Manual for Laboratories
CHAFrER D
Engineering Controls
D4. Ventilation
and above the interior working space to
locate any dead or turbulent spots. (Note:
turn off auxiliary air supply for test).
Class i i BSCs
The smoke should move from the plane of
the sash into the forward intake grill. The
smoke at the working area should move
toward either the forward or rear exhaust
slots with minimum turbulence.
Glove Boxes or Class III BSCS
Since these installations are gas-tight and
maintained under negative pressure, a
smoke tube test is performed to identify
leaks around the joints and seals. The test
is conducted by placing the smoke tube at
the outside glove gaskets and inside the
rubber gloves, and checking for evidence
of smoke inside the box.
Other Local Exhaust Equipment
The smoke tube should be placed around
the outer boundaries of the area to be
exhausted or the zone of contaminant gen-
eration (e.g., the edge of a waste container
that is exhausted along the back side, or
the top of an atomic absorption spectro-
photometer that is exhausted by a canopy
hood). In all cases, the smoke should
move directly into the exhaust inlet.
6.2.2 Face Velocity Measurements
Face velocities for Laboratory fume hoods
should be measured on a quarterly sched-
ule. Face velocities for BSCs should be
calculated and laminar downflow in the
work space should be measured. These
tests should be performed by qualified per-
sonnel using a properly calibrated, thermal
or mechanical velometer.
EPA SHEMD requires that the face veloci-
ties of laboratory fume hoods be recerti-
fled at least annually, or after any signifi-
cant maintenance, with recertification
records maintained on-site.
The following procedures should be used
for conducting face velocity measurements
of laboratory fume hoods, BSCs, and
glove boxes.
Laboratory Fume Hoods
The average of the velocities in each of
nine points on a grid for a standard four to
six-foot hood at the hood face will repre-
sent the overall face velocity. Measure-
ments should be taken at full open or at a
designated sash height (e.g., 18 inches, 20
inches). If the airflow is too low (i.e., less
than 80 fpm), adjustments will be neces-
sary to increase face velocity.
When these measurements are made, the
auxiliary air supply (if present) should be
turned off. If the hood is connected to
other hoods, the face velocity should be
measured under the maximum worst-case
conditions (e.g., all the connecting hoods
with sashes fully open and exhaust on).
The average face velocity should be 80 to
120 1pm, with no individual point less than
80fpmorgreaterthan 100 fpm withaface
velocity greater than 120 1pm must be
checked with a smoke tube or candle to
ensure that no backflow or eddies occur.
BSCs (laminar flow)
In Class II, Type A and B cabinets, the
supply blower should be switched off for
the face velocity measurement. The face
velocity should be 100 1 pm ± 10 percent.
The vertical downflow of the supply
blower should also be measured. The
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CHM’mR D
Engineering Controls
D4. Ventilation
downflow at the work space should be
approximately 50 to 80 fpm, depending
on the manufacturer’s recommendations.
Several types of Class II, Type B hoods are
not easily switched off to determine face
velocity measurements. For these cabi-
nets, a combination of supply/working
surface measurements and inlet smoke
tubes tests should be performed by experi-
enced personnel. If the inlet supply air is
too great (e.g., greater than 80 f pm) and
the smoke tubes indicate lazy inflow air
patterns at the face, the supply/exhaust
airflow may be out of balance, the HEPA
filters may be overloaded, or the exhaust
fan may be malfunctioning. In these cases,
further testing or maintenance may be
required.
Glove Boxes
If the glove box has a filtered air inlet
without a supply blower, a velometer read-
ing can be taken to detennine the exhaust
volume. The exhaust volume, in cubic feet
per minute (cfm), is calculated by multi-
plying the average inlet velocity, in fpm,
by the inlet area, in square feet. This
exhaust volume for most manufacturers’
specifications is in the range of 30 to 50
cftn. When a glove box has a supply air
blower (the glove box airflow can be de-
termined by measuring the air velocity at
the fan inlet), periodic smoke tube leak
tests (outlined above) should be con-
ducted, and annual exhaust flowrate mea-
surements should be taken.
The results of quarterly inspection and
testing for all local exhaust ventilation
systems should be recorded. These records
should bi kept in an accessible location so
that users or maintenance personnel can
refer to them when suspected malfunctions
occur. In addition, laboratory fume hoods
and other local exhaust hoods should be
labeled with the design hood flowrate
(e.g., cfm or m 3 /s) and the hood flow resis-
tance (e.g., static pressure or SPh, inches or
mm water gauge).
6.23 Additional Tests
Additional tests of exhaust slots and ex-
haust enclosures are recommended for
verifying the effectiveness of local exhaust
ventilation systems.
Exhaust Slots
Adjustable rear exhaust slots in laboratory
fume hoods should be checked periodi-
cally for proper adjustment. Also, the sup-
ply and exhaust air flows in a BSC should
be checked to determine if they are prop-
erly balanced. When the exhaust inflow
and downflow are unbalanced, contami-
nated air may be forced outside the cabinet
into the breathing zone of the worker.
Exhaust Enclosures
All exhaust enclosures should be smoke-
tested to qualitatively dethonstrate the
effective capture of contaminants gener-
ated during normal operating procedures.
The smoke test is conducted by placing
a smoke tube inside the enclosure, and
observing whether all the generated smoke
is captured. If smoke leaks out of the
enclosure, contaminated air may also
leak out of the enclosure during normal
conditions.
6.3 Maintenance
In addition to periodic inspection and test-
ing, comprehensive annual maintenance
of the entire ventilation system should be
I A
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SHEMP Operations Manual for Laboratories
CHAFrER D
Engineering Controls
D4. Ventilation
performed by qualified personnel. This
section provides general maintenance
guidelines, which should be used in con-
junction with any specific recommenda-
tions providedby the manufacturer.
6.3.1 Exhaust Fan
Exhaust fan blades should be inspected for
deterioration from corrosion. etc. The fan
manufacturer should recommend the fre-
quency and content of necessary mainte-
nance, including lubrication and belt re-
placement.
6.3.2 Ductwork
The ductwork between the hood or exhaust
inlet should be checked for leaks, corrosion,
deterioration, and buildup of liquid or solid
condensate. Although dampers are not rec-
ommended for laboratory exhaust systems,
any dampers that are used for balancing the
system should be lubricated and checked
for proper operation and corrosion/erosion
damage. Unused ductwork or old hood in-
stallations should be removed.
6.3.3 Air Cleaning Equipment
Charcoal or HEPA filters in the exhaust
system should be monitored for contami-
nant buildup or breakthrough. Mechanical
or absorbent filters not equipped with
monitors (e.g., differential pressure
gauges, audible alarms, etc.), should be
leak-checked at least annually. Absorbent
or adsorbent filters for gas and vapors can
be leak-checked by challenge tests (i.e.,
release of a trace gaseous agent and use
of a suitable detector). HEPA filters can
be checked using the dioctylphthalate
(DOP) method (see the National Sanitation
Foundation [ NSF] Standard for Class I
Biohazard Cabinets [ NSF Standard 49]).
This type of test is often performed by an
outside contractor.
6.3.4 Velocity Measurement
As mentioned earlier, total-exhaust Class
H, Type B2 BSCs and glove boxes require
exhaust air flow rate measurements to ver-
ify the proper airflow in the enclosures. In
the total exhaust cabinet, the supply vol-
ume can be subtracted from the exhaust
volume to yield the amount drawn in at the
opening, and this value can be divided by
the area of the average face opening to
calculate the face velocity. For the glove
box, the exhaust air flowrate range should
be 30 to 50 cfm.
When these maintenance procedures are
performed, suitable precautions should be
taken to protect maintenance personnel
from toxic contaminants inside the enclo-
sure, ductwork, or filters. Any excess con-
taminated material or filters removed from
the ventilation system should be disposed
of according to the facility’s approved haz-
ardous waste disposal practices.
6.3.5 Special Tests for BSCs
There are special tests that are used to
maintain and evaluate BSCs, which in-
clude, among others:
• Calculated inflow
• In-place leak testing of HEPA filters
• Ground continuity (containment and
instruction)
• Noise level and vibration
Some of these tests may be performed by
the manufacturer. However, the purchas-
ing laboratory should arrange for testing
and certification of each BSC at the time
of installation, whenever the BSC is
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls D4. Ventilation
moved, and at least annually to ensure
proper function. This is necessary since
shipping, filter load, and installation of
the BSC may alter performance. Testing
should conform to the NSF requirements
outlined in NSF Standard 49.
7.0 User Training
Before employees use any laboratory fume
hood or other exhaust system, they should
be trained in proper work practices and
be familiar with hood operation and the
required monitoring programs. Users
should be trained on the work practices
outlined in Section 3.4 of this chapter, as
well as any guidance provided by the man-
ufacturer.
The practice of daily visual inspections
and smoke tube tests should also be
included in the user training program.
Training on local exhaust ventilation sys-
tems is one of the recommended topics for
the annual laboratory safety refresher
training.
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SHEMP Operations Manual for Laboratories
CHAPTER D
Attachment D4-1: Record for Laboratory Fume Hood Monitoring
Purpose: To serve as a recordkeeping form for laboratory fume hood monitoring.
Instructions: To use the form, follow these instructions:
1. Indicate the hood identification number (if applicable), location (e.g., room number,
building), date of monitoring, and expected re-test date in the spaces provided.
2. Indicate the type of hood and the hood features, as shown. Include notes on any other
features (e.g., filters), design characteristics, and special use conditions (e.g., use of
radionuclides, perchionc acid, heating equipment).
3. Record readings from fixed, automatic measuring devices (e.g., magnahelic gauge, face
velocity monitor). Describe other alarms, monitors, and gauges.
4. Note any interference with air inflow to the hood. Interference may be caused by
windows, doors, busy walkways, supply air diffusers, etc., in the vicinity of the hood.
5. Adjust the hood sash height, if appropriate. Release smoke from a smoke tube at the face
of the hood, along the front and at the bottom corners. The smoke should move smoothly
and directly into the exhaust slot. Release smoke at or above the interior working space
to locate “dead” or turbulent areas. Record the results of the smoke test in the space
provided.
6. Using a calibrated velometer, measure the average face velocity of at least nine points for
any hood that is four to eight feet long. (If applicable, turn off auxiliary air before
measuring face velocity.) For hoods that are 8 to 12 feet long, double the number of
measurements. Ideally, face velocity should be measured with sashes at full open. If
measurements are not taken at full open, indicate the sash height.
Add the values of each measurement and divide by the number of points measured to
obtain the average face velocity. Multiply the hood length by its width to obtain the hood
area, and multiply this value by the average face velocity to obtain the hood flowrate.
Record these calculations in the spaces provided. Also indicate the type of instrument
used to take measurements, and include its most recent calibration date.
Face velocities for laboratory fume hoods should average approximately 100±20 fpm.
No individual point should be outside the acceptable range unless the smoke test
demonstrates that the hood provides adequate capture without significant turbulence.
7. Based on the data generated, evaluate whether the hood needs adjustments or design
modifications. Add other comments as necessary, and enter your name on the line
provided.
&EA June 1998 D4-15
-------
Monitoring Record for Laboratory Fume Hoods
hood Identification Date
Location Re-test Date
Types of Features
Hood Manufacturer
Bypass
Auxiliary Air
Yes (No
Yes jNo
Flow Controlled (variable air volume)
Connection to Other Hoods
Yes (No
Yes (No
Adjustable Sashes
Yes No (Vertical (Horizontai
Damper(s) Fan Switch Bottom Air Foil
Yes f No Yes No Yes No
Other Features, Design Characteristics
Special Use Conditions (e.g., radionuclides, percblorlc acid)
Automatic Measuring Devices
Hood Static Pressure Monitor (In or mm w.g.)
Hood Face Velocity Monitor (fpm or mis)
Yes No
Yes (No
Other Alarms, Gauges, etc.
Yes
1NO
Capture Test
interference from doors, windows, walkways,
supply air diffusers
Yes 1
No
Smoke Test Results
Face Velocity Measurements
Test device
Calibration date
Hood flow rate
(cfm or m 3 Is)
Sash height (non-VAV hoods)
(In or mm)
Hood flow rate
cftn or m’/s)
Hood area (sash open)
or m’)
Hood Adjustment Indicated
Yes (No
Comments
Tested By (signature):
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D5.
Hazard-Specific Controls
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SHEMP Operations Manual for Laboratories
CHAPTER D
Engineering Controls D5. Hazard-Specific Controls
1.0 Introduction
Engineering controls must be applied
based on the specific hazards present in
the laboratory and the degree of potential
risk associated with the hazards. This
chapter addresses the following specific
hazards that may be present in EPA
laboratories:
• Chemical
• Biological
• Radiation
• Fire
• Noise
• Poor lighting
EPA Program Requirements
To effectively implement hazard-specific
engineering controls. EPA laboratories
must:
• Evaluate laboratory hazards
• Design, purchase, and implement
appropriate controls
• Train employees in proper use of engi-
neering controls
• Implement an inspection and mainte-
nance program for control equipment
Program Administration
For effective control of laboratory hazards,
responsibilities should be assigned for:
• Assessing laboratory hazards
• Selecting engineering controls
• Training employees in proper use of
controls
• Inspecting engineering controls
• Evaluating the effectiveness of applied
controls
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D5. Hazard-Specific Controls
2.0 Chemical Hazards
Engineering controls must be the primary
means of controlling hazards presented by
laboratory chemicals. This section pro-
vides information and guidance for work
surfaces, chemical storage, and contain-
ment as shown in Figure D5-l. Certain
chemicals used in EPA laboratories specif-
ically require the use of engineering con-
trols based on the individual the U.S.
Occupational Safety and Health Adminis-
tration (OSHA) standards.
2.1 Work Surfaces
Contaminated work surfaces increase the
potential for worker injury or illness, and
the spread of contamination throughout the
laboratory. Laboratory benchtops, floors,
and walls should be constructed of a
smooth material that is easy to clean. The
material must be resistant to chemical ab-
sorption. Good housekeeping practices
(e.g., storing chemicals away from work
areas) must be promoted at all times. Even
the smallest
spills must be cleaned immediately, using
the appropriate absorbent or neutralizer.
A regular schedule of thorough laboratory
cleaning should be implemented, basing
the schedule on the frequency of use, as
well as the types and amounts of chemicals
used.
2.2 Segregated Storage
Appropriate storage cabinets should be
employed for all chemicals not in imznedi-
ate use. For OSHA-specific requirements,
refer to 29 CFR 1910.106(d)(5). Cabinets
must be selected based on the types of
chemicals to be stored. Often, ventilated
cabinets are available for certain types of
chemicals. Outlined below are the types of
cabinets to be used for specific groups of
chemicals, as well as good work practices
and maintenance procedures associated
with the cabinets.
2.2.1 Flammables
Examples of flammable materials include,
but are not limited to, acetone, ethyl ether,
toluene, and methyl formate. Cabinets for
flammable chemicals must be:
Figure D5-1: Chemical Hazard Considerations
Work Surfaces
Chemical Hazard
Considerations
Segregated Storage
Containment
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• Specifically designed to store flarnma-
ble materials
• Fire resistant
• in compliance with NFPA 30 and
OSHA 1910.106 standards
• Designed to protect contents from the
heat and flames of external fire (not to
confine burning liquids within)
• Designed with double-wall construc-
tion and doors which are two inches
above the base
• Used and maintained properly
11 flammable materials are to
be poured or transferred to or
from a metal container within
the storage area, there may
be an accumulation of static
charge on the container. The
discharge of the static charge could gener-
ate a spark, igniting the liquid. Flammable
dispensing and receiving containers must
be bonded together before pouring. Large
containers, such as drums, must also be
grounded when used as dispensing or
receiving vessels. All grounding and bond-
ing connections must be metal to metal.
Flammable chemicals must never be
stored in a standard household refrigerator.
There are several ignition sources located
inside a standard refrigerator which can Set
off a fire or violent explosion.
Flammable storage cabinets should be
inspected regularly. Chemicals that are not
compatible with flammables must never be
stored within the cabinet. The cabinets
must be kept clean. Leaks and spills must
be controlled and cleaned immediately. All
chemicals should be readily accessible in
the cabinet to avoid spills and breaking
containers. Cabinets should never be
over-stocked.
2.2.2 Acids/Corrosives
Cabinets for storing acids have similar
construction features to a flammable stor-
age cabinet, but they are also coated with
an epoxy enamel to guard against chemical
attack. They frequently contain polyethyl-
ene trays to collect small spills and pro-
vide additional protection from corrosion
of the shelves. Bases must stored in sepa-
rate storage cabinets, never with acids. A
wooden cabinet is common for storing
bases. Common examples of corrosives in
EPA laboratories may include sulfuric
acid, stannic chloride, and ammonium
hydroxide. Nitric acid should have its own
storage cabinet by itself. Hydrofluoric acid
(HF) must never be stored in a glass con-
tainer, as these materials are incompatible..
HF should also have its own separate stor-
age cabinet. Corrosive material cabinets
must never be situated above eye level.
Spills and breaks could lead to serious eye
and facial injury.
To promote safe storage of corrosives,
materials should be purchased in contain-
ers that are coated with a protective plastic
film to minimize the danger if dropped or
tipped. Corrosives should also never be
purchased in amounts more than necessary
in the laboratory.
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Cabinets used for storing corrosives must
also undergo regular inspection. Incompat-
ibles must be removed and separated. Cab-
inets must be kept clean and free from
leaks and spills. Shelves and supports must
be periodically inspected for corrosion. if
corrosion is detected the cabinet must be
replaced immediately. Chemicals must be
readily accessible and never over-stocked.
2.2.3 Oxidizers
Oxidizers, which include peroxides, chlo-
rates, nitrates, perchiorates, and others,
present fire and explosion hazards on con-
tact with combustible materials (oxidizers
are also typically corrosive). Oxidizers
must be stored away from flammables,
organics, and all combustible materials.
Strong oxidizing agents, such as chromic
acid, must be stored in glass or other inert
container that is unbreakable. Corks and
rubber stoppers should not be used, as they
may “pop” open and explode or spill.
Perchioric acid is of particular concern.
Hazards increase with an increase in tem-
perature and concentration. It must be
stored away from heat, and may be stored
in a perchioric acid fume hood. Where
possible, substitutes for perchioric acid
should be used to eliminate its presence in
the laboratory. Only the amount necessary
for work should be kept on-site.
Inspections of storage areas for oxidizers
must be performed on a regular basis. The
primary focus of inspections should be
container stability, cleanliness of storage
areas, and the potential for spiiis and leaks.
2.2.4 Reactives
Water-reactive materials must be stored
in an isolated part of the laboratory. A
cabinet far-removed from any water
sources, such as sinks, emergency showers
and chillers, is the most appropriate loca-
tion. The cabinet must be labeled, “Water-
Reactive Chemicals-No Water.” Pyro-
phones must also be isolated within the
labora-tory. The cabinet must be clearly
marked. Peroxide-forming materials must
be stored away from heat, sunlight, and
sources of ignition to prevent the accelera-
tion of peroxide formation. They must also
never be stored in glass containers with
screw cap lids or glass stoppers. Friction
and grinding must be avoided.
The integrity of containers used for
reactives must be inspected regularly.
If the container is corroded or otherwise
damaged, the material should be disposed.
of in the appropriate manner. Storage areas
must also be regularly inspected for clean-
liness, spills, and leaks.
2.2.5 Chemical Waste
Chemical and/or hazardous waste must be
stored in containers designed for the accu-
mulation of such waste. Containers must
be in good condition, free of leaks, and
compatible with the waste being stored
within. The container should be opened
only when necessary to add waste, and
otherwise should always be capped. Haz-
ardous waste storage containers holding
waste that is incompatible with any waste
or other materials stored nearby must be
separated by means of a partition, wall, or
other secondary containment device. Caps
should be non-leaking screw-on caps.
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Additional information on the storage of
hazardous waste can be found in
Chapter C14.
2.3 Containment
Barrier systems for laboratories will
depend on the functions and activities to
be performed within the laboratory. Some
systems may be designed to contain haz-
ardous agents and prevent accidental
releases, while others are designed to
exclude contaminating agents that could
compromise an experiment. Others may
both confine and exclude. These objectives
are achieved through a combination of
design features, operating procedures, spe-
cialized safety equipment, and contamina-
tion control systems. Table D5-1 presents
the three levels of containment, what they
protect, and how they are achieved.
Table D5-1: Levels of Containment
Laboratory waste must be provided with
an isolated, exhausted, secured storage
area. An interim storage area should be
immediately accessible to the “dirty” side
of the barrier facility. For animal waste, a
cage dump station exhausted to the outside
must be located where animal cages are
dumped prior to washing.
Walls of diked areas must be made of
earth, steel, concrete, or solid masomy and
must be liquid tight. Walls and ceilings
should be flat and monolithic, with light-
ing recessed to minimize places where
dust may accumulate. All wall, floor, and
ceiling penetrations should be carefully
sealed to contain the spread of fire and
to preserve separation between adjacent
areas. Additional information on drains,
dikes, and walls can be found in 29 CFR
1910.106. Containment areas should
Levels of Containment
Primary Containment Level
• Protects laboratory personnel and the environment from direct exposure to hazardous
materials
• Provided by engineering controls such as laboratory fume hoods and biological safety
cabinets, with the exhaust air filtered or treated to remove the contaminants before
discharge
Secondary Containment Level
• Protects areas outside the laboratory
• Provided by the physical characteristics of the laboratory (e.g., corridor and room con-
siruction and arrangement, airlocks, ventilation systems, clothing change rooms, and
showers)
Tertiary Containment Level
• Protects an entire area or facility
• Provided by isolation or physical separation
I k
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undergo a regular inspection focusing
on the condition of the barrier, as well
as leaks and spills within the barrier. All
barrier systems must be kept clean and
well-maintained.
3.0 Biological Hazards
Detailed information on the control of
biological hazards is included in Chapter
C7 of this manual. Presented here is gen-
eral information on containers and other
devices used to control biological hazards.
Engineering controls must be the primary
source of controlling biological hazards.
For any contaminated needles and/or other
sharps, mechanical devices specified for
such purpose must be used for bending,
recapping, or needle removal, where nec-
essary. This practice should be avoided
where feasible.
Containers for sharps must
be puncture resistant,
leakproof on at least the
sides and bottom, and
labeled or color-coded
for identification. Blood and
other potentially infectious materials must
be placed in a container that prevents leak-
age and that is also labeled or color-coded.
If outside contamination of the primary
container occurs, a secondary container
must be used to prevent leakage. A sec-
ondary container should also be used if the
specimen may puncture the primary con-
tainer. Decontamination of all engineering
controls must take place after each use.
Engineering controls for biological haz-
ards must be examined and maintained on
a regular basis to ensure their effective-
ness. Examination should focus on the
integrity of storage containers and other
containment devices.
4.0 Radiation Hazards
Engineering controls for radiation safety
are design features or devices that are used
to minimize radiation hazards to employ-
ees and the environment. This section pro-
vides examples of radiation safety
engineering controls for several types of
equipment that may be found in an EPA
laboratory (e.g., lasers, accelerators, x-ray
machines). Refer to Chapter C6 of this
manual for more information on radiation
safety.
4.1 Lasers
Engineering controls for lasers can include
beam housings, beam shutters, attenuators
and remote firing controls. Control mea-
sures are determined by the laser class.
Table D5-2 presents information extracted
from ANSI Z136.l-1993 pertaining to
engineering controls according to laser
class.
The following sections describe some of
these engineering controls.
Protective Housing. A laser shall have an
enclosure around it that limits access to the
beam or radiation at or below the rnaxi-
mum permissible exposure (MPE) level.
Housing is required for all classes of lasers
except at the beam aperture. In some cases,
the walls of a properly enclosed room can
be considered a “walk-in” enclosure that
serves as protective housing for an open-
beam laser.
t I A
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Table D5-2: Engineering Control Measures by Laser Class
Engineering Control Measure
Laser Classification
I
11
ifia
ifib
P /
Protective housing
MUST
MUST
MUST
MUST
MUST
Interlocks on housing
SNCL
ENCL
ENCL
MUST
MUST
Service access panel restriction
ENCL
ENCL
ENCL
MUST
MUST
Master switch control
NR
NR
REC
MUST
Optical viewing portals
>
>MPE
>MPE
>MPE
Collecting optics below MPE
>
>MPE
>MPE
>MPE
>MPE
Totally or partially open beam path
‘q’w
NHZ
Interlock
MUST
Beam stop/attenuator
NR
Nit
REC
MUST
Activation warning
NR
NR
NR
REC
MUST
Beam emission delay
NR
NR
NR
NR
MUST
Indoor/outdoor controlled area
NHZ
NHZ
Navigable airspace
REC
REC
REC
Temporary controlled area
or
>MPE
ENCL
or
>MPE
ENCL
or
>MPE
NR
NR
Remote firing/monitoring
--
Labels
MUST
MUST
MUST
MUST
MUST
Posting of signs
Nit
REC
NHZ
NHZ
This table shows that there are controls that are:
• Required based on the Easer class (MUST)
• Not required for the laser class (NR)
• Required if the maximum permissible exposure is exceeded (>MPE)
• Required in addition to establishing a nominal hazard zone (NHZ)
Required if the laser is an enclosed Class 11Th or IV (ENCL)
• Recommended based on the laser class (REC)
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Master Switch Con troL All Class JV
lasers and laser systems require a master
switch control. The switch can be operated
by a key or computer code. When dis-
abled, the laser cannot be operated. Only
authorized system operators are to be per-
mitted access to the key or code.
Optical Viewing System Safety. Inter-
locks, filters, or attenuators are to be incor-
porated in conjunction with beam shutters
when optical viewing systems such as tele-
scopes, microscopes, viewing ports, or
screens are used to view the beam or
beam-reflection area. For example, an
electrical interlock could prevent laser
system operation when a beam shutter is
removed from the optical system viewing
path. Such optical filter interlocks are
required for all except Class I lasers.
Beam Stop or Attenuator. Class IV lasers
require a permanently attached beam stop
or attenuator which can reduce the output
emission to a level at or below the appro-
priate MPE level when the laser system is
on “standby.” Such a beam stop or attenu-
ator is also recommended for Class ifia
and Class flub lasers.
Laser Activation Warning System. An
audible tone or bell and/or visual warning
such as a flashing light is recommended as
an area control for Class ifib laser opera-
tion. Such a warning system is mandatory
for Class 1V lasers. These systems are re-
quired to be activated upon system start-up
and are to be uniquely identified with the
laser operation. Verbal countdown com-
mands are an acceptable audible warning
and should be part of the standard operat-
ing procedure.
Service Access Panels. The ANSI Z136.1
standard requires that any portion of the
protective housing that permits direct
access to an embedded Class flub or Class
IV laser must have either an interlock or
require a tool in the removal process. If an
interlock is used and is defeatable, a warn-
ing label indicating this fact is required on
the housing near the interlock. The design
shall not allow replacement of a removed
panel with the interlock in the defeated
condition.
Protective Housing Intelock Require-
ments. Interlocks that cause beam term-
ination or reduction of the beam to MPE
levels must be provided on all panels
intended to be opened during operation
and maintenance of all Class ifia, Class
ifib and Class IV lasers. The interlocks are
typically electrically connected to a beam
shutter. The removal or displacement of
the panel closes the shutter and eliminates
the possibility of hazardous exposures.
Remote Interlock Connector. All Class IV
lasers or laser systems must have a remote
interlock connector to allow electrical con-
nections to an emergency master discon-
nect interlock or to room, door or fixture
interlocks. When open circuited, the inter-
lock shall cause the accessible laser radia-
tion to be maintained below the appropri-
ate MPE level. The remote interlock con-
nector is also recommended for Class ifib
lasers.
In some cases, such as during research and
development, the operation of an unen-
closed laser or laser system may be neces-
saiy. In such cases, the laser safety officer
must determine the hazard and ensure that
controls are instituted appropriate to the
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class of maximum accessible emission to
ensure safe operation. Such controls may
include:
• Access restriction
• Eye protection
• Area controls
• Barriers, shrouds, beam stops, etc.
• Administrative and procedural
controls
• Education and training
4.2 Accelerators
Particle accelerators must be installed with
primary and secondary barriers that are
necessary to ensure that exposures are
minimized. Instrumentation, readouts and
controls on the accelerator control console
should be clearly identified and easily dis-
cernable. The accelerator area can be
equipped with an easily observable flash-
ing, rotating warning light that operates
when radiation is being produced. A radia-
tion survey should be conducted to deter-
mine compliance with exposure limits as
discussed in Chapter C6 of this manual.
43 X-Ray Equipment and Radiation
Generating Devices
Analytical x-ray equipment and radiation
generating devices should be equipped
with engineering controls as follows:
Safely Devices. Devices that prevent the
entry of any portion of an individual’s
body into the primary x-ray beam path or
which causes the beam to be shut off upon
entry into its path must be provided on all
open-beam configurations.
Warning Devices. Open-beam configura-
tions must be labeled so that their purpose
is easily identified, and have fail-safe
characteristics. In addition, they should be
provided with a readily discernible indica-
tion of:
• X-ray tube status - whether the tube is
on or off; located near the radiation
source housing, if the primary beam is
controlled in this manner
• Shutter status - whether the shutter is
open or closed; located near each port
on the radiation source housing, if the
primary beam is controlled in this
manner
Ports. Unused ports on radiation machine
source housings must be secured in the
closed position in a manner which will
prevent casual opening.
Labeling. All analytical x-ray equipment
must be labeled with a readily discernible
sign or signs such as:
Shutters. On open-beam configurations,
each port on the radiation source housing
shall be equipped with a shutter that can-
not be opened unless a collimator or a cou-
pling has been connected to the port.
Warning Lights. An easily visible warning
light labeled with the words “X-RAY ON”
shall be located near any switch that ener-
gizes x-ray tube and must be illuminated
only when the tube is energized. Warning
lights must have fail-safe characteristics.
CAuTiON
High Intensity II
BeamjJ
II CAUTION
Rd
II ThIS E uIpmsnt
liProdue.. R.dI.d.n
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D5. Hazard-Specific Controls
5.0 Fire Hazards
5.2 Protection Systems
Control and prevention of fires in a labora-
tory involve the use of the following engi-
neering controls, as outlined in the sec-
tions below:
• Alarm systems
• Protection systems
• Fire extinguishers
5.1 Alarm Systems
An integral component of an
Emergency Action Plan (refer
to Chapter 0 of this manual)
‘ . is a reliable, well-designed
employee alarm system. Each
EPA laboratory must be
equipped with an employee
alarm system that complies with OSHA’s
standard on employee alarms (29 CFR
1910. 165). The system must:
• Provide warning for necessary emer-
gency action or for reaction time for
safe evacuation of employees from the
workplace
• Be perceived above ambient noise or
light levels by all employees in the
affected portions of the laboratory
• Be distinctive and recognizable as a
signal to evacuate the work area or to
perform designated actions
The laboratory must ensure that all de-
vices, components, and systems installed
as part of the employee alarm system are
approved, maintained, and regularly tested.
Protection systems are used at EPA labora-
tories to protect employees, as well as
the facility in a fire. This section describes
requirements for detection systems, auto-
matic sprinkler systems, and other extin-
guishing systems.
5.2.1 Detection Systems
Detection systems are used at EPA labora-
tories to identify conditions that could
lead to fire and/or explosion, or the early
stages of a fire. Detection systems are also
used to detect releases of harmful chemi-
cals or other hazardous materials. There
are four types of detection systems often
used in facilities to protect against fire
hazards:
Heat Detectors: These devices respond
to the convected thermal energy of a fire.
They are activated when the detecting
element reaches a predetermined fixed
temperature, or when a specified rate of
temperature change occurs. The former
are called fixed-temperature detectors;
the latter are rate-of-rise detectors. Some
detectors combine both features.
Smoke Detectors: loniza
non smoke detectors typi-
cally respond faster than
the photoelectrictype to
flaming fires, as these fires
produce smaller smoke particles. The
larger smoke particles that are generated
by smoldering fires are typically detected
faster by photoelectric detectors.
Flame Detectors: These detectors re-
spond to radiant energy from flames, coals
or embers. There are two types: infrared
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and ultraviolet flame detectors. The major
difference is the insensitivity of the latter
to sunlight.
Combustible Gas Detectors: These units
detect the presence of flammable vapors
and gases. They are used to warn when
concentrations of these vapors in the air
approach the explosive range.
Toxic Gas Detectors: This instrumentation
can be used for detecting both major
releases and small leaks of toxic materials
so that the proper response action can be
initiated at the earliest time.
5.2.2 Detector Selection and
Installation
The selection of a detector should be based
on the anticipated hazard(s) and the envi-
ronment to be protected. Criteria include:
• Type and amount of combustibles
• Possible hazard sources
• Environmental conditions
• Property values
Heat Detectors: Heat detectors are used
most effectively to protect confined
spaces, or the areas immediately next to
a particular hazard. Because the heat from
a fire can dissipate quite rapidly over a
larger area, further propagation of fire is
required before the device is tripped. The
operating temperature of a heat detector is
typically 25 degrees higher than maximum
ambient conditions.
Smoke Detectors: These detectors typi-
cally respond more quickly to fire than
heat detectors, and can be used effectively
in large, open spaces. Photoelectric de-
vices are preferable if smoldering fires are
anticipated, while ionization devices are
more effective at detecting flaming fires.
Prevailing air currents, as well as ceiling
and room configurations, are a key consid-
eration in their placement.
Flame detectors: Flame detectors are gen-
erally installed in high-hazard areas where
rapid fire detection is critical. However,
infrared flame detectors are subjected to
interference from solar radiation, so the
potential for false trips is important. Since
flame detectors are line-of-sight devices,
an unobstructed view of the flame must
occur for detection.
Combustible Gas Detectors: These detec-
tors are selected and calibrated for the spe-
cific substances to be detected. They are
typically located close to the hazard and
are set to activate an alarm when a certain
percent of the lower flammable limit is
reached.
Additional details on selection and instal-
lation of automatic fire detectors can be
found in NFPA No. 72, “National Fire
Alarm Code.”
Toxic Gas Detectors: Toxic gas detectors
are selected based on considerations such
as sensitivities, speed of response, sub-
stance to be detected, and sampling mode.
Additional details on selection and instal-
lation can be found in Guidelines for
Postrelease Mitigation Technology in the
Chemical Process Industry published by
the Center for Chemical Process Safety.
Testing and Maintenance
Testing and maintenance of detection sys-
tems and their components are keys to reli-
able operation. These activities also help
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05. Hazard-Specific Controls
reduce the number of false alarms. Such
actions should be performed on a regular
basis and documented for review.
5.23 Automatic Sprinkler Systems
The following infonnation
is presented as reference
material for personnel at
laboratories which have, or
are considering the install a-
tion of, such systems.
Types
Sprinkler systems automatically provide
water to extinguish fires. The different
types of systems available include:
We: pipe systems: These are character-
ized by the presence of water in the
lines under pressure. The water will
flow through any head(s) that fuses in
a fire environment.
• Dry pipe systems: These are character-
ized by the presence of air in the lines
under pressure. The air will flow
through any head(s) that fuses in a fire
environment. This allows water to
flow into the lines. Water then flows
through the fused head(s).
• Preaction systems: These have air in
the lines, and have a fire detection sys-
tem. The detection system operates a
valve that allows water to flow into
the lines. The system then operates
like a traditional sprinkler system.
Water Supply Requirements
While there are various sprinkler system
designs, a critical characteristic of all
systems is the design density. Design
density is expressed in gallons per minute
per square foot (gpm/W) over an area of
sprinkler operation. The design density
required for adequate fire protection of a
laboratory depends upon the fire loading
of combustibles, and may vary from mom
to room. The design density provided
by the sprinkler system is a function of
head spacing, pipe scheduling, and water
supply. Thus, the design density required
by the laboratory and the design density
provided by the sprinkler system are both
important considerations.
In considering water supply requirements,
data on the static pressure (psi) and the
residual pressure (psi) when water is flow-
ing (gpm) are important. Allowance must
also be made for the demand of hose
streams, typically 250 gpm, in anticipation
of possible manual fire-fighting efforts.
Additional details on the design and instal-
lation of automatic sprinkler systems can
be found in the NFPA No. 13, “Sprinkler
Systems.”
inspection and Maintenance
Inspection and maintenance are critical to
the reliability of sprinlder system opera-
tion. Items to be inspected include the
sprinkler control valves, the water pres-
sure, and (in the case of dry systems),
the air pressure. Fire pumps and suction
tanks should also be checked if they are
system components. Sprinkler system
maintenance should address head condi-
tion, corrosion, and freezing. Periodic
flushing of yard mains and branch lines
will help ensure reliable water flow. More
specific maintenance items are a function
of system design (e.g., annual trip testing
for dry pipe valves).
a ma
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5.2.4 Other Extinguishing Systems
The following information is presented as
reference material for personnel at labora-
tories which have, or are considering the
installation of, such systems.
When selecting or evaluating automatic
extinguishing systems, the nature of the
area to be protected must be understood.
There are four basic types of fires, all
of which can occur in the laboratory
environment:
Dry Chemical Systems
Dry chemicals are powders that are effec-
tive in extinguishing Class A, B, and/or
C fires. Advantages of using this type
of automatic extinguishing system
include quick knockdown capability
and nonconductivity; however, disadvan-
tages include slight corrosivity and diffi-
culty in clean-up.
A fixed dry chemical system consists of
the agent, an expellant gas, a means to
activate the system (e.g., a flame detector),
and fixed piping and nozzies. Designs
include both total-flooding and local-
application types. Additional details
on the design and installation of fixed
dry chemical systems can be found in
NFPA No. 17, “Dry Chemical Extinguish-
ing Systems.”
Carbon Dioxide Systems
Carbon dioxide is effective in extinguish-
ing Class B and C fires. Extinguishment
is accomplished by reducing the oxygen
content of the atmosphere, so it no longer
supports combustion. It can also extin-
guish a fire by cooling. Advantages of
this type of extinguishing system include
its own pressure for discharge and the lack
of residue after use. Disadvantages, how-
ever, include the need for retention of the
extinguishing atmosphere, and the inherent
danger of oxygen displacement when used
in areas occupied by personnel.
A carbon dioxide system consists of the
agent, a means to activate the system
(e.g., heat detector), and fixed piping and
nozzles. Designs include both total flood-
ing and local application types. Although
enclosure is mandatory for total flooding,
it is strongly recommended for local appli-
cations. Additional details on the design
and installation of carbon dioxide systems
can be found in NFPA No. 12, “Carbon
Dioxide Extinguishing Systems.”
Foam Systems
There are several different types of foams
used to suppress fires and/or vapors from
flammable or combustible chemicals.
Foams are defined by their expansion
ratio, or their final foam volume compared
Class A: Fires in ordinary combustible
materials, such as wood, cloth, paper,
rubber, and some plastics
Class B: Fires in flammable liquids,
oils, greases, tars, oil base paints,
lacquers, and flammable gases
Class C: Fires that are engendered by
energized electrical equipment
CLass I): Fires in combustible metals,
such as magnesium, titanium,
zirconium, sodium, lithium, and
potassium
% FIA
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CHAPTER D
to their original foam solution volume
before adding air. There are:
• Low-expansion (<20:1)
• Medium-expansion (20-200:1)
• High-expansion (200-1,000:1)
Different foaming agents include aqueous
film-forming foam, fluoroprotein foam,
alcohol-type foam, and high-expansion
foam. Application can be effected via
fixed or portable systems.
Additional details on the design and
installation of foam systems can be found
in NFPA No. 11, “Low Expansion Foam
Systems” and NFPA No. hA, “Medium
and High Expansion Foam Systems.”
53 Fire Extinguishers
Hand portable fire extinguishers
are considered to be the first
line of fire defense. They repre-
sent the most mobile equipment
available and are used primarily
to suppress small, accessible
fires before those fires have the
opportunity to grow in size and
intensity. This section provides
information on the types of
extinguishers, their location and
installation, proper use, inspection,
testing and maintenance, and training.
5.3.1 Types of Extinguishers
The selection of fire extinguisher type
should be based on the class of hazards to
be protected:
For the majority of research laboratory
applications, water and AFFF extin-
guishers should have a capacity of 2.5 gal-
lons. Dry chemical, carbon dioxide, and
foam extinguishers should hold 20 to
30 pounds. In site selection, one should
consider both the hazards and the strength
of the personnel using the extinguisher.
Historically, bromochiorodifluoromethane
(Halon 1200) and bromotrifluoromethane
(Halon 1301) extinguishers have been
recommended for use on certain types
of fires. In light of the ozone layer deple-
tion and the resulting Montreal Protocol
that set a goal of halving the use of chloro-
fluorocarbons by the end of the nineties,
halon use is decreasing and is not recom-
mended.
53.2 Location and Installation
Fire extinguishers should be located
conspicuously and br readily accessible
in the event of a fire. There should be
a maximum travel distance of 30 feet
to an extinguisher, and it should be
D5. Hazard-S iecific Controls
Class A hazards should be protected with water,
multipurpose dry chemical, and foam or aqueous
flim-fornung foam (AFFF).
Class B hazards should be protected with dry
chemical, carbon dioxide, foam or AFFF.
Class C hazards should be protected with dry
chemical or carbon dioxide.
Class D hazards should be protected with
extinguishers and extinguishing agents approved
for use on the specific combustible metal hazard
(e.g., G.1 powder for magnesium fires, Lith.X for
lithium fires).
It
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Engineering Controls
D5. Hazard-Specific Controls
located along normal paths of travel,
including exits from an area. Preferably,
extinguishers should be located close to
any known hazard. In addition, the top
of the extinguisher should be installed no
more than five feet above the floor, and
the clearance between the bottom of the
extinguisher and the floor should be no
less than four inches. Finally, operating
instructions should be placed on the front
of the extinguisher, where they can be
easily seen.
5.3.3 Extinguisher Use
The acronym ‘PASS” represents the fol-
lowing procedure, which should be
observed after selecting the correct fire
extinguisher and readying it for use.
In addition, the following should be noted
for fighting fires:
• When approaching a fire, be sure you
can retreat rapidly in a straight line.
• Never turn your back on a fire or the
place where the fire was just burning.
• Never use water on combustible met-
als, flammable liquids, or on electrical
fires while the current is on.
• Keep the wind at your back to avoid
flashback.
5.3.4 Inspection, Testing and
Maintenance
Inspections of fire extinguishers should
be conducted regularly (at least monthly)
to ensure that they have been properly
placed and are operable. It is also impor-
tant that each inspection be documented,
with records retained, for review.
Staff performing routine inspections
should check that each extinguisher:
• Is in its designated place
• Is conspicuous
• Is not blocked in any way
• Has not been activated and become
partially or completely emptied
• Has not been tampered with
• Has not sustained any obvious physi-
cal damage or been subjected to an
environment that could interfere with
its operations (e.g,. corrosive fumes)
• Shows satisfactory condition, if equip-
ped with a pressure gauge and/or tam-
per indicators
Maintenance of extinguishers involves a
complete and thorough examination, It
should include examining the mechanical
parts, the amount and condition of the
extinguishing agent, and the condition of
the agent’s expelling device. Maintenance
techniques vary for each extinguisher, and
inspections should be performed by quali-
fied personnel. Formal maintenance activ-
ities should be conducted at least yearly.
PULL out the locking pin and the
plastic seal or push the activator
AIM the nozzle at the base of the fire
SQUP 1F the release trigger
SWEEP the extinguishing material
across the base of the fire from side to
side
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D5. Hazard-Specific Controls
In addition to routine maintenance, hydro-
static testing must be performed on
extinguishers subject to internal pressures
to protect against failure caused by the
following:
• Internal COlTOSiOfl from moisture
• External corrosion from atmospheric
humidity or corrosive vapors
• Damage from rough handling
• Repeated pressurizations
• Manufacturing flaws
• Improper assembly of valves or safety
relief discs
• Exposure to abnormal heat, such as
fire
Hydrostatic tests should be conducted
by qualified personnel using proper
equipment. Such tests are often per-
formed by firms that sell and service fire
extinguishers. A recommended schedule
for hydrostatic testing is five years for
water, dry chemical, carbon dioxide,
foam, and aqueous film-forming foam
extinguishers, as stipulated in 29 CFR
1910.157 and NFPA No. 10.
Tags and seals should be used to record
inspection and maintenance checks. (A
seal is a good indicator of whether an
extinguisher has been used.) In addition,
a record should be kept of the date of
purchase and dates of maintenance for
each extinguisher. For maintenance,
recharging, and hydrostatic tests, records
should include the date of testing, and the
name of the person or agency who per-
formed the test. For hydrostatic tests, the
record should also include a description of
dents that remained after passing a hydro-
static test.
6.0 Noise
Loud noise levels in laboratories are typi-
cally attributed to ventilation equipment
and laboratory animals. Noise levels must
stay below 85 decibels (dBA) for an 8-
hour time-weighted-average (TWA) in
work areas, otherwise a hearing conserva-
tion program must be implemented. Levels
this loud through, are not common in labo-
ratories. Engineering control techniques
must be the primary means of controlling
noise exposures above 85 CIBA, and are
often applied to control levels lower than
this for an even more comfortable range.
For the application of engineering noise
controls, a professional engineer or
experienced industrial hygienist should
be consulted.
6.1 Ventilation Equipment Noise
The American National Standard for Labo-
ratory Ventilation (ANSI/AIHA Z9.5-
1992) states that fans, ductwork, and air
velocities of laboratory ventilation equip-
ment must not exceed 85 dBA at labora-
tory work locations. Fans must be located
or provided with noise treatment to main-
tain levels below this limit at any fre-
quently occupied work station. The system
must be designed to provide control of
exhaust system noise in the laboratory.
The types of fans used for laboratory hood
exhaust are flat blade and backwardly-
curved-blade centrifugal fans, in-line cen-
trifugal fans, and vane axial fans. If possi-
ble, increased sound levels due to new
installations of fans and/or other ventilat-
ing equipment should be calculated in
advance. Then, noise may be controlled
by selection and design.
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D5. Hazard-Specific Controls
The fundamental controls of centrifugal
fan noise include the utilization of absorp-
tive, parallel, or circular baffle-type silenc-
ers. This type of silencer has good high-
frequency attenuation and minimal aerody-
namic pressure loss (not likely to affect fan
efficacy). Figure D5-2 illustrates a simple,
common approach. A tubular silencer is
installed on the inlet of the fan using an
adapter, and a parallel baffle duct-type
silencer is installed on the exhaust. A flex-
ible coupling of dense material adapts the
silencers to the fan and provides vibration
isolation between the fan and the duct-
work. Vibration mounts are used to isolate
the fan from the duct system.
Figure D5-2: Centrifugal Fan Silencer
For axial fans, the basic approach of
installing a tubular absorptive silencer
on the inlet and exhaust is used for noise
control. Figure D5-3 demonstrates this
approach for axial fans. Also, the fan
should be isolated from the ductwork,
floor, ceiling, and/or platform. To select
a silencer, use the following method:
• Calculate the volume flow or face
velocity, and compare it to the silencer
manufacturer’s pressure loss
specifications.
Size the silencer so the open flow-
through cross section is 1.25 to 1.5
times the fan duct cross-sectional area.
In office buildings, a common approach
to control noise associated with ventilating
equipment is to line ductwork with absorp-
tive material. This method must never
be applied to laboratory ventilation
equipment. Materials used to absorb noise
will also absorb chemicals, preventing air-
stream cleaning. The materials are also
typically combustible, promoting a fire
within the ductwork upon contact with
certain chemicals.
6.2 Animal Noise Control
Laboratory animals, as well as the associ-
ated support functions such as cage-
washing, may create a high level of noise
within a laboratory. The noise is not only
harmful to human workers, but to the ani-
mals themselves. Masonry walls are a
good source of noise control, as opposed
to metal or plaster. The density of the
masonry walls reduces the transmission
of noise through the walls. The use of
acoustic materials for noise absorption
on the ceilings is not recommended, as
this could present sanitation problems.
Sanitizable sound-attenuating materials
bonded to walls or ceilings can be applied
for noise control, as appropriate. Again,
a professional must be consulted to deter-
mine the applicability and effectiveness
of such control techniques. Other general
noise control methods used to prevent
transmission down corridors include:
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Engineering Controls
D5. Hazard-Specific Controls
• Well-constructed corridor doors
• Sound-attenuating doors
• Double-door entry
Figure D5-3: Axial Fan Silencer
For the protection of laboratory animals,
fire and environmental-monitoring alarm
systems and public-address systems should
be selected and located to minimize poten-
tial exposure to animals. Many species can
discriminate much higher frequencies than
humans, so it is important to consider the
location of equipment, avoiding the gener-
ation of ultrasonic frequency sound.
7.0 Laboratory illumination
Proper laboratory illumination not only
increases the quality of the work environ-
ment, but also:
• Improves worker morale
• Reduces the potential for accidents
• Improves laboratory housekeeping
This section describes some general
provisions for the design of laboratory
lighting, required lighting levels for EPA
laboratories, and a basic description of
lighting level measurements.
7.1 Design of Lighting Systems
An illumination engineer should be con-
sulted for installation of new lighting sys-
tems, or for any major laboratory redesign.
Adequate quantity and quality of light are
essential considerations in the design pro-
cess. The quantity of light needed within
the laboratory will be different based on
different tasks performed within the labo-
ratory. For example, work performed
inside a laboratory hood will typically
require a greater quantity of light than
tasks performed in storage areas, based
simply on the inherent characteristics of
tasks performed in these two types of
areas. Glare, contrast, and color are impor-
tant quality considerations. Laboratory
personnel should be consulted about the
scale of the tasks they perform, and the
types of equipment (e.g., size, color, etc.)
they use. Lighting systems are then
designed based on this information. The
physical characteristics of the room and
the desired appearance of the finished
installation are considerations as well.
Localized lighting systems should be
installed where high light intensity is
needed (i.e., specialty-seeing critical
tasks). Localized lighting systems are
also useful where a directional quality
is needed. When installing a localized
lighting system, caution must be taken
to ensure a reasonable relationship
between intensities of the general and
of the localized lighting. An excessive
luminance ratio between the work point
and the surroundings will create an un-
comfortable seeing condition.
Other factors to consider in the design of a
lighting system include:
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• Choice of light source (i.e., filament,
mercury vapor, fluorescent)
• Heat produced from the source
• Efficiency of the lamp or light source
• Electrical features (e.g., type of wir-
ing)
• Mechanical structure of the support of
the fixtures
•
A
It is important to note that the types of haz-
ards and chemicals present in the labora-
tory may affect the choice and design of
lighting systems. For example, flammable
storage areas should be designed with
explosion-proof lighting systems.
Within laboratories, the following recom-
mendations should be considered:
Laboratory
Working and
Storage Areas
50 foot-candles
Bench-Top
Work Surfaces
100-1000
foot-candles
WorkSurface
Under Hoods
100-1000
foot-candles
Interior
Corridors
30 foot-candles
7.3 Measurement of Light
7.2 illumination Requirements and
Reconunendations
The EPA’s Facility Safely, Health, and
Environmental Management Manual
dictates that work-area lighting must be
maintained, as near as practical, to the
recommendations of the illuminating
Engineering Society of North America,
in their handbook entitled Recommended
Practices. Guidelines established in 41
CFR 101-20 (Federal Property Manage-
ment Regulations) and the General
Services Administration’s (GSA) Public
Buildings Service (PBS) PXIOO-1 must
also be followed where possible. In these
guidance documents, the following light-
ing levels in Table D5-3 are generally
recommended:
All ultraviolet lights installed for scientific
operations must be evaluated for safety on
a case-by-case basis. Shielding and inter-
locks must be provided where appropriate.
mumination is measured in foot-candles,
which is actually a measurement of light
density. To measure light, there are many
types of foot-candle meters available. Typ-
ical meters are portable, with a wide range
of sensitivity. The type of meter chosen is
based on the areas monitored and desired
accuracy of results. Careful handling and
frequent calibration is necessary with most
foot-candle meters to maintain reliability.
Ordinary field measurements cannot be
expected to have an accuracy greater than
±5% under the most favorable conditions.
In addition, the user must understand the
following meter characteristics to obtain
the best possible results:
• The instrument must be color cor-
rected, due to the difference between
instrument sensitivity and that of the
human eye
• The instrument must be adjusted for
the angle of the reflected light
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Engineering Controls
Table DS-3: Reeommended Lighting Levels
D5. Hazard-Specific Controls
Levels
Work Location
Measurement Location
50 to 100-foot levels
Laboratory spaces
At bench level
50 foot candles
General office areas
30 inches above floor level
30 foot candles
Other work areas
30 inches above floor level
5 to 10-foot candles
Corridors and stairways
At walking surface
• The light-sensitive cells of the insiru-
ment will exhibit fatigue (tendency for
the meter indication to drop off slowly
over a period of minutes until a con-
stant reading is reached). This effect
is predominant at high foot-candle
levels, especially if the meter was
recently taken from a dark storage
location. The meter must be given
an adaption period, and must experi-
ence constant calibration.
The owner’s manual for foot-candle
meters must be consulS on the particular
techniques used for the specific meter, to
obtain the best possible results.
To perform a lighting survey, the follow-
ing information must be obtained:
• Description of the illuminated area
— Room dimensions
— Color
— Reflectance
— Conditions of the mom surface
— Temperature surounding the
lights
• Description of The general lighting
system
— Quantities
— Conditions
— Wanages
— Lamps
— Distribution
— Spacings
— Mountings
• Description of any supplementary
lighting That might be used
• Description of instruments to be used
— illumination measurement
— Do not cast shadows
— Do not reflect additional light
from clothing
— Test surfaces as close to the work-
ing plane as possible (if no work-
ing plane, take measurements on a
horizontal plane 30 inches above
the floor)
• Luminance measurements
The data resulting from the light survey
can be used to compare the illumination
levels for compliance with EPA-required
levels. Results may also be used to
determine:
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Engineering Controls D5. Hazard-Specific Controls
• Luminance ratios for visibility and
safety
• Comfort level and pleasantness in the
area
• Lighting deficiencies
• A light-system maintenance schedule
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Protective Clothing and Equipment
El. Introduction
Controlling laboratory hazards involves a combination of substitutions, engineering controls,
administrative controls and work practices, and protective clothing and equipment. Generally,
the hierarchy of hazard control should be:
• Removal
• Replacement/substitution
• Engineering controls
• Administrative controls
• Protective clothing and equipment
Protective clothing and equipment should only be used when other controls are not feasible,
while they are being implemented, or during emergency situations. Respiratory protection is a
type of personal protective equipment used to control those health effects caused by breathing
air contaminated with harmful or potentially harmful gases, vapors, or aerosols. Other types
of protective equipment used to minimize the risk from laboratory hazards include emergency
drenching facilities, such as safety showers and eyewash stations.
This section provides guidance for EPA laboratories on protective clothing and equipment in
the following chapters:
Chapter
Topic
E2
Personal Protective Equipment
E3
Respiratory Protection
E4
Emergency Eyewashes and Showers
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Protective Clothing and Equipment
E2. Personal Protective Equipment
1.0 Introduction
EPA laboratory employees face the risk
of exposure to a wide variety of hazardous
substances, including chemical, physical,
and biological agents. Engineering con-
trols, standard operating procedures,
administrative controls, and materials
substitutions are considered the first
line of defense in controlling workplace
hazards. Personal protective equipment
(PPE) should be used only in the capacity
of a secondary exposure control strategy,
where other controls are not feasible or
fully sufficient.
Unlike engineering controls that isolate or
otherwise control a hazard, PPE isolates
the wearer from the hazard. PPE and, more
specifically, chemical protective clothing
(CPC), provide a physical barrier to the
hazard.
Exposure to chemical, physical, and bio-
logical hazards without the use of PPE or
other controls can have a number of differ-
ent adverse effects. For instance, several
general effects of chemical exposure can
be experienced based on the type and
degree of exposure. Exposures can be
either acute (i.e., short-term and generally
high concentrations) or chronic (i.e., long-
term and generally lower concentrations),
and the effects can be either localized or
systemic. Localized effects are seen at the
point of contact, such as burns of the skin
when exposed to a corrosive substance,
while systemic effects are seen in a target
organ. An example of a systemic effect is
the depression of the central nervous sys-
tem caused by the skin absorption of
phenol.
In addition, many laboratory personnel
are working with samples that contain
unknown chemical and/or biological haz-
ards. The majority of adverse effects could
be prevented with properly selected and
used PPE and CPC.
This chapter addresses the use of PPE in a
laboratory setting. It also discusses the
hazards against which protection is need-
ed, and the types of PPE that are available.
Finally, it focuses on the PPE require-
ments to control exposure to chemical,
physical, and biological hazards via con-
tact with the skin, eyes, or mucous mem-
branes. Respiratory protection will be
addressed in the following chapter.
EPA Program Requirements
Each location must conduct and certify a
hazard assessment for laboratory tasks and
areas to determine what potential hazards
are present that necessitate the use of PPE.
Where PPE is needed, laboratories must:
• Select and have each employee use the
appropriate types of PPE based on the
results of the hazard assessment.
• Communicate selection decisions to
each affected employee.
• Select PPE that properly fits each
affected employee.
• Establish a maintenance and care
program for PPE.
• Provide training to each employee
required to wear PPE.
• Maintain required documentation.
EPA SHEM Guide 44 provides guidance
on conducting the hazard assessment and
implementing an effective PPE program.
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Protective Clothing and Equipment E2. Personal Protective Equipment
In addition, it outlines the requirements of
the U.S. Occupational Safety and Health
Administration (OSHA) standards on PPE
contained in 29 CFR 1910 Subpart I.
Program Administration
To effectively manage the laboratory PPE
program, responsibilities should be
assigned for:
Completion and certification of the
PPE hazard assessment
• Selection of appropriate PPE based on
the workplace hazards, the level of
risk, and the individual needs of the
worker (e.g., fitting requirements)
• Procurement and distribution of
selected PPE
• Training of employees in the use,
maintenance, and limitations of PPE
• Performance of periodic checks to
ensure that employees are properly
using required PPE and that damaged
or defective equipment is not used
• Evaluation of the effectiveness of the
overall PPE program
• Maintenance of required records
(e.g., assessment certification, training
documentation)
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E2. Personal Protective Equipment
2.0 Hazard Assessment and Selection of
PPE
EPA SHEM Guide 44 provides detailed
guidance on conducting the hazard assess-
ment and implementing an effective PPE
program. These requirements will not be
repeated here. Instead, the following infor-
mation is provided to supplement Si-EM
Guide 44.
The individual or group designated to con-
duct the hazard assessment must:
• Be familiar with the potential hazards,
the type of protective equipment that
is available, and what it can do (e.g.,
splash protection, impact protection).
• Compare the hazards associated with
the environment (e.g., impact veloci-
ties, masses, projectile shape, radiation
intensities) with the capabilities of the
available protective equipment.
• Select the protective equipment that
ensures a level of protection greater
than the minimum required to protect
the employees from the hazards.
• Select equipment that meets the Amer-
ican National Standards Institute
(ANSI) design specifications as pre-
sented in Table E2-1.
An example of a completed laboratory
hazard assessment, referenced from EPA
SHEM Guide 44 Personal Protective
Equipment, is located in Attachment E2-l
of this manual.
EPA Si-IBM Guide 44 also includes
examples of forms that can be used for
documentation. Laboratory locations can
use the types of hazard assessment forms
most suitable for their needs, as long as all
required information is documented. An
alternate example of a form is included in
Attachment E2-2 of this manual. Com-
pleted PPE Assessments must be main-
tained with the laboratory’s chemical
hygiene plan.
Table E2-1: ANSi Design Specifications
Equipment
Spedliadons
(j) Head Protection
ANSI Z89.l- 1997, Industrial Head Protection
Q Eye and Face Protection
ANSI Z87.1—1989, Practice for Occupational and Educational
Eye and Face Protection
( ) Hearing Protectors
ANSi 512.6-1997, Methods for Measuring Real-Ear Auenua-
tion of Hearing Protectors
3 Protective Footwear
ANSI Z41-1991, Personal Protection-Protective Footwear
•Ø aoT
Selection based on performance characteristics of gloves in
relation to tasks to be performed.
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Protective Clothing and Equipment
E2. Personal Protective Equipment
There may be multiple hazards associated
with specific jobs or tasks. PPE Selection
must be based on all potential hazards. For
additional guidance on multiple hazards,
refer to the risk assessment information
located in Chapter B of this manual.
2.1 Selection Process
Selection of the most appropriate PPE
depends on the work scenario; chemical,
biological, physical, and environmental
hazards; expected duration of exposure;
current controls; worker compliance; and
other factors. Accident data may also be
reviewed to help identify problem areas.
The hazard assessment must be updated
regularly to determine if hazards have
changed and if the selected PPE is appro-
priate for hazards present.
After identifying potential hazards associ-
ated with a task, the following criteria
should be used in evaluating hazards and
selecting PPE:
• Type of hazard and degree of exposure
• Duration of exposure
• Frequency of exposure
• Type and seriousness of potential
injury
• Level of risk of injury
• Required chemical and physical
performance of PPE
PPE selection factors are illustrated in
Figure E2-l.
Selection of the most appropriate personal
protective equipment ensemble should be
made by a trained health and safety
professional since it encompasses multiple
steps and decision points.
Figure E2-1: PPE Selection Factors
• Chemical (e.g., liquid, solid.
gas/vapor, aerosol)
• Physical (e.g.. temperature,
impact, compression,
puncture, pressure)
Biological
• Cusrent conirols
• Duration (e.g., houra per day)
• Frequency (e.g., times per
day, month, year)
• Chemical resistance
• Durability and flexibility
• Abrasion and cut resistance
• Service life
• Cleanability
• Size
• Acute
• Chronic
• Seriousness (e.g., minor,
moderate, severe)
• Risk (e.g., low, moderate,
high)
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E2. Personal Protective Equipment
Whenever possible, employees should
be allowed to choose the particular style/
model of clothing and equipment from
a preselected group of different types
that meet the performance and job
requirements.
2.2 Additional Resources
Information on chemical and physical per-
formance of select protective materials is
contained in Attachment E2-3 of this man-
ual. The tables contained in this attach-
ment summarize chemical resistance of a
number of materials against chemicals
commonly used in EPA laboratories, and
also provide general information on physi-
cal performance of select materials.
Vendor catalogs often provide permeation
data and other recommendations that can
be used in the selection of PPE. Many also
offer a technical assistance number to fur-
ther assist in selection decisions. Often an
Internet search may produce a variety of
PPE selection guidance information.
A definitive comprehensive document that
reviews the selection process for PPE is
entitled, “Guidelines for the Selection of
Protective Clothing, 3rd edition.” It was
prepared by Arthur D. Little, Inc. (A.D.
Schwope et al.). This publication is avail-
able from the American Conference of
Governmental Industrial Hygienists, Inc.
Other useful resources include:
• Material Safety Data Sheets (MSDSs)
• Laboratory chemical hygiene plan
• Technical references related to PPE
(e.g., OSHA, NIOSH)
3.0 Types of PPE
OSHA requires that protective equipment
be provided, used, and maintained in a
sanitary and reliable condition. PPE must
be accessible to laboratory personnel at all
times.
Basic PPE requirements for laboratory
tasks include:
• Laboratory coat with long sleeves
• Safety glasses with side shields
• Closed-toe, practical shoes—no
open-toed shoes or sandals
Additional PPE will be required for certain
tasks based on the results of the
laboratory-specific hazard assessment.
The following sections provide additional
guidance on the specific types of
protection:
S
Eye and Face
• Hand
• Body
• Head
• Hearing
3.1 Eye and Face Protection
Protective eye and face equipment are
required, under 29 CFR 19 10.133, when
there is a reasonable probability of injury
to the eyes or face that could be prevented
by the use of such equipment. This
includes potential exposure to chemical
splashes, gases or vapors, or dusts. Suit-
able eye and face protection must be made
available to workers for laboratory opera-
tions where there is a hazard of flying
objects, liquids, glare, injurious radiation,
or a combination of these hazards.
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Protective Clothing and Equipment
E2. Personal Protective Equipment
Safety Glasses
Safety glasses have tradi-
tionally been used as the
eyewear of choice in the
majority of EPA
laboratories. Safety
glasses are available in many different
configurations and styles, and can be fitted
with prescription lenses if required. For
operations where there is a hazard from
flying objects, the safety glasses must have
sideshields. However, sideshields are
highly recommended for all laboratory
operations.
Goggles
In work areas where a
splashing liquid or rap-
idly moving airborne par-
ticulate may cause potential injury, clear
plastic goggles that completely enclose the
eyes will provide superior protection over
safety glasses.
Goggles may be either “chemical splash
goggles” or “safety goggles,” for protec-
tion against particulate matter. Be sure to
specify the desired type in ordering.
Both safety glasses and goggles are avail-
able in tints and shades that permit their
use for exposure to non-ionizing radiation
such as ultraviolet light. When working
with lasers, the frequency of the radiation
must be known to provide adequate pro-
tection, since the absorbing media are
frequency-specific and, when there is a
potential for exposure to nonionizing
radiation the spectral distribution must
be determined in order to provide adequate
protection.
For specific eyewear recommendations
related to laser safety, refer to Chapter
C6 of this manual.
Faceshields
Based on the exposure
scenario, faceshields
may be required to elim-
inate the risk of facial
injury from chemical
splashes and fast-
moving objects. For instance, faceshields
should be used for dispensing cryogenic
liquids or working with substantial
amounts of corrosive liquids. Caution
should be used with faceshields. The
potential does exist for entrapment of
chemicals inside the shield close to the
eyes and face, especially when working
with volatile chemicals below the face
level.
Faceshields can be either clear or tinted
and flat or contoured. Faceshields should
be selected based on a combination of the
requirements for physical and chemical
resistance. Safety glasses or goggles must
always be worn beneath a faceshield.
Where needed, throat protectors can be
attached to the face shield to provide addi-
tional protection. For instance, throat pro-
tectors should be used for tasks involving
explosive materials.
3.2 Hand Protection
Hand protection is required when there is a
potential for exposure to hazards from skin
absorption of chemicals, chemical burns,
contact dermatitis or sensitization, cuts or
lacerations, severe abrasions, punctures,
thermal burns, or contact with blood or
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E2. Personal Protective Equipment
other potentially infectious materials.
Hand protection is essential for protecting
laboratory employees from contact with
and possible absorption of hazardous
materials, as well as from physical hazards
(e.g., cuts, burns, etc.).
Using two dissimilar pairs of gloves,
referred to as “double gloving,” is highly
recommended when working with materi-
als known to be highly hazardous, or
where there are unknowns. For instance,
when handling samples—which generally
contain a number of unknown contarni-
nants—using two dissimilar pairs of dis-
posable gloves (e.g., nitrile disposables
over vinyl disposables) can provide ade-
quate protection for the short duration of
contact and will also allow the required
hand and finger dexterity.
Whenever using disposable gloves, it’s
important to change them:
• As soon as possible after known con-
tact with a hazardous material
• Whenever the integrity of the glove
has been compromised
• Periodically throughout the day
Also, when worn near moving machinery,
gloves must fit tightly enough to avoid
getting caught or pulled into the moving
parts.
A summary of recommended types of
gloves for various hazards is presented in
Table E2-2.
3.3 Body Protection
At a minimum, long-sleeve, button-up
laboratory coats must be worn for all
laboratory tasks. Long pants should also
be worn to protect the skin between the
bottom of the lab coat and the top of
shoes. For most tasks, a laboratory coat
will provide adequate protection. How-
ever, there may be some operations where
additional protection is needed. For exam-
ple, a splash apron may be necessary for
glassware operations to protect the body
and clothes from contact with corrosive
chemicals. Also, animal handlers may
wear jump suits for greater freedom of
action and better coverage.
Caution must be used with the sleeves of
laboratory coats. Loose sleeves have a ten-
dency to drag through the chemicals being
used, thereby creating the same potential
dennal exposure the coat is intended to
eliminate. Employees should consider
taping sleeves tight if this is a potential
hazard.
Laboratory coats and other types of protec-
lion must not be worn out of laboratory
areas into public areas such as lunch
rooms, restrooms, the library, conference
rooms, etc.
3.4 Head Protection
Head protection must be worn when there
is a risk of flying or falling objects or elec-
trical shock. It is not anticipated that head
protection will be needed in the majority
of EPA laboratories. However, there may
be instances where head protection is
required, under 29 CFR 1910.135, based
on the results of the hazard assessment.
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E2. Personal Protective E uipment
Hard hats are available in a variety of
styles, including those used for light duty
(i.e., bump caps) and electrical operations.
Hard Hat Bump Cap
3.5 Foot Protection
Foot protection is required, under 29 CFR
1910.136, where there is a danger of foot
injuries due to faffing or rolling objects,
sharp objects piercing the sole, or where
feet are exposed to electrical hazards. For
example, manually moving compressed
gas cylinders is a task where foot protec-
tion would be required.
When selecting the appropriate footwear,
a primary consideration is the type of sole
since slips, trips, and falls are one of the
most common causes of occupational
injuries.
At a minimum, laboratory employees must
wear closed-toe, “sensible” shoes when-
ever working in the laboratory. Sandals or
open-toed shoes must not be allowed.
3.6 Hearing Protection
Laboratory employees must be provided
with hearing protection if noise levels are
above the limits established by OSHA (29
CFR 1910.95). OSHA requires that a hear-
ing conservation program be implemented
if noise levels exceed an 8-hour time-
weighted-average (TWA) sound level of
85 decibels (dBA). The program must in-
clude a comprehensive monitoring pro-
gram, personnel training, hearing testing,
and PPE. As part of this program, hearing
protection must be provided to employees
working in areas with noise levels exceed-
ing 90 decibels (dBA). Some laboratories
may supply hearing protection to employ-
ees for increased comfort, even where it’s
not required according to the OSHA stan-
dard. As a rule, if it’s necessary to raise
voices when communicating at arm’s
length, the area should be tested and evalu-
ated to determine if engineering controls
are needed to reduce noise and/or if the
use of hearing protection is required.
Two basic styles of hearing protection are
available:
Earplugs are available in a variety of mate-
rials and configurations ranging from inex-
pensive disposables to custom-fit devices.
A trained health and safety professional
should select the necessary types of hear-
ing protection based on noise monitoring
data, exposure scenarios, and the noise
reduction rating (i.e., measure of noise
suppression) of candidate protective
devices.
Earplugs
(worn inside the ear)
4;’,
Earmuffs
(worn over the ear)
r A
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Protective Clothing and Equipment
Table E2-2: Types of Hand Protection
E2. Personal Protective Equipment
4.0 Performance Requirements for
Chemical Protective Clothing (CPC)
There are a number of performance
requirements that must be considered
in selecting the appropriate chemical-
protective material. Their relative
importance is determined by the
particular work activity and laboratory
conditions. Performance requirements
include:
• Chemical resistance
• Durability
• Flexibility
• Temperature
• Service life
• Cleanability
• Size
• Cost
User factors, such as the potential for aller-
gic response to protective materials (e.g.,
latex) must be considered as well.
Each of these performance requirements is
discussed in the sections that follow.
I
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4.1 Chemical Resistance
Chemical resistance is the ability of
a material to withstand chemical and
physical change. A material’s chemical
resistance is the most important perfor-
mance requirement. The material must
maintain its structural integrity and
protective qualities upon contact with a
hazardous substance.
The effectiveness of materials to protect
against chemicals is based on their resis-
tance to penetration, degradation, and
permeation. Each of these properties
must be evaluated when selecting the
style of CPC and the material from
which it is made. In choosing protective
materials, the information in the follow-
ing sections should be kept in mind.
4.1.1 Penetration
Penetration is the transport of chemicals
through openings in a garment. A chemical
may penetrate due to design or garment
imperfections. Stitched seams, button
holes, pinholes, zippers, and woven fabrics
can provide a route for the chemical to
penetrate the garment. A well-designed
and -constructed garment prevents this
by using self-sealing zippers, seams over-
laid with tape, storm flap closures, and
non-woven fabrics. Rips, tears, punctures,
or abrasions to the garment also allow
penetration.
4.1.2 Degradation
Degradation is a chemical action involving
the molecular breakdown of the material
due to chemical contact. Degradation is
evidenced by physical changes to the
material that may cause the material to
shrink or swell, become brittle or soft,
or change its chemical properties. Other
changes may be slight discoloration,
rough or gummy surface, or cracks in
the material. Such changes may enhance
permeation or allow penetration by the
contaminant.
4.1.3 Permeation
Permeation is a chemical action involving
the movement of chemicals, on a mole-
cular level, through intact material. Perme-
ation is a process that involves the sorption
of the chemical on the outside surface,
diffusion through, and desorption of the
chemical from the inside surface of the
protective material. A concentration
gradient (e.g., high on the outside: low
on the inside) is established. Because the
tendency is to achieve concentration equi-
librium, molecular forces “drive”
the chemical into the material toward the
area of lower concentration. Eventually
the highest flow of permeating chemical
exists. Once the chemical desorbs from the
fabric, exposure may occur via direct con-
tact with liquid, contact with contaminated
Principles of CPC
• There is no protective material
that is impermeable.
• There is no one material that
affords protection against all
chemicals.
• For certain contaminants and
chemical mixtures, there are no
materials available that will
protect for more than an hour
after initial contact.
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E2. Personal Protective Equipment
inner clothing that becomes soaked with
the chemical, or by contact with the chem-
ical vapor.
Two terms quantify permeation: penne-
ation rate and breakthrough time. These
values are determined in a controlled
laboratory test specified by the American
Society for Testing and Materials (ASTM)
F739.
Permeation rate is the quantity of chemical
that will move through an area of protec-
tive material in a given time. It is usually
expressed in micrograms of chemical per-
meated per square centimeter per minute
of exposure (uglcm 2 /min).
Factors affecting permeation rate include:
• Type of material
• Thickness of material
• Chemical concentration
• Contact time
• Temperature
• Material grade
• Humidity
• Solubility of the material in the
chemical
A general rule of thumb is that the perm-
eation rate is inversely proportional to the
thickness (2 x thickness ½ x permeation
rate).
Another measure of permeation is break-
through time, expressed in minutes. Break-
through is the elapsed time between initial
contact of a chemical with the outside
surface and detection at the inside surface
of the material. Breakthrough times vary
from seconds to days, depending on the
chemical/material combination and
concentration, exposure scenario, and
environmental conditions. Like permeation
rate, breakthrough time is chemical-
specific for a particular material and is
influenced by the same factors. A rule-of-
thumb concerning breakthrough time is
that it is directly proportional to the square
of the thickness (2 x thickness 4 x break-
through time).
Permeation test data are available through
the majority of CPC manufacturers, and
most of the data are currently generated
through several independent third-party
testing laboratories. Individuals making
CPC selection decisions should use chemi-
cal resistance information available from
the actual manufacturer of the candidate
material, as well as from third-party testing
laboratories. For instance, the guidelines
developed by Arthur D. Little (see refer-
ence in Section 2.2) have PPE recommen-
dations for 465 individual chemicals
and 21 generic classes of chemicals
(i.e., aldehydes, inorganic acids).
However, caution should be exercised
when using “generic” chemical resistance
information since similar CPC materials
(e.g., nitrile) available from different
manufacturers may perform in a radically
different manner when challenged with the
same chemical.
4.2 Durability
Durability is the ability to withstand wear
and to resist punctures, abrasions, and
tears. It is the material’s inherent strength.
Certain physical requirements may be
placed on an item of PPE based on the use
scenario. Physical hazards Involved may
include cut, slash, and puncture from vari-
ous sharps. Several materials are available
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C wr E
Protective Clothing and Eq iprnent
E2. Personal Protective Equipment
that provide good cut and slash resistance,
including stainless-steel fibers, Keviar®,
Spectra®, and chrome leather. Puncture
resistance, however, is a difficult hazard
to provide protection against. The puncture
resistance of CPC materials increases with
increasing thickness, but at the expense of
dexterity and flexibility. The primary con-
trol measure for puncture hazards should
be safe work practices and procedures.
4.3 Flexibility
Flexibility is the ability to bend or flex
(i.e., pliability). It is extremely important
for glove materials, because it directly
affects the worker’s mobility, agility,
and ability to work.
4.4 Temperature Resistance
Temperature resistance is the ability
of a material to maintain its chemical
resistance during temperature extremes
(especially heat) and to remain flexible
in cold weather. A general tendency for
most materials is that higher temperatures
reduce their chemical resistance and lower
temperatures reduce flexibility.
4.5 Service Life
Service life is the ability of a material to
resist aging and deterioration. Factors such
as chemicals, extreme temperatures, mois-
ture, ultraviolet light, oxidizing agents,
and others, decrease a material’s service
life. Storage away from, and proper care
against, these conditions can help prevent
aging and extend the life of the suit. Man-
ufacturers should be consulted regarding
any recommendations on a protective mate-
rial’s shelf-life.
4.6 Cleanabiity
Cleanability is the ability to effectively
decontaminate protective materials.
Cleanability is a relative measure of the
ability of a material to release the contact
substance. Some materials are nearly
impossible to decontaminate, so it may
be important to cover those materials with
disposable garments to prevent gross
contamination.
4.7 Size
Size is the physical dimension or propor-
tion of clothing. Size is directly related
to comfort and influences the number of
unnecessary physical accidents. ill-fitting
gloves, boots, or suits limit a worker’s
mobility, dexterity, and concentration. It’s
essential that protective clothing properly
fit the individual.
4.8 Cost
The cost of chemical protective clothing
varies considerably. Cost will often play
a role in selection. Less expensive, single-
use gloves are often as safe as more costly
clothing. Other situations require costly
high-quality clothing that may have to be
discarded after limited use. It is always
important not to let cost get in the way
of selecting proper protective clothing.
Protective clothing can also be categorized
as disposable or reusable based on the cost
of the garment. Disposable garments are
typically constructed of thin plastic films
or laminates, are relatively inexpensive
and light-weight, and exhibit only fair to
poor physical properties (i.e., abrasion and
cut resistance). Reusable garments are
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Protective Clothing and Equipment
E2. Personal Protective Equipment
typically constructed of a rubber-based
material, are more expensive and heavier
than disposable garments, and offer
improved physical properties.
5.0 Care and Maintenance
The following sections provide guid-
ance for EPA laboratories on the care
and maintenance of protective equip-
ment. These requirements address only
protection against eye, skin, and clothing
contact; requirements for respiratory pro-
tection are presented in Chapter E3
of this manual. A special testing facility
may be required for testing the integrity
of electrical safety devices and PPE.
In order to ensure the anticipated level of
protection, it’s important that PPE is prop-
erly cared for and maintained. This section
outlines practices for inspection, storage,
and disposal.
5.1 Inspection Practices
A general inspection of PPE should be
conducted before each use and include a
check of the following:
• Abrasions, cuts, holes, or tears
• Signs of chemical contamination,
such as discoloration, rough surfaces,
gummy feeling, cracks
• Missing, damaged, or defective com-
ponents
Supervisors and staff must be trained in
inspection practices. The manufacturer’s
recommendations for inspection should
always be referenced.
5.2 Storage Practices
PPE must be stored properly to prevent
damage or malfunction due to the condi-
tions listed in Table E2-3.
Table E2-3: Factors Affecting PPE in
Storage
-
Ha
Chcm.
Coinaniinates and breaks down mate-
nal
Can cause mold or break down mate-
riai
Damages materials and increases ag-
ing
Contaminates material
Can alter configurations of material;
melt (hot) or crack (cold)
Can damage, break, or tear material
5.3 Disposal Practices
General disposal practices for PPE include
the following:
Disposable items should be discarded
after each use or when the material’s
integrity is suspect. For instance, dis-
posable gloves should be discarded
after known contact with a hazardous
substance, whenever rips or holes are
identified, or periodically (e.g., after
3 or 4 wearings).
• Any street clothing contaminated with
a chemical or biological agent (e.g.,
by a spill) should be discarded as
laboratory-contaminated waste,
unless decontamination is possible.
Damaged or defective PPE must
never be used!
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Protective Clothing and Equipment
E2. Personal Protective Equipment
Any street shoes contaminated with
a chemical will also be disposed of in
the same manner.
Contaminated non-disposable items
should be stored in covered containers
until washed. If washing is done by
laboratory personnel, they may need
gloves and disposable suits while han-
dling contaminated items, depending
on the amount and nature of the con-
tamination. If washing is done by an
outside service, they must be notified
(in writing) that they are handling
items with potential contamination.
Outside services must provide labeled
containers. Contaminated clothing
should never be taken home by
employees for cleaning or discarding.
Employees must be informed of the
standard procedures for washing and
disposing of PPE specific to the labo-
ratoly. For each item of protective
equipment, employees must also
understand who is responsible for
cleaning and disposal.
6.0 Effect of PPE on Job Performance
PPE should be selected to have minimum
impact on job performance. However, cer-
tain types of PPE, may interfere to some
degree with a worker’s ability to perform
his/her assigned duties. Worker productiv-
ity may be reduced, and the PPE itself may
introduce additional health and safety
problems to the situation. For instance:
Gloves may reduce dexterity and
tactility.
• Respirators can obstruct and
distort vision, stress the respiratory
system, and interfere with speech
intelligibility.
• Garments may restrict mobility and
induce heat stress.
• Some types of PPE may increase the
time it takes to complete a task.
These and other effects may present a risk
to the worker (e.g., induced heat stress)
or contribute to some other risk (e.g., slips,
trips, and falls). The magnitude of the
effects will depend on the type of PPE
used, the nature and duration of the work,
environmental conditions, and worker
training.
Individuals assigned to selecting PPE
should consider the physical and psycho-
logical effects of using such equipment
and do their best to select PPE that pro-
vides optimum protection with minimum
impact on job performance.
7.0 Recordkeeping
Laboratories must maintain the following
PPE documentation:
• Hazard assessment certification
• Training verification
The hazard assessment certification must
include:
• The workplace evaluated
• The person certifying the evaluation
• The date(s) of the hazard assessment
&EPA June 1998
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CHAFFER E
Protective Clothing and Equipment E2. Personal Protective Equipment
In addition, most laboratories will find it
helpful to document the specific tasks
evaluated and the recommended PPE as
part of the hazard assessment certification.
The training verification must include:
• The name of each employee trained
• The date(s) of training
• The subject of certification
In addition, records of PPE assignment,
disposal, and/or replacement should be
maintained.
& A June 1998 E2-15
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SHEMP Operations Manual for Laboratories
Ciw’ra E
Attachment E2-1: Example of a Completed WE Hazard Assessment
Purpose: To provide an example of a completed PPE Hazard Assessment
Instructions: Not Applicable
SERk June 1998 E2- 16
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E Hazard Assessment
S. -
Risk
6. -
P S
7.
Pit CrIteria’
Chemicals in the
laboratory
Laboratory operations
All labs
Splashing of acids and chemicals
during handling
Absorption of acids and chemicals
during handling
Busts and irritation to the hands.
face, body
Irritation of the skin, hands, and
eyes
Spectacles
Lab coat
Shoes
Gloves
Z87
Full length
No open toes
Chemical-specific
(see below)
Genetic chemical and
product handling
Laboratory operations
All labs
Contact with chemicals and dusts
during handling
Contamination of the skin
Gloves
Latex. nitrile or PVC
Acids
Preparing the acid
solutions for glassware
washing
Re 185
Splashing of acids and chemicals
during handling
Bums and irritation to the hands.
face, and body
Gloves
Apron
Face Shield
Goggles
Nitrile
Rubber
Splash
Solvents
Transfer of liquids,
greater than 4 liters
All labs
Absorption of acids and chemicals
during handling
Irritation of and absorption into
the skin, hands, and eyes
Gloves
Goggles
Chemical- specific
Splash
Methylene Chloride
Organic sample prepara-
Lion and analysis
Rita lfla. 178,
179
Absorption of acids and chemicals
during handling
Irritation of and absorption into
the skin, hands, and eyes
Gloves
Viton
Diazomethane
Methylation (generating
dsazomethane)
Rm 181
Impact frost explosions
Cuts and lacerations to the face
and eyes
Gloves
Spectacles with face shield
Explosive shielding
Nitrile
—
See manufacturer
Perch lorotes
Perch lonnation
Rm 181
Impact front explosions
Cuts and lacerations to the face
and eyes
Gloves
Explosive shielding
N at a lIe
See manufacturer
Heat
Hoiplates
Autoclave
Ovens
‘flimughout
Rm 185
Rita tgs, 197,
204
Contact during the handling of hot
glassware
Burns to the hands and arms
Gloves
Insulated
Sharp Objects
Laboratory
Al ) labs
Sharp objects such as needles and
broken glassware
Cuts to hands and skin
Gloves
Leather or heavy-
duty knit-lined rubber
Compression
Cylinders
Lab and Wait-
house
Moving and rolling cylinders (gas
and cryogetsic) and containers
(including drama in the warehouse)
Crushing of the foot
Shoes
Steel toes
Impact
Drill Press
Rm 203
Impact from flying fragments, ob-
jects, large chips, etc.
Irritation or damage to the eye
Spectacles
Z87. with side
shields
Cargours ,nchtdc impact. Penetration. Conprnsma, Orion!, Heat. Hartoast dust LtaJO radjatott, Notse.EkctrttJ -
‘Footnar = AN5t 451991; Stead pvteetmna ANs I 559 1 5956. HaS rotenwn PPE Program. E)t and face ptotectnt a ANSS 7275 t9t9.
‘spectacles or tetag apsotted S taboratary splash mardi S both tatmraro.y opetatora and nsnota Spectacles art co,a,dncd a dowaa.ade S taborato.y operstart ant at. opaTade Sir niacin sirctactca t ic roptacd aSp m tubontory morn, mid oaty thtnna
ot ctog opnmra other ttmn o nto amtçtsag atid asinamathe taska(c 5. sang eotupsccrs) Goggles we 1 nStt (or tabordouy opottatmi where itt tptahhasard to çcra (trmtfuttag he iSt Son ’ catamnma at Inst 4 tan to votawa) v i ttunng tic bath
tmnttitttg of ettetoado and wren
‘Vesm gloves nay tat 55 tIc tatany needed to pothna tic oporsan Lain vi Hhtnte glows. if otesrare wbh Mahylcia Chbnt. nay coamrdtaie tic tmtipte Gloves trot tote thqasnd c i as root at they becoar desoimated (estates after cent S
Narita sod Lan. tip to two wceta Lw Veon)
- -- 8. -
Ha So ’
- - . -
Operation — ItoomlAraa
4:
Bawd Aaaesametri
Date:
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SHEMP Operations Manual for Laboratories
CHAPTER E
Attachment E2-2: PPE Hazard Assessment
Purpose: This form is to be utilized for the completion of a PPE Hazard Assessment.
Instructions: A walk-through survey of the work areas and operations should be per-
formed to identify sources and locations of hazards, and to identify the
operation with which the hazards are associated. The risk related to the
hazards present should also be characterized. PPE must be selected based on
the hazards and the degree of risk present. The final column is used to
identify the PPE specifications (e.g., glove material, etc.).
June 1998 E248
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PPE Hazard Assessment
Assessor:
Date:
Chemical Hazards
Phy nd Hazards
particles, chips
crush, rollover
splash, high temperatures
temperatures
Biological Hazards
-------
PPE Hazard Assessment (continued)
Persossal Protective Eqalpmw itRecoimnendations
Where engineering and adminisuanve controls ate not feasible or sufficient for controlling hazards. PPE must be used to protect workers.
The following PPE are teconinrended for this task:
Eve and Face hontcEan
Safety glasses with side shields
Reflective goggleslfaceshield
Chemical splash goggles J
Cuuinglbrazinglwethng
Paceshield j
Other.
Comments
Head tection
Hard hat, bump cap
Welding helinezhnask
Helmet, cowl, hood
Louut
Comments
ros.cli.n - -
Safety shoeslboots
Other:
Chemical-resistant boots
Comments
Hand F,v& td ori
—
Leather. cazivas, cotton gloves
—
Chemical-resistant gloves
Type of chemical(s):
Type of glove:
Comments
Sod,
F vuctioa
‘
Apron (splash, work)
Heat-reflective garments
Coveralls (worh. chemical resislam)
Type of chemical(s):
Type of coveralls:
Sleeves (cur-zesismani)
Other
Comments
E
lecatitwl
P,otnttion
Rubber insulating gloves
Rubber insulating sleeves
— Rubber insulating hoods — Other:
Ruiipi, ntgry Praeecdon -
Raspuaior Type of respirator:
Comments
Hazard assessment certification:
Signature Date
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SHEMP Operations Manual for Laboratories
C mit E
Attachment E2-3: Chemical and Physical Performance of Select Materials
CheSS Protective Clothing Resistance Chart
Breakthrough Times for Common EPA Laboratory Chemicals Against Select Materials
PROTECTiVE
MATERIAL
CHEMICAL
Methylene
Chloride
Henna
Nitric
Acid’
Acetone
Hydrochloric
Acid 2
Sulfuric AcicP
Butylnibber
clhr
8hrs
>Shrs
>8hrs
>8hrs
Neopmne
.clhr
8hrs
8hrs
Nithie
< 11w
>8hrs
>8hrs
<1 1w
c lhr
lto4hrs
Polyvinylalco-
hol
>8hrs
>8hrs
8hzs
<1 1 w
<11w
> Shrs
TeflonTh
lto4hn
>8hm
NO
DATA
>8hrs
NODATA
>8hrs
VitonTh
<1 1 w
>8hrs
NO
DATA
<11w
NODATA
>8hrs
SaranexTh
<1 1 w
Shzs
<1 1 w
>8hn
>4hrs
4H&
Silvershield”
>8hrs
>8hrs
>4hrs
>8brs
lto4hrs
>4hrs
1. Data based on a concenuation of c sO%
2. Data based on a conceniration of 30 to 70%
IMPORTANT NOItS
• This table is based ONLY on permeation data. Additional factors must be considered in the selection process, such as
the physical characteristics required (e.g., need for cut resistance 1 temperature resistance. etc.), and the human factors
required (e.g., need fur deAterity, Ileitibility, etc.).
• The data in tbs table re based on GENERIC protective materials, with the exception of a few specific wadenasnes, and
represents average breakthrough times. Specific manufacturer’s information must be used to supplement this data, since
material available from different manufacturers will provide varying levels of protection based on the thickness or grade
of material.
a ma
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SHEMP Operations Manual for Laboratories
CHAPTER E
Attachment E2-3: Chemical and Physical Performance of Select Materials
Physical Characteristics of Select Chemical Protective Clothing Materials*
Glove Material
Abrasion
Resistance
Cut Reals-
tance
flexibility
Puncture
Resistance
Tear Resis-
tance
Cost
Butyl
F
G
0
0
0
HIGH
Coated TyvekR
F
P
G
F
F
LOW
Natural Rubber
E
E
E
E
E
MED
Neoprene
G
E
G
G
G
MED
Ni ile
E
E
E
0
G
MED
Polyethylene
F
F
G
F
F
LOW
Polyvinyl Alco-
hol
F
F
P
0
0
HIGH
Polyvinyl Chlo-
ride
0
P
F
0
G
LOW
SilverShield’
/4H
F
P
F
F
F
LOW
Viton
G
G
G
0
HIGH
Razings arc subject to variation depending on formulation, thickness, and whether the material is supported by fabric.
E=Excellent
G=Good
F=Fair
P=Poor
EPA June 1998 E2-22
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E3.
Respiratory Protection
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SHEMP Operations Manual for Laboratories
C vr E
Protective Cl itingand Equipment
E3. Respiratory Protection
1.0 Introduction
The respiratory system is able to tolerate
some exposures to toxic gases, vapors,
and particulates, but only to a limited
degree. Some chemicals can impair or
destroy portions of the respiratory tract,
or they may be absorbed directly into the
bloodstream from the lungs. Chemicals
that enter the blood may eventually affect
the function of other organs and tissues.
The respiratory system can be protected
by avoiding or minimizing exposure to
hannful substances. Engineering controls
such as ventilation help decrease exposure.
When these methods are not feasible or
not fully sufficient, respirators may be
used to provide protection. Certain
respirators can filter gases, vapors, and
particulates in the ambient atmosphere.
The various types of respiratory protective
devices available on the market can be
placed into two categories: air-purifying or
air-supplied respirators. An air-purifying
respirator, as the name implies, protects
the user by removing contaminants from
inhaled air. The mechanism by which con-
tammants are removed from the air is
substance-specific; that which effectively
eliminates one contaminant will not neces-
sarily do the same to another. An air-
supplied respirator provides an external
source of breathable air that is not affected
by a hazardous environment.
Today there are many respirators available
for use in an endless variety of situations.
The regulations and recommendations
affecting their use am continuing to evolve
with changing technology. This chapter
presents information for the development
of a respiratory protection program and
provides direction for its implementation.
EPA Program Requirements
Each laboratory where respirators are used
must ensure that:
• Engineering and administrative
controls have been implemented
wherever feasible
• A written program outlining the
specific procedures for selection,
assignment, use, and maintenance has
been developed and implemented
• Employees required to wear respira-
tors have been provided with medical
evaluation, training, and fit-testing
• Periodic inspection of work activities
requiring respirators is conducted, as
well as an evaluation of the effective-
ness of the overall program
• Required documentation is maintained
EPA laboratories with respirator use are
required to comply with all provisions of
the U.S. Occupational Safety and Health
Administration (OSHA) standard 29 CFR
19 10.134 and, included by reference in
this OSHA standard, the American
National Standards Institute (ANSI) stan-
dard for Respiratory Protection Z88.2-l-
992. In addition, EPA SHEM Guide 46
addresses requirements and guidelines for
respiratory protection.
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Protective Clothing and Equipment E3. Respiratory Protection
Program AdminL tration
To effectively manage the selection,
procurement, use, and care of respirators,
responsibilities should be assigned for:
• Assessing respiratory hazards to
identify engineering and admini-
strative controls wherever feasible
• Selecting appropriate respiratory pro-
tective equipment
• Developing and maintaining a written
respiratory protection program
• Procuring and distributing selected
respirators
• Coordinating a medical evaluation
program for respirator users
• Providing fit-testing for respirator
users
• Implementing a maintenance and care
program for respirators
• Conducting training for respirator
users
• Maintaining required records (e.g.,
training, medical evaluation, fit-
testing, etc.)
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2.0 Written Respiratory Protection
Program
For respirators to provide optimum protec-
tion, they must be properly selected,
inspected, and maintained in good working
condition and only be used by trained and
qualified individuals according to the pro-
visions of the respiratory protection pro-
gram. All laboratories with respirator use
must develop, implement, and document a
respiratory protection program. The pur-
pose of a written program is to specify and
document work-specific procedures for the
selection, assignment, use, and mainte-
nance of respirators.
The written program serves as a handbook
of the respirator program. Laboratories
must revise it, as necessary, to reflect
current practices, usage, and changing
regulations. Guidance for developing a
written program is included in SHEM
Guide 46, Respiratory Protection.
3.0 Requirements for Respirator Users
In order to ensure that respirators are used
safely, there are a number of requirements
for the user. Each employee assigned to a
task requiring a respirator must:
• Use only respirators approved by the
National Institute for Occupational
Safety and Health (NIOSH)
• Receive a medical evaluation to
ensure he/she can safely wear a
respirator
• Be fit-tested on the specific size and
model of the respirator
• Complete the required training
Each of these requirements is discussed in
more detail in the following sections.
3.1 NIOSH-Approved Respirators
The respiratory protection program must
specify that laboratory staff may use only
respirators certified by NIOSH. Further-
more, the staff must use and maintain the
respirators in a manner that is consistent
with the manufacturer’s institutions and
recommendations.
For chemical-cartridge air-purifying respi-
rators, the certificate indicates approval of
the entire assembled mask. This procedure
precludes interchanging the parts of one
manufacturer’s respirator with those of
another manufacturer.
Written Program Elements
• Procedures for selecting respira-
tory protection
• Medical evaluation of respirator
users
• Fit-testing procedures
• Training of employees
• Procedures for handling foresee-
able emergencies
• Care and maintenance, including
inspection, cleaning, and storage
• Procedures for safe use of respira-
tors in dangerous atmospheres
• Procedures for disposal of con-
taminated air-purifying elements
• Air quality for supplied-air respi-
rators, if applicable
• Training of employees in respira-
tory hazards and proper use of res-
pirators
• Inspection and evaluation of the
overall program
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The NIOSH certificate explicitly lists the
contaminants for which the certified
equipment is effective and describes the
conditions under which it may be used.
The maximum use concentrations differ
for the listed contaminants as a function
of both the relative effectiveness of the
equipment against the different substances,
and their relative toxicological characteris-
tics. In cases where uncertainty exists
about the actual use concentration, one
should exercise caution and opt for a more
protective respirator.
3.2 Medical Evaluation
The use of a respirator can impose signifi-
cant physiological and psychological stress
on the wearer. Since such stress may place
the individual at an elevated risk of injury
or illness, a physician must evaluate the
fitness of each user assigned to wear a res-
pirator. Of course, the physician must be
familiar with respirators and the conditions
under which they are worn. Such an evalu-
ation should include, but not be limited to:
• Medical history, with special emphasis
on cardiovascular or pulmonary
disease
• Facial abnormalities that may interfere
with a respirator seal
• Visual acuity
• Hearing ability
• Cardiovascular fitness
• Pulmonary function test
• Other tests deemed appropriate by the
physician (e.g., endocrine evaluation,
psychological status, neurological
health, exercise stress tests)
After the evaluation, the physician should
provide a written statement of the results
of the exam, including whether or not the
person is medically qualified to use a
respirator and, if so, under what limita-
tions, if any.
3.3 Fit-Testing Procedures
Not all respirators fit everyone, so each
individual must find out which mask
he/she can properly wear. At best, any
given respirator will fit 60 percent of the
working population. But with the large
number of respirators available, at least
one type should be found to fit an
individual.
The integrity of the face-to-facepiece seal
of a respirator can be tested either quanti-
tatively or qualitatively. The quantitative
lest is an analytical determination of the
concentration of a test agent inside the
facepiece compared to that outside the
mask. The concentration ratio of test agent
measured outside the mask versus inside
quantifies the potential performance of the
respirator under specified conditions. This
concentration ratio is called the Protection
Factor (PF) and is a measure of the relative
protection offered by a respirator. Protec-
tion factors are an important aspect of the
selection process.
In a qualitative fit-test, sensory perceptions
(e.g., odor) or involuntary responses (e.g.,
coughing from irritant smoke) of the user
are relied on for detection of the test agent
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Protective Clothing and Equipment
E3. Respiratory Protection
inside the mask. Detection of the chemical
agent inside the facepiece indicates the
presence of a leak and the mask must be
adjusted or replaced with another size,
model, or brand until a proper fit is
achieved.
The laboratory must fit-test all employees
who are required to wear negative-pressure
respirators to determine which mask best
conforms to their facial features. A labora-
tory should fit-test an employee prior to
initial assignment to any job that may
require the use of a respirator, and at
least annually thereafter. More frequent
fit-testing is necessary for new mask
config-urations, or if one’s facial contours
change radically from weight loss, injury,
or illness.
EPA SHEM Guide 46-06 provides addi-
tional guidance on fit-testing, and Attach-
ment E3-1 of this manual outlines several
fit-testing procedures.
Another factor that may affect the fit and
protection afforded by a respirator is the
presence of facial hair between the mask
and the surface of the face. Facial hair will
permit the passage of unpurified air into
the interior of the facepiece. For this rea-
son, laboratory staff with facial hair cannot
rely on negative-pressure respirators with
tight-fitting half or full facepieces. Facial
hair in the seal area is unacceptable for
persons required to wear a respirator.
Respirators must not be worn with temple
bars or other parts penetrating through the
face-to-facepiece seal. Special corrective
lens inserts designed specifically for that
respirator must be used.
3.4 Training
The quality and quantity of training pro-
vided to respirator users are critical in
determining the level of protection
afforded in a given situation. At a mini-
mum, the laboratory should offer appropri-
ate training on initial assignment, and at
least annually thereafter, or whenever the
potential for exposure changes.
4.0 Respirator Selection Process
Selection of the proper respirator is one
of the most important components of this
program. There are many factors to con-
sider when selecting a respirator,
including:
Training Program Elements
• Functional components of a
respirator
• Pre-use inspection
• Air-purif ing element selection
• Donning instructions
• Positive/negative-pressure fit
checks
• Limitations
• Typical-use situations
• Emergency instructions
• Care and maintenance
• Storage locations
&EP 1 June 1998
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Protective Clothing and Equipment
E3. Respiratory Protection
• Type, identity, and concentration of
hazard
• Exposure limit and Immediately Dan-
gerous to Life and Health (IDLH)
value
• Concentration of ambient oxygen
• Chemical/physical characteristics of
the hazard
• Acute/chronic health effects of
exposure
• Warning properties
• Employee comfort level
• Ease of escape from contaminated
area
• Length of time for which respirator
must be worn
• Work activities and characteristics
• Need for face andlor eye protection
• Respirator characteristics and
limitations
EPA SHEM Guide 46-04 contains addi-
tional details on each of these elements,
which must be considered in the selection
process.
Additional resources to aid in the respira-
tor selection process are the ANSI stan-
dard for Respiratory Protection (ANSI
Z88.2), the NIOSH decision logic, and the
OSHA decision logic.
NIOSH has compiled many of the deci-
sions that go into the selection process in a
document entitled the “NIOSH Respirator
Decision Logic.” Use of the decision logic
provides a rigorous framework within
which one can progressively exclude inap-
propriate respirators until only correct res-
pirators remain under consideration.
OSHA has published a second decision
logic as part of its Industrial Hygiene
Technical Manual.
After each of these factors are evaluated,
the selection process should attempt to
provide employees with the “optimum”
respiratory protection, a maximum level of
comfort, and a minimum impact on worker
productivity.
Protection Factors and Marunum Use
Concentration
The basis for assigning respirators is the
protection factor (PF). The PF is the mini-
mum level of performance that NIOSH
considers to be achievable in the work-
place when the respirator is used by a
trained, properly fit-tested, and medically
qualified worker according to a well-
defined respiratory protection program.
Table E3-1: Respirator Protection
Factors (Pf)
Respirator Type
PF
Haif-Facepiece
10
Full-Facepiece APR
100
Full-Facepiece PAPR (with HEPA
filters and sorbent caruidges)
1000
Full-Facepiece PAPR (with dust
filter)
100
Self-contained breathing apparatus
(SCBA)
*
‘Recent studies have concluded that all users of positive.
pressure SCBAs may not achieve protection factors of
10.000. Therefore. ANSI has not listed a definitive pro-
tection factor but has suggested that for emergency plan-
ning purposes where hazardous concentrations can be
estimated, an assigned protection factor of no higher
than 10.000 be used.
Source: ANSI 728.2-1992
_ I A
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Protective Clothing and Equipment
E3. Respiratory Protection
Half-Face
Respirator
&
Full-Face
Respirator
• For temporary control to reduce or
eliminate employee exposure in
contaminated environments while
engineering or administrative controls
are being implemented
The protection factor is then used to deter-
mine the Maximum Use Concentration
(MUC) of a fit-tested respirator. The MUC
is the highest concentration of a specific
contaminant in which the respirator can be
worn and is calculated by multiplying the
PF by the exposure limit for that contami-
nant (MUC = PF x Exposure Limit). How-
ever, the MUC is only identifying the up-
per limit for the respirator; there may be
other conditions that would preclude per-
sonnel entry into areas where concentra-
tions approach the MTJC (e.g.. if the IDLH
value is exceeded).
Protection factors and the maximum use
concentration are only two of the several
considerations for selecting the proper
respirator. As mentioned previously, there
are many factors to consider in the respira-
tor selection process. The facility or
regional health and safety officer should
be consulted for selection decisions.
5.0 Respirator Use
Respiratory protective equipment must
only be used:
• For operations involving exposure to
air contaminants above the allowable
limits where engineering and adminis-
trative controLs are not feasible or are
not sufficiently effective
• For emergencies
Prior to each use, the wearer must inspect
the respirator to make sure that all the
necessary parts are present, that it is clean,
and that it is equipped with the proper
cartridges for the contaminant(s) expected
to be encountered. The cartridges should
be attached firmly to the facepiece, and
should be clean and dry.
In addition, negative-pressure respirators
with tight-fitting facepieces must be fit-
checked before each use to ensure that the
respirator is providing an effective face-
facepiece seal. The procedures for fit-
checking are described in the sections that
follow, as well as some considerations for
service life.
5.1 Fit-Checking Procedures
Before each use, the wearer must conduct
both a negative and a positive pressure
fit-check:
Negative-pressure fit-check: Cover the
inhalation port(s) of the respirator (i.e.,
canister of cartridges for air-purifying
respirators) with the palm(s) of the hand
while inhaling gently. The respirator
should fit tightly, collapse slightly, and
allow no air to pass around or through for
approximately ten seconds. This blockage
should be maintained to determine if there
is any leakage. The facepiece seal is
&ER4 June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER E
Protective clothing and Equipment
E3. Respiratory Protection
considered effective if a negative pressure
can be maintained with no evidence of
inward leakage from the seal.
Positive-pressure fit-check: Cover the
exhalation valve with the palm of one
hand while exhaling gently. The facepiece
seal is considered effective if a positive
pressure can be maintained with no evi-
dence of outward leakage from the seal.
5.2 Service Life
One of the most important considerations
when using a respirator is that all respira-
tors have a limited service life. At some
point, the protective capability of a respira-
tor (e.g., cartridges or air supply) will be
used up, and it will be necessary to change
the cartridges. Thus, the user must have
some warning that this is about to happen.
When chemical-type air-purifying respira-
tors are used, the airborne contaminant
must have good warning properties. The
user should be alerted to the presence of
contaminant(s) by a taste, smell, or inita-
tion (i.e., breakthrough). This occurs when
the adsorptive capacity of the respirator
cartridge has been exceeded and the con-
taminant is no longer being removed from
the inspired air. An air-purifying respirator
should not be used for a substance with
poor warning properties (e.g., carbon
monoxide).
Particulate-type air-purifying respirator
cartridges may reach the end of their
useful life by clogging up (i.e., load-up).
Here the filter gets so loaded that it makes
breathing difficult. This increased breath-
ing resistance is a signal to change filter
cartridges. Users of air-purifying
respirators must be fully aware of each of
these conditions. In addition, some respira-
tor cartridges may be equipped with end-
of-service-life indicators.
6.0 Maintenance and Care
Maintenance and care of respirators is a
critical element of an effective program.
Using a poorly maintained or damaged
respirator can be as or more dangerous as
not wearing a respirator at all. Laboratories
where respirators are used must establish a
maintenance and care program that
includes provisions for:
• Inspection for defects
• Cleaning and disinfection
• Replacement of parts
• Storage
Wherever possible, respirators should be
assigned to individuals for their exclusive
use. The user is responsible for routine
maintenance and care, including cleaning,
disinfecting, and properly storing the
respirator after each use. Finally, respira-
tors that have been designated for general
or emergency use must be inspected at
least monthly, and cleaned and disinfected
after each use.
The procedures to be followed for care and
maintenance are described in detail in the
sections that follow.
6.1 Inspection
Inspections must be performed by each
respirator wearer prior to use. The follow-
ing general procedures should be used
for inspection of air-purifying units (if
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Protective Clothing and Eciuipment
E3.Re piratoryProtecton
available, specific inspection instructions
from the respirator manufacturer should
also be used):
• inspect facepieces for scratches and
abrasions that may obstruct vision.
• Check threads and any “0” rings or
gaskets that may be in the unit.
• Examine straps for cuts, tears, broken
buckles, cracks, or signs of drying out.
• Inspect elastomer parts, including
inhalation and exhalation valves, for
holes, cracks, and any misshapen
pieces.
Where disposable respirators are used,
they should be inspected for:
• Holes or other damage to the mask
• Damage to or lack of elasticity of the
straps
• Deterioration of the nose clip
Emergency-use respirators must be
inspected at least monthly. For those
laboratories that maintain self-contained
breathing apparatus (SCBAs) or escape
units for emergency use, guidance on
inspection is contained in Attachment
E3-2 of this manual.
6.2 Cleaning and Disinfection
Respirator manufacturers specify correct
cleaning procedures for the particular
respirator. Typically, they recommend that
the user break down the respirator into its
component parts and wash each part thor-
oughly with a mild detergent. The user
should then rinse the components thor-
oughly and allow them to air dry.
Where a specific procedure is not outlined
by the respirator manufacturer, the follow-
ing procedures should be used for cleaning
and disinfecting:
• Remove the cartridge to keep cartridge
dry or for disposal
• Remove straps, head harness, cradle,
and adaptor and keep dry; wipe only
with alcohol disinfecting pad
• Remove all of the following and wash
each separately
— Inhalation port valves
— Exhalation port valves
— Cartridge connector/adaptor
— Exhalation port cover
• Wash in sanitizing solution
• Agitate the respirator in the sanitizing
solution and allow it to soak for two
(2) minutes.
• Rinse in warm water
• Dry at room temperature in a non-
contaminated atmosphere
• Reassemble
6.3 Replacement of Parts
Upon reassembly, the user should carefully
inspect the respirator and replace any worn
or missing parts. Users should pay particu-
lar attention to the inhalation and exhala-
tion valves, the condition of the facepiece,
the elasticity of the straps, and the pres-
ence of any rusted metal parts. They
should also check the date on the air-
purifying element and, if necessary, they
should replace the old elements with fresh
ones.
The replacement of old or depleted air-
purifying elements is part of the normal
care and maintenance of a respirator. In
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Protective Clothing and Equipment
E3. Respiratory Protection
cases where the cartridge/canister may be
safely reused, depletion of the air purifying
capacity is indicated by:
• Penetration of the substance through
the cartridge (breakthrough)
• Increase in the resistance to breathing
(overloading)
• A change in the end-of-service-life
indicator (ESL1). An end-of-service-
life indicator is a visible signal that the
air-purifying capability of a cartridge
or canister is, or is not, viable. It is
particularly important for substances
with poor warning properties, like
carbon monoxide, for which a
cartridge/canister breakthrough is not
detectable either by smell or taste.
Upon evidence of any of these signs, the
user should replace the cartridge/canister
without delay. However, the user should
anticipate the need to change the cartridgel
canister and regularly replace old or used
air-purifying elements. The frequency of
replacement can vary from weekly, for
high-use respirators, to annually for respi-
rators used only for non-routine tasks or
emergencies. In any case, one should place
the service date on the side of the
cartridge/canister.
Special disposal procedures may be neces-
sary when the air-purifying elements, by
virtue of the contaminants in question,
become a possible source of exposure after
use. Such may be the case with cartridges
used to clean up a hazardous material spill.
In these instances 1 it may be necessary to
treat the contaminated cartridges/canisters
as hazardous waste, and dispose of them
accordingly.
Any repairs must be performed only by
persons trained in proper respirator main-
tenance and assembly.
64 Storage
Respirators must be stored to protect
against damaging elements:
After the respirator is cleaned and dried,
it should be stored in an air-tight plastic
bag. The bagged respirator should be
stored loosely so that it does not become
deformed. Do not hang unprotected respi-
rators by their straps from hooks, and
ensure that the respirator is protected from
crushing or other mechanical damage.
Full-facepiece respirators should be stored
with their head harness and straps in a
relaxed position.
7.0 Recordkeeping and Documentation
Rigorous recordkeeping, which is neces-
sary to document compliance with the
written program, is also an invaluable
Damaging Elements
• Damaging chemicals
• Dust
• Direct sunlight
• Mechanical damage
• Extreme heat or cold
• Excessive moisture
• Any other factor that could impair
its function
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Protective Clothing and Equipment E3. Respiratory Protection
management tool. The program adminis-
trator should maintain records of the
following:
• Training
• Medical evaluations
• Fit-testing
• Maintenance
• Written respiratory protection program
and pertinent amendments
• Standard operating procedures (SOPs)
for specific routine and foreseeable
use situations, and pertinent
amendments
&ERA June 1998 E3-1 1
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Attachment E3-1: Fit-Testing Procedures
Part I. OSHA-Accepted Fit-Test Protocols
A. Fit-Testing Procedures--General Requirements
The employer shall conduct fit-testing using the following procedures. The requirements in
this attachment apply to all OSHA-accepted fit-test methods, both qualitative fit-testing
(QLFT) and quantitative fit-testing (QNFT).
1. The test subject shall be allowed to pick the most acceptable respirator from a sufficient
number of respirator models and sizes so that the respirator is acceptable to, and correctly
fits, the user.
2. Prior to the selection process, the test subject shall be shown how to put on a respirator,
how it should be positioned on the face, how to set strap tension, and how to determine
an acceptable fit. A mirror shall be available to assist the subject in evaluating the fit and
positioning of the respirator. This instruction may not constitute the subject’s formal
training on respirator use, because it is only a review.
3. The test subject shall be informed that he/she is being asked to select the respirator that
provides the most acceptable fit. Each respirator represents a different size and shape,
and, if fitted and used properly, will provide adequate protection.
4. The test subject shall be instructed to hold each chosen facepiece up to the face and
eliminate those that obviously do not give an acceptable fit.
5. The more acceptable facepieces are noted in case the one selected proves unacceptable;
the most comfortable mask is donned and worn at least five minutes to assess comfort.
Assistance in assessing comfort can be given by discussing the points in the following
item A.6. If the test subject is not familiar with using a particular respirator, the test
subject shall be directed to don the mask several times and to adjust the straps each time
to become adept at setting proper tension on the straps.
6. Assessment of comfort shall include a review of the following points with the test subject
and shall allow the test subject adequate time to determine the comfort of the respirator:
(a) Position of the mask on the nose
(b) Room for eye protection
(c) Room to talk
(d) Position of mask on face and cheeks
7. The following criteria shall be used to help determine the adequacy of the respirator fit:
(a) Proper chin placement
(b) Adequate strap tension, not overly tightened
(c) Proper fit across nose bridge
(d) Proper respirator size (to span distance from nose to chin)
June 1998 E3-12
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Attachment E3-1: Fit-Testing Procedures (continued)
(e) Tendency of respirator to slip
(I) Self-observation in mirror to evaluate fit and respirator position
8. The test subject shall conduct a user seal check; either the negative- and positive-pressure
seal checks described in Attachment B-i of this section or those recommended by the
respirator manufacturer if they provide protection equivalent to the procedures in Attach-
ment B-I. Before conducting the negative- and positive-pressure checks, the subject shall
be told to seat the mask on the face by slowly moving the head from side to side and up
and down while taking in a few slow deep breaths. Another facepiece shall be selected
and retested if the test subject fails the user seal check tests.
9. The test shall Dot be conducted if there is any hair growth (such as stubble beard growth,
beard, mustache, or sideburns) between the skin and the facepiece sealing surface, which
crosses the respirator sealing surface. Any type of apparel that interferes with a satisfac-
tory fit shall be altered or removed.
10. If a test subject exhibits difficulty in breathing during the tests, she or he shall be referred
to a physician or other licensed health care professional, as appropriate, to determine
whether the test subject can wear a respirator while performing her or his duties.
11. If the employee finds the fit of the respirator unacceptable, the test subject shall be given
the opportunity to select a different respirator and to be retested.
12. Exercise regimen: Prior to the commencement of the fit-test, the test subject shall be
given a description of the fit-test and the test subject’s responsibilities during the test
procedure. The description of the process shall include a description of the test exercises
that the subject will be performing. The respirator to be tested shall be worn for at least
5 minutes before the start of the fit-test.
13. The fit-test shall be performed while the test subject is wearing any applicable safety
equipment that may be worn during actual respirator use which could interfere with
respirator fit.
14. Test Exercises: The following test exercises are to be performed for all fit-testing
methods prescribed in this attachment, except for the controlled negative pressure (CNP)
method. A separate fit-testing exercise regimen is contained in the CNP protocol. The
test subject shall perform exercises, in the test environment, in the following manner:
(a) Normal breathing: In a normal standing position, without talldng, the subject shall
breathe normally.
(b) Deep breathing: In a normal standing position, the subject shall breathe slowly and
deeply, taking caution so as not to hyperventilate.
GEPA June 1998 E3-l3
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Attachment E3-1: Fit-Testing Procedures (continued)
(c) Turning head side to side: Standing in place, the subject shall slowly turn his/her
head from side to side between the extreme positions on each side. The head shall be
held at each extreme momentarily so the subject can inhale at each side.
(d) Moving head up and down: Standing in place, the subject shall slowly move his/her
head up and down. The subject shall be instructed to inhale in the up position (i.e.,
when looking toward the ceiling).
(e) Talking: The subject shall talk out loud slowly and loud enough so as to be heard
clearly by the test conductor. The subject can read from a prepared text such as the
Rainbow Passage below, count backward from 100, or recite a memorized poem or
song.
Rainbow Passage
When the sunlight strikes raindrops in the air, they act like a prism and form a
rainbow. The rainbow is a division of white light into many beautiful colors. These
take the shape of a long round arch, with its path high above, and its two ends appar-
ently beyond the horizon. There is, according to legend, a boiling pot of gold at one
end. People look, but no one ever finds it. When a man looks for something beyond
reach, his friends say he is looking for the pot of gold at the end of the rainbow.
(f) Grimace: The test subject shall grimace by smiling or frowning. (This applies only
to QNFT testing; it is not performed for QLFT)
(g) Bending over: The test subject shall bend at the waist as if he/she were to touch
his/her toes. Jogging in place shall be substituted for this exercise in those test
environments such as shroud type QNFF or QLFT units that do not permit bending
over at the waist.
(h) Normal breathing: Same as exercise (I).
(1) Each test exercise shall be performed for one minute, except for the grimace
exercise, which shall be performed for 15 seconds. The test subject shall be
questioned by the test conductor regarding the comfort of the respirator upon
completion of the protocol. if it has become unacceptable, another model of
respirator shall be tried. The respirator shall not be adjusted once the fit-test
exercises begin. Any adjustment voids the test, and the fit-test must be repeated.
aERD June 1998 E3-14
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Attachment E3-1: Fit-Testing Procedures (continued)
B. Qualitative Fit-Test (QLFT) Protocols
1. General
(a) The employer shall ensure that persons administering QLFT are able to prepare test
solutions, calibrate equipment and perform tests properly, recognize invalid tests,
and ensure that test equipment is in proper working order.
(b) The employer shall ensure that QLFT equipment is kept clean and well maintained
so as to operate within the parameters for which it was designed.
2. Isoamyl Acetate Protocol
Note: This protocol is not appropriate to use for the fir-testing of particulate respira-
tors. If used to fit-test particulate respirators, the respirator must be equipped with an
organic vapor filter.
(a) Odor Threshold Screening
Odor threshold screening, performed without wearing a respirator, is intended to
determine if the individual tested can detect the odor of isoamyl acetate at low levels.
(1) Three l-literglassjarswithmetallidsarerequired.
(2) Odor-free water (e.g., distilled or spring water) at approximately 25°C
(77°F) shall be used for the solutions.
(3) The isoamyl acetate (IAA) (also known at isopentyl acetate) stock solution is
prepared by adding I ml of pure IAA to 800 ml of odor-free water in a 1-liter
jar, closing the lid and shaking for 30 seconds. A new solution shall be pre-
pared at least weekly.
(4) The screening test shall be conducted in a room separate from the room used
for actual fit-testing. The two rooms shall be well-ventilated to prevent the odor
of JAA from becoming evident in the general room air where testing takes
place.
(5) The odor test solution is prepared in a second jar by placing 0.4 ml of the stock
solution into 500 ml of odor-free water using a clean dropper or pipette. The
solution shall be shaken for 30 seconds and allowed to stand for two to three
minutes so that the J.AA concentration above the liquid may reach equilibrium.
This solution shall be used for only one day.
(6) A test blank shall be prepared in a third jar by adding 500 cc of odor-free water.
&EPA June 1998 E3-15
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Attachment E3-1: Fit-Testing Procedures (continued)
(7) The odor test and test blank jar lids shall be labeled (e.g., I and 2) for jar
identification. Labels shall be placed on the lids so that they can be peeled off
periodically and switched to maintain the integrity of the test.
(8) The following instruction shall be typed on a card and placed on the table in
front of the two test jars (i.e., 1 and 2): “The purpose of this test is to determine
if you can smell banana oil at a low concentration. The two bottles in front of
you contain water. One of these bottles also contains a small amount of banana
oil. Be sure the covers are on tight, then shake each bottle for two seconds.
Unscrew the lid of each bottle, one at a time, and sniff at the mouth of the
bottle. Indicate to the test conductor which bottle contains banana oil.”
(9) The mixtures used in the fAA odor detection test shall be prepared in an area
separate from where the test is performed, in order to prevent olfactory fatigue
in the subject.
(10) If the test subject is unable to correctly identify the jar containing the odor test
solution, the fAA qualitative fit-test shall not be perfonned.
(11) If the test subject correctly identifies the jar containing the odor test solution,
the test subject may proceed to respirator selection and fit-testing.
(b) Isoamyl Acetate Fit-Test
(1) The fit-test chamber shall be a clear 55-gallon drum liner suspended inverted
over a 2-foot diameter frame so that the top of the chamber is about 6 inches
above the test subject’s head. If no drum liner is available, a similar chamber
shall be constructed using plastic sheeting. The inside top center of the chain-
ber shall have a small hook attached.
(2) Each respirator used for the fitting and fit-testing shall be equipped with
organic vapor cartridges or offer protection against organic vapors.
(3) After selecting, donning, and properly adjusting a respirator, the test subject
shall wear it to the fit-testing room. This room shall be separate from the room
used for odor threshold screening and respirator selection, and shall be well-
ventilated, as by an exhaust fan or lab hood, to prevent general room
contamination.
(4) A copy of the test exercises and any prepared text from which the subject is to
read shall be taped to the inside of the test chamber.
(5) Upon entering the test chamber, the test subject shall be given a 6-inch-by-
5-inch piece of paper towel, or other porous, absorbent, single-ply material,
folded in half and wetted with 0.75 ml of pure IAA. The test subject shall hang
June1998 E3-16
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Attachment E3-1: Fit-Testing Procedures (continued)
the wet towel on the hook at the top of the chamber. An LAA test swab or
ampule may be substituted for the IAA wetted paper towel, provided it has
been demonstrated that the alternative IAA source will generate an IAA test
atmosphere with a concentration equivalent to that generated by the paper
towel method.
(6) Allow two minutes for the IAA test concentration to stabilize before starting
the fit-test exercises. This would be an appropriate time to talk with the test
subject; to explain the fit-test, the importance of his/her cooperation, and the
purpose for the test exercises; or to demonstrate some of the exercises.
(7) If at any time during the test, the subject detects the banana-like odor of IAA,
the test is failed. The subject shall quickly exit from the test chamber and leave
the test area to avoid olfactory fatigue.
(8) If the test is failed, the subject shall return to the selection room and remove the
respirator. The test subject shall repeat the odor sensitivity test, select and put
on another respirator, return to the test area and again begin the fit-test proce-
dure described in (b)(1) through (7) above. The process continues until a
respirator that fits well has been found. Should the odor sensitivity test be
failed, the subject shall wait at least 5 minutes before retesting. Odor sensitivity
will usually have returned by this time.
(9) If the subject passes the test, the efficiency of the test procedure shall be
demonstrated by having the subject break the respirator face seal and take a
breath before exiting the chamber.
(10) When the test subject leaves the chamber, the subject shall remove the satu-
rated towel and return it to the person conducting the test, so that there is no
sigrnficant IAA concentration buildup in the chamber during subsequent tests.
The used towels shall be kept in a self-sealing plastic bag to keep the test area
from being contaminated.
3. Saccharin Solution Aerosol Protocol
The entire screening and testing procedure shall be explained to the test subject prior to
the conduct of the screening test.
(a) Taste threshold screening: The saccharin taste threshold screening, performed
without wearing a respirator, is intended to determine whether the individual being
tested can detect the taste of saccharin.
(1) During threshold screening as well as during fit-testing, subjects shall wear an
enclosure about the head and shoulders that is approximately 12 inches in
diameter by 14 inches tall with at least the front portion clear and that allows
‘&EPA June 1998 E3-17
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Attachment E3-1: Fit-Testing Procedures (continued)
free movements of the head when a respirator is worn. An enclosure substan-
tially similar to the 3M hood assembly, parts # FT 14 and # FT 15 combined,
is adequate.
(2) The test enclosure shall have a 3 4-inch (1.9 cm) hole in front of the test sub-
ject’s nose and mouth area to accommodate the nebulizer nozzle.
(3) The test subject shall don the test enclosure. Throughout the threshold screen-
ing test, the test subject shall breathe through his/her slightly open mouth with
tongue extended. The subject is instructed to report when he/she detects a
sweet taste.
(4) Using a DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent,
the test conductor shall spray the threshold check solution into the enclosure.
The nozzle is directed away from the nose and mouth of the person. This
nebulizer shall be clearly marked to distinguish it from the fit-test solution
nebulizer.
(5) The threshold check solution is prepared by dissolving 0.83 gram of sodium
saccharin USP in 100 ml of warm water. It can be prepared by putting I ml of
the fit-test solution (see (b)(5) below) in 100 ml of distilled water.
(6) To produce the aerosol, the nebulizer bulb is firmly squeezed so that it col-
lapses completely, then released and allowed to fully expand.
(7) Ten squeezes are repeated rapidly and then the test subject is asked whether the
saccharin can be tasted. If the test subject reports tasting the sweet taste during
the ten squeezes, the screening test is completed. The taste threshold is noted as
10 regardless of the number of squeezes actually completed.
(8) if the first response is negative, 10 more squeezes are repeated rapidly and the
test subject is again asked whether the saccharin is tasted. if the test subject
reports tasting the sweet taste during the second 10 squeezes, the screening test
is completed. The taste threshold is noted as 20 regardless of the number of
squeezes actually completed.
(9) If the second response is negative, 10 more squeezes are repeated rapidly and
the test subject is again asked whether the saccharin is tasted. If the test subject
reports tasting the sweet taste during the third set of 10 squeezes, the screening
test is completed. The taste threshold is noted as 30 regardless of the number of
squeezes actually completed.
(10) The test conductor will take note of the number of squeezes required to solicit a
taste response.
apER June 1998 E3-18
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Attachment E3.1: Fit-Testing Procedures (continued)
(11) if the saccharin is not tasted after 30 squeezes (step 10), the test subject is
unable to taste saccharin and may not perform the saccharin fit-test.
Note to paragraph 3.(a): If the test subject eats or drinks something sweet before the
screening test, he/she may be unable to taste the weak saccharin solution.
(12) If a taste response is elicited, the test subject shall be asked to take note of the
taste for reference in the fit-test.
(13) Correct use of the nebulizer means that approximately I ml of liquid is used at
a time in the nebulizer body.
(14) The nebulizer shall be thoroughly rinsed in water, shaken dry, and refilled at
least each morning and afternoon or at least every four hours.
(b) Saccharin solution aerosol fit-test procedure:
(1) The test subject may not eat, drink (except plain water), smoke, or chew gum
for 15 minutes before the test.
(2) The fit-test uses the same enclosure described in 3.(a) above.
(3) The test subject shall don the enclosure while wearing the respirator selected
in part l.A. of this attachment. The respirator shall be properly adjusted and
equipped with a particulate filter(s).
(4) A second DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent
is used to spray the fit-test solution into the enclosure. This nebulizer shall be
clearly marked to distinguish it from the screening test solution nebulizer.
(5) The fit-test solution is prepared by adding 83 grams of sodium saccharin to 100
ml of warm water.
(6) As before, the test subject shall breathe through the slightly open mouth with
tongue extended, and report if he/she tastes the sweet taste of saccharin.
(7) The nebulizer is inserted into the hole in the front of the enclosure and an
initial concentration of saccharin fit-test solution is sprayed into the enclosure
using the same number of squeezes (either 10, 20 or 30 squeezes) based on the
number of squeezes required to elicit a taste response as noted during the
screening test. A minimum of 10 squeezes is required.
(8) After generating the aerosol, the test subject shall be instructed to perform the
exercises in part l.A. 14. of this attachment.
&ER June1998 E3-19
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Attachment E3-1: Fit-Testing Procedures (continued)
(9) Every 30 seconds the aerosol concentration shall be replenished using one half
the original number of squeezes used initially (e.g., 5, 10, or 15).
(10) The test subject shall indicate to the lest conductor if at any time during the fit-
test the taste of saccharin is detected. If the test subject does not report tasting
the saccharin, the test is passed.
(11) If the taste of saccharin is detected, the fit is deemed unsatisfactory and the test
is failed. A different respirator shall be tried and the entire test procedure is
repeated (taste threshold screening and fit-testing).
(12) Since the nebulizer has a tendency to clog during use, the test operator must
make periodic checks of the nebulizer to ensure that it is not clogged. If
clogging is found at the end of the test session, the test is invalid.
4. Bitrex (Denatonium Benzoate) Solution Aerosol Protocol
The Bitrex ’ (Denatomum benzoate) solution aerosol QLFT protocol uses the published
saccharin test protocol because that protocol is widely accepted. BitrexT? is routinely
used as a taste aversion agent in household liquids that children should not be drinking,
and it is endorsed by the American Medical Association, the National Safety Council, and
the American Association of Poison Control Centers. The entire screening and testing
procedure shall be explained to the test subject prior to the conduct of the screening test.
(a) Taste Threshold Screening:
The Bitrexmi taste threshold screening, performed without wearing a respirator, is
intended to determine whether the individual being tested can detect the taste of
Bitrex .
(1) During threshold screening as well as during fit-testing, subjects shall wear an
enclosure about the head and shoulders that is approximately 12 inches (30.5
cm) in diameter by 14 inches (35.6 cm) tall. The front portion of the enclosure
shall be clear from the respirator and allow free movement of the head when a
respirator is worn. An enclosure substantially similar to the 3M hood assembly,
parts #14 and #15 combined, is adequate.
(2) The test enclosure shall have a ¾-inch (1.9 cm) hole in front of the test sub-
ject’s nose and mouth area to accommodate the nebulizer nozzle.
(3) The test subject shall don the test enclosure. Throughout the threshold screen-
ing test, the test subject shall breathe through his or her slightly open mouth
with tongue extended. The subject is instructed to report when he/she detects a
bitter taste.
& A June 1998 E3-20
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Attachment E3 -1: Fit-Testing Procedures (continued)
(4) Using a DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent,
the test conductor shall spray the Threshold Check Solution into the enclosure.
This nebulizer shall be clearly marked to distinguish it from the fit-test solution
nebulizer.
(5) The Threshold Check Solution is prepared by adding 13.5 milligrams of
BjtrexTM to 100 ml of 5 percent salt (NaCI) solution in distilled water.
(6) To produce the aerosol, the nebulizer bulb is firmly squeezed so that the bulb
collapses completely, and is then released and allowed to fully expand.
(7) An initial 10 squeezes are repeated rapidly and then the test subject is asked
whether the BitrexTM can be tasted. If the test subject reports tasting the bitter
taste during the 10 squeezes, the screening test is completed. The taste thresh-
old is noted as 10 regardless of the number of squeezes actually completed.
(8) 11 the first response is negative, 10 more squeezes are repeated rapidly and the
test subject is again asked whether the BitrexTM is tasted. If the test subject
reports tasting the bitter taste during the second 10 squeezes, the screening test
is completed. The taste threshold is noted as 20 regardless of the number of
squeezes actually completed.
(9) If the second response is negative, 10 more squeezes are repeated rapidly and
the test subject is again asked whether the BitrexTM is tasted. If the test subject
reports tasting the bitter taste during the third set of 10 squeezes, the screening
test is completed. The taste threshold is noted as 30 regardless of the number of
squeezes actually completed.
(10) The test conductor will take note of the number of squeezes required to solicit a
taste response.
(11) If the BitrexTM is not tasted after 30 squeezes (step 10), the test subject is
unable to taste Bitrex and may not perform the Bitrex 1 ” fit-test.
(12) If a taste response is elicited, the test subject shall be asked to take note of the
taste for reference in the fit-test.
(13) Correct use of the nebulizer means that approximately I ml of liquid is used at
a time in the nebulizer body.
(14) The nebulizer shall be thoroughly rinsed in water, shaken to dry, and refilled at
least each morning and afternoon or at least every four hours.
aEPA June 1998 E3-21
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Attachment E3-1: Fit-Testing Procedures (continued)
(b) BitrexTM Solution Aerosol Fit-Test Procedure:
(1) The test subject may not eat, drink (except plain water), smoke, or chew gum
for 15 minutes before the test.
(2) The fit-test uses the same enclosure as described in 4.(a) above.
(3) The test subject shall don the enclosure while wearing the respirator selected
according top LA. of this attachment. The respirator shall be properly
adjusted and equipped with any type particulate filter(s).
(4) A second DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent is
used to spray the fit-test solution into the enclosure. This nebulizer shall be
clearly marked to distinguish it from the screening test solution nebulizer.
(5) The fit-test solution is prepared by adding 337.5 mg of Bitrex to 200 ml of a
5 percent salt (NaC1) solution in warm water.
(6) As before, the test subject shall breathe through his or her slightly open mouth
with tongue extended, and be instructed to report if he/she tastes the bitter taste
of BitrexTh.
(7) The nebulizer is inserted into the hole in the front of the enclosure and an
initial concentration of the fit-test solution is sprayed into the enclosure using
the same number of squeezes (either 10,20, or 30 squeezes) based on the
number of squeezes required to elicit a taste response as noted during the
screening test.
(8) After generating the aerosol, the test subject shall be instructed to perform the
exercises in part I.A.14. of this attachment.
(9) Every 30 seconds the aerosol concentration shall be replenished using one half
the number of squeezes used initially (e.g., 5, 10, or 15).
(10) The test subject shall indicate to the test conductor if at any time during the fit-
test the taste of BitrexTh is detected. If the test subject does not report tasting
the BitrexTM, the test is passed.
(11) If the taste of Bitrex is detected, the fit is deemed unsatisfactory and the test
is failed. A different respirator shall be tried and the entire test procedure is
repeated (taste threshold screening and fit-testing).
June 1998 E3-22
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Attachment E3-1: Fit-Testing Procedures (continued)
5. Irritant Smoke (Stannic Chloride) Protocol
This qualitative fit-test uses a person’s response to the irritating chemicals released in the
“smoke” produced by a stannic chloride ventilation smoke tube to detect leakage into the
respirator.
(a) General Requirements and Precautions:
(1) The respirator to be tested shall be equipped with high-efficiency particulate air
(HEPA) or P100 series filter(s).
(2) Only stannic chloride smoke tubes shall be used for this protocol.
(3) No form of test enclosure or hood for the test subject shall be used.
(4) Since the smoke can be irritating to the eyes, lungs, and nasal passages, the test
conductor shall take precautions to minimize the test subject’s exposure to irri-
tant smoke. Sensitivity varies, and certain individuals may respond to a greater
degree to irritant smoke. Care shall be taken when performing the sensitivity
screening checks that determine whether the test subject can detect irritant
smoke to use only the minimum amount of smoke necessary to elicit a response
from the test subject.
(5) The fit-test shall be performed in an area with adequate ventilation to prevent
exposure of the person conducting the fit-test or the build-up of irritant smoke
in the general atmosphere.
(b) Sensitivity Screening Check:
The person to be tested must demonstrate his or her ability to detect a weak concen-
tration of the irritant smoke.
(1) The test operator shall break both ends of a ventilation smoke tube containing
stannic chloride, and attach one end of the smoke tube to a low-flow air pump
set to deliver 200 mL per minute, or an aspirator squeeze bulb. The test opera-
tor shall cover the other end of the smoke tube with a short piece of tubing to
prevent potential injury from the jagged end of the smoke tube.
(2) The test operator shall advise the test subject that the smoke can be irritating to
the eyes, lungs, and nasal passages and instruct the subject to keep his/her eyes
closed while the test is performed.
&EFA June 1998 E3-23
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Attachment E3-1: Fit-Testing Procedures (continued)
(3) Before the respirator is donned, the test subject shall be allowed to smell a
weak concentration of the irritant smoke to become familiar with its irritating
properties and to determine if he/she can detect the irritating properties of the
smoke. The test operator shall carefully direct a small amount of the irritant
smoke in the test subject’s direction to determine if he/she can detect it.
(c) Irritant Smoke Fit-Test Procedure:
(1) The person being fit-tested shall don the respirator without assistance, and
perform the required user seal check(s).
(2) The test subject shall be instructed to keep his/her eyes closed.
(3) The test operator shall direct the stream of irritant smoke from the smoke tube
toward the face seal area of the test subject, using the low-flow pump or the
squeeze bulb. The test operator shall begin at least 12 inches from the facepiece
and move the smoke stream around the whole perimeter of the mask. The
operator shall gradually make two more passes around the perimeter of the
mask, moving to within six inches of the respirator.
(4) If the person being tested has not had an involuntary response and/or detected
the irritant smoke, proceed with the test exercises.
(5) The exercises identified in part I.A.14. of this attachment shall be performed by
the test subject while the respirator seal is being continually challenged by the
smoke, directed around the perimeter of the respirator at a distance of six
inches.
(6) if the person being fit-tested reports detecting the irritant smoke at any time,
the test is failed. The person being retested must repeat the entire sensitivity
check and fit-test procedure.
(7) Each test subject passing the irritant smoke test without evidence of a response
(e.g.. involuntary cough, irritation) shall be given a second sensitivity screening
check, with the smoke from the same smoke tube used during the fit-test, once
the respirator has been removed, to determine whether he/she still reacts to the
smoke. Failure to evoke a response shall void the fit-test.
(8) If a response is produced during this second sensitivity check, then the fit-test
is passed.
Qj P.j* June 1998 E324
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Attachment E3-1: Fit-Testing Procedures (continued)
C. Quantitative Fit-Test (QNY ) Protocols
The following quantitative fit-testing procedures have been demonstrated to be acceptable:
• Quantitative fit-testing using a non-hazardous test aerosol (e.g., corn oil, polyethylene
glycol 400 [ PEG 400], di-2-ethyl hexyl sebacate [ DEHS], or sodium chloride) generated
in a test chamber, and employing instrumentation to quantify the fit of the respirator
• Quantitative fit-testing using ambient aerosol as the test agent and appropriate instrumen-
tation (e.g., condensation nuclei counter) to quantify the respirator fit
• Quantitative fit-testing using controlled negative pressure and appropriate instrumentation
to measure the volumetric leak rate of a facepiece to quantify the respirator fit
1. General
(a) The employer shall ensure that persons administering QNFT are able to calibrate
equipment and perform tests properly, recognize invalid tests, calculate fit-factors
properly and ensure that test equipment is in proper working order.
(b) The employer shall ensure that QNFF equipment is kept clean, and is maintained and
calibrated according to the manufacturer’s instructions so as to operate at the
parameters for which it was designed.
2. Generated Aerosol Protocol
(a) Apparatus:
(1) Instrumentation: Aerosol generation, dilution, and measurement systems using
particulates (e.g., corn oil, polyethylene glycol 400 [ PEG 400], di-2-ethyl hexyl
sebacate [ DEHS] or sodium chloride) as test aerosols shall be used for quanti-
tative fit-testing.
(2) Test chamber: The test chamber shall be large enough to permit all test sub-
jects to perform freely all required exercises without disturbing the test agent
concentration or the measurement apparatus. The test chamber shall be
equipped and constructed so that the test agent is effectively isolated from
the ambient air, yet uniform in concentration throughout the chamber.
(3) When testing air-purifying respirators, the normal filter or cartridge element
shall be replaced with a HEPA or P100 series filter supplied by the same
manufacturer.
(4) The sampling instrument shall be selected so that a computer record or strip
chart record may be made of the test showing the rise and fall of the test agent
concentration with each inspiration and expiration at fit-factors of at least
&EPA June 1998 E3-25
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Attachment E3-1: Fit-Testing Procedures (continued)
2,000. Integrators or computers that integrate the amount of test agent penetra-
tion leakage into the respirator for each exercise may be used, provided a
record of the readings is made.
(5) The combination of substitute air-purifying elements with the test agent and
test agent concentration shall be such that the test subject is not exposed in
excess of an established exposure limit for the test agent at any time during the
testing process, based on the length of the exposure and the exposure limit
duration.
(6) The sampling port on the test specimen respirator shall be placed and con-
structed so that no leakage occurs around the port (e.g., where the respirator is
probed), a free air flow is allowed into the sampling line at all times, and there
is no interference with the fit or performance of the respirator. The in-mask
sampling device (probe) shall be designed and used so that the air sample is
drawn from the breathing zone of the test subject, midway between the nose
and mouth and with the probe extending into the facepiece cavity at least 14
inch.
(7) The test setup shall permit the person administering the test to observe the test
subject inside the chamber during the test.
(8) The equipment generating the test atmosphere shall maintain the concentration
of test agent constant to within a 10 percent variation for the duration of the
test.
(9) The time lag (i.e., interval between an event and the recording of the event
on the strip chart or computer or integrator) shall be kept to a minimum. There
shall be a clear association between the occurrence of an event and its being
recorded.
(10) The sampling line tubing for the test chamber atmosphere and for the respirator
sampling port shall be of equal diameter and of the same material. The length
of the two lines shall be equal.
(11) The exhaust flow from the test chamber shall pass through an appropriate filter
(i.e., high-efficiency particulate or P100 series filter) before release.
(12) When sodium chloride aerosol is used, the relative humidity inside the test
chamber shall not exceed 50 percent.
(13) The limitations of instrument detection shall be taken into account when
determining the fit-factor.
&EPA June 1998 E3-26
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Attachment E3-1: Fit-Testing Procedures (continued)
(14) Test respirators shall be maintained in proper working order and be inspected
regularly for deficiencies such as cracks or missing valves and gaskets.
(b) Procedural Requirements:
(1) When performing the initial user seal check using a positive- or negative-
pressure check, the sampling line shall be crimped closed in order to avoid air
pressure leakage during either of these pressure checks.
(2) The use of an abbreviated screening QLFT test is optional. Such a test may be
used to quickly identify poor-fitting respirators that passed the positive- and/or
negative-pressure test and reduce the amount of QNFT time. The use of the
contamination nuclei counter (CNC) QNFT instrument in the count mode is
another optional method to obtain a quick estimate of fit and eliminate poor-
fitting respirators before going on to perform a full QNFT.
(3) A reasonably stable test agent concentration shall be measured in the test cham-
ber prior to testing. For canopy or shower curtain types of test units, the deter-
mination of the test agent’s stability may be established after the test subject
has entered the test environment.
(4) immediately after the subject enters the test chamber, the test agent concentra-
tion inside the respirator shall be measured to ensure that the peak penetration
does not exceed 5 percent for a half mask or 1 percent for a full facepiece
respirator.
(5) A stable test agent concentration shall be obtained prior to the actual start of
testing.
(6) Respirator restraining straps shall not be over-tightened for testing. The straps
shall be adjusted by the wearer without assistance from other persons to give a
reasonably comfortable fit typical of normal use. The respirator shall not be
adjusted once the fit-test exercises begin.
(7) The test shall be terminated whenever any single peak penetration exceeds 5
percent for half masks and 1 percent for full facepiece respirators. The test
subject shall be refitted and retested.
(8) Fit-factors shall be calculated.
(I) The fit-factor shall be determined for the quantitative fit-test by taking the
ratio of the average chamber concentration to the concentration measured
inside the respirator for each test exercise except the grimace exercise.
&EPA June 1998 E3-27
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Attachment E3-1: Fit-Testing Procedures (continued)
(ii) The average test chamber concentration shall be calculated as the arithine-
tic average of the concentration measured before and after each test (i.e., 7
exercises) or the arithmetic average of the concentration measured before
and after each exercise or the true average measured continuously during
the respirator sample.
(iii) The concentration of the challenge agent inside the respirator shall be
determined by one of the following methods:
(a) Average peak penetration: the method of determining test agent
penetration into the respirator using a strip chart recorder, integrator,
or computer. The agent penetration is determined by an average of
the peak heights on the graph or by computer integration, for each
exercise except the grimace exercise. Integrators or computers that
calculate the actual test agent penetration into the respirator for each
exercise will also be considered to meet the requirements of the
average peak penetration method.
(b) Maximum peak penetration: the method of determining test agent
penetration in the respirator as determined by strip chart recordings
of the test. The highest peak penetration for a given exercise is taken
to be representative of average penetration into the respirator for
that exercise.
(c) Integration by calculation of the area under the individual peak for
each exercise except the grimace exercise. This includes computer-
ized integration.
(d) The calculation of the overall fit-factor using individual exercise fit-
factors involves first converting the exercise fit-factors to penetra-
tion values, determining the average, and then converting that result
back to a fit-factor.
(9) The test subject shall not be permitted to wear a half mask or quarter facepiece
respirator unless a minimum fit-factor of 100 is obtained, or a full facepiece
respirator unless a minimum fit-factor of 500 is obtained.
(10) Filters used for quantitative fit-testing shall be replaced whenever increased
breathing resistance is encountered, or when the test agent has altered the
integrity of the filter media.
June 1998 E3-28
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Attachment E3-1: Fit-Testing Procedures (continued)
3. Ambient Aerosol Condensation Nuclei Counter (CNC) Protocol.
The ambient aerosol CNC quantitative fit-testing (Portacount Th) protocol quantitatively
fit-tests respirators with the use of a probe. The probed respirator is only used for
quantitative fit-tests. A probed respirator has a special sampling device, installed on the
respirator, that allows the probe to sample the air from inside the mask. A probed
respirator is required for each make, style, model, and size that the employer uses and can
be obtained from the respirator manufacturer or distributor. The CNC instrument
manufacturer, TSI Inc., also provides probe attachments (e.g., TSI sampling adapters) that
permit fit-testing in an employee’s own respirator. A minimum fit-factor pass level of at
least 100 is necessary for a half-mask respirator and a minimum fit-factor pass level of at
least 500 is required for a full-facepiece negative-pressure respirator. The entire screening
and testing procedure shall be explained to the test subject prior to performing the
screening test.
(a) Portacount Fit-Test Requirements:
(1) Check the respirator to make sure it is fitted with a high-efficiency filter and
that the sampling probe and line are properly attached to the facepiece.
(2) Instruct the test subject to don the respirator for five minutes before the fit-test
starts. This purges the ambient particles trapped inside the respirator and
permits the wearer to make certain the respirator is comfortable. This individ-
ual shall already have been trained on how to wear the respirator properly.
(3) Check the following conditions for the adequacy of the respirator fit: chin
properly placed; adequate strap tension, not overly tightened; proper fit across
nose bridge; respirator of proper size to span distance from nose to chin;
tendency of the respirator to slip; self-observation in a mirror to evaluate fit and
respirator position.
(4) Have the person wearing the respirator do a user seal check. If leakage is
detected, determine the cause. If leakage is from a poorly-fitting facepiece,
try another size of the same model respirator, or another model of respirator.
(5) Follow the manufacturer’s instructions for operating the PortacountTM and
proceed with the test.
(6) The test subject shall be instructed to perform the exercises in part l.A. 14. of
this attachment.
&EPA June 1998 E3-29
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Attachment E3-1: Fit-Testing Procedures (continued)
(7) After the test exercises, the test subject shall be questioned by the test conduc-
tor regarding the comfort of the respirator upon completion of the protocol. If it
has become unacceptable, another model of respirator shall be tried.
(b) Portacount Test Instrument:
(1) The Portacount will automatically stop and calculate the overall fit-factor for
the entire set of exercises. The overall fit-factor is what counts. The pass or fail
message will indicate whether or not the test was successful. If the test was a
pass, the fit-test is over.
(2) Since the pass or fail criteria of the Portacount are user programmable, the
test operator shall ensure that the pass or fail criteria meet the requirements for
minimum respirator performance in this attachment.
(3) A record of the test needs to be kept on file, assuming the fit-test was success-
ful. The record must contain the test subject’s name; overall fit-factor; make,
model, style, and size of respirator used; and date tested.
4. Controlled Negative Pressure (CNP) Protocol
The CNP protocol provides an alternative to aerosol fit-test methods. The CNP fit-test
method technology is based on exhausting air from a temporarily sealed respirator face-
piece to generate and then maintain a constant negative pressure inside the facepiece. The
rate of air exhaust is controlled so that a constant negative pressure is maintained in the
respirator during the fit-test. The level of pressure is selected to replicate the mean inspir-
atory pressure that causes leakage into the respirator under normal use conditions. With
pressure held constant, air flow out of the respirator is equal to air flow into the respirator.
Therefore, measurement of the exhaust stream that is required to hold the pressure in the
temporarily sealed respirator yields a direct measure of leakage air flow into the
respirator.
The CNP fit-test method measures leak rates through the facepiece as a method for deter-
mining the facepiece fit for negative-pressure respirators. The CNP instrument manufac-
turer Dynatech Nevada also provides attachments (e.g., sampling manifolds) that replace
the filter cariridges to permit fit-testing in an employee’s own respirator. To perform the
test, the test subject closes his mouth and holds his breath, after which an air pump
removes air from the respirator facepiece at a pre-selected constant pressure. The face-
piece fit is expressed as the leak rate through the facepiece, expressed as milliliters per
minute. The quality and validity of the CNP fit-tests are determined by the degree to
which the in-mask pressure tracks the test pressure during the system measurement time
of approximately five seconds. Instantaneous feedback in the form of a real-time pressure
trace of the in-mask pressure is provided and used to deter-mine test validity and quality.
&EPA June 1998 E3-30
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Attachment E3-1: Fit-Testing Procedures (continued)
A minimum fit-factor pass level of 100 is necessary for a half-mask respirator and a
minimum fit-factor of at least 500 is required for a full face-piece respirator. The entire
screening and testing procedure shall be explained to the test subject prior to the conduct
of the screening test.
(a) CNP Fit-Test Requirements:
(1) The instrument shall have a non-adjustable test pressure of 15.0 mm water
pressure.
(2) The CNP system defaults selected for test pressure shall be set at —1.5 mm of
water (-0.58 inches of water) and the modeled inspiratory flow rate shall be
53.8 liters per minute for performing fit-tests.
(Note: CNP systems have built-in capability to conduct fit-testing that is
speci:flc to unique work rate, mask, and gender situations that might apply
in a specific workplace. Use of system default values, which were selected to
represent respirator wear with medium cartridge resistance at a low-
moderate work rate, will allow inter-test comparison of the respirator fit.)
(3) The individual who conducts the CNP fit-testing shall be thoroughly trained to
perform the test.
(4) The respirator filter or cartridge needs to be replaced with the CNP test mani-
fold. The inhalation valve downstream from the manifold either needs to be
temporarily removed or propped open.
(5) The test subject shall be trained to hold his breath for at least 20 seconds.
(6) The test subject shall don the test respirator without any assistance from the
individual who conducts the CNP fit-test.
(7) The QNFT protocol shall be followed according to part I.C. 1. of this attach-
ment, with an exception for the CNP test exercises.
(b) CNP Test Exercises:
(I) Normal breathing: In a normal standing position, without talking, the subject
shall breathe normally for 1 minute. After the normal breathing exercise, the
subject needs to hold his or her head straight ahead and hold his or her breath
for 10 seconds during the test measurement.
&EPA June 1998 E3-3 1
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Attachment E3-1: Fit-Testing Procedures (continued)
(2) Deep breathing: In a normal standing position, the subject shall breathe slowly
and deeply for 1 minute, being careful not to hyperventilate. After the deep
breathing exercise, the subject shall hold his or her head straight ahead and
hold his or her breath for 10 seconds during test measurement.
(3) Turning head side to side: Standing in place, the subject shall slowly turn his
or her head from side to side between the extreme positions on each side for 1
minute. The head shall be held at each extreme momentarily so the subject can
inhale at each side. After the turning head side to side exercise, the subject
needs to hold his or her head full left and hold his or her breath for 10 seconds
during test measurement. Next, the subject needs to hold his or her head full
right and hold his or her breath for 10 seconds during test measurement.
(4) Moving head up and down: Standing in place, the subject shall slowly move
his or her head up and down for 1 minute. The subject shall be instructed to
inhale in the up position (i.e., when looking toward the ceiling). After the
moving head up and down exercise, the subject shall hold his or her head full
up and hold his or her breath for 10 seconds during test measurement. Next, the
subject shall hold his or her head full down and hold his or her breath for 10
seconds during test measurement.
(5) Talking: The subject shall talk out loud slowly and loud enough so as to be
heard clearly by the test conductor. The subject can read from a prepared text
such as the Rainbow Passage, count backward from 100, or recite a memorized
poem or song for 1 minute. After the talking exercise, the subject shall hold his
or her head straight ahead and hold his or her breath for 10 seconds during the
test measurement.
(6) Grimace: The test subject shall grimace by smiling or frowning for 15
seconds.
(7) Bending Over: The test subject shall bend at the waist (as if he or she were to
touch his or her toes) for 1 minute. Jogging in place shall be substituted for this
exercise in those test environments such as shroud-type QNFI’ units that pro-
hibit bending at the waist. After the bending over exercise, the subject shall
hold his or her head straight ahead and hold his or her breath for 10 seconds
during the test measurement.
(8) Normal Breathing: The test subject shall remove and re-don the respirator
within a one-minute period. Then, in a normal standing position, without
talking, the subject shall breathe normally for 1 minute. After the normal
breathing exercise, the subject shall hold his or her head straight ahead and
hold his or her breath for 10 seconds during the test measurement. After the test
&EPA June 1998 E3-32
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Attachment E3-1: Fit-Testing Procedures (continued)
exercises, the test subject shall be questioned by the test conductor regarding
the comfort of the respirator upon completion of the protocol. If it has become
unacceptable, another model of a respirator shall be tried.
(c) CNP Test Instrument:
(1) The test instrument shall have an effective audio warning device when the test
subject fails to hold his or her breath during the test. The test shall be termi-
nated whenever the test subject failed to hold his or her breath. The test subject
may be refitted and retested.
(2) A record of the test shall be kept on file, assuming the fit-test was successful.
The record must contain the test subject’s name; overall fit-factor; make,
model, style, and size of respirator used; and date tested.
Part II. New Fit-Test Protocols
A. Any person may submit an application to OSHA for approval of a new fit-test protocol. If
the application meets the following criteria, OSHA will initiate a rulemaking proceeding
under section 6(b)(7) of the OSHA Act to determine whether to list the new protocol as
an approved protocol.
B. The application must include a detailed description of the proposed new fit-test protocol.
This application must be supported by either:
1. A test report prepared by an independent government research laboratory (e.g.,
Lawrence Livermore National Laboratory, Los Alamos National Laboratory, the
National Institute for Standards and Technology) stating that the laboratory has
tested the protocol and had found it to be accurate and reliable; or
2. An article that has been published in a peer-reviewed industrial hygiene journal
describing the protocol and explaining how test data support the protocol’s accuracy
and reliability.
C. If OSHA determines that additional information is required before the Agency com-
mences a rulemaking proceeding under this section, OSHA will so notify the applicant
and afford the applicant the opportunity to submit the supplemental information. Initia-
tion of a rulemaking proceeding will be deferred until OSHA has received and evaluated
the supplemental information.
&EPA June 1998 E3-33
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E4.
Emergency Eyewashes
and Showers
-------
SHEMP Operations Manual for Laboratories
CHAPTER E
Protective Clothing and Equipment
E4. Safety Showers and Eyewash Stations
1.0 Introduction
Accident anticipation and emergency
response are among the most critical
aspects of an effective laboratory manage-
ment plan. Laboratories must establish
means for responding to accidental eye
and body exposure to hazardous materials.
Primary protective devices, such as safety
glasses and lab coats, are essential to the
prevention of accidental exposure to haz-
ardous materials. Eyewashes and safety
showers, though not substitutes for protec-
tive devices, are critical for an effective
response to accidental exposure. For
instance, the first few seconds following
accidental eye contact with a corrosive
chemical is often critical to keeping eye
injury to a minimum. It’s essential that
laboratories locate emergency eyewashes
and safety showers in immediately accessi-
ble areas, maintain them appropriately, and
train employees on the procedures for
proper use.
EPA Program Requirements
Emergency eyewashes and showers must
be located in the immediate area where
employees may be exposed to corrosive
chemicals, and are recommended in all
areas where personnel may have accidental
contact with hazardous materials. Each
laboratory must ensure that:
• Emergency eyewashes and showers
are provided in all required areas
• Emergency eyewashes and showers
are immediately accessible and are
maintained free of obstructions at all
times
• Locations are labeled with a highly
visible sign
• Employees are trained in proper use
• Emergency eyewashes and showers
are properly maintained and routinely
tested
The requirement for suitable facilities for
quick drenching or flushing of the eyes
and body is contained in the U.S. Occupa-
tional Safety and Health Administration
(OSHA) standard on Medical Services and
First Aid 29 CFR 1910.151. OSHA does
not specifically address the operation and
maintenance of eyewashes and safety
showers, but does accept the guidelines
established by the American National
Standards Institute (ANSI) for emergency
eyewash and shower equipment in ANSI
Z358.l-1990 (A new issue, ANSI Z358.l-
1998 has recently been released).
ANSI published the first standard for the
design, installation, and use of eyewash
and shower equipment in 1981. The most
recent update of the standard is the 1998
version. The standard provides specifica-
tions for equipment design, performance,
installation, and maintenance for several
types of eyewashes and safety showers, as
well as training requirements for the use
of this equipment.
Program Administration
To effectively manage the provision, use,
and maintenance of emergency eyewashes
and showers, responsibilities should be
assigned for:
&EPA June 1998
E4-1
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SHEMP Operations Manual for Laboratories
CHAPTER E
Protective Clothing and Equipment E4. Safety Showers and Eyewash Stations
• Developing procedures to document
the measures for management of eye-
washes and showers
• Ensuring that eyewashes and showers
are located in all required areas and
installed to meet the ANSI
specifications
• Training employees on the procedures
for proper use
• Periodically activating showers (e.g.,
weekly) and eyewashes (e.g., daily)
to flush the lines and verify proper
operation
• Coordinating regular maintenance
according to the manufacturer’s speci-
fications
• Inspecting eyewash and shower
locations to ensure they are free
of obstructions at all times
&EPA June 1998 E4-2
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SHEMP Operations Manual for Laboratories
CHAPTER E
Protective Clothing and Equipment
E4. Safety Showers and Eyewash Stations
2.0 Types
Several types of eyewash units and safety
showers shown below are available for
laboratory use. However, any eyewash
must be capable of flushing both eyes
simultaneously.
3.0 Location
Eyewash and shower units should be
located throughout the facility as close to
the hazard as possible without physically
causing a hazard itself (e.g., from protrud-
ing fittings). All laboratory employees
should know the locations of eyewashes
and showers in their areas. Locating equip-
ment on normal access and egress paths in
the work area helps reinforce the location
to potential users.
The maximum time required to reach the
unit should be determined by the potential
effect of the chemical. It is recommended
Types of Eyewash Units and Safety Showers
Plumbed Shower: A plumbed
unit permanently connected to a
source of potable water. These
units enable the user to have
water cascading over the entire
body.
Combination Unit: A unit com-
bining a shower with an eyewash
or eye/face wash, or with a drench
hose, or with both, into one com-
mon assembly.
that a consulting physician or appropriate
professional be contacted for advice on the
proper distance. However, as a rule of
thumb, eyewashes and showers should be
located with a maximum travel distance of
100 feet so that employees can reach them
in no more than 10 seconds, taking into
account the fact that individuals may be
partially blinded by chemicals. Highly cor-
rosive chemicals may require the installa-
tion of eyewashes and showers within 10
to 20 feet from the hazard. Eyewashes and
showers must never be located so that
employees must open doors to reach them.
A blanket should always be stored close to
the safety shower to protect the user from
shock or freezing conditions, and to pro-
vide privacy. Safety showers should be
equipped with a modesty curtain, as well.
Attachment E4- I of this manual provides a
quick reference for the installation specifi-
cations of each category of equipment.
Plumbed Eyewash: An eyewash unit
permanently connected to a source of
potable water. These devices are used to
irrigate and flush the eyes.
iland-Reld Drench hose: A flexible
hose connected to a waler supply and
used to irrigate and flush eyes, face,
and body areas.
Personal Eyewash: A supplemen-
tary eyewash that supports plumbed
units, self-contained units, or both,
by delivering immediate flushing
liquid. These are not a substitute for
self-contained eyewashes.
&EPA June 1998
E4-3
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SHEMP Operations Manual for Laboratories
CHAPTER E
Protective Clothing and Equipment
E4. Safety Showers and Eyewash Stations
4.0 Labeling
6.0 Use
Each emergency shower and eyewash unit
should be identified with a highly visible
sign. The area around the units must be
well-lighted and highly visible. Instruc-
tions and expiration dates, if applicable,
should be permanently affixed to the emer-
gency shower/eyewash unit.
5.0 Water Flow and Control
Drenching and flushing facilities must be
able to provide copious amounts of water
for at least 15 minutes. For most of the
equipment, the ANSI standard states that
the velocity of the water flow should be
low enough so that it is not injurious to
the user. Specific flow rates and flow pres-
sures are summarized in Attachment E4-2
of this manual.
Laboratories should provide only potable
water in their safety stations and keep the
temperature of the water within a comfort-
able range (27° to 29°C or 80° to 85°F) is
the optimum temperature range; 78-92 is
considered acceptable.
Except for personal eyewash equipment
and hand-held drench hoses, control valves
must be designed so the water flow
remains on without requiring the use of
the operator’s hands. The valve must be
designed to remain activated until inten-
tionally shut off. The valve must go from
“off” to “on” in one second or less.
Nozzles of all emergency showers and
eyewashes must be protected from air-
borne contaminants.
The laboratory should have written docu-
mentation of emergency and first aid pro-
cedures, and should communicate these
procedures clearly to laboratory person-
nel. Laboratory personnel should be
familiar with the controls and operating
devices, as well as with the procedures
to assist an injured person. Very often
an injured person cannot flush his/her
own eyes, and two people are needed—
one to hold open the victim’s eyes and
the other to restrain the victim if the
victim is in pain. Laboratory management
should introduce their personnel to the
appropriate actions required during such
an emergency.
People who have been splashed with
chemicals may panic and need assistance
to find the safety shower or eyewash unit.
They may also be in shock and need help
washing. Assistance should be provided,
but helpers need to wash themselves thor-
oughly as well.
The following actions should be taken in
the event of a chemical splash to the skin:
Safety Showers
1. Activate the safety showers to get
as much of the concentrated
chemical off the skin as possible.
2. Remain under the safety shower
for a minimum of 15 minutes.
3. When leaving the shower area,
wrap yourself in a blanket and
seek immediate medical help.
&EPA June 1998
E4-4
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SHEMP Operations Manual for Làboraiories
CHAPTER E
Protective Clothing and Equipment
E4. Safety Showers and Eyewash Stations
Usually clothing and shoes will need to be
removed to reduce or eliminate contact
with the chemical. Wet clothing kept on
can actually cause more severe damage
than if removed because it holds residual
chemicals in contact with skin.
The following actions should be taken in
the event of a chemical splash to the eyes:
Immediate rinsing is essential since a delay
of even a few seconds may result in per-
manent eye damage.
7.0 Inspection and Maintenance
Safety showers and eyewash units must
inspected on a regular basis. According
the ANSI standard, plumbed.
and safety showers, drench hoses, and
combS nation units should be activated
w y to flush the lines and observe
roper pressurization levels. Self-con-
tained and personal eyewashes should be
tested and maintained in accordance with
manufacturer’s instructions. Laboratory
management should develop formal proce-
dures for regular testing and inspection.
A frequent water replacement program
must be adopted and implemented for self-
contained eyewash units to protect against
growth of harmful microorganisms. Any
stored flushing fluid must be protected as
well.
8.0 User Training
All employees who might be exposed to
chemical splash should be instructed in the
proper use of emergency showers and eye-
wash units. The training should cover:
Location(s) of eyewashes and showers
relative to the user
• Importance of immediate drenching
and flushing
• Operation of and components of the
type of eyewashes and showers in the
user’s area
• Proper procedures for drenching and
flushing, including instructions on
how to aid a co-worker
• Testing and maintenance
Eyewash Units
1. Immediately flush eyes at nearest
eyewash unit.
2. Roll eyes to allow water to reach
all areas.
3. Irrigate eyes and inside lids for a
minimum of 15 minutes.
4. When leaving the eyewash area,
seek immediate medical help.
EPA June 1998
E4-5
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SHEMP Operations Manual for Laboratories
CHAFFER E
Attachment E4- 1: Installation Specification for Eyewash Units and Safety Showers
Safety Equipment
Specifications
Plumbed and self-contained
showers
• Water column: 82 to 96 inches in height from the
surface on which the user stands
• Center of spray: greater than 16 inches from any
obstruction
• Enclosures: unobstructed area greater than 34
inches in diameter
• Travel distance: less than 100 feet from hazard
Plumbed and self-contained
eyewashes
• Water nozzles: 331034 inches above floor;
6 inches from any obstruction
• Travel distance: less than 100 feet from hazard
Personal eyewash equip-
ment
• May be kept in the immediate vicinity of employ.
ees working in a potentially hazardous area
• Not a substitute for self-contained eyewashes
• Follow manufacturers’ recommendations for loca-
tion, use, an expiration periods
Eyelfacewash units
• Water nozzles: 33 to 34 inches above floor;
6 inches from any obstruction
• Travel distance: less than 100 feet from hazard
Hand-held drench hoses
• Not a substitute for safety shower/eyewash stations
Combination umts
• Must meet the requirements for each individual
component
• Travel distance: less than 100 feet from hazard
• Water line at least 1 ‘4 inches in diameter
!&EPA June 1998 E4-6
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S HEMP Operations Manual for Laboratories
CHAPTER E
Attachment E4-2: Specifications for Water Flow Control, Eyewash Units & Safety Showers
Safety Equipment
Spedfications
Plumbed and self-contained
showers
• Water column: greater than 20 inches in diameter at
60 inches above the surface
Water delivery: greater than 20 gallons per minute
(gpm)
Plumbed and self-contained
eyewashes
• Water delivery: greater than 0.4 gpm for 15 mm
• Water pressure: greater than 30 lbs/square inch
Personal eyewash equip-
ment
• Water delivery: greater than 0.4 gpm for 15 mm
Eye/facewash units
• Water delivery: greater than 3.0 gpm for 15 mm
• Water pressure: greater than 30 lbs/square inch
Hand-held drench hoses
• Water delivery: greater than 3.0 gpm
Combination units
• Must meet the requirements for each individual
component
1 & k June 1998 E4-7
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F. Work Practice Controls
-------
Fl.
Introduction
-------
SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
.
I—
Fl. Introduction
Rules and regulations regarding work practices are designed to help EPA employees live a
safe and healthy life. It cannot be overstressed that each person is largely responsible for their
own safety and health. Studies of industrial accidents show that less than 15 percent of
accidents can be attributed to equipment failure alone; the other 85 percent or more involve
human error.
This section contains information on many operations at EPA laboratories. These guidelines
provide a basis for safe laboratory operations. Some basic rules need the full support and
cooperation of all employees:
• Do not smoke in the laboratory.
• Do not pipette by mouth.
• Do not eat or drink in the laboratory.
• Wear eye protection at all times in the laboratory.
• Wear appropriate personal protective equipment.
Following these rules is essential for employee safety and health. This chapter of the manual
provides the following guidance for EPA laboratories on work practice controls:
Chapter Topic ___I
F2
General Work Practice Controls
F3 Work Practice Controls for Chemicals
EPA June 1998
ri-i
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F2.
General Work Practice
Controls
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
1.0 Introduction
EPA laboratory employees may encounter
various hazards that can be controlled
by safe work practices. Guidelines and
standard operating procedures (SOPs)
are designed to decrease the chance of
employee chemical exposure or chemical
cross-contamination. This chapter includes
work practices associated with basic labo-
ratory hygiene and general laboratory
safety. These practices are developed and
implemented to provide control over labo-
ratory hazards.
EPA Program Requirements
Each laboratory must ensure that:
Guidelines and SOPs are developed
and followed for basic laboratory
hygiene and general laboratory safety.
• Employees have been provided train-
ing on general work practice controls.
• Laboratories have been surveyed to
determine compliance with guidelines
and SOPs.
Program Administration
To effectively implement general work
practice controls, responsibilities should
be assigned to:
• Ensure that laboratory employees are
following basic practices for food and
beverages, apparel and jewelry, house-
keeping, and personal hygiene.
• Review requests for performing unat-
tended and overnight operations or
working alone.
• Develop SOPs for the safe operation
of laboratory equipment and labora-
tory electrical and mechanical safety.
• Train laboratory employees on general
work practice controls.
• Perform laboratory surveillance to
assess conformance with glassware
and sharps handling, disinfection, and
sterilization techniques.
• Ensure that proper decontamination of
laboratories, equipment and personnel
is being performed.
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
2.0 Basic Laboratory Hygiene Practices
Outlined below are many basic laboratory
hygiene practices that should be imple-
mented in all EPA laboratories to decrease
the possibility of employee chemical expo-
sure or cross-contamination. Figure F2-1
summarizes major categories covered for
these practices and depicts some examples
of signage.
2.1 Food and Beverages
When working in an EPA laboratory, eat-
ing, drinking, chewing gum, applying cos-
metics, and handling contact lenses are not
permitted. In addition, the storage of food
and beverages in laboratory refrigerators or
freezers is not permitted.
2.2 Apparel and Jewelry
Clothing to be worn in the laboratory must
provide adequate coverage to protect
against hazards. For example:
• Open-toed shoes are not permitted in
laboratories.
• Long pants and long-sleeved shirts
should be encouraged.
For additional information on laboratory
clothing, refer to Chapter E2 of this
manual.
The jewelry being worn must be limited to
small items with little chance of projection
into operations. Rings must be removed
during materials handling, mechanical
work, or operations involving contact with
chemicals or solvents. Hands should be
washed thoroughly after any contact with
a chemical or solvent, prior to replacing
rings. Watches become magnetized when
near large magnets such as those found
in nuclear magnetic resonance (NMR)
machines, mass spectrometers, etc. They
must then be demagnetized to keep reli-
able time.
2.3 Housekeeping
Laboratory supervisors and employees are
responsible for keeping their work areas
neat and orderly. All aisles, walkways,
halls, and exits must be kept clear, dry,
and free of obstructions and hazards, such
as bottles, boxes, and open drawers or cab-
inets, to allow safe passage.
Figure F2-1: Major Categories of Basic Laboratory Hygiene Practices
Food and Beverages
NOTICE
FOOD AND DRINK
PROHIBITED
Personal Hygiene
Facilities and
Res ooms
NOTICE
WASH YOUR
HANDS
Major Categories of
Basic Laboratory
Hygiene Practices
I
Housekeeping
Appaiel and Jewerly I
I
s p,
I
I
KEEP THIS AREA
SAFE AND CLEAN
&EPA June 1998
F2-2
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SHEMP Operations Manual for Laboratories
CHAFFER F
Work Practice Controls
F2.qeneral Work Practices
Step stools should be kept out of passage-
ways when not in use. Equipment should
be placed back from the edge of tables
and benches, or be placed in such a posi-
tion to minimize the possibility of it strik-
ing laboratory employees or obstructing
their exit. Also, emergency equipment
(e.g., eyewash stations, safety showers,
and fire extinguishers, etc.) should be
readily accessible and not obstructed by
equipment.
The following practices are recommended
to provide safe storage, use, and mainte-
nance of laboratory equipment:
Establish a definite storage place for
each item; return all apparatus, equip-
ment, or reagents to their proper loca-
lion immediately after use. Carefully
choose the storage location for hazard-
ous materials.
• Make certain that connecting lines
such as flexible tubing and power
cords are not longer than necessary;
remove defective equipment (includ-
ing equipment with frayed electrical
cords) from service until it is repaired.
• Dispose of cracked or broken glass-
ware by placing it in a separate recep-
tacle. Under no circumstances should
damaged glassware be used.
• Properly ground equipment in which
a buildup of static electricity may be
expected (e.g., when pouring solvents
or transferring dry powder).
• Wash nondisposable personal protec-
tive equipment (PPE) frequently to
reduce the possibility of irritation or
contamination.
L4 Personal Hygiene Facilities and
Practices
Handwashing with lukewarm water and
antimicrobial soap (not bar soap) must be
performed immediately following removal
of gloves and other PPE. When h .nd-
washing facilities are not available, anti-
septic hand cleansers or antiseptic
towelettes must be used until the individ-
ual is able to wash his or her hands.
3.0 General Safe Laboratory Work
Practices
Policies and procedures are in place at
EPA laboratories to promote employee
safety. Operational and handling tech-
niques to be employed in the laboratory
are described in the following sections and
the major categories covered are surnma-
rized in Figure F2-2.
3.1 Employee Conduct
The proper conduct of employees in EPA
laboratories is critical to promoting a safe
working environment. Safe laboratory
work requires an alert, clear mind. Any
person who is under the influence of alco-
hol or drugs is a hazard to himself and
fellow employees.
NO RUNNING
DIE USE OP ALCOHOL
ON THE PREMISES
WiLL MEAN IMMEDIATE
DISMISSAL
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFrER F
Work Practice Controls
F2. General Work Practices
Figure F2-2: Major Categories of
General Safe Laboratory Work
Practices
— Employee Conduct
— Signage
— Unattended and
Overnight Operations
— Glassware Handling
— Syringe Handling
— Disinfection and Sterilization
Decontamination
Running in laboratory buildings is prohib-
ited unless life is threatened by an extreme
hazard such as sudden release of toxic or
flammable gases. A fast walk will suffice
for an escape or for a response to an
emergency.
3.2 Signage
Prominent signs and labels of the follow-
ing types should be posted throughout the
laboratory:
• Identity labels showing contents of
containers and associated hazards
• Location signs for safety showers, eye-
wash stations, other safety and first-
aid equipment, exits, and areas where
food and beverage consumption and
storage are permitted
• Warnings at areas or equipment where
special or unusual hazards exist
• Emergency telephone numbers and
evacuation routes
Figure F2-3 presents some examples of
these signs.
There are regulations and guidelines that
require specific signs and labels for spe-
cific hazards. These specific requirements
can be found in chapters of this manual
that pertain to specific hazards. Examples
include:
C6
Radiation Safety
Cl
Biosafety
E4
Safety Showers and Eyewash
Stations
F3
Work Practice Controls for
Chemicals
G3
Emergency Systems and
Equipment
3.3 Unattended and Overnight
Operations
At EPA laboratories there may be unat-
tended and overnight operations such as
extractions, stirred reactions, and refluxing
solvents. Special precautions should be
taken if any of the following conditions axe
present:
• Room temperature and/or pressure
changes.
• Flammable, hazardous, or reactive
chemicals are used.
• Equipment depends on utilities for
continued safe operation.
Major
Categories of
General Safe —
Laboratory
Work
Practices
— Working Alone
— Safe Operation of
Laboratory Equipment
— Laboratory Electrical Safety
— Laboratory Mechanical Safety
June 1998
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SREMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
Figure F2-3: Examples of Signage Posted in a Laboratory
F2. General Work Practices
E cit
EXIT
—
Safety Shower
• Radiant energy (emitted or transmit-
ted) is used.
Special precautions to be taken under these
conditions include the use of containment,
automatic shutdown, and appropriate loca-
tion and warnings.
if working at night, on weekends or holi-
days, laboratory employees may be alone
and without immediate assistance in an
emergency. in these situations, work per-
formed should be limited to low-hazard
procedures (e.g., office work, gravimetric
weighing), avoiding potentially hazardous
operations such as:
• Using flammable solvents
• Handling corrosive or toxic chemicals
• Manipulating large glass apparatus
• Working with experimental electrical
or radioactive systems
If potentially hazardous procedures must
be performed during off-hours, accompa-
niment should be arranged.
An additional consideration during over-
night operations is that the ventilation in
some EPA laboratory buildings may not be
operating during off-hours (6 p.m. to 6
a.m.). If work must be performed during
this period, the building manager should
be contacted to maintain the ventilation in
the area.
33.1 Containment
The following containment precautions
can be taken to reduce risk during unat-
tended and overnight operations:
• Provide adequate exhaust ventilation
for chemical vapors.
• Place a metal or plastic pan under
breakable glassware to contain spills.
Eyewash Station
First-Aid
Equipment
Telephone Numbers
6EPA June 1998
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SHEMP Operations Manual for Laboratories
Ca’ rrI R F
Work Practice Controls
F2. General Work Practices
• Operate heating elements through a
variable transformer set at the lowest
voltage that will maintain the desired
temperature.
• Wire or clamp all water tubing to pre-
vent release of water in case of a pres-
sure surge.
3.3.2 Automatic Shutdown
Automatic shutdown can be accomplished
by the use of a circuit breaker to stop the
current in case of a malfunction or electri-
cal short. if possible, a monitoring device
should be used to stop the operation if
conditions deviate from safe limits.
3.33 Location
The location of the experimental apparatus
and other laboratory operations can reduce
risk. The following are precautions that
can be taken:
Place the apparatus where it does not
interfere with other operations.
• Keep all operations visible from the
doorway, if possible.
• Post the names and telephone numbers
of those familiar with the operation on
the laboratory door.
• Do not lock the laboratory door
overnight.
3.3.4 Warnings
The following precautions can be an effec-
tive means of reducing risk:
• Post signs to warn laboratory employ-
ees and staff of possible dangers.
• Use buzzers or other warnings to alert
laboratory employees and staff of mal-
functions if hazardous materials or
hazardous operations are involved.
In cases where an unattended overnight
operation is planned, the experimental set-
up should be reviewed. If the hazard level
is acceptable, then an authorization for a
specified time can be issued.
3.4 Working Alone
When any individual is performing work
out of audio or visual range of another
individual for more than a few minutes at
a time, they are considered to be working
alone. As a general policy, if at all possi-
ble, no one should work alone or under
conditions where emergency aid is not
available.
The availability of emergency aid, the
degree of training, the type of the emer-
gency aid, and the means of summoning
the help depend on the nature of the hazard
and the degree of exposure to the hazard.
Most work assignments can be set up with
the appropriate emergency aid available.
Whenever there is a doubt concerning a
work assignment and this philosophy, the
principle investigator and Safety, Health
and Environmental Management Program
(SHEMP) Manager should review, and
jointly define, the work assignment and the
emergency aid compatible with the work
assignment.
3.5 Safe Operation of Laboratory
Equipment
The safe operation of laboratory equip-
ment is an important part of work practice
controls. Some common examples of labo-
ratory equipment are discussed below and
shown in Figure F2-4.
&EPA June 1998
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SILEMP Operations Manual for Laboratories
CFL PTER F
Work Practice Controls
Figure F2-4: Examples of Laboratory Equipment
12. General Work Practices
a ma
at m June 1998
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SHEMP Operations Manual for Laboratories
C pmi F
Work Practice Controls
F2. General Work Practices
3.5.1 Vacuum Pumps
Every vacuum pump used in the laboratory
must have a belt guard in place whenever
it is operating. Its service cord and switch
must be free of observable defects. A trap
should be used on the suction line to pre-
vent liquids from being drawn into the
pump. If vapors are being drawn through
the pump, a cold trap should be inserted in
the suction line to prevent dilution of the
pump oil. A pan under the pump is useful
to catch any dripping oil.
if the pump is used for vacuum distillation
or filiration of organic liquids, the dis-
charge should be directed to an operating
hood or other exhaust system. Discharge
into an enclosed space, such as a labora-
tory cabinet, can lead to an explosive
release of vapors.
If the pump is used in an area where flam-
mable gas, vapors, or dust (which, when
present in large enough quantities, can
form explosive mixtures in air) are pres-
ent, the motor, cord, plug, and all other
electrical parts must be explosion-proof.
3.5.2 Vacuum Vessels and Dewar
Flasks
Glassware items used for vacuum distilla-
tion or other uses at reduced pressure must
be properly chosen for their ability to with-
stand the external pressure of the atmo-
sphere (e.g., round-bottom vessels or other
types, such as Erlenmeyer filtration flasks,
that are specially designed for vacuum
use). Each vessel must be carefully in-
spected before each use for defects such
as scratches, star cracks, or etching marks.
At reduced pressure, glass vessels can col-
lapse violently, either spontaneously (if
cracked or in some other way weakened),
or from an accidental impact. All vacuum
equipment is subject to failure by implo-
sion. The atmospheric pressure propels
pieces inward and they then continue out-
ward with considerable force. For this rea-
son, all vacuum operations must be carned
out behind a table shield or lowered hood
sash.
Dewar Flasks
Dewar flasks should not be filled to more
than 80 percent of capacity. This limit is a
precaution against possible thermal expan-
sion of the contents and bursting of the
vessel by hydrostatic pressure.
Pouring cold liquid onto the edge of a
Dewar flask may cause the flask to break
and implode. Liquid nitrogen must never
be poured out of a Dewar flask. Dewars
can collapse as a result of thermal shock or
a very slight scratch by a stirring rod.
Glass Dewar flasks have a vacuum be-
tween the walls, and, upon failure, can
propel glass into the eyes. For this reason,
all glass Dewars should be wrapped from
top to bottom with cloth tape, such as elec-
trician’s friction tape, or, if transparency is
needed, mylar tape. They can also be en-
closed in a wooden or metal container, to
reduce the hazard of flying glass in case of
collapse. Stainless steel vacuum containers
are also safe, as received. However, these
containers must be properly vented. Sec-
tion 3.8.5 provides more information on
the use of Dewar vessels for cryogenic
materials.
&EPPI June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
Glass Desiccator
Glass desiccators are often subjected
to partial vacuum caused by the cooling
of their contents. They have inherent
strains due to glass thickness and the
relatively flat top and bottom surfaces.
A desiccator guard made of perforated
metal is available and is strongly recom-
mended. An alternative is to use a molded
spherical plastic desiccator with high ten-
sile strength.
3.53 Blenders
Household-type blenders used in the labo-
ratory are a common cause of solvent fires.
The motors of such blenders have con-
stantly sparking brushes that can readily
ignite any released vapors or liquid
splashed out of the cup. Consequently,
solvents having a flash point below 100°F
(37.8°C) must never be used in these
blenders.
A catch pan under a blender is useful for
limiting spills of liquids or solids from the
cup. If a fire should occur, its extent will
be limited and extinguishing it should be
easy. An explosion-proof blender is avail-
able in a one-liter size. However, it has a
slow motor and is very expensive. As
such, the type of blender used should be
selected based on the intended use and
associated hazards.
CHEMICAL
ONLY
No flammable liquids (i.e., flash point
below 100°F [ 37.8°C]) may be placed in
an ordinary domestic-type refrigerator or
freezer. Flammable liquids can vaporize,
forming flammable mixtures that explode
when the thermostat sparks. Likewise,
carcasses containing ether or materials
soaked in alcohol are not permitted in
domestic-type refrigerators or freezers.
Refrigerators and freezers must have signs
on the doors specifying their use.
NO FLAMMABLE
LIQUIDS
When refrigeration is needed for flamma-
ble materials, there are two options. If the
refrigerator is in a room in which hydro-
carbon gases or vapors may be present, an
explosion-proof refrigerator should be
specified. lithe appliance will contain
flammable materials but be in a room free
of vapors or gas, an explosion-safe unit
can be purchased at lesser cost. Either
type, however, must include an appropriate
warning sign:
3.5.4 Refrigerators
Food must never be placed in a refrigerator
or freezer used for chemicals or biological
agents. If food is found in a chemical
refrigerator, it must be removed and dis-
carded. Refrigerators designated for food
storage must not be located in laboratories.
EXPLOSION-
PROOF
EXPLOS ION-
SAFE
All refrigerators must be marked either:
FOOD ONLY
II&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
If materials stored in a refrigerator are sen-
sitive to elevated temperatures, a battery-
powered alarm should be installed to sig-
nal an elevated temperature, that may
occur due to power loss.
3.5.5 Microwave Sample Preparation
Systems
Microwave sample preparation systems
are being used to drastically reduce the
time required to perform digestion of
both inorganic and organic samples. The
safety devices built into the units vary by
the manufacturer and the age of the unit.
In addition, safety measures taken by
researchers depend on the type of sample
digestion being performed (e.g., inorganic
or organic). Following are specific recom-
mendations for digestion of inorganic and
organic samples in a microwave sample
preparation system.
Inorganic Sample Digestion
A mixture of concentrated acids under
high temperature and pressure is used dur-
ing the inorganic sample digestion process.
Organic Sample Digestion
A mixture of concentrated acids and sol-
vents under high temperature and pressure
is used during the organic sample diges-
tion process.
The microwave systems that are designed
to use potentially flammable solvents
should be equipped with additional safety
devices such as: vibration sensors, solvent
sensors, and a button-latch door.
In both types of sample digestions, to pro-
tect against acid burns if a vessel should
rupture, laboratory employees should be
equipped with PPE such as an apron, face
shield and goggles, and neoprene gloves
(gauntlet length). When the microwave
door is opened, the pressure inside the
sample vessels should be monitored to
ensure that it has dropped to 20 pounds
per square inch.
A negative pressure should be created in-
side the microwave cavity by drawing air
from the back of the microwave system
into the laboratory ventilation system. This
will prevent fumes from entering the labo-
ratory employee’s breathing zone.
Sample Vessels and Caps
During the microwave digestion process,
only one of the sample vessels is moni-
tored for pressure through the attachment
of a sensor. The vessel selected for attach-
ment to the sensor should be representative
in contents to the other vessels.
:: L
• : __,
Both sample vessels made of polyether
emid and sample caps with a TeflonTM
coating have been shown to deteriorate
over time. Sample vessels made of
polyether emid can show bowing of the
sides of the vessel. Vessel caps can show
bubbling, blistering, and peeling of the
TeflonTM coating on the underside of the
caps. This could be due to acid fumes
escaping during the uncapping of the ves-
sels or processing of the caps through the
glass wash using an acid solution, which is
typically not required for the caps of the
vessels.
t
June 1998
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SHEMP Operations Manual for Laboratories
CHApmi F
Work Practice Conirols
F2. General Work Practices
Manufacturers recommend that each ves-
sel be used no more than 100 times. As
such, each vessel should be given a serial
number and the number of uses tracked
with a log sheet. However, if any signs of
deterioration are seen prior to the 100 uses,
the vessel should be taken out of use and
properly disposed of.
3.5.6 Heating Equipment
A variety of heating equipment is used in
the laboratory during experimental proce-
dures. Ovens, hot plates, bunsen burners
and other heating equipment should be
used with caution to avoid burns and igni-
tion of combustible materials. Ovens
should have, reliable and well-maintained
thermostatic controls. Hot plates should
have an on-off switch, enclosed wiring,
and be designated for laboratory use.
Bunsen burners, as well as any equipment
with an open flame, should be used with
extreme care to prevent ignition of com-
bustible or flammable materials in the
laboratory.
3.5.7 Centrifuges
Centrifuges used in a laboratory can be
one of two models: benchtop and floor.
EPA laboratory staff who use centrifuges
should be certain that the centrifuge is se-
curely anchored (e.g., suction cups or
wheel brakes) and balanced each time it is
used. In addition, they should be inter-
locked so that the rotor shuts off if the top
is opened during motion.
3.6 Laboratory Electrical Safety
The following sections provide an over-
view of the important aspects of electrical
safety applicable to the laboratory. Refer
to SHEM Guide 30 “Electrical Safety” for
detailed information on electrical safety.
A 115-volt, 60-hertz current of only 1/10th
of an ampere (100 milliamperes) may be
fatal if it passes through vital organs. The
fatality usually occurs because of ventricu-
lar fibrillation, which interrupts normal
heart action. Ventricular fibrillation can
occur as long as two weeks after the initial
shock. Therefore, any time even the
slightest electrical shock is received, it is
recommended that an electrocardiogram
(EKG) be performed to detect any heart-
beat irregularities. If the shock occurs on
the job at an EPA laboratory, the SHEMP
Manager must be contacted immediately.
To protect laboratory employees from
electrical shock during the servicing or
maintenance of machines and equipment,
the U.S. Occupational Safety and Health
Administration (OSHA) has promulgated
lockout/tagout regulations in 29 CFR
1910. 147. These regulations establish min-
imum performance requirements to control
hazards such as the unexpected start-up of
machinery or equipment, or the release of
stored energy that could cause injury to
employees. SHEM Guide 34, “Lockout/
Tagout,” provides additional information
on shock protection.
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CHAPTER F
Work Practice Controls
F2. General Work Practices
Most electrical work at EPA laboratories
requires a permit issued by the appropriate
local and state officials to ensure that the
work meets local and state building codes.
To protect EPA employees and property,
electrical work is restricted as follows:
Work on electrical circuits and equip-
ment, power lines, and power outlets
is restricted to qualified electricians,
except where research is being done
on instrumentation and other electrical
or electronic circuits.
• All electrical installations shall be in
accordance with the National Electri-
cal Code and must be appropriate for
the kinds of materials found in the
area. All conduits, outlets, and equip-
ment that could involve physical con-
tact must be grounded.
• All 115-volt outlets and plugs in EPA
laboratories shall be three-wire
grounded. Exceptions are made only
for equipment that cannot be
grounded, such as clocks.
if there is a chance that an accidental spill
of a liquid may increase the conductivity
of floors, benches, etc., use of a ground-
fault circuit interrupter (GFC1) should be
considered. Plugging equipment into this
device will protect employees from elec-
trocution by leakage to ground. The
National Fire Protection Association
(NFPA) has specific guidelines for when
GFCIs should be used.
3.6.1 Extension Cords
Extension cords waste energy, are subject
to damage, and constitute tripping hazards.
The use of extension cords in place of
permanent wiring is not allowed. The use
of extension cords should be limited to
temporazy needs such as hooking up porta-
ble equipment and power tools. OSHA has
interpreted temporary to mean less than
eight hours, if the cord from a permanent
piece of equipment, such as a refrigerator
or chromatograph, does not reach an out-
let, the equipment should be relocated or
a new outlet installed within accessible
range.
Multiple-outlet devices attached to a
length of wire are commonly used in labo-
ratories. These devices must have circuit
interrupters. Unfortunately, there is a
temptation to overload these devices with-
out considering that they plug into only
one of the outlets on a circuit. Where addi-
tional outlets are needed, they should be
installed, even if additional branch circuits
must be run.
Furniture and equipment in offices and
laboratories should be arranged so that
access to electrical panels is clear. Electri-
cal panel doors and locks must be main-
tained in working order. A three-foot
access aisle to electrical supplies and
transformers must be provided.
3.6.2 Static Electricity
Laboratory employees must guard against
the dangers of accumulation of static elec-
iricity, that may generate sparks.
Nonconductive surfaces moving past each
other generate static electricity. Therefore,
even certain forms of safety clothing,
such as plastic shoe coverings, may pro-
duce static electricity. It is advisable to
use grounded conducting surfaces, and
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F2. General Work Practices
conducting materials, in cases where there
is a danger that explosive mixtures of
gases may be present.
3.7 Laboratory Mechanical Safety
In the normal course of EPA laboratory
work, nothing more than standard PPE
will be needed as a safeguard. However,
some types of operating equipment should
have guards provided to protect laboratory
employees and passersby.
It is dangerous to leave a guard off of any
piece of machinery or equipment. If a
guard is removed from a machine for
maintenance or any other reason, the ma-
chine must be made inoperative until the
guard has been replaced.
Whenever work takes employees near
equipment in any of the categories covered
in this section, and shown in Figure F2-5,
proper guards must be in place.
3.7.1 Equipment Guarding
Rotating equipment, gears, belt drives,
in-running rolls, and other power transmis-
sion machinery must be guarded so that
employees are not injured by accidental
contact. Wherever moving parts can
catch hands or clothing, a guard should
be installed over the moving parts.
Guards of ample strength should be per-
manently anchored around any rotating
units, such as fan blades and grinding
wheels, that could break or separate.
Every power-driven machining tool (e.g.,
saw, shaper, drill, grinder, etc.) should
have its own hinged guard, which should
ride over the work but protect the hands
against accidental contact; or a point-of-
operation guard. Examples of moving
parts that require guarding include:
• Shaft collars or other rotating mem-
bers with protruding parts
• Where belts engage their pulleys
• Where chains engage their sprockets
• Where gears mesh
Figure F2-5: Categories of Mechanical Safety
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F2. General Work Practices
Whenever oil or other fluids may be
thrown off from a rotating unit or squirted
out of any vessel or machinery, a shield
should be placed to prevent the debris
from striking the floor and rendering it
slippery, or from striking employees in
the vicinity.
If machinery is commercially constructed
with point-of-operation guards, they
should not be removed. If an employee
finds a guard off, they should not operate
the machine until the guard is replaced. If
an employee takes a guard off for any pur-
pose, it should be replaced before they
leave the equipment or area. Remove
guards only when equipment has been
properly deenergized, and when it needs to
be repaired. Do not remove guards simply
for convenient operation.
if a laboratory setup is being designed or
constructed involving power transmission
or mechanical work, all nip points should
be guarded. If new mechanical equipment
with exposed moving parts is requested, it
should be determined whether it is, or can
be, factory-equipped with guards. If a vac-
uum pump or other motor-driven equip-
ment is ordered, be sure a belt guard is
part of the order.
Some equipment, such as dynainometer
rolls and rubber mills, is extremely hard to
properly guard. Sawhorses or ropes can be
used to enclose an area. Limit switches can
help safeguard rolls and mills, but proper
operator safety training is essential to pre-
vent serious accidents. SHEM Guide 35,
“Machine Guarding and the Use of Hand
Tools,” contains additional information on
machine guarding.
3.7.2 Hot Surfaces Safeguarding
Touching a surface that is 150°F (66°C)
may not cause a burn, but it will cause a
reflexive jerk of the hand away which may
cause it to strike something else. Because
of the possibility of personal injury or
damage to delicate equipment, any surface
at 150°F (66°C) or above should be
guarded against personal contact.
Above 200°F (93°C), the added hazard of
ignition of flammable materials exists.
Any surfaces reaching this temperature
should be guarded, not only against per-
sonal contact, but also against possible
exposure to chemical drips or spills.
In many cases, an adequate layer of insula-
tion will serve to prevent contact with a
hot surface. Steam lines and hot oil lines,
for example, must be insulated whenever
physical contact is possible.
3.7.3 Equipment Safeguarding
Reactors, stills, or other equipment operat-
ing at pressures or temperatures signifi-
canfly above or below ambient levels, or
containing hazardous materials, may
require shielding to protect laboratory
employees and property in the vicinity.
A self-supporting plastic shield is the min-
imum for bench-top work. It is required
for laboratory glassware under pressure or
vacuum, and for glassware containing:
• Corrosive chemicals
• Reactive chemicals
• Chemicals that can be absorbed
through the skin
• Unknown reactions
• Exothermic reactions
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The SHEMP Manager may prescribe a
steel barricade surrounding any metal
equipment that:
• Contains undefined reactions
• Contains exothermic reactions
• Operates at very high pressure
Whenever operating pressure will be
above 15 pounds per square inch, the
equipment must be inspected and ap-
proved in accordance with the American
Society of Mechanical Engineers (ASME)
Pressure Vessel Code.
Any equipment that contains radioactive
materials or that can produce ionizing radi-
ation must be installed and operated in
accordance with directions of the radiation
safety officer. Refer to Chapter C6 of this
manual for more information on radiation
safety.
3.8 Glassware Handling
Glass is strong during compression and
tension, but weak under bending stress.
Scratches, severe temperature changes,
seals between different types of glass or
poor annealing, can cause glass to break.
A large percentage of laboratory injuries
are due to glass cuts. Most cuts cause only
superficial injury but some glass cuts may
puncture blood vessels or sever tendons.
The following are some precautions for
use of glass under various conditions.
3.8.1 General Glassware Precautions
Use only the right size and type of glass-
ware for any given procedure and be sure
it is in good condition before use. Avoid
chipped, cracked, or scratched glass. Any
broken pieces of glassware should be dis-
carded in the proper container unless they
are sufficiently valuable to warrant repair.
Inspect all glassware to be used under
pressure or vacuum. Round-bottom flasks
used for vacuum distillations are a special
problem. This type of glassware frequently
gets scratched or cracked in handling, even
by letting one piece rub against another.
Examine and anneal any flasks or other
glassware to be used under pressure or
vacuum.
3.8.2 Glass Tubing
Pushing a glass tube into a rubber stopper
is one of the most common, yet most haz-
ardous, laboratory operations. Be sure the
tubing end has been fire-polished and both
the tubing and stopper are lubricated. If
heavy leather gloves are not readily avail-
able, wrap several layers of cloth around
the tubing and the stopper. Use the same
precautions for similar procedures with
any piece of glass tubing.
3.8.3 Glassware Under Pressure
Most laboratory glassware is dependable
only near atmospheric pressure. Certain
types of glass bottles or other glass vessels
have been used to carry out chemical reac-
tions at moderate pressures.
Minimum precautions to be followed
when using glassware under pressure in-
clude the following:
• Do not exceed the manufacturer’s rec-
ommendation for maximum working
pressure and temperature.
• Use only reactors designed to be safe
for the reactions occurring.
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• Discard any bottles subjected to hard
impacts or that have observable
scratches or other defects on the
surface.
• Ensure the reactor, when under pres-
sure, is inside a perforated metal
sleeve or similar protection.
• Use supplementary shielding, such as
a plastic half-cylinder, as additional
protection.
• Keep glassware under pressure behind
a shield or within a suitable guard.
Wear heavy gloves when handling or
reaching around any glass apparatus
that is under pressure.
Glass vials sealed with a flame are some-
times used as containers for chemicals or
samples. Heavy-walled glass tubes are
sometimes sealed and used as reaction
vessels. Excessive pressure, thermal
shock, mechanical shock, or faulty glass
in one of these vials can result in a violent
rupture.
Use extreme care to prevent such break-
age. Table shields or other devices must
be used to protect the laboratory employee
and others from the chemical contents of
the tube, glass fragments, and heating bath
liquid. Temperature should be raised and
lowered slowly, and a cushion should be
provided for protection against mechanical
shocks. Presented below are safe tempera-
tures for glass.
F2. General Work Practices
3.8.4 Glassware Under Vacuum
Vacuum or pressure operations need
approval from the SHEMP Manager if
the glassware to be used has more than
a two-liter capacity.
An implosion can scatter sharp-edged
glass fragments just as violently as an
explosion of a vessel. Ensure that any
glass equipment under vacuum pressure is
shielded or guarded as safely as pressur-
ized equipment.
Certain types of glass equipment, such as
heavy-walled filtration flasks, are made for
use under vacuum. Vacuum distillations in
glass should be performed only in round-
bottom flasks.
3.8.5 Glass Dewar Flasks and Vessels
Many double-walled vessels are used
throughout EPA laboratories to transport
or handle cryogenic materials. Because the
space between the two walls is a vacuum,
a possibility always exists for implosion.
A crack in the inner wall may allow the
cryogenic material to leak in between the
walls, causing a sudden expansion of gas
and possibly an explosion of the Dewar.
Many Dewars are encased in a metal
sheath to prevent physical shock. Smaller
Dewars are often unprotected and must be
wrapped in friction tape or other secure
Soft glass 230°F (110°C)
(lead alkali)
Borosilicate glass 700°F (370°C)
(Pyrex , kimax)
Quartz (VycorTM) 1690°F (900°C)
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binding and coated with a special plastic
dip, or encased in metal. Even when pro-
tected, Dewars must be handled carefully
to prevent breakage.
3.9 Syringe Handling
Clinical-type hypodermic syringes are fre-
quently used to:
• Measure and transfer small quantities
of fluid components
• Administer injections to animals
• Inject materials into instruments
• Withdraw liquids from vials or bottles
kept closed by rubber diaphragms or
septa
Syringes are available in various capaci-
ties. The needles, which range in length
from ‘4 inch to over 6 inches, are identi-
fied by gauge numbers. Techniques for
handling syringes and needles vary with
size and the liquid being handled, but the
following general rules always apply:
• Place an alcohol-moistened pledget
around the stopper and needle when a
syringe and needle is removed from a
rubber-stoppered vaccine bottle con-
taining infectious material.
• Use only needle-locking hypodermic
syringes.
• Always choose the shortest needle that
will serve the purpose, as shorter nee-
dles are less likely to bend or break.
• Vertically expel excess fluid and bub-
bles from syringes into disposable
cotton pledgets. Moisten cotton pledg-
ets with a disinfectant for use with
infectious materials. Do not hold a
needle vertically due to the potential
release of airborne contaminants.
• Reusable sharps, such as large-bore
needles and scalpels, must be stored in
a manner in which sharp ends are not
exposed.
• Reusable sharps may be stored in shal-
low pans as long as employees use
mechanical devices to retrieve them
from the pan.
3.9.1 Syringe Capacity
Never fill a syringe above its graduated
capacity. The extra length of the barrel is
necessary to guide the plunger during ejec-
tion of the fluid from the syringe. Without
this length of guide, the plunger may jam
and break the syringe barrel. The syringe
should not be more than half-filled with a
slurry containing solid particles.
3.9.2 Glass Syringes Under Pressure
The working limits for glass syringes vary
with diameter. Excessive force on the
plunger may cause the barrel to burst,
releasing toxic or corrosive material.
When syringes are used to inject materials
into instruments such as gas chromato-
graphs, stand to the side of the injection
port, not directly in front of it. Keep your
thumb on the end of the plunger through-
out the injection procedure. When the
syringe first enters the injection port, the
difference in temperature (especially for
very volatile compounds) tends to force
the plunger out of the syringe.
3.9.3 Temperature Extremes
Many syringes are made of soft glass, so
they may not withstand thermal shock.
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They should not be heated above 250°F
(120°C), nor should they be chilled or
heated suddenly.
3.9.4 Cleaning of Syringes
Wash a syringe immediately after each
use. Flush appropriate solvent such as
naphtha, alcohol, or acetone through the
ban el and over the plunger. Do not use
any abrasive material, either dry or in liq-
uid suspension. The soft glass may be
scratched, allowing the next fluid used to
squirt out the plunger end.
3.9.5 Disposal of Needles
When disposing of needles, place them in
puncture-resistant, closeable sharps con-
tainers. Disposable needles must be placed
directly into designated sharps containers
after use without recapping, shearing, clip-
ping, or breaking the tip. Always locate
sharps containers in the work area. In
cases where it is absolutely necessary to
recap needles (e.g., remote location where
no sharps containers are nearby), use some
type of device that protects the hand, or
use the one-handed recapping method.
If the sharp item was used with, or ex-
posed to, human blood or other potentially
infectious materials, the sharps container
must be color-coded red and labeled with
the universal biohazard symbol. Refer to
Chapter C7 of this manual for more infor-
mation on biosafety.
A]] waste needles and syringes must be
placed in puncture-resistant, closeable pu-
mary containers. Never place needles in
trash cans, glass bottles, or any container
that is not puncture-resistant. Refer to
Chapter C14 of this manual for more
information on sharps disposal.
3.10 Disinfection and Sterilization
Disinfection is an important procedure to
follow when handling any biohazardous or
toxic agents. Work surfaces used for
biohazardous agents must be disinfected
using an approved disinfectant after com-
pletion of the work, upon visible contami-
nation, after spills, or at the end of the
work day.
Inspect all bins, pails, cans, and similar
receptacles that have been in contact with
biohazardous agents. Check for contami-
nation and disinfect regularly or upon visi-
ble contamination.
3.10.1 Heat Sterilization
The application of heat, either moist or
dry, is recommended as the most effective
method of sterilization. Moist heat, or
steam, at 250°F (120°C) under pressure
(15 pounds per square inch) in the auto-
clave is the most convenient method of
rapidly achieving sterility. However, steril-
ity is not guaranteed by the machine
merely reaching this temperature, since
many variables can influence the effective-
ness of the autoclave.
Several factors affect the steam steriliza-
tion process including load size, distribu-
tion and compaction, altitude above sea
level, and heat penetration. The investiga-
tor or personnel responsible for steriliza-
tion may have to determine the appropriate
time at standard autoclave temperature and
pressure for certain loads of biohazardous
materials.
Therefore, the autoclave should be
monitored to ensure that the procedure
used results in full sterilization. Two
methods of monitoring exist, chemical
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and biological. Chemical, although ade-
quate for routine daily monitoring, is not
considered an acceptable method of test-
ing. Biological monitoring is done with
spores, usually Bacillus stearother-
mophilus, which can survive 250°F
(120°C) for 13 minutes. These microor-
ganisms are more resistant to temperature
than most and thus provide an adequate
safety margin when validating sterilization
procedures.
Laboratory employees should be cautious
because steam under pressure can be a
source of scalding jets if the equipment for
its application is mishandled. Loads of
manageable size should be used. Fluids
treated by steam under pressure may be
superheated if removed from the sterilizer
too promptly after treatment. This can
cause a sudden and violent boiling of the
contents from containers that can splash
scalding liquids onto personnel handling
the containers.
Dry heat at 160° to 170°C for periods of
two to four hours is suitable for destruc-
tion of viable agents on impermeable non-
organic material such as glass. However,
it is not reliable for even thin layers of
organic or inorganic material which can
act as insulation. In this case, incineration
kills microorganisms and serves as an effi-
cient means for disposal.
3.10.2 Radiation Sterilization
Ionizing radiation will destroy microorgan-
isms and has been used for sterilization,
however, it is not a practical tool for labo-
ratory use. Nonionizing radiation such as
ultraviolet radiation (UV), is a practical
method for inactivating viruses, myco-
plasma, bacteria and fungi. The non-
ionizing radiation is especially useful for
the destruction of airborne microorgan-
isms, the inactivation of microorganisms
on exposed surfaces, or the treatment of
products of unstable composition that can-
not be treated by conventional methods.
The usefulness of UV radiation as a sani-
tizer is limited by its low penetrating
power. Information is not available regard-
ing the effectiveness of 1W radiation for
inactivating microorganisms containing
recombinant DNA (rDNA) molecules, but
it is highly unlikely that increased resis-
tance to UV radiation is imparted to a cell
by the insertion of rDNA. UV radiation is
primarily useful in air locks, animal hold-
ing areas, ventilated cabinets and in labo-
ratory rooms during unoccupied periods to
reduce the levels of viable airborne micro-
organisms and to maintain good air hy-
giene.
The use of UV radiation carries the danger
of burns to the cornea and the skin if
exposed for even a short time. Proper
shielding should be maintained where irra-
diation treatment is used when personnel
and laboratory animals are present. Guard
against reflecting surfaces (e.g., polished
stainless steel) occurring in line with the
light source. in areas irradiated without
shielding on special occasions or during
off-duty hours, post the area with warning
signs to prevent unscheduled entry of
personnel. Refer to Chapter C6 of this
manual for more information on radiation
safety.
3.10.3 Liquid Disinfectants
In general, liquid disinfectants are most
practical for use in surface treatment and,
at sufficient concentration, as sterilants of
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liquid waste for final disposal in sanitary
sewerage systems. Liquid disinfectants are
effective in the test tube but may fall in a
practical situation. Failures often occur
because proper consideration was not
given to:
• Temperature
• Time of contact
pH
Concentration
• The presence and state of dispersion,
penetrability and reactivity
• The presence of organic material at the
site of application
Small variations in these factors may make
large differences in effectiveness of disin-
fection. For this reason, even when used
under highly favorable conditions, corn-
piele reliance should not be placed on liq-
uid disinfectants when the end result must
be sterility.
Selection
There are many liquid disinfectants avail-
able under a wide variety of trade names.
In general, these can be categorized as
halogens, acids or alkalies, heavy metal
salts, quatemary ammonium compounds,
phenolic compounds, aldehydes, ketones
alcohols, and amines. Unfortunately, the
more active disinfectants often possess
undesirable characteristics, such as corro-
sive properties. No type of liquid disinfec-
tant is equally useful or effective under all
conditions.
Laboratory personnel should be familiar
with the various disinfectants that will
effectively kill the biohazardous agents
being used. The following information is
provided to assist in the selection of
appropriate disinfectants such as: alcohols,
chlorine compounds, iodophors, phenolic
compounds, quarternary ammonium com-
pounds, and formaldehyde solutions.
Alcohols
Ethyl and isopropyl alcohol are good disin-
fectants for the vegetative forms of bacte-
ria and lipoviruses.
When used in a dilution of 70 to 95 per-
cent, ethyl alcohol effectively inactivates
vegetative bacteria and lipoviruses; has
variable results with inactivating non-
lipoviruses and is ineffective with inacti-
vating bacterial spores.
Some of its other characteristics include:
flammability, eye irritation, and toxicity
(threshold limit value [ TLV] of 1000 parts
per million [ ppm]).
Isopropyl alcohol has the same effective-
ness at inactivating biohazardous agents as
ethyl alcohol. However, its toxicity is
greater ( LV of 400 ppm).
Chlorine Compounds
The germicidal effect of chlorine com-
pounds is dependent upon the release of
hypochiorous acid and is therefore depend-
ent upon the available chlorine. A contact
time of 10 to 30 minutes should be
allowed.
A use-dilution of 500 ppm available chlo-
rine is recommended for vegetative bacte-
ria and most viruses. Chlorine solutions
that are neutral or slightly acidic, and with
a concentration of approximately 2,500
ppm chlorine, are needed for effectiveness
against bacterial spores. Undiluted com-
mon household bleach is alkaline with a
pH of 8 or greater. Household bleach
.
S
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typically contains 5.25 percent sodium
hypochlonte for 52,500 ppm of available
chlorine.
Chlorine compounds are corrosive to met-
als; leave a residue; irritate the skin, eyes,
and respiratory tract, and are toxic. They
are also rapidly inactivated by organic
matter. While chlorine compounds are not
generally reconunended for routine use,
undiluted household bleach is frequently
used with biological spills.
lodophors
The germicidal effect of iodophors is
dependent on the free iodine released
from the compound in which it is con-
tained. A contact time of 10 to 30
minutes should be allowed.
Use-dilutions can range from 25 to 1,600
ppm of available iodine, whereas solutions
containing 75 to 150 ppm are generally
recommended for use.
lodophors inactivate vegetative bacteria,
fungi, and viruses but have poor activity
against bacterial spores.
Although iodophors are less harmful to
man than chlorine compounds, they can
irritate the skin and eyes. lodophors are
corrosive (less than chlorine), they leave
a residue, and may stain. However, iodo-
phor stains can be readily removed with
solutions of sodium thiosulfate (e.g.,
Na 2 S 2 O 3 ). As with the chlorine com-
pounds, iodophors are rapidly inactivated
by organic matter. One advantage is that
iodophors have a built-in indicator. As
long as the solution is brown or yellow it
is still active.
Phenolic Compounds
These compounds are effective against
vegetative bacteria (including mycobacle-
rium tuberculosis), fungi, and lipoviruses.
Effectiveness against nonlipid viruses is
variable depending on the virus. However,
phenolic compounds are ineffective
against bacterial spores.
Use-dilutions of 1.0 to 5.0 percent, which
contain 0.5 to 2.0 percent phenol are effec-
tive against lipoviruses.
Phenolic compounds are corrosive and
may leave a sticky, gummy residue. They
are irritating to the skin and eyes and are
relatively toxic (e.g., TLV 5 is5 ppm).
Quaternary Ammoniwn Compounds
The efficiency of quaternaiy ammonium
compounds still generates considerable con-
troversy. They are effective in destroying
ordinai y vegetative bacteria and lipid- con-
taining viruses but are not effective against
pseudomonas, proteus and other gram-nega-
tive bacteria. Also, quatemary ammonium
compounds are not effective against bacte-
rial spores at the typical use concentrations
of 1 to 750 ppm. Use-dilutions of 0.1 to 2.0
percent aie recommended.
Quaternary ammonium compounds are
surface-active compounds that posses the
useful property of lowering the surface
tension of the solution. Other advantages
include being nontoxic, odorless, nonstain-
ing, noncorrosive to metals and stable. If
used at recommended concentrations, they
are nonirritating. Quaternary ammonium
compounds are rapidly inactivated by
organic matter.
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Formaldehyde Solutions
Formaldehyde in a 5 to 8 percent concen-
tration is an effective liquid decontaminant
that inactivates vegetative bacteria, bacte-
rial spores, lipid and nonlipid viruses and
fungi.
The odor, irritation to skin and eyes and
toxicity (e.g., TLV of 1.0 ppm) of formal-
dehyde solutions reduce its desirability for
general use. Fonnaldehyde solutions are
active in the presence of organic matter
and do not corrode metal.
Use of Disinfectants
Particular care should be observed when
handling concentrated stock solutions of
disinfectants. Personnel assigned the task
of making up use-concentrations from
stock solutions must be properly informed
as to the potential hazards and trained in
the safe procedures to follow. The concen-
trated quaternary and phenolic disinfec-
tants are particularly harmful to the eyes.
Even a small droplet splashed in the eyes
may cause blindness. Face shields and
goggles should be used for eye protection,
and long-sleeved garments and chemically
resistant gloves, aprons, and boots should
be worn to protect against corrosive and
depigmentation effects to the skin. One of
the initial sources for hazard information
on any given product is the label on the
container.
humidity, sterilization can be achieved.
Vapor and gas disinfectants are primarily
useful in sterilizing:
• Biological safety cabinets (BSCs) and
associated air-handling systems and
air filters
• Bulky or stationary equipment that
resists penetration by liquid
disinfectants
• Instruments and optics that might be
damaged by other sterilization
methods
3.11 Decontamination
Decontamination is the process of physi-
cally removing contaminants or changing
their chemical nature to innocuous sub-
stances. How extensive decontamination
must be depends on a number of factors,
the most important being the type of con-
taminants involved. The more harmful
the contaminant, the more extensive and
thorough decontamination must be. Less
harmful contaminants may require less
decontamination.
The objective of decontamination is not
only the protection of personnel and the
environment from exposure to hazardous
agents, but also the prevention of contami-
nation of experimental materials. This fac-
tor should also be considered in selecting
decontamination materials and methods.
3.10.4 Vapor and Gas Disinfectants
A variety and vapors and gases possess
germicidal properties. The most useful
of these are formaldehyde and ethylene
oxide. When these substances can be
used in closed systems and under con-
trolled conditions of temperature and
3.11.1 General Decontamination
Guidelines
Contaminants can be located either on
the surface of a material or permeated
into the material. Surface contaminants
may be easy to detect and remove;
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however, contaminants that have perme-
ated a material are difficult or impossible
to detect and remove.
Five major factors affect the extent of
permeation:
Contact time. The longer a contami-
nant is in contact with an object, the
greater the probability and extent of
permeation. For this reason, minimiz-
ing contact time is one of the most
important objectives of a decontami-
nation program. Additionally, if labo-
ratory personnel are splashed, make
every effort to remove the contamina-
tion as soon as possible.
• Concentration. Molecules migrate
from areas of high concentration
to areas of low concentration. As con-
centrations of hazardous materials in-
crease, the potential for permeation
increases.
• Temperature. An increase in tempera-
ture generally increases the perine-
ation rate of the contaminants.
• Size of contaminant molecules and
pore space. Permeation increases as
the contaminant molecule becomes
smaller, and as the pore space of the
material to be permeated increases.
• Physical state of hazardous materials
and wastes. As a rule, gases, vapors,
and low viscosity liquids tend to per-
meate more rapidly than high-viscos-
ity liquids or solids.
Decontamination methods vary in their
effectiveness for removing different sub-
stances. The effectiveness of any decon-
tamination method should be assessed at
the beginning of a program and periodi-
cally throughout the lifetime of the pro-
gram. If contaminated materials are not
being removed, the decontamination pro-
gram must be revised. The following
methods may be useful in assessing the
effectiveness of decontamination.
Visual Observations
There is no reliable test to immediately
determine how effective decontamination
is. in some cases, effectiveness can be esti-
mated by visual observation using natural
or ultraviolet light.
• Natural Light. Discolorations, stains,
bubbling, corrosive effects, visible
dirt, or alterations in clothing fabric
may indicate that contaminants have
not been removed. However, not all
contaminants leave visible traces;
many contaminants can permeate
clothing and are not easily observed.
• Ultraviolet light. Certain contami-
nants, such as polycyclic aromatic
hydrocarbons, which are common
in many refined oils and solvent
wastes, fluoresce and can be visually
detected when exposed to ultraviolet
light. Ultraviolet light can be used to
observe contamination of skin, cloth-
ing, and equipment; however, certain
areas of the skin may fluoresce natu-
raliy, thereby introducing an uncer-
tainty into the test. In addition, use of
i A
o rii June 1998
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SFIEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
ultraviolet light can increase the risk
of skin cancer and eye damage; there-
fore, a qualified health professional
should assess the benefits and risks
associated with ultraviolet light prior
to its use.
a less harmful substance. Especially trou-
blesome are mixtures from a variety of
known or unknown substances. The
appropriate decontamination solution
must be selected in consultation with
qualified experts.
Wipe Sampling
Wipe sampling provides after-the-fact
information on the effectiveness of decon-
tamination. In this procedure, a dry or wet
cloth, glass-fiber filter paper, or swab is
wiped over the surface of the potentially-
contaminated object and is then analyzed
in a laboratory. Both inner and outer layers
of protective clothing should be tested.
Skin may also be tested using wipe sam-
ples. Use of pH paper is a common
method for checking the “cleanliness”
of equipment that has been exposed to
corrosives.
Cleaning Solution Analysis
Another method used to test the effective-
ness of decontamination procedures is to
analyze the cleaning solutions. Elevated
levels of contaminants in the final rinse
solution may suggest that additional clean-
ing and rinsing are needed.
Decontamination Solution
Personal protective equipment, surfaces,
and laboratory equipment are usually
decontaminated by scrubbing with
detergent-water followed by rinsing
with a sufficient amount of water. While
this process may not be fully effective
in removing some contaminants (or in a
few cases, contaminants may react with
water), it is a relatively safe option com-
pared with using a chemical decontaininat-
ing solution. A decontamination chemical
is intended to change the contaminant into
It is important that decontamination per-
sonnel understand the potential hazards
of the contaminants, as well as any hazards
associated with cleaning equipment or spe-
cial decontamination solutions.
Common decontamination solutions
include aqueous solutions, usually 5 to
10 percent, of sodium carbonate, sodium
bicarbonate, trisodium phosphate, and
calcium hypochiorite.
Additional specialized decontaminants
or neutralizing agents that may be consid-
ered include: hexane, ethanol, acetone
and solvents such as 1,1,1-trichloroethane
for small items used in sampling; super-
tropical bleach (STh); DS2, a mixture
of diethylenetriamine (70%), ethylene gly-
col monmethyl ether (28%), and sodium
hydroxide (2%); sodium hydroxide (caus-
tic soda); chelating agents such as ETDA,
citric acid, tartaric acid and oxalic acid.
Biological contaminants have been decon-
taininated using: betapropiolactone (BPL);
formaldehyde solution; ethylene oxide-
fluorinated hydrocarbon mixture; peracetic
acid; and strong bleaches and caustics.
These decontaminants all require special
care in their handling and use. In addition,
many can degrade rubber products which
may be found on heavy equipment.
&EPft June 1998
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CHAPTER F
Work Practice Controls
F2. General Work Practices
311.2 Glassware Decontamination
Laboratories using chromic acid for clean-
ing laboratory glassware should begin to
abandon the practice due to limitations
on the concentration of chromium in
waste-water discharge and elevated costs
for proper treatment and disposal of the
spent cleaning product.
Laboratories should seek alternative glass-
ware cleaning solutions to meet their
needs. Glassware cleaning solutions that
do not contain chromium are readily avail-
able. Nochromixml mixed with sulfuric
acid is as effective as ChromergeiM in
removing trace metals and enzyme resi-
dues, but it eliminates the need for special
handling caused by the toxicity of
ChromergeTM. Purchasers of reagents and
chemicals for the affected laboratories
should determine if their suppliers can
provide such environmentally suitable
glassware cleaning agents.
As an alternative to a sulfuric acid bath,
a 95 percent ethanol/hydrochloric acid
bath or 95 percent ethanol/potassium
hydroxide bath can be used effectively
against organic residues. In cases where
it is imperative that glassware must be
cleaned using a solution containing chro-
mium, the spent cleaning reagent should
be classified as a hazardous waste.
3.11.3 Biological Decontamination
Figure F2-6 presents some general guide-
lines for performing biological decontami-
nation.
In addition to the general guidelines, per-
sonnel should observe the following pro-
cedures when performing decontamination
after a spill:
• Consider the use of impermeable
aprons/garments and boat covers if the
amount of contamination is
significant
• Clean up and remove all visible mate-
rial first, using disposable towels or
other means that prevents direct skin
contact with the blood or other poten-
tially infectious material (OPIM)
• Place soiled toweling immediately in a
leak-proof bag to prevent contamina-
tion of other surfaces
• Decontaminate the entire area with
clean towels and a 1:10 solution of
common household bleach and water
• Collect contaminated items (e.g.,
paper towels, gloves, etc.) when
decontamination is complete and
place into a labeled leak-proof bag
for disposal
The following sections discuss biological
decontamination of equipment; bins,
pails, and cans; and biosafety cabinets (in-
side and outside)
Decontamination of Equipment
Contaminated equipment should be
washed thoroughly with a 1:10 solution of
common household bleach and water.
Contaminated towels and waste must be
placed in a leak-proof bag for disposal.
Bins, Pails, Cans
All reusable receptacles (e.g., bins, pails,
cans) that have a reasonable likelihood
for becoming contaminated with blood
tk
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CHAPTER F
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F2. General Work Practices
-——U--
or OPIM, must be inspected and decon-
taminated on a regular basis. They should
be cleaned and decontaminated immedi-
ately, or as soon as feasible, upon visible
contamination.
All equipment and environmental surfaces
must be decontaminated after contact with
blood or OPIM at the end of a procedure
or work shift, if contamination may have
occurred.
Biohazard Spills inside BSCs
The occurrence of a spill in a BSC poses
less of a problem than a spill in an open
laboratory as long as the spilled material is
contained in the BSC. Decontamination of
the work zone can usually be effected by
direct application of concentrated liquid
disinfectants along with a thorough wipe
down procedure. Gaseous decontamination
may be required to clean up the interior
sections of the BSC.
Chemical decontamination procedures
should be initiated immediately while the
BSC continues to operate. Continuing the
operation of the BSC helps to prevent the
escape of’ containments from the cabinet.
While wearing protective gloves, spray
or wipe walls, work surfaces, and equip-
ment with an appropriate decontamination
solution. A disinfectant detergent, such
as Wescodyne or EnvironTM has the
Figure F2-6: General Guidelines for Biological Decontamination
Safety glasses
Prepare
for Decon Put on PPE —c Latex gloves
Pickup sharps r Remove all visible material
using mechnical -1— Prevent skin contact
L Wipe entire surface area with
Decon l:lOsolutionofbleachand
wa
Place soiled decon equipment
up in a leak-proof bag
Place soiled PPE in a leak-proof bag
Remove WE —E Remove gloves last
Wash hands
Complete
Decon
Remove
r Place soiled garments in a
—f leak-proof bag
‘— Launder work uniforms
aEPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F2. General Work Practices
advantage of detergent action on extrane-
ous organic substances that may interfere
with the microbicidal activity of the
disinfectant.
Flood the tray top, drain pans, and catch
basins below work surface with decontam-
inating solution and allow to stand for 20
minutes.
Drain excess decontamination solution
from the tray and drain pans into the cabi-
net base. Lift out the tray and the remov-
able exhaust grille work. Clean the top and
bottom (e.g., underside) surfaces using a
sponge or clean cloth soaked in decontam-
ination solution. Following the cleaning
process, replace the tray and exhaust grille
work in their proper position. Place gloves
and sponge or cloth in the autoclave pan
and autoclave these items.
Drain the decontaminating solution from
the cabinet base into an appropriate con-
miner and autoclave according to standard
procedures.
If gaseous decontamination of the cabi-
net’s interior sections is needed, call the
BSO or SHEMP Manager. Figure F2-7
presents a schematic of this process.
Biohazardous Spills Outside BSCs
The protocol to be used in cleaning up of
spills involving microorganisms will
depend on the amount of material spilled
and the degree of laboratory containment
required.
If individuals believe that their outer
garments have been contaminated, they
should remove their clothing in the labora-
tory area and place them in an autoclave
or a container for autoclaving. They
should change into a clean clothing in a
non-contaminated area. All laboratory
personnel should keep a complete change
of clothing, including shoes at the labora-
tory in case of spills.
Special care in decontamination may be
necessary if a spill goes under or between
fixed furniture or behind base moldings
(e.g., floor/wall), or if floor penetrations
are involved.
This procedure for minor spills of Class 2
Organisms is shown in Figure F2-8.
Minor Spills of CLass 2 Organisms
For minor spills (e.g., less than 10 millili-
ters and generating little aerosol) of Class
2 Organisms on equipment, laboratory
benches, walls, or floors perform the fol-
lowing:
• Warn all personnel not essential
for spill containment to stay clear
of the contaminated area. This may
be accomplished verbally or, when
appropriate, by posting warning
signs on the doors.
• Thoroughly wash hands and other
apparently contaminated areas with
soap and water. Put on clean dispos-
able gloves.
• Cover the spill area with paper towels
soaked in appropriate decontamination
solution.
• Wipe up the spill with the soaked
paper towels and place the used towels
in an autoclave pan. Autoclave the
used towels.
EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER F
Work Practice Controls
Figure F2-7: Chemical Decontamination of a BSC
Maintain BSC
Operation
4r
Put on PPE
‘I ,
I
F2. General Work Practices
Spray or wipe with
decon solution
1
Flood tray top, drain pans and
catch basins with decon solutio
4, 20 minutes
Drain decon solution into
BSC base
4,
I
Remove, clean and replace the —
exhaust grille work and the tray
I
+
Drain decon solution
into a container
;‘
-
Autoclave
Take off PPE
• Pour decontamination solution around
and on the area of the spill. Let it stand
for 20 minutes and then wipe it up
with paper towels. Place gloves and
paper towels in an autoclave pan and
then autoclave.
• Wash hands and other apparently con-
taminated areas again with soap and
water.
Major SpilLs of Class 2 Organisms
For major spills (e.g., more than 10 millili-
ters or with considerable aerosol) of Class
2 organisms in a laboratory, perform the
following:
• Close laboratory doors and post warn-
ing signs to prevent other employees
from entering the laboratory.
• Wash hands and other apparently con-
taniinated areas with soap and water.
• Report the accident to the laboratory
supervisor and to the SHEMP
Manager.
• If personal clothing is contaminated,
remove all outer clothing and place
it in an autoclave plan or other con-
miner for autoclaving. Put on clean
garments.
June 1998
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CHAPTER F
Work Practice Controls
Wa,b eoat.mlnatsd body part.
with seep sod wat.r
F2. General Work Practices
• Leave the laboratory for 20 minutes to
allow dissipation of aerosols created
by the spill.
• Upon returning to the laboratory to
start decontamination, check to see
if laboratory doors are closed and
appropriate signs are displayed. Put
on surgical gloves. Respirators or
other safety equipment may be
required, depending on the microor-
ganism involved. Check with the labo-
ratory supervisor or SHEMP Manager.
• Pour a decontamination solution
around the spill and allow this solution
to flow into the spill. Paper towels
soaked with decontamination solution
may be used to cover the area. Do
not pour decontamination solution
directly onto the spill to avoid addi-
tional release of aerosols.
• Let decontamination solution—
spill mixture stand for 20 minutes or
longer to allow adequate contact time.
• Using a dust pan and squeegee, irans-
fer all contaminated materials to a
deep autoclave pan, cover it with a
suitable cover, and autoclave accord-
ing to standard directions.
Figure F2-8: Spill Cleanup Procedure Outside BSCs—Minor Spills of Class 2
Organisms
+
Post warning to iboit a s
to epWsee n
+
Put on prutetfive gluw
aDd .sftty g-
+
Cover spill area with Psp*F towels
— ‘ In dr on .alodon
+
Wipe up spill with the paper towels
4 ,
Poar decon .oludon on and
— i
Wipe up spill with the paper towels
+
Ir ___
k ve — —
ill L 1I1If1WflJ J ImJ L
d
I
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls F2. General Work Practices
Place dust pan and squeegee in an Special care in decontamination must be
autoclave bag and autoclave according taken. The biosafety officer and/or the
to standard directions. SHEMP Manager may require the collec-
tion of sample cultures to determine that
• Remove gloves and other contarni- the area has been effectively decontami-
nated garments and place them in an nated. This procedure for major spills of
autoclave container for autoclaving. Class 2 and 3 organisms is shown in Fig-
ure F2-9. Refer to Chapter C7 for more
• Thoroughly wash hands, face, and information on biosafety.
other apparently contaminated areas.
Figure F2-9: Spill Cleanup Procedure for Outside BSCs—Major Spills of Class 2
and 3 Organisms
Wash contaminated body
parts with soap and water
Post warning to limit
access to spill area
- Put on PPE as required for the hazards
Reportspillto
SHEMP Manager
Remov: all contaminated Follow procedures for Minor Spills of
Place in autoclave container f
V
Put on clean garments
Leave the laboratory I
Verify that the lab door is closed j 2OnufluteS -
that warning signs are posted
&EPA June 1998 F2-30
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F3.
Work Practice Controls
for Chemicals
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SI-IEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F3. Work Practice Controls for Chemicals
1.0 Introduction
Among the many risks to worker safety
and health that arise through EPA
laboratory activities, chemical handling
operations, as well as the storage and
transportation of chemicals, represent key
areas of potential exposure. For any labo-
ratory activity in which chemicals are han-
dled or used, laboratory management must
recognize—and address—the risks associ-
ated with the physical and health hazards
of chemicals, including chemical incom-
patibilities. The mixing of incompatible
chemicals, for example, can result in sud-
den. violent and unforeseen hazards, and
may cause significant personal injury and
property damage.
This section outhnes the fundamental
approach to chemical work practice con-
trols through widely-recognized tech-
niques for minimizing risks associated
with receiving, distributing, storing,
transporting, and handling hazardous
chemicals. For example, microscale exper-
iments are being used by some EPA labo-
ratories as a method to reduce exposure
potential to hazardous chemicals.
These work practices, along with the
appropriate engineering controls and
personal protective equipment, should
be implemented by all EPA laboratories
to ensure a safe work environment.
• Work areas have been surveyed to
determine proper implementation of
work practice controls for chemicals.
• Employees have been trained in work
practice controls for chemicals.
• Facilities have been inspected to verify
appropriate storage for incompatibles.
• Regulatory requirements for transport
and disposal of chemicals are met.
Program Administration
The use of chemicals in the laboratory can
be effectively managed through the use of
work practice controls. Responsibilities
should be assigned to:
• Develop standard operating proce-
dures for the procurement and distri-
bution of hazardous chemicals in the
laboratory.
• Monitor general work practice con-
trols for chemicals.
• Train laboratory employees on the
proper use and handling of hazardous
chemicals, including corrosives,
flammables, toxics, reactives, and
compressed gases.
• Determine whether storage of hazard-
ous chemicals is appropriate and take
into account all special considerations
for incompatibility, flammability, and
peroxide formation.
EPA Program Requirements
To promote and ensure safe use and han-
dling of laboratory chemicals, each labora-
tory must ensure that:
Standard operating procedures for
chemical use and handling have been
developed and implemented.
• Verify that hazardous chemicals are
transported and disposed of according
to regulatory requirements.
&EPA June 1998
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F3. Work Practice Controls for Chemicals
2.0 Procurement and Distribution
Methods of procurement, receipt, and dis-
tribution of hazardous chemicals may vary
widely among different Laboratories, and
may be highly dependent on the size and
complexity of the organization, as well as
the degree to which its procurement sys-
tems are formalized.
However, every laboratory should estab-
lish a means by which chemical purchases
and deliveries can be reviewed and ap-
proved. A pre-purchase review, for exam-
ple, can be used to evaluate new hazards
introduced by procurement of a chemical
not previously used at the facility. A pre-
purchase review can also be used to mini-
mize the quantities of chemicals pur-
chased, thereby reducing the magnitude of
risk. Minimum quantities of chemicals,
consistent with normal laboratory needs
and requirements, should be maintained.
Before a substance is received, laboratory
management should ensure that informa-
tion on its proper handling, storage, and
disposal has been provided to those who
will handle the substance. A mechanism
should be established, through staff
responsible for receiving chemicals, to
ensure that no chemical container is
accepted without an adequate identifying
label or material safety data sheet (MSDS).
If the facility or individual users of chemi-
cals maintain a chemical inventory, new
chemicals should be entered in the inven-
tory at the time of chemical receipt.
This general procurement process is
shown in Figure F3- 1.
Figure F3-1: Chemical Procurement
and Distribution
Pre-Purchase Review
Receipt
‘I ,
Storage
‘J r
Use
‘Jr
— 1
3.0 General Work Practice Controls for
Chemicals
As with the control of other safety and
health hazards, control of chemical haz-
ards should adhere to the hierarchy of
control:
Engineering Conirols
Adminislrniivc Controls
Use of Personal
Protective Equipment
&EPPt June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls
F3. Work Practice Controls for Chemicals
Both health and physical risks associated
with hazardous chemicals need to be con-
sidered when establishing storage and han-
dling guidelines. For example, local
exhaust ventilation systems can be used to
prevent employee exposures to solvent
vapors, and to avoid the creation of flam-
mable or combustible atmospheres in the
work area. Physical and health hazards
unique to particular chemicals must also
be adequately controlled through specific
handling and storage methods selected
for the work site. In general, the use of
the smallest quantity of chemical neces-
sary can help control the magnitude of
chemical hazards.
Fundamental chemical hygiene practices
should also be observed to prevent
chemical ingestion, regardless of the
type and quantity of chemicals used in
the laboratory.
Refer to Chapter F2 for more information
on general work practice controls.
4.0 Chemical Use and Handling
Among the many tasks and operations per-
formed daily by laboratory employees,
those involving direct handling and/or
transport of hazardous chemicals pose the
greatest potential for exposure. Procedures
that may produce aerosols, including
particulates and mists as well as vapors
and gases, must be conducted in ways that
minimize the generation of air contami-
nants. Sound chemical-handling practices
also help minimize other forms of poten-
tial exposure (e.g., through the skin). The
following common laboratory chemical
operations are typically associated with
higher exposure iisk:
• Weighing, transferring, pouring,
siphoning
• Mixing, blending, shaking
• Stirring and vortexing
Even when mechanical methods are
employed to conduct these operations,
laboratory management and employees
must always anticipate the possibility of
mechanical failure, and be prepared for an
unexpected release of hazardous materials.
Specialized handling precautions and good
laboratory practices have been developed
for specific classes of chemical and physi-
cal hazards. The following guidelines
should be used in conjunction with infor-
mation on chemical and physical hazards
associated with hazardous chemicals used
at laboratory facilities. Chemicals of any
hazard class should be used only if the
quality of the available ventilation sys-
tem(s) is appropriate. Personal protective
equipment should be worn during all oper-
ations that require chemical handling.
Figure F3-2 presents a summary of the
major types of chemicals discussed in this
chapter.
4.1 Corrosives
The following controls and handling tech-
niques should be employed when handling
corrosives (acids and bases):
As applicable, wear appropriate per-
sonal protective clothing (e.g., acid-
resistant apron, chemical-resistant
gloves, splash goggles and face
shield).
June 1998
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SHEMP Operations Manual for Laboratories
Ci vr F
Work Practice Controls
F3. Work Practice Controls for Chemicals
Figure F3.2: Major Types of Chemicals Used and Handled at EPA Laboratories
• Conduct the procedure in a laboratory
fume hood.
• Use proper pouring techniques when
pouring acids into water.
• Perform all dilutions of corrosives in
a laboratory fume hoo4.
4.2 Flammables
The following controls and handling tech-
niques should be employed when handling
flammables:
• Keep flammable compound(s) away
from ignition sources, such as open
flame.
• Conduct procedure in a laboratory
fume hood, especially while transfer-
ring chemicals from one container to
another or heating chemicals in an
open container.
• Heat flammable substances in steam,
water, oil, hot air baths, or heating
mantle.
• When flammable liquids are trans-
ferred in metal equipment, minimize
generation of static sparks by using
bonding and grounding straps as
appropriate.
Flammable
• i I I
Major Types of
Chemicals
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CHAPTER F
Work Practice Controls
F3. Work Practice Controls for Chemicals
4.3 Toxics
If a less-toxic substance cannot be substi-
tuted, there are general safeguards avail-
able to provide protection:
• Check with other labs performing sim-
ilar research to investigate the proce-
dures and safety precautions they are
using.
• Have the needed toxic material trans-
ferred from other labs instead of pur-
chasing additional material.
• Always work with the smallest
amount of material possible.
• Label all containers with the chemical
name and warning of the material’s
potential hazards.
SHEM Guide 24, “Chemical Hygiene 1 ”
contains additional information on work-
ing with particularly hazardous substances.
In addition to these general safeguards,
below are specific recommendations for
personal protective equipment (PPE),
hoods, spills, and first aid.
4.3.1 Use of PPE
Appropriate PPE must be used, including
impervious gloves, safety glasses with
solid side shields, and a fully-fastened lab-
oratory coat or other protective clothing.
Double gloving is highly recommended
when working with toxic materials. This
involves wearing an inner glove of a par-
ticular material that is resistant to the
chemicals in use, and wearing an outer
pair of gloves of a different material that is
also impervious to the chemicals. This is a
good practice to use at all times, but is
particularly important when working with
highly toxic materials that are easily
absorbed through the skin.
4.3.2 Use of Fume Hoods
Work with toxic materials must be per-
formed in a chemical fume hood. Work
with the material should be performed at
least six inches into the hood. Before
beginning work, personnel must verify that
the hood has a current certification sticker
and is in good working condition. Jf any
problems with the operation of the hood is
noted, the SHEMP Manager must be con-
tacted immediately.
4.3.3 Toxic Material Spill Cleanup
In the event of a spill, the materials and the
area must be cleaned promptly. The materi-
als’ MSDS should be checked to verify use
of proper types of cleaning materials and
procedures. I.f any questions arise, the
SHEMP Manager should be contacted.
The used cleanup material must be safely
and promptly disposed of.
4.3.4 First Aid for Toxic Material
Exposure
Laboratory personnel should know not
only the toxicity of the material they are
working with, but also the first-aid proce-
dures needed in case of exposure. If an
antidote or special first-aid procedure is
required, it must be verified that the medi-
cal provider has the provisions available to
accommodate potential emergency needs.
Knowledge of the hazardous properties of
materials and proper response actions must
be communicated to anyone working in
areas where toxics are used.
0 ’EPA June 1998
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CHAPTER F
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F3. Work Practice Controls for Chemicals
4.3.5 Specific Examples of Toxic
Materials
The following sections present specific
work practice controls for use of such
toxic materials as dioxin, formaldehyde,
methylene chloride, polychiorinated
biphenyls (PCBs), and pesticides. Figure
F3-3 summarizes these toxic materials and
shows typical signs related to their use.
Dioxins
Dioxins must be handled as “particularly
hazardous substances,” as outlined in
SHEM Guide 24, “Chemical Hygiene.”
FormaLdehyde
For work with formaldehyde, in addition
to the general safeguards outlined above,
specific work practices must be followed.
A regulated area must be established for
any locations with formaldehyde concen-
trations exceeding the time-weighted aver-
age (TWA) or short-term exposure limit
(STEL). The regulated area must bear a
sign with the following information:
Methylene Chloride
A regulated area must also be established
for locations with methylene chloride con-
centrations exceeding the TWA or STEL.
The area must be marked with the appro-
priate hazard warning. Work must be
performed in a fume hood. Employees
must be trained specifically for work with
methylene chloride. The facility’s CHP
may contain additional information on
laboratory work with methylene chloride.
Figure F3-3: Typical Signage for Toxic
Materials
FORMALDEHYDE
I TTM(TAKD PO1Vfl*AI.
I CANCER HAZARD
PERQNNeL ORLY
I TOXIC —
LMATERIAL J
Work with formaldehyde must be per-
formed in a fume hood. Employees must
be trained specifically for work with
formaldehyde. The facility’s chemical
hygiene plan (CHP) may contain addi-
tional infonnation on laboratory work
with formaldehyde.
S, June 1998
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SHEMP Operations Manual for Laboratories
CHAFFER F
Work Practice Controls
F3. Work Practice Controls for Chemicals
Chloroform
During the use of chloroform, a hazard can
be presented by preserving chloroform
with alkenes. Spontaneous generation of
phosgene gas may occur. Laboratory per-
sonnel should not store chloroform in this
manner. In addition, all old alkene.
preserved chloroform bottles should be
tested for phosgene. When wetted with
five percent diphenylamine and five per-
cent dimethyl-aminobenzaldehyde, then
dried, filter paper strips turn yellow in
the presence of phosgene vapor.
Cyanide
Employees working with cyanide must
follow the safe work practices outlined in
the EPA Standard Operating Procedure
(SOP) for cyanide. Researchers perform-
ing cyanide analyses are required to read
the SOP and MSDSs of all materials
involved before beginning an analysis.
High levels of cyanide may be present in
some samples analyzed at EPA laborato-
ries, and it is possible for hydrogen cya-
nide and cyanogen chloride to be released
during analyses. Extreme care must be
taken when handling cyanide-containing
substances, as well as the reagents used in
sample preparation.
The work practices outhned below must be
followed when working with cyanide:
Medical surveillance. Any employee
working with cyanide must be
included in a medical surveillance
program, including a baseline
medical evaluation and an annual
exam thereafter.
• Training. All staff members working
with cyanide must be trained in car-
diopulmonary resuscitation (CPR).
Training must be documented and
updated each year.
• Labeling. Containers of cyanide
solutions or waste must be labeled
as containing cyanide. Solutions and
standards must be labeled with the
following:
— Cyanide
— Additional contents (list must be
specific)
— Hazard warnings
— Date of preparation
— Date of expiration
— Researcher’s initials
• Waste Disposal. Waste disposal must
be documented into an electronic
waste disposal documentation system
and a log book. Cyanide waste con-
tainers must have the following infor-
mation on the label:
— Cyanide
— Additional contents (list must be
specific)
— Physical state of the waste
— Accumulation start date
— The words “Hazardous Waste”
— Hazard warnings
— Name and address of the generator
• PPE. A fully-fastened laboratory coat,
gloves, and safety glasses must be
worn at all times when working with
cyanide solutions. All cyanide distilla-
tion procedures must be conducted
in the fume hood with the sash com-
pletely closed. Personnel who enter
the laboratory while cyanide analysis
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F3. Work Practice Controls for Chemicals
is being perfonned should be cau-
tioned that the analysis is taking place
and informed of the potential hazards.
Housekeeping. After an activity is
completed, all work areas must be
cleaned by disposing of any used and
unwanted materials and supplies.
Equipment, materials, and supplies
must be cleaned immediately after use
and returned to proper storage. Hands
must be washed prior to leaving the
laboratory, after analyses are
complete.
• Accidental Spills. In the case of an
accident involving cyanide, personnel
must notify the SHEMP Manager at
the laboratory as soon as possible. For
a major cyanide spill in the laboratory,
all personnel must immediately evacu-
ate the room, locking the doors on the
way out. The SHEMP Manager and
the fire department must be notified
immediately.
PCBs
hems containing PCBs must be marked
with the label:
For example, the following items must be
labeled:
• PCB containers
• PCB article containers
• Each storage area used to store PCBs
and PCB items for disposal
• PCB equipment containing PCBs
• PCB items containing PCBs in con-
centrations of 50 to 500 ppm
• Any chemical substance or mixture
that is manufactured and that contains
less than 500 ppm PCB
Laboratory personnel should always order
the lowest concentration required for PCB
research projects, since waste solutions are
characterized by their initial concentration
of the PCB, and PCB materials with a con-
centration of less than 50 ppm may be
characterized as excluded PCB product for
waste disposal purposes. PCB waste must
be transported off-site to an approved
waste management facility.
Pesticides
Pesticides should be handled as “particu-
larly hazardous substances,” as outlined in
SHEM Guide 24, “Chemical Hygiene.”
Handling procedures are as follows:
• Establish a designated area for pesti-
cide handling.
• Use containment and control devices
(e.g., fume hoods, secondary
containment).
• Use the smallest amount of pesticide-
containing material as possible.
• Provide training specialized for pesti-
cide handling.
• Use appropriate protective equipment
(absorption through skin is a primary
pesticide hazard).
• Wash hands and exposed areas imme-
diately after handling.
• Follow established equipment decon-
tamination procedures.
• Keep records of amounts of pesticides
stored and used; include dates and
names of users.
• Follow established procedures for safe
removal of contaminated waste.
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F3. Work Practice Controls for Chemicals
4.4 Reactives
A routine chemical reaction is one that
occurs at a slow reaction rate and can be
easily controlled. However, reactive chem-
icals can lead to reaction rates that differ
greatly. Such reactions can be initiated by
elevated temperatures, others by mechani-
cal shock or pressure. Many reactive
chemicals have little warning of shock
sensitivity, if any, on bottle labels. This
section presents work practice controls for
commonly used reactives, including
organic peroxides, perchioric acid, and
ether peroxides. However, there are others,
such as nitrates and persulfates, that can be
shock-sensitive. In addition, azide solu-
tions should NOT be poured down the
drain because they form shock-sensitive
salts on metallic plumbing systems.
Figure F3-4 presents a summary of the
reactive materials discussed here with
typical signage associated with their use.
4.4.1 Organic Peroxides
Organic peroxides have unusual stability
problems that make them among the most
hazardous of substances handled in the
laboratory. As a chemical class, these
materials are low-power explosives and
are hazardous because of their extreme
sensitivity to shock, sparks, heat, friction,
light, and strong oxidizing and reducing
agents.
Peroxides have a specific half-life, or rate
of decomposition, under any given set of
conditions. Before using a peroxide or
potential peroxide-forming material (i.e.,
ethyl ether, picric acid), personnel should
find out all they can about the material, its
hazards, and the conditions causing the
decomposition.
Work must be planned carefully so that
only small quantities of materials will
be used. A micro-reaction can yield ade-
quate information and product. In bulk
quantities, a material’s low rate of decom-
position may autoaccelerate and cause a
violent explosion.
Metal spatulas or metal containment pans
should not be used with organic peroxides,
because contamination by metals can lead
to explosive decomposition. Ceramic
implements and con-
tainment pans should
be used. Work should
be performed around
a good table shield
so that it is between
the employee and the
operation. A 0.25-inch-thick acrylic shield
is recommended for use with a maximum
5-gram quantity detonation. However, this
is not effective against metal shrapnel.
Figure F3-4: Typical Signage for Reac-
five Materials
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F3. Work Practice Controls for Chemicals
If more than a few grams of unstable mate-
rial must be handled, or if containment in
metal equipment is contemplated, a bath-
caded cell should be provided with opera-
tions conducted by remote control.
Appropriate PPE must always be used for
work with organic peroxides:
Long-sleeve, fully-fastened
laboratory coat
Protective gloves
Safety glasses with solid
sideshields
Face shield (preferably
with a snap-on throat
protector)
Apparatus that is easily controlled should
be used so that rapid elevations of temper-
ature or pressure are avoided. For exam-
ple, an oil bath heater with redundant
controls helps guarantee that the desired
temperature will not be exceeded.
Personnel must be alert to signs that an
operation is not going as expected and
be prepared to reduce the heat, quench
the reactants, or dump the contents—
usually into water.
Organic peroxides should be discarded if
their expiration dates have been reached,
even if they have been stored for less than
a year.
4.4.2 Perchioric Acid
Some analytical procedures involve treat-
ing residues with perchioric acid. This acid
is a powerful oxidizing agent that may
react explosively with reducing agents and
organic compounds. Because this reagent
combines with oil and other combustibles
to form explosive perchiorates, the work
must be done in a special perchioric acid
fume hood equipped with wash-down
facilities to remove the water-soluble
materials from all contacted surfaces. if
work with these materials is anticipated,
the SHEMP Manager must be contacted so
that proper safety precautions can be
taken.
Strong oxidizing agents should be stored
and used in glass containers. Corks or rub-
ber stoppers should not be used. Primary
containers should be kept on glass or
ceramic trays that have enough volume to
hold all the material in the container
should it break.
4.43 Ether Peroxides
Diethyl ether, isopropyl ether, dioxane,
and many other common laboratory mate-
rials can form explosive peroxides when
stored or evaporated in the presence of air.
Although ethers can be tested for the pres-
ence of peroxides, which can be removed
by proper treatment, preventing peroxide
formation is the preferred method of
control. Peroxide-forming materials are
listed in three categories in Table F3-l.
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Table F3-1: Peroxide Formation Potential
F3. Work Practice Controls for Chemicals
The lists are broken down by the manner
in which the peroxides are fonned. When
any material listed in category A or B of
this table is purchased, each container
must be labeled with the date of receipt. If
a peroxide analysis is obtained, the result
should also be entered on each container.
Unopened cans or bottles should be dis-
carded one year after receipt.
Upon opening a can or bottle, the date
opened must be entered on the label. All
containers must be discarded six months
after opening. All containers of doubtful
history or condition should be discarded.
Crystals seen in ether may be peroxides.
Laboratory personnel must not agitate the
container or loosen the cap. The SHEMP
Manager should be contacted for assis-
tance with disposal.
Ether solutions should not be evaporated
or distilled to dryness. Ten percent of the
volume should be left in the container. An
air stream should never be used to evapo-
rate or agitate ether—nitrogen must be
used carefully. A table shield should be
used for protection when evaporating or
distilling ether or other materials noted in
Table F3-1. A long-sleeved laboratory
coat, protective gloves, safety glasses with
solid sideshields, and a face shield (prefer-
ably with a snap-on throat protector) must
be worn at all times when handling these
materials.
4.5 Compressed Gases
Compressed gases may present a unique,
simultaneous mechanical and chemical
hazard. Release of flammable gases pres-
ents the danger of fire or explosion. Haz-
ards can arise from the reactivity and
toxicity of certain gases. Also, asphyxia-
tion may occur by high concentrations of
released gases; even those considered
“harmless,” such as nitrogen. The amount
of potential energy resulting from vessel
pressure can cause the additional hazard
presented by a cylinder “torpedo.”
Category A
Category B
‘ Category C
Peroxides may form in storage
Perox.ides may form during
concentration
Peroxides may form during
polymerization
Isopropyl ether
Divinyl acetylene
Vinylidene chloride
Potassium metal
Sodium amide
Diethyl ether
Tetrahydrofuran
Dioxane
Glyme
Vinyl ethers
Dicyclopentadiene
Diacetylene
Methyl acetylene
Methyl methacrylate
Styrene
Acrylic acid
Acrylonin i1e
Vinylidene chloride
Tetrafluoroethylenc
Vinyl acetylene
Chiorotrifluoroethylene
Vinyl acetate
Vinyl chloride
Vinyl pyridine
hloroprene
Decahydronaphthalene
Tetrahydronapthalene
Cyc lohexane
Diglyme
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F3. Work Practice Controls for Chemicals
This section provides a summary of some
work practice controls for use of all com-
pressed gas cylinders as well as informa-
tion on specific types.
4.5.1 Storage, Handling and
Inspection
Work practices for storage, handling, and
inspection of compressed gases are pre-
sented in the following sections.
Storage
Compressed gas cylinders must be stored
away from excessive heat and at least
20 feet away from highly combustible
materials. They must be stored in a
secured area where they cannot be dam-
aged or knocked over by passing or falling
objects. All cylinders in use and being
stored must be secured to a fixed structure.
Suitable restraining devices must be sup-
plied in all storage locations.
If stored inside, the cylinders must be in a
well-protected, ventilated, and dry loca-
tion. Only minimum prac-
tical quantities of com-
pressed gases should be
kept and used inside build-
ings. It is preferable to
store cylinders in suitable
outdoor storage areas.
Storage locations should
be assigned by class of
material, as well as
whether the cylinder is full
or empty. Unless the cylin-
der is in use, the valve cap must be on both
full and empty cylinders at all times.
Handling
Compressed gas cylinders must be moved
using a hand cart, with a chain to secure
the cylinder. During transport, the steel
safety cap must be attached to the top of
the cylinder to prevent the valve from be-
ing snapped off if the cylinder is dropped.
When changing gas cylinders, the safety
cap must remain in place until the new
cylinder is secured. A safety cap must be
snugly screwed onto old cylinders before
moving them. An old regulator must never
be used for a new application. Gases per-
fuse the metal in the regulators. A new gas
used in an old regulator may react with the
old gas as it passes through the regulator.
This may cause an explosion. Regulators
should always be used for the same appli-
cation, or changed upon new application.
inspection
Visual inspections must be performed to
determine that compressed gas cylinders
are in a safe condition. The threading and
airways on both the cylinder and regulator
should be checked for damage and cleanli-
ness. The tubing should be checked for
leaks and corrosion. The hydro-test date of
the cylinder (stamped on the neck) should
be checked to ensure the date is within the
last five years. Inspections must be con-
ducted as per U.S. Department of Trans-
portation (DOT) regulations, 49 CFR parts
171-179 and 14 CFR part 103. In addition,
Compressed Gas Association Pamphlets
C-6-1968 and C-8-1962 must be consulted
for inspection procedures.
Leak detection is an important component
of cylinder inspection. Most leaks will
occur at the top of the cylinder in areas
such as valve threads, regulator, valve
stem, and valve outlet. A flammable-gas
leak detector or soapy water (or other suit-
able solution) should be used for leak
detection. Laboratory staff must never
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F3. Work Practice Controls for Chemicals
attempt to repair a leak at the valve threads
or regulator. The supplier must be con-
sulted for instruction, if a leak is detected
and cannot be remedied by tightening the
valve or a packing nut, emergency action
procedures should be followed.
A leak of minimum size can often be han-
dled without serious personnel exposure. If
it is necessary to move a leaking cylinder
through populated portions of the building,
a plastic bag or rubber-type shroud should
be placed over the top and taped to confine
the leaking gas. The procedures shown in
Table F3-2 must then be followed based
on gas type.
If the leak constitutes a more serious haz-
ard, self-contained breathing apparatus
or protective apparel (or both) may be
required. Basic action for large or uncon-
trolled leaks may include any of the fol-
lowing steps:
• Evacuation
• Rescue of injured personnel by crews
equipped with adequate personal pro-
lective apparel and breathing apparatus
• Fire-fighting action
• Emergency repair
• Decontamination
Table K3-2: Procedures for Leaking Cylinders Based on Gas Type
- - - -‘ -. -
Typé - . Prucedur • - - -
Inert, or
Gases
Move the cylinder to an isolated area away from combustible material.
Post signs that describe the hazards and state warnings.
Gases
Move the cylinder to an isolated, well-ventilated area.
Use suitable means to direct the gas into an apprepriate chemical
neutralizer.
Post signs that describe the hazards and state warnings.
Note: The size of the leak may increase as the gases are released.
Gases
Move the cylinder to an isolated, well-ventilated area.
Use suitable means to direct the gas into an appropriate chemical
neutralizer.
Post signs that describe the hazards and state warnings.
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F3. Work Practice Controls for Chemicals
The facility must be prepared for any of
these actions. Guidelines for controlling
and handling compressed gases are sum-
marized in Table F3-3.
4.5.2 Examples of Compressed Gases
and Gas Generators
Safety considerations for some common
types of gases and gas generators (e.g.,
ciyogenics, ozone and hydrogen genera-
tors) are discussed in the following sec-
tions.
C,yogenics
Cryogenic fluids are liquefied gases that
boil at 212°F (100°C) or below. They are
shipped and stored at low pressures in
special insulated vessels. Liquid nitrogen
and liquid oxygen are commonly used in
the laboratory as sources of gas and also as
low-temperature cooling media. Liquid
hydrogen and liquid helium are also avail-
able for specialized laboratory operations.
Table F3-4 lists the most commonly used
cryogenic materials and their respective
boiling points.
Table K3-3: Guidelines for Controlling and Handling Compressed Gases
Use
Regulatory requirements of 29 CFR 1910 Subparts H-M must be met.
Construction
Cylinders must be constructed, charged, shipped and maintained in accor-
dance with DOT specifications and regulations in 49 CFR and OSHA specifi-
cations in 29 CFR 1910.101 through 169, Subparts H-M.
Size and number
Depends on system size, room size, construction, ventilation, cylinder con-
tents, and availability of fire suppression mechanisms.
Maximum cubic feet
A single flammable gas or oxygen cylinder must be 220 cubic feeL
Table 8-2 of NFPA Standard No.45 defines the number of cylinders allowed
in the laboratory (typically 6 cylinders in a sprinidered space and 3 cylinders
in a non-sprinklered space).
Inspection
EPA laboratories must verify the safe condition of compressed gas cylinders.
Visual inspections must be performed pursuant to DOT Hazardous Materials
Regulations (49 CFR 171-179).
Where DOT requirements do not apply, guidance in CGA pamphlets
C-I -1968 and C-8.1962 should be followed.
flandling/storage/use
Guidance provided in CGA Pamphlet P-1-1965 must be used.
Ventilation rates
Must be sufficient to prevent gas concentration from reaching the lower
explosive limit (LEL) resulting from the leakage of one cylinder.
Pressure relief devices
Must be installed and maintained in accordance with CGA Pamphlets
S-1.l-1963 with 1965 Addenda, and S-1.2-1963.
Supply lines
Must be securely fastened or anchored every five feet for high-pressure
cylinders.
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F3. Work Practice Controls for Chemicals
Table F3-5: Boiling Points for
Commonly Used Cryogens
Cryogen
Boiling Point
Oxygen
-290°F (-1 83°C)
Nitrogen
-32°F (-196°C)
Hydrogen
-423°F (-253°C)
Helium
-452°F (-269°C)
As with gas cylinders, containers of cryo-
genic materials must be clearly marked as
to their contents. For example:
_Hi
I HYDROGEN I
FLAMMABLE GASI
NOSMO aNG OR OPEN FLAME )
K G
The primary hazards of cryogenic materi-
als are:
• Fire or explosion
• Pressure buildup
• Embrittlement of structural materials
• Destruction of living tissue
• Asphyxiation
‘Fire
Each are described in the following
sections.
• Fire or Explosion. Fire or explosion is
of concern when gases such as oxygen
are used. Enriched oxygen will greatly
increase the flammability of ordinary
combustible materials. Noncombusti-
ble materials may even be caused to
burn readily in the presence of oxygen.
Oxygen-saturated wood has been
known toli y explode when
subjected to shock.
• Pressure Buildup. When cryogenic
materials are maintained in pressure
vessels, adequate ventilation and pres-
sure relief must be provided. First,
there is the experimental volume,
which could be any space with the
experimental device immersed in the
cryogen within which cryogenic fluid
could leak and later cause excess pres-
sure when the system is warmed up.
Next is the bath space, or the space
above and including the cryogenic
fluid. This too must be vented. Last is
the vacuum space, which must be
independently provided with pressure
relief. If a cryogenic fluid is leaking
into a vacuum space, no problems will
arise as long as the cold fluid is pres-
ent. However, when the cryogenic fluid
is withdrawn, the air or gas that has
leaked in can expand, and blow up the
vacuum space by imploding in the
inner vessel.
• Enzbrittlement of Structural Materials.
Embnttlement is a situation where the
gas/liquid being stored actually pene-
trates the material of the cylinder or
other container, which can cause a cat-
astrophic failure of the vessel.
• Destruction of Living Tissue. Even
very brief skin contact with a cryogenic
liquid can cause tissue destruction sim-
ilar to that of thermal burns. Prolonged
skin contact can result in blood clots
that have potentially serious conse-
quences. For this reason, gloves that
are impermeable to the fluid being han-
died and loose enough to be tossed off
easily must be worn when working
with cryogenic materials.
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F3. Work Practice Controls for Chemicals
If cryogenic materials are dispensed
from one cylinder into any other con-
tainer, gloves and a face shield must be
used and remain at the site of dispens-
ing, if the cryogen is piped directly into
an instrument or apparatus, the gloves
and face shield must be in the immedi-
ate vicinity (within the same room).
Asphyxiation. Cryogenic fluids
released or spilled in a confined area
can rapidly alter the air composition by
displacement or contamination. Thus,
an asphyxiating or toxic risk is intro-
duced.
Massive amounts of nitrogen, helium,
carbon dioxide, or other inert gases can
displace oxygen and asphyxiate people
or animals.
Fire. A spill of any cryogenic material
boils rapidly and releases very large
volumes of the material into the atmo-
sphere, oxygen can cause combustible
materials to burn violently or explode.
Before working with cryogens, read mate-
rial on safe handling and discuss the haz-
ards and proper procedures with your
supervisor. Refer to Chapter F2 for general
work practice controls when using Dewars
to hold and transport cryogens.
Ozone Generators
Ozone generators have two principal
hazards:
• The toxicity of ozone
• The high voltages required in the
process
Ozone should be released only in a hood
and should never be sniffed or breathed.
The detectable odor level is substantially
higher than the concentration acceptable
for breathing. Therefore, if it can be
smelled, the concentration breathed is too
high. The gas should be connected to the
apparatus consuming it before the current
is turned on.
All cabinet parts and shields must be kept
in place when the generator is energized.
Before any interior adjustments are made,
disconnect the power source and ground of
all parts (especially condensers and vac-
uum tubes), before touching any terminals
or other metal parts.
Some ozone compounds are unstable; ele-
vated concentrations should be avoided
and quantities in the experiment should be
kept as small as possible. A table shield
should be used for protection. Ozonides
formed at low temperatures may be unsta-
ble at room temperature. Therefore, such
materials must be kept behind a shield or
other protection.
CRYOGEN SAFETY
DO:
• Wear proper eye and hand protection.
• Work with adequate room ventilation.
• Handle cryogenic fluid containers with
great care.
• Keep vents open.
• Watch for a blue color indicating
condensed oxygen.
DON’T:
• Shake cryogenic liquid containers, as it
stimulates boiling.
• Bump containers.
• Touch cold fittings or lines without gloves.
• Vaporize large quantities of cryogenic
liquid in a closed room
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F3. Work Practice Controls for Chemicals
Ozone may react violently with organic
materials such as rubber and plastic. All
materials used in an apparatus must be
acceptable for ozone use and thoroughly
degreased before introducing ozone flow.
Hydrogen Generators
Electrolytic cells used to generate hydro-
gen for chromatography are substantially
safer than having a hydrogen cylinder in
the room. However, one hazard involves
the presence of hydrogen possibly mixed
with air or oxygen, particularly at startup
or during other unstable conditions.
Ignition sources must be kept away from
hydrogen generators or vent locations. The
manufacturer’s directions should be read
carefully before installing or servicing a
hydrogen generator. Only the electrolyte
specified or furnished by the manufacturer
should be used and replaced according to
the instructions.
For more information on hazard-specific
controls, refer to Chapter D5.
This section provides information on the
storage of incompatible flammable and
peroxide-fonrnng chemicals, as shown in
Figure F3-6.
Figure F3-6: Storage of Incompatible,
Flammable, and Peroxide-Forming
Chemicals
5.0 Chemical Storage
Chemicals in storage should be protected
to preclude leaks, spills, and other forms
of physical damage (e.g., earthquakes and
fire). For this reason, storage on benchtops
and in hoods should be avoided. Spill
trays, spill- and shatter-proof containers,
secondary containers, and proper recepta-
cles should be used as needed. To ensure
that chemicals do not deteriorate while
stored, they should be properly identified
and labeled with date of receipt, opening.
and expiration; expired chemicals should
be disposed of as soon as possible. Chemi-
cals should also be stored away from
direct sunlight and high-heat sources.
Water-reactive chemicals should not be
stored in storage areas that have sprinklers.
When incompatible chemicals are mixed,
whether inadvertently during a chemical
manipulation or accidentally in storage,
they can react to form compounds or other
chemicals, with an attendant consumption
or generation of energy. The end-products
or byproducts themselves may be hazard-
ous, or the magnitude of energy generated
by the mixture may be destructive. A fire,
for example, will produce not only light
and heat, but also toxic combustion prod-
ucts. Whenever generation of light. heat,
or pressure occurs in excessive magnitude,
or with excessive speed, an explosion or
fire can result, and the effects can be cata-
strophic. Even reactions that generate an
innocuous gas or vapor warrant concern,
5.1 Incompatible Chemicals
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F3. Work Practice Controls for Chemicals
since significant amounts can displace the
available oxygen in an enclosed area and
create an oxygen-deficient environment.
To minimize the risks associaS with
chemical incompatibility, the laboratory
should establish a segregation scheme for
chemicals in storage to ensure that acci-
dental breakage, leaks, or other destruction
of chemical containers do not result if they
should react with incompatible materials.
Sources such as the chemical incompati-
bility table (refer to Attachment F3-l),
MSDSs, and other references should be
consulted for guidance. In addition, some
chemical manufacturers color-code their
labels according to compatibility to help
chemical users readily segregate sub-
stances appropriately.
At a minimum, laboratories should segre-
gate acids, bases, oxidizers, and flammable
chemicals from one another. Also, chemi-
cals should not be stored alphabetically
unless they belong to one segregation
class.
5.2 Flammable Chemicals
Numerous guidelines, including the
National Fire Protection Association’s
(NFPA) Standard 45 for laboratories, pro-
vide guidance on the storage and handling
of flammable liquids. In general, prudent
storage practices include the following:
• flammable liquids (flashpoint less than
1000 F) must be stored away from heat
and ignition sources.
• Flammable liquids in large quantities
should be stored in metal safety cans.
The cans should be used only as rec-
ommended by the manufacturer.
• Users should:
— Never disable the spring-loaded
closure.
— Always keep the flame arrestor
screen in place.
— Replace the flame arrestor if it is
punctured or damaged.
• if a reagent must be stored in glass for
purity, the glass container may be
placed in a bottle carrier to lessen the
danger of breakage.
• Small quantities (working amounts) of
flammable chemicals may be stored on
open shelves.
Flammable chemi- __________
cats must be stored —
in flammable-liquid F LAM
storage cabinets that KEEP F
have been approved
by Factory Mutual
and/or listed by
Underwriters Labo-
ratory and designed
in accordance with
NFPA Code No. 30. The following
safety practices should be observed:
— Store only compatible materials
inside a cabinet.
S
4
MASLE
?E AWAY
SE P /k June 1998
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SHEMP Operations Manual for Laboratories
C mi F
Work Practice Controls
F3. Work Practice Controls for Chemicals
— Do not store paper, cardboard, or
other combustible packaging mate-
rial in a flammable-liquid storage
cabinet.
— Do not overload cabinets; follow
manufacturers’ established quantity
limits.
— Follow NFPA guidelines for maxi-
mum allowable volumes.
• Do not store flammables in areas
exposed to direct sunlight.
• The quantities of flammable chemicals
stored in laboratories should be kept to
a minimum.
53 Peroxide-Forming Chemicals
If stored or handled improperly, chemicals
that can form peroxides may be explosive.
The following guidelines should be
observed if these chemicals are stored in
the laboratory or elsewhere:
• Label peroxide-forming chemicals with
the date they were opened.
• Store peroxide-forming chemicals
away from heat sources and light.
• Do not use metal containers since some
metal oxides can promote the forma-
tion of peroxides.
• Use proper antioxidant inhibitors.
[ Note: The inhibitor may be consumed
with time, making the compound again
sensitive to peroxidation.J
• Test peroxide-forming chemicals for
peroxides every three months using test
paper strips (dietheyl and diisopropyl
ether should be tested on a monthly
basis). if the test is positive, the mate-
rial must be treated to remove the per-
oxides, or it must be discarded.
6.0 Transportation of Chemicals
Below are some guidelines for transporting
chemicals:
• Whenever chemicals are transported
outside the laboratory, the container
should be placed in a secondary, non-
breakable container.
• Carts should be used when possible.
• Before moving containers, check and
tighten caps, taps, or other enclosures.
• Personnel at the destination area should
be informed of the transport.
7.0 Chemical Waste Disposal
Disposing of wastes (including dyes and
stains) through laboratory sinks and drains
is absolutely prohibited at EPA laboratory
facilities. All waste is handled through the
EPA Waste Management Program. Only
biohazardous and general laboratory waste
is treated on-site. All waste regulated by
the Resource Conservation and Recovery
Act (RCRA) is sent off-site for recycling,
fuel blending, or incineration.
All chemical waste generated at the EPA
laboratory facilities must be submitted
with the appropriate paperwork into the
waste management program. The SHEMP
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER F
Work Practice Controls F3. Work Practice Controls for Chemicals
Manager will review the EPA Form 435
and any additional paperwork and will
determine if the waste is RCRA-regulated
or non-regulated waste. Based on this
determination, the SHEMP Manager will
make arrangements for appropriate
disposal. Refer to Chapter C14 of this
manual for specific guidelines on waste
management.
EPA June 1998 F3-20
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SHEMP Operations Manual for Laboratories
CHAPTER F
Attachment F3-1: Incompatibility Table
Purpose: To provide a list of chemicals that could cause hazardous reactions due to
incompatibility.
Instructions: Substances in the right-hand column should be stored and handled so they
cannot possibly accidentally contact corresponding substances in the left-hand
column. The following list contains some of the chemicals commonly found in
laboratories, but it should not be considered complete.
&EPA June 1998 F3-21
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SHEMP Operations Manual for Laboratories
CHAPTER F
Attachment F3- 1: Incompatibility Table
Alkaline and alkaline earth metals,
such as sodium,
potassium, cesium, lithium, mag-
nesium, calcium
Carbon dioxide, carbon tetrachloride and other chlorinated hydrocar-
bons, any free acid or halogen (Do not use water, foam or dry chemical
on fires involving these metals)
Acetic annhydride
Chromic acid, nitric acid, hydroxyl-containing compounds, ethylene
glycol, perchioric acid, peroxdes, and permanganates
Acetone
Concentrated nitric and sulfuric acid
mixture
Acetylene
Copper, silver, mercury, and halogens
Aluminum alkyls
Halogenated hydrocarbons, water
Ammonia (anhydrous)
Silver, mercury, chlorine, calcium hypochionte, iodine, bromine,
hydrogen fluoride, chlorine dioxide
Ammoniuni nitrate
Acids, metal powders, flammable liquids, chiorates, nitrates, sulfur,
finely divided organics or combustibles
Aniline
Nitric acid, hydrogen peroxide
Benzoyl peroxide
Chloroform, organic materials
Bromine
Ammonia, acetylene, butadiene, butane and other petroleum gases,
sodium carbide, turpentine, benzene, and finely divided materials
Calcium carbide
Water (see also acetylene)
Calcium hypochlorite
Methyl carbitol, phenol, glycerol, niiromethane, iron oxide, ammonia,
activated carbon
Calcium oxide
Water
Carbon, activated
Calcium hypochiorite
Chiorates
Ammonium salts, acids, metal powders, sulfur, finely divided organics
or combustibles
Chlorine
Ammonia, acetylene, butadiene, butane and other petroleum gases,
hydrogen, sodium carbide, turpentine, benzene, and finely
divided metals
Chlorine dioxide
Ammonia, methane, phosphine, and hydrogen sulfide
Chiorosulfonic acid
Organic materials, water, powdered metals
Chromic acid
Acetic acid, naphthaleue, camphor, glycerine, turpentine, alcohol and
other flammable liquids, paper or cellulose
Copper
Acetylene, hydrogen peroxide, ethylene oxide
Cumene hydroperoxide
Acids (organic or mineral)
&EPA June 1998 F3-22
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SHEMP Operations Manual for Laboratories
C u’mR F
Attachment F3-1: Incompatibility Table
Ethylene oxide
Acids, bases, copper, magnesium
perchiorate
Fluorine
Almost all oxidizable substances
Hydrocyanic acid
Nitric acid, alkalis
Hydrogen peroxide
Copper, chromium, iron, most metals or their salts, any flammable
liquid, combustible materials, aniline, nitromethane
Hydrides
Water, air, caibon dioxide, chlorinated hydrocarbons
Hydrofluoric acid, anhydrous (by-
drogen fluoride)
Ammonia (anhydrous or aqueous), organic peroxides
Hydrogen sulfide
Fuming nitric acid, oxidizing gases
Hydrocarbons (benzene, butane,
propane, gasoline, turpentine, etc.)
Fluoride, chlorine, bromine, chroinic acid, sodium peroxide, fuming
nitric acid
Hydroxylaniiuc
Barium oxide, lead dioxide, phosphorus pentachioride and trichloride,
zinc, potassium dichromate
Iodine
Acetylene, ammonia (anhydrous or aqueous)
Maleic anhydride
Sodium hydroxide. pyridine and other tertiary amines
Mercury
Acetylene, fulminic acid, ammonia, oxalic acid
Nitrates
Acids, metal powders, flammable liquids, chlorates, sulfur, finely
divided organics or combustibles
Nitric acid (concentrated)
Acetic acid, aniline, chromic acid, hydrocyanic acid, hydrogen sulfide,
flammable liquids, flammable gases, nitratable substances, organic
peroxides, chlorates
Nitroparaffins
Inorganic bases
Oxygen
Oil, grease, hydrogen, flammable liquids, solids or gases
Oxalic acid
SilveT, mercury, organic peroxides
Perchlorates
Acids
Perchloric acid
Acetic anhydride, bismuth and its alloys, alcohol, paper, wood, grease,
oil, organic amines or antioxidants
Peroxides, organic
Acids (organic or mineral); avoid friction
Phosphorus (white)
Air, oxygen
Phospohorus pentoxide
Propargyl alcohol
Potassium chlorate
Acids (see also chiorates)
Potassium perchlorate
Acids (see also perchioric acid)
ERA June 1998 F3-23
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SHEMP Operations Manual for Laboratories
CHAPTER F
Attachment fl-i: Incompatibility Table
Potassium permanganate
Glycerine, ethylene glycot, benzaldehyde, any free acid
Silver
Acetylene, oxalic acid, lartaric acid, fulnunic acid, ainmonium
compounds
Sodium
See alkaLine metals
Sodium azide
Air, water
Sodium nitrite
Ammonium nitrate and other anunonium salts
Sodium oxide
Water, any free acid
Sodium peroxide
Any oxidizable substance, such as ethanol, methanol, glacial acetic
acid, acetic anhydride, benzaldehyde, carbon disulfide, glycerine,
ethylene glycol, ethyl acetate, methyl acetate and furfural
Sulfuric acid
Chiorates, perchiorates, permanganates, organic perioxides
UDMH
Oxidizing agents such as hydrogen peroxide and fuming nitric acid
Zirconium
Water, carbon tetrachlonde, foam and dry chemical or zirconium fire
extinguishers
q ,EPA June 1998 F3-24
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G. Laboratory Emergency Management
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Gi.
Introduction
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SHEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management
Gi. Introduction
‘This chapter addresses the programs, principles, and methods of emergency management
used to protect a laboratory’s employees, property, and equipment. Specific aspects of
laboratory emergency management described include planning for emergencies, emergency
action, and incident investigation and analysis.
The U.S. Federal Property Management Regulations (FPMR) require the U.S. General
Services Administration (GSA) to assist each EPA laboratory in developing and maintaining
an Occupant Emergency Program (OEP). This program is intended to provide procedures for
safeguarding lives and property during emergencies in federal facilities such as EPA
laboratories. After an incident occurs at an EPA laboratory, an investigation must be
performed to gather evidence. This information is critical in determining the root cause of
the incident in order to prevent further occurrences.
This chapter provides guidance to EPA laboratories on emergency management in the
following chapters:
Chapter Topic
G2
G3
04
Emergency Planning
Emergency Action
Investigation and Analysis
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Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
1.0 Introduction
EPA laboratories must prepare and imple-
ment an emergency action plan. However,
there are benefits to going beyond compli-
ance to mitigate potential consequences
of an evolving emergency situation. Using
a risk-based approach to emergency
response planning results in technical
focus and cost-effectiveness.
In using a risk-based approach, laborato-
ries should perform hazard assessments to
identify all hazards and events that present
of risk of fatalities, injuries, property dam-
age, and/or business interruption. From a
cost-benefit standpoint, resources must
first be allocated to address the risks with
a high probability of occurrence. Conse-
quence analysis is performed in conjunc-
tion with hazard identification to help
determine the impact of a risk (e.g.,
on-site or off-site).
Hazard assessments provide a basis for
investing resources in equipment and pro-
grains. Such an approach can be used in
laboratories to lay the foundation for com-
prehensive planning and implementation.
Chapter B of this manual discusses risk
analysis techniques. This chapter includes
planning and prevention measures for
potential EPA laboratory emergencies.
• Prepare and train staff for potential
laboratory emergencies
• Ensure that emergency medical treat-
ment is available
• Provide employees with emergency
response notification information
• Implement emergency prevention
techniques
• Ensure that adequate means of egress
is provided
Program Administrolion
To effectively manage emergency situa-
tions, responsibilities should be assigned
for:
• Developing the emergency response
program with the command center
team.
• Designating floor team coordinators,
damage control coordinators, and
technical advisors.
• Assessing laboratory hazards that
may affect emergency planning and
response.
• Training laboratory staff in emer-
gency response techniques, evacua-
tion procedures, first aid, and
cardio-pulmonary resuscitation
(CPR), as appropriate.
EPA Program Requirements
To ensure that EPA laboratories properly
prepare for emergencies, they must:
• Assist the command center team in
program development
• Assess laboratory-specific hazards that
may affect emergency planning and
response
• Posting emergency notification infor-
mation and evacuation routes.
• Performing a head count of laboratory
personnel upon evacuation.
• Implementing emergency prevention
measures.
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CHAPTER 0
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
2.0 Regulatory Requirements
OR
All EPA laboratories must comply with
applicable federal, state, and local require-
ments for emergency planning, response,
investigation and follow-up. The following
sections summarize these requirements.
2.1 GSA
The U.S. General Services Administration
(GSA) is the agency responsible for ensur-
ing the safety and security of all occupants
of federally owned or leased facilities. The
Federal Property Management Regulations
(FPMR) in Part 101-20, “Management of
Buildings and Grounds,” require GSA to
assist the federal agencies that occupy
these facilities in establishing and main-
taining an Occupant Emergency Program.
This program is defined by FPMR as “a
short-term emergency response guide that
establishes procedures for safeguarding
lives and property during emergencies in
particular facilities.”
2.2 OSHA
The U.S. Occupational Safety and Health
Administration (OSHA) has established
various fire prevention standards and
emergency procedures to provide indus-
tries with a mechanism to maintain a safe
and healthful working environment for
employees. Emergency action and fire
prevention plans described in 29 CFR
1910.38 (a) and (b), respectively must
be prepared:
If required by a particular OSHA Stan-
dard (e.g., 29 CFR 19 10.157, Portable
Fire Extinguishers)
• Where facilities provide fire
extinguishers that are not intended for
employee use, specifically:
— A facility providing portable fire
extinguishers for employee use
in fighting incipient-stage fires
is required to have an emergency
action plan but is not required to
have a fire prevention plan.
— A facility providing portable
fire extinguishers for selected
employee use in fighting incipient
stage fires must have an emer-
gency action plan, but is not
required to have a fire prevention
plan.
— A facility equipped with portable
fire extinguishers but requiring
total evacuation of all employees
in an emergency must have an
emergency action plan and a fire
prevention plan.
Fire prevention plans and emergency
action plans each must have certain
elements. The plan must be written,
except for those employers with 10 or
fewer employees. In that case, the plan
may be communicated orally. The require-
ment for a written employee emergency
action or fire prevention plan is based on
the number of employees that are physi-
cally in a facility at any time of the work-
ing day and not on the number of employ-
ees that are employed.
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CHAPTER G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
23 EPA
There are several federal statutes and
implementing regulations that require
reporting of releases to the environment.
A release into the environment is generally
The term “environment” is also defined
very broadly and generally includes all
navigable and other surface waters, land-
surface or subsurface waters, ground-
waters, drinking water supplies, land
surface or subsurface strata, and ambient
air. Reporting of releases under CERCLA,
EPCRA. CWA, and/or RCRA depends on
the substance and quantity re’eased to the
environment. Different federal and state
agencies must also need to be contacted,
depending on the substance and quantity
released. in addition, the facility’s air
permit(s) and water discharge permit(s)
may specify release-reporting require-
ments (generally, if there are releases
or emissions in excess of permit limita-
tions, these exceedances must be reported
to the appropriate state regulatory
authorities).
The environmental regulations applicable
to emergency response notification are in
Table G2-1.
Table G2-1: Environmental Regulations for Emergency Response
En fronmenta1 Standard
.,
40 CFR 110
Oil into navigable waters
40 CFR 280
Petroleum and hazardous substances from underground storage tanks
40 CFR 302
Hazardous substances into the environment
40 CFR 355
Hazardous substances and extremeLy hazardous substances into the
environment
40 CFR 60
Air emissions regulated under New Source Performance Standards
40 CFR 61
Air emissions regulated under National Emission Standards for Hazard-
ous Air Pollutants
40 CFR 63
Air emissions regulated under National Emission Standards for Hazard-
ous Air Pollutants for Source Categories
Facility Air Permit
Air emissions
Facility Wastewater Discharge
Permits
Wastewater to surface water or municipal treatment plant
defined as any:
Spilling
• Leaking
• Pumping
• Pouring
• Emitting
• Emptying
• Discharging
• Injecting
• Escaping
• Leaching
• Dumping
• Disposing
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CHAPTER G
Laboratory Emergency Management
02. Administration of Laboratory Emergencies
EPA laboratories and facilities are less
likely to be subject to 40 CFR 60,61,
and 63, but in some cases, certain require-
ments may apply. More detailed discus-
sions of these requirements are discussed
in Chapter C.
2.4 NFPA
The principle industry standard that
applies to the fire safety of laboratories
is the National Fire Protection Association
(NFPA) Standard No. 45, “Standard on
Fire Protection for Laboratories Using
Chemicals.” It addresses such topics as
laboratory unit design and construction,
fire and explosion hazard protection,
laboratory ventilating systems, chemical
storage and handling, and waste disposal.
Other more general NFPA standards also
apply, such as those listed in Table 02-2.
NFPA 101 establishes minimum require-
ments that will provide a reasonable
degree of public safety from fire in
buildings and other structures. The code
addresses those construction, protection,
and occupancy features necessary to mini-
mize danger from fire, smoke, fumes, or
panic. NFPA 101 also identifies the mini-
mum criteria for design of egress facilities
to allow prompt escape of occupants from
buildings or, where desirable, into safe
areas within the building.
3.0 Content of the Emergency Plan
The occupant emergency plan (OEP)
contains emergency information such as
telephone numbers; facility information
such as number and layout of occupants;
the emergency organization; and response
guidance for specific emergencies.
Table G2-2: Summary of Generally
Applicable NFPA Standards
NFPA
Standard
THIe
10
Standard for Portable Fire
Extinguishers
13
Standard for the Installation of
Sprinkler Systems
45
Standard on Fire Protection for
Laboratories Using Chemicals
101
Life Safety Code
A comprehensive list of emergency
information that should be considered
and addressed, as appropriate, is pre-
sented in Attachment 02-1. Each labora-
tory should review this list and select
areas to address that are relevant to their
operations. If a laboratory determines that
disaster recovery planning is needed to
ensure business continuity, the information
in the OEP can be adapted to address
events that could result in downtime
(e.g., electrical outage, ventilation system
failure, etc).
3.1 Emergency Organization
A chain-of-command structure is used for
the coordination of emergency response
procedures. This organization typically
consists of a command center team, floor
teams, and damage control teams as shown
in Figure G2-l. Duties of organization
members should be clear to provide for
efficient response. The team sizes should
be limited to the minimum number needed
to respond, as too many people may get in
the way and inhibit efficiency. Titles and
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management
02. Administration of Laboratory Emergencies
telephone numbers for members of the
organization must be included in the plan
and posted as appropriate.
3.1.1 The Command Center Team
Emergency operations are directed by
the command center team from the
laboratory’s command center. The
team will generally have the following
members:
• Designated Official
• Emergency Coordinator
• Floor Team Coordinator(s)
• Damage Control Coordinator
• Medical Coordinator
• Advisor(s)
For small laboratories, some people may
fulfill more than one duty. Team members
must have quick access to the command
center and be available for emergency
notification. Laboratories that are typically
a unit of a facility must have direct contact
with the command center, as well as input
into the emergency plan. Laboratory per-
sonnel may also serve as team members.
The following sections summarize the
responsibilities of the command center
team members.
Designated Official
The Designated Official is usually the
team member who develops the emer-
gency plan and coordinates with facility
occupants. Laboratory management
should work with the Designated Official
to ensure that emergency plans are consis-
tent with laboratory activities and occu-
pants. The Designated Official will ensure
that appropriate procedures are followed
during a response. Any appropriate notifi-
cations to federal, state, and local agencies
are made by the Designated Official.
Figure G2-1: Typical Chain-of-Command Structure
Designated Official
Emergency Coordinator
1
Floor Team
Coordinator
Damage Control
Coordinator
Floor Teams
Medical
Coordinator
Technical
Advisors
Damage Control
Teams
1
Medical Services
and First Aid/
CPR Teams
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Laboratory Emergency Management
-- - 02. Administration of Laboratory Emergencies
Emergency Coordinator
The Emergency Coordinator acts as a
direct assistant to the Designated Official
and fulfills primary responsibilities in the
Designated Official’s absence. The Emer-
gency Coordinator will also typically act
as a liaison between the Designated Offi-
cial and other team members.
Floor Team Coordinator
The Floor Team Coordinator facilitates
occupant movement during an emergency.
Areas that floor teams are responsible for
include:
• Wings
• Floors
• Stairwells
• Elevators
• Alternative routes for people request-
ing assistance
Damage Control Coordinator
The Damage Control Coordinator is
responsible for emergency response
equipment and affected systems,
including:
• Utilities
• Alarms
• Communication systems
Medical Coordinator
The Medical Coordinator identifies and
communicates with medical services. This
coordinator is also responsible for first aid
equipment and medical training, such as
cardiopulmonary resuscitation (CPR) and
first aid. Typically, the Medical Coordina-
tor will maintain lists of all medically
trained personnel.
Adv&cors
Advisors typically consist of the Building
Manager, a Security Specialist, and any
other occupants who may be familiar with
the building’s utilities and mechanical
systems. These advisors may have primary
responsibilities such as shutting down
mechanical systems during certain types
of emergencies.
3.2 Laboratory-Specific Infonnation
In order to prepare an emergency plan,
specific information about the laboratory
must be provided. This information
includes:
• Laboratory operations
• Description of the physical area
• Prevailing weather conditions
• Potential laboratory hazards
• Natural hazards
For EPA laboratories, it is essential to
share all operations and potential hazards
with emergency coordinators to facilitate
a response in all situations. This can be
accomplished through the use of signage
on laboratory doors that states the emer-
gency contacts, types of hazardous materi-
als in the laboratory, and information on
local alarms. An example of such a form
is presented in Attachment G2-2. This
information, in addition to facility plans
and material safety data sheets (MSDSs)
for hazardous chemicals, should be main-
mined at the command center or security
office.
&EPA June 1998
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CHu’ml G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
3.3 Preparation for Typical
Emergencies
In an EPA laboratory, a variety of emer-
gency situations could occur. This chapter
discusses the preparation for fires, chemi-
cal spills and releases, medical emergen-
cies, bomb incidents, evacuation, radiation
emergencies, biological emergencies,
emergencies involving animals.
33.1 Fires
The potential for fire and/or
explosion is always present at
any laboratory. While the prob-
ability and consequences asso-
ciated with such events may
vary as a function of laboratory design and
operations, steps can be taken to minimize
potential losses.
All occupants must know locations of fire
alarm boxes and extinguishers, how to use
them, and procedures to follow in the
event of an alann. They should also be
familiar with notification procedures when
they pull an alarm, so the command center
team can be activated.
3.3.2 Chemical Spills and
Releases
To adequately prepare for
the unlikely event of a chemical spill or
release, EPA laboratories must assess
potential spill and release scenarios and
have appropriate absorption, containment,
and neutralization equipment available.
Employees must be trained in both appro-
priate response techniques for incidental
spills and in response measures and notifi-
cation for larger releases.
In the event of a non-incidental spill,
employees are required to evacuate the
laboratory (based on laboratory-specific
Emergency Action Plans). Where
employees are trained for response to
non-incidental releases, the laboratory
must develop programs in accordance
with OSHA’s standard on hazardous
waste operations and emergency response
in 29 CFR 1910.120.
333 Medical
Emergencies
Policies for providing emer-
gency medical treatment
should be integrated with the
EPA laboratory facility’s Emergency
Action Plan. Arrangements should be
made in advance for emergency transpor-
tation to, and treatment at, a nearby medi-
cal facility. In addition, local emergency
transport and hospital personnel should
be educated about possible medical prob-
lems that could occur at the facility,
including the types of hazards and their
consequences, potential for exposure, and
the scope and function of the medical pro-
grain. Providing medical facilities with
MSDSs and protocols involving hazard-
ous materials is an effective means of
informing medical personnel of potential
emergencies.
Employees should be aware of all person-
nel trained to respond to medical emergen-
cies (e.g., first aid, CPR). They must also
be familiar with command center team
notification procedures. If available,
on-site medical support staff can usually
provide immediate medical attention.
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CHAPTER G
Laboratory Emergency Management
G2. Adininistrationof Laboratory Emergencies
f 33.4 Bomb Emergencies
Each EPA laboratory must
develop bomb incident proce-
dures as part of their overall
emergency plan. By establish-
ing a laboratory-specific bomb incident
plan and training employees on the proper
procedures, EPA laboratories can reduce
the potential for:
• Death or significant injuries to EPA
staff, customers or the public
• Physical or environmental damage
• Business interruption
• Damage to the agency and the
laboratory’s public image or
financial standing
Employees must be trained to immediately
report a suspicious object. Appropriate
search teams and disposal units can then
be notified. Occupants should be prepared
for evacuation when a suspicious object is
reported.
3.3.5 Evacuation
in planning for a timely and
efficient evacuation in case
of an emergency, a suitable
means of egress should be
carefully considered and
addressed. Egress can be defined as a con-
tinuous path of travel from any point in
a building or structure to the open air out-
side at ground level. Considerations
for safe egress include:
• The type, width, number, access,
and arrangement of exits
• Lighting and identification of exits
• Travel distance to exits
• Exit capacity
There are several primary considerations
in the design or assessment of means of
egress. Every section or area of a labora-
tory should have at least two separate
means of egress arranged so that the possi-
bility of any fire blocking both of them is
minimized. In planning for building evacu-
ation, the following requirements set forth
in NFPA No. 101 should be met:
A sufficient number of unobstructed
exits of adequate capacity and proper
design, with convenient access
• Protection of exits against fire and
smoke during the length of time they
are designed to be in use
• Alternate exit(s) for use in the event
that a primary exit is blocked by fire
• Subdivision of areas and construction
to provide areas of refuge in those
occupancies where evacuation is the
last resort
• Protection of vertical openings to limit
fire effects to a single floor
• Alarm systems to alert occupants and
notify the fire department
• Adequate lighting of, and paths of
travel to, exits
• Signs indicating the direction of travel
to reach exits
• Safeguarding of equipment and areas
of unusual hazard (e.g., flammable
liquid storage areas) that could pro-
duce a fire capable of endangering the
safety of persons exiting
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Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
• Exit drill procedures to ensure orderly
exit
• Control of psychological factors
conducive to panic
• Control of interior design to prevent
a fast-spreading fire that could trap
occupants
Specific facility requirements concerning
means of egress depend on the particular
occupancy. Attachment G2-3 provides a
partial listing of general requirements.
Each EPA laboratory should assess and
implement laboratory-specific require-
ments as described in NFPA No. 101.
/ \\ 3.3.6 Radiation
Emergencies
, Every EPA laboratory that
uses radioactive materials or
radiation-generating devices
should have procedures for responding to
associated emergencies such as:
• Spills (non-incidental and incidental)
• Staff exposure
• Staff contamination
Based on the specific radiation hazard
in the laboratory, staff must understand
their role in responding to a radiation
emergency. For example, if there is an
incidental spill of radioactive materials,
laboratory staff who are trained in moni-
toring and decontamination techniques
may handle the spill without additional
outside assistance.
1 3.3.7 Biological
Emergencies
¼ 1 Biological emergencies
1 OHAZARp ) can involve dermal contact
with spills of biohazardous
agents, inhalation of aerosols, ingestion
of bio-hazards, accidental injection or
inoculation, and release of an agent to
the environment. Laboratories should
be prepared to respond to biological
emergencies that are likely due to the
types of experimental procedures that
are being performed. This not only
includes emergency response procedures
and training staff on their implementation,
but also having adequate biological spill
cleanup equipment.
3.3.8 Emergencies
InvoMng Animals
In the event of an emergency
in a laboratory animal facility,
response personnel should
notify the animal manager or
veterinarian responsible for the animals.
Emergency notification procedures for
responsible staff, including their names
and telephone numbers, should be posted
in prominent locations in the animal facil-
ity and provided to security as part of the
emergency action plan. In addition, emer-
gency procedures for handling animals
with special hazards (e.g., chemical carcin-
ogens, radioactive materials, infectious
agents) should be prominently posted.
4.0 Emergency Prevention
The preferred practice is to prevent
all types of emergencies. Prevention is
achieved through proper planning, train-
ing, and the practices outlined in the fol-
lowing sections for:
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CHAPTER G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
• Utility service interruption
• Fires
• Chemical spills and releases
• Medical emergencies
• Bomb emergencies
• Radiation emergencies
• Biological emergencies
4.1 Utility Service Interruption
Interruption of utility service to a labora-
tory can cause major problems. An
interruption can be caused by storms,
earthquakes, vandalism, maintenance
outages, and equipment breakdowns.
Each laboratory must have a comprehen-
sive plan that outlines its response to a
loss of utilities. If the loss does not create
an emergency, it will render the labora-
tory more vulnerable to an emergency situ-
ation. Therefore, a utility interruption con-
tingency plan should be included as part of
a laboratory’s emergency action plan.
EPA laboratories must have a tested
backup power source with automatic
changeover equipment that is sufficient
to preserve the integrity of the testing
experiment. Emergency power must
support those critical areas such as animal
rooms, inhalation chambers, heating,
ventilation and air-conditioning (HVAC)
systems, storage freezers/refrigerators,
etc. Essential mechanical equipment must
be guarded or alarmed. In addition, provi-
sions for prompt maintenance response
must be made. Alternative air-handling
systems for inhalation studies are also
required.
4.1.1 Functions of an Emergency
Power Generator System
All emergency equipment must be
equipped with auxiliary backup power.
Exit signs, lighting, evacuation alarms,
and other emergency equipment must not
be disabled at a time when they will be
needed. Frequent operational checks must
be conducted where backup batteries are
used to ensure a constant state of readi-
ness. If a system-wide backup generator
is used, it must be designed to provide
power immediately. In addition, equip-
ment to be used by emergency personnel
must be immediately available in the
event of a power outage.
Employee exposure-control apparatus
must also be kept operating during a
power outage. Air-moving and air-
cleaning devices critical to personal
safety and health must be equipped
with backup power. In addition, if the
effectiveness of the ventilation system
may be compromised by a power outage,
the rate at which air contaminants are gen-
erated must be minimized.
If auxiliary power is used to maintain
the ventilation system, the characteristics
of the system running on auxiliary power
must be evaluated (e.g., by checking
pressure gauges). Any change in air
flow between rooms, or in any operational
parameter of the ventilation system, must
be recognized. The impact of these
changes on the safety and health of labora-
tory personnel must also be assessed.
For example, if during a power failure
the laboratory ventilation is supported
by an emergency generator, but the hood
system is not, the air balance in the room
may be compromised by the loss of the
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Laboratory Emergency Management
02. Administration of Laboratory Emergencies
exhaust provided by the hood. If the hood
system was providing most of the exhaust,
then the laboratory may become positive in
relation to the clean corridor and may
contaminate it.
Laboratories should provide auxiliary
power to ensure the integrity of experi-
ments in progress. The effect of power
interruption on dose administration and
environmental control must be known
and controlled. Backup power must be
provided to refrigerated areas, and a con-
tinuous source of power must be supplied
to computers.
Any interruption of utilities may have
adverse consequences that place a facility,
its employees, and the surrounding com-
munity at an elevated risk. In addition, the
substantial investment in ongoing experi-
ments may be placed in jeopardy. It is the
responsibility of EPA laboratories to
foresee these consequences and to make
adequate preparations to minimize them.
to resolve them. The inspection checklist,
in Attachment G4-2, provides a guide for
fire-safe practices that should be followed.
Material hazards should be identified,
as evident on the specific MSDSs, and
labeled on containers as soon as they
arrive in the laboratory. The identification
system should be Consistent with the labora-
tory’s hazard communication
program.
4.2.1 Material Storage and Handling
The storage of material should be arranged
such that adequate clearance is maintained
away from heating surfaces, air ducts,
heaters, flue pipes, and lighting fixtures.
All storage containers or areas should
prominently display signs to identify the
material stored within. Storage of chemi-
cals should be separated from other mate-
rials in storage, from handling operations,
and from incompatible materials. All indi-
vidual containers should be identified as to
their contents.
4.1.2 Maintenance and Testing
At EPA laboratories, all emergency power
systems must be placed on a maintenance
program. The maintenance program should
include testing emergency equipment (e.g.,
generators, batteries, etc.) at regular peri-
ods as recommended by the manufacturer
or engineering department. This testing
program should be documented and
described in a formal plan.
4.2 Fires
This section discusses two steps involved
in fire prevention: identifying existing fire
hazards in the workplace and taking action
Only containers designed, constructed, and
tested in accordance with the U.S. Depart-
ment of Transportation (DOT) specifica-
tions and regulations are to be used for
storage of compressed or liquefied gases.
Compressed gas storage rooms should be
areas reserved exclusively for that purpose
with good ventilation and at least a one-
hour fire resistance rating. The gas cylin-
ders must be secured in place and stored
away from any heat or ignition source.
Pressurized gas cylinders shall never be
used without pressure regulators. For
more information on work practice con-
trols for chemicals, refer to Chapter F3
of this manual.
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CHAPTER G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
Combustible Materials
Wooden pallets must not be stacked over
six feet high. If feasible, extra pallets
should be stored outside or in separate
buildings to reduce the risk of fire hazards.
Piles of combustible materials must be
stored away from buildings and apart from
each other to prevent the spread of fire,
and to provide room for firefighters.
Flammable Materials
Bulk quantities of flammable liquids must
be stored outdoors and away from build-
ings. Smaller quantities are then brought
into a mixing room where they are pre-
pared for use. The mixing room must
be located next to an outside wall equip-
ped with explosion-relief vents, if neces-
sary. The room must also have sufficient
mechanical ventilation to prevent the accu-
mulation of flammable vapor concentra-
tions in the explosive range. Flammable
liquids must never be transferred from one
container to another by applying air pres-
sure to the original container. Pressurizing
such containers may cause them to rupture,
creating a serious flammable liquid spill.
Quantities must be limited to an amount
necessary to perform an operation for one
working shift, and must be stored in, and
dispensed from, approved safety contain-
ers equip-ped with vapor-tight, self-clos-
ing caps, screens, or covers.
The storage and use areas should include
fire-resistant separations, automatic sprin-
klers, special ventilation, separation of
incompatible materials, and the separation
of flammable materials from other materi-
als, as appropriate.
4.2.2 Potential Ignition Sources
The following precautions can be taken to
eliminate potential ignition sources:
• Use classified electrical equipment in
accordance with Article 500 of the
National Electrical Code
• Provide grounding and bonding in ac-
cordance with NFPA No. 77, Recom-
mended Practice on Static Electricity
• Ensure that utility lights always have a
wire guard over them.
• Never install a fuse rated higher than
specified for the circuit.
• Investigate any appliance or equip-
ment that smells strange. Space heat-
ers, microwave ovens, hot plates, cof-
fee makers, and other small appliances
must be rigidly regulated and closely
monitored.
• The use of extension cords to connect
heating devices to electric outlets must
be prohibited.
Table G2-3 lists common sources of igni-
tion that cause fires in the workplace,
gives examples in each case, and suggests
preventive measures.
4.2.3 Welding And Cutting
Welding and cutting will not be permitted
in areas not authorized by the Safety,
Health, and Environmental Management
Program (SHEMP) Manager. If practical,
welding and cutting operations must be
conducted in well-ventilated rooms with a
fire-resistant floor. If this practice is not
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Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
Table G2-3: Examples of Common Sources of Ignition and Preventive Measures
Sources of Ignition
Examples
Preventive Measures
Electrical
equipment
Electrical defects, generally due
to poor maintenance, mostly in
wiring, motors, switches, lamps,
and hot elements.
Use only approved equipment. Follow
National Electrical Code. Establish
regular maintenance program.
Open flames
Cutting and welding torches, gas
and oil burners, misuse of gaso-
line torches.
Follow established welding precau-
tions. Keep burners clean and prop-
erly adjusted. Do not use open flames
near combustibles.
Smoking and
matches
•
.:
Dangerous near flammable liq-
uids and in areas where combusti-
bles are stored or used.
Smoke only in permitted areas. Make
sure matches are out. Use appropriate
receptacles.
Static
electricity
:1.
Occurs where liquid flows from
pipes
Ground equipment. Use static elimina-
tors HumidifS’ the atmosphere
Hot surfaces
Exposure of combustibles to fur-
naces, electric lamps, or irons,
Provide ample clearances, insulation,
air circulation. Check heating appara-
tus prior to leaving it unattended.
&EPA June 1998
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Laboratory Emergency Management
02. Adniinistration of Laboratory Emergencies
feasible, the SHEMP Manager must ensure
that the work areas have been surveyed for
fire hazards; the necessary precautions are
taken to prevent fires; and a work permit
is issued. This work permit must only
encompass the area, item and time which
is specified on it.
If welding is to be performed over wooden
or other combustible-type floors, the floors
will be swept clean, wetted down, and
covered with either in-c-retardant blankets,
metal or other noncombustible coverings.
Welding will not be permitted in or near
areas containing flammable or combustible
materials (e.g., liquids, vapors, or dusts)
or closed tanks that contain, or have con-
tained, flammable liquids unless they have
been thoroughly drained, purged, and
tested free from flammable gases or
vapors. Welding must not begin until all
combustible materials have been removed
at least 35 feet from the affected areas or,
if unable to relocate, covered with a fire-
retardant covering. This also applies to
walls, partitions, ceilings, or roofs made
of combustible materials. Openings in
walls, floors, or ducts must be covered if
located within 35 feet of the intended work
area. Welding will not be permitted on any
closed containers.
Fire extinguishers will be provided at
each welding or cutting operation. A
trained watcher will be stationed at all
times during the operation and for at
least 30 minutes following the completion
of the operation. This person will ensure
that no stray sparks cause a fire and will
immediately extinguish tires that do start.
4.2.4 Open Flames
No open flames will be permitted if any
spraying operations take place. If indoor
spray-painting work needs to be performed
outside of standard spray-painting booths,
adequate ventilation will be provided. All
potential ignition sources will also be
eliminated.
4.2.5 Static Electricity
It is impossible to prevent the generation
of static electricity in every situation, but
the hazard of static sparks can be avoided
by preventing the buildup of static charges.
One or more of the following preventive
methods should be used: grounding, bond-
ing, maintaining a specific humidity level
(e.g., 60 to 70 percent), and ionizing the
atmosphere.
Where a static-accumulating piece of
equipment is unnecessarily located in a
hazardous area, it is better to move the
equipment, rather than attempt to prevent
static accumulation.
4.2.6 Housekeeping Preventive
Techniques
The following are housekeeping tech-
niques and procedures to prevent occur-
rences of fires:
• Keep storage and working areas free
of trash.
• Place oily rags in covered containers
and dispose of daily.
• Do not use gasoline or other flamma-
ble solvent or finish to clean floors.
I EPA June 1998
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Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
• Use noncombustible oil-absorptive
materials for sweeping up sawdust or
other combustible material treated
with oil.
• Dispose of materials in noncombustI-
ble containers that are emptied daily.
• Remove accumulation of combustible
dust.
• Do not refuel gasoline-powered equip-
ment in a confined space, especially in
the presence of equipment such as fur-
naces or water heaters.
• Do not refuel gasoline-powered equip-
ment while it is hot.
• Follow proper storage and handling
procedures.
• Ensure that combustible materials are
present only in quantities required for
the work operation.
• Clean up any spill of flammable liq-
uids immediately.
• Ensure that if clothing becomes con-
taminated with flammable liquids, the
clothing is changed before continuing
work.
• Post “No Smoking” signs near the
storage areas.
• Report any hazardous condition,
such as old wiring, worn insulation,
or broken electrical equipment, to the
supervisor.
• Keep motors clean and in good work-
ing order.
• Do not overload electrical outlets.
• Ensure that all equipment is turned off
at the end of the work day.
• Maintain the right type of fire extin-
guisher available for use.
• Use the safest cleaning solvents
(e.g., nonflammable and nontoxic)
when cleaning electrical equipment.
Such solvents include inhibited methyl
chloroform, or a blend of Stoddard
solvent and perchioroethylene.
• Ensure that all passageways and fire
doors are unobstructed. Stairwell
doors must never be propped open,
and materials must not be stored in
stairwells.
• Periodically remove overspray resi-
due from walls, floors, and ceilings in
areas where spray operations may
take place.
• Do not allow materials to block auto-
matic sprinkler systems or fire extin-
guisher locations.
• Check daily for any discarded lumber,
broken pallets, or pieces of material
stored on-site, and remove promptly.
• Restack any pile of material that falls
into an aisle or passageway.
June 1998
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CHAPTER G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
4.3 Chemical Spills and Releases
Each laboratory should be equipped with
spill cleanup materials for response to inci-
dental spills. Equipment and materials may
include the following:
• Plastic pail
• Bentonite clay
• Plastic bags
• Dust pan and brush (polypropylene)
• Disposable nitrile gloves
• Tags and stickers to label waste
• Shoe covers
• Sign “Spill Area—Keep Out”
• Instruction information for cleanup
4.4 Medical Emergencies
At each EPA laboratory, an emergency
first-aid station(s) should be established
that is capable of providing both general
first aid (e.g., minor cuts, sprains, and
abrasions), and stabilization for patients
requiring off-site treatment. The station(s)
hould contain a standard first-aid kit, or
equivalent supplies, plus additional items
such as stretchers, ice, emergency eye-
washes, and fire extinguishing blankets.
Supplies should also include:
• Ipecac syrup or table salt for inducing
vomiting
• Activated charcoal for making a slurry
todrinlc
• Maalox “ , Milk of Magnesia , or
aluminum gel to neutralize dilute acids
4.5 Bomb Emergencies
There are a number of mitigation
mea-sures that EPA locations can take
to reduce the risk or consequences of a
bomb emergency.
Tightened security and controlled access
should be used to make access to likely
hiding places—both inside and outside
the building—as difficult as possible. The
local police department may be contacted
for assistance in identifying specific pre-
vention measures for the laboratory. The
following general measures can be used as
guidance to increase security against bomb
incidents:
• Restrict visitor entrances. Secure visi-
tor identification and require all visi-
tors to sign a register indicating their
name and the company they represent,
as well as the name and location of the
person whom they wish to visit.
• If possible, restrict parking to 300 feet
from the building to minimize effects
of bombs being delivered in a car or
left in a car. if restricted parking is not
feasible, consider having properly
identified employee vehicles parked
closer to the building, with visitor
vehicles parked at a distance.
• Keep heavy shrubs and vines close to
the ground to reduce their potential to
conceal bombs. Remove window
boxes and planters, or, if they must
remain, have a security patrol check
them during regular rounds.
• Ensure adequate illumination—both
inside and outside—and emergency
lighting.
• Install an adequate access control and
intrusion system and post signs that
such a system is in place.
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CHiumi G
Laboratory Emergency Management
G2. Administration of Laboratory Emergencies
• Keep doors or access to areas such as
boiler rooms, mail rooms, computer
areas, switchboards, and elevator con-
trol rooms locked.
• Provide for effective key control.
Establish a procedure for accountabil-
ity of keys.
area to another. A cart should be used
when transferring samples between
laboratories.
• Use protective coverings and lids.
• Use unbreakable containers to store
radionuclides, if possible.
• Enforce good housekeeping practices
to minimize debris in trash or dump-
ster areas.
• Install detection devices at all
entrances and closed-circuit televi-
sion in those areas identified as likely
places where a bomb may be placed.
Post signs that such measures are in
place.
• Discourage the mailing of personal
packages to the business address.
• Establish a procedure for inspecting
mail and packages for suspicious
objects.
4.6 Radiation Emergencies
Spills, fires, or explosions that can cause
radioactive materials to be spread around
the laboratory or come into contact with
personnel are the emergencies most likely
to be encountered at a radiation laboratory.
The following guidelines should be fol-
lowed, when appropriate, to reduce the
risk of spills and contamination of the
workplace:
• Use double containers andlor
leakproof trays when transferring
radionuclides in solution from one
• Use extreme caution in transfers—try
a trial run to test the procedure.
• Use a glove box or hood for dusty and
volatile materials and operations.
• Do not pipette by mouth. Use rubber
bulbs, syringes, or pipettors.
• Always plan the procedure to be used.
Have a safety plan developed before
beginning work.
• Cover the work area and use absorbent
paper with a nonpermeable backing to
absorb the radioactive materials in the
event of a spill, and replace it when
wet or torn.
• Check for contamination with radia-
tion survey instruments and/or wipe
test the work area after completing
procedures where contamination may
have occurred.
• Store liquid radioactive materials in
trays capable of containing the volume
should a spill or breakage occur.
• Notify the Radiation Safety Officer
(RSO) irmnediately in the event of a
spill containing radionuclides.
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CHAI’TER G
Attachment G2-1: Elements of a Comprehensive Emergency Response Plan
4.7 Biological Emergencies
Each laboratory must be equipped to
handle incidental biological emergencies.
Contents of a basic biological spill kit
include the following:
• Spill cleanup procedure
• Personal protective equipment (e.g.,
latex gloves, safety glasses)
• Chemical disinfectant (e.g., 5 percent
Wescodyne ‘ ‘ or 5 to 10 percent
bleach)
• Absorbent material (e.g., spill pillows,
padding, paper towels, etc.)
• Disposal bags and hazard labels
• Sharps container
• Forceps for picking up broken glass or
sharps
• Paper, incident reporting form, and
pen or pencil to document the spill and
any possible personnel exposure
&EPA June 1998 G2- 18
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment 02-1: Elements of a Comprehensive Emergency Response Plan
Purpose: To provide a list of all the elements that could be considered for inclusion in
a comprehensive emergency response plan.
Instructions: Use this list as a guide to determine whether the laboratory emergency
response plan addresses all of the emergency scenarios that could occur at
the laboratory.
&EPA June 1998 02-19
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SHEMP Operations Manual for Laboratories
CHAFFER G
Attachment G2- 1: Elements of a Comprehensive Emergency Response Plan
Preface to Plan
• List of key telephone numbers
• Table of contents
• Preface
• Record of changes
• Distribution list
Laboratory Policy and Plan Objectives
• Introduction
• Purpose of plan
• Laboratory policy regarding emergency planning
• Coordination and cooperation with Local Emergency Planning Committees
• Update procedures and schedule
Emergency Response Organization: Structure and Duties
• Authority
• Designation of site Emergency Coordinator/Commander and alternatives
• Duties of site Emergency Coordinator/Commander
• Chain-of-command
• Designation of key personnel and alternatives, including
— Medical Emergency Director
— Fire Brigade Team Leader
— Oil Spill Response Team Leader
— HazMat Spill Response Team Leader
— Public Affairs Coordinator/Press Officer
— Legal Counsel
— Security Coordinator
— Insurance and Claims Coordinator
— Emergency Communications System Coordinator
— Coordinator of Personnel Services
— Purchasing and Logistical Support Coordinator
— Maintenance and Engineering Support Coordinator
— Scientific/Environmental Documentation Coordinator
— Others (as needed)
• Responsibilities and duties of key personnel
• Designation of laboratory emergency operations center
• Establishment of field emergency command post
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SI-1EMP Operations Manuai for Laboratories
CHAPTER G
Attachment G2-l: Elements of a Comprehensive Emergency Response Plan
Detection, Alarm, and Notification Procedures
• Notification check-off lists for various types of events
• Telephone rosters
• On-site accident detection and alarm procedures
• identification and policy for notification of:
— Local authorities
— State authorities
— Federal authorities
— Various facility personnel
— Special off-site occupancies
— Downsiream waterusers
— Water treatment plants
— Electric and gas utilities
— Air, rail, and marine traffic
— Laboratory management
— Person(s) responsible for initial notification and continuation of coi
(where necessary)
— Documentation of communications during emergencies
Emergenq Communication Systems
• Intrafacility communication systems
• Links to public authorities
• Need and availability of backup systems
• Links to the public
On-Site Evacuation and Security
• On-site alert/alarm systems
• Employee awareness program
• Evacuation procedures and policies
• Provisions for handicapped employees or visitors
• Places of refuge
• Designated assembly areas and alternates
• Procedure for identification of the missing
• Search and rescue procedures
• On-site traffic control
• Accident site boundary control
• Facility access control
• Procedures for protection of vital records
• Periodic drills
• Documentation of drills and activities during emergencies
&EPA June 1998 G2-21
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CHAPTER 0
Attachment G2-l: Elements of a Comprehensive Emergency Response Plan
Emergency Facility Shutdown Procedures
• References to emergency operating procedures
• Operator training for emergencies
• Safety features of control rooms and other locations for control of facility
processes
• Drills and exercises
• Documentation of training and drills
Medical Emergency Procedures
• On-site health care resources
• Available Ambulance Services and Emergency Medical Technicians (EMTs)
• Coordination of emergency planning with off-site medical facilities
• Toxic substance information resources
• Special antidotes and supplies
• Victim decontamination procedures
• Provisions to protect medical providers from contamination
• Documentation of activities before and during emergencies
On-Site Emergency Response Teams
• Fire Brigade team organization
• Oil spill team organization
• HazMat team organization
• Response team activation procedures
• Response times during normal working hours
• Response times on nights and weekends
• State and federal training requirements
• Actual training provided
• Drills and exercises
• Documentation of training and drills
Personal Protection of Response Teams
• List of hazardous materials likely to be encountered
• Selection of respiratory protective devices
• Availability of respiratory protective devices
• Resupply of Self-Contained Breathing Apparatus
• Selection of protective clothing
• Availability of protective clothing
• Medical surveillance and care
• Decontamination procedures
• Documentation of activities during emergencies
rt&EPA June 1998 G2-22
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment G2-1: Elements of a Comprehensive Emergency Response Plan
Fire Response Procedures
• General procedures by incident type
• Required resources for postulated events
• Available resources for postulated events
• Documentation of activities during emergencies
Spill Contsiinment and Cleanup Procedures
• Plugginglstopping of leaks
• Suppression of hazardous gas or vapor evolution
• Intentional ignition of combustible toxic gases
• Containment of spills on land
• Cleanup of spills on land
• Containment of spills on water
• Cleanup of spill on water
• Support services for response forces
• Field maintenance of response equipment
• Waste handling and disposal
• Documentation of activities during emergencies
Environmental Monitoring
• Tracking of oil spills on water
• Surveillance of other types of spills
• Monitoring of atmospheric and environmental conditions
• Sampling/monitoring of environmental contamination
• Documentation of activities during emergencies
Public Relations in Emergencies
• Corporate policy directives
• Designation of media briefing location
• Communications with the Command Center
• Provision of Press Officer support (including legal counsel)
• Coordination and cooperation with public authorities
• Availability of press kits
• Media contact list
• Documentation of activities and statements during emergencies
Application of Plan to Natural Hazards
• Procedures and policies for various hazards
• Need and availability of special resources
• Documentation of activities during emergencies
• Documentation of statements during emergencies
&ERIk June 1998 G2-23
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CHAPTER G
Attachment G2- 1: Elements of a Comprehensive Emergency Response Plan
Off-Site Post-Incident Recovery
• Monitoring the status of injured parties
• Wildlife rescue and rehabilitation
• Assessment of environmental damage
• Restoration of the environment
• Assessment of off-site property damage or loss of business
• Availability of insurance and other resources
• Claim-handling procedures
• Documentation of activities
On-Site Post-Incident Recovery
• Post-incident response debriefing and review
• Assistance to families of injured employees
• Assistance to employees laid-off due to the incident
• Investigation of causal factors
• Site property damage assessment
• Site decontamination and cleanup
• Waste and debris disposal
• Site reconstruction/restoration
• Post-incident response debriefing
• Pre-startup checklist
• Documentation of activities
Off-Site Sources of Assistance
• Corporate resources
• Mutual-aid cooperatives
• Spill cleanup contractors
• Other types of key contractors
• Expert consultants
• Local government
• State government
• Federal government
• Private and volunteer organizations
• Expected response time
&EPA June 1998 G2-24
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment G2- 1: Elements of a Comprehensive Emergency Response Plan
Resource Listings: Supplies and Supplemental Services
• Specialized medical supplies
• Oil spill dispersants and application equipment
• Oil spill burning/wicking agents and application equipment
• Sorbent materials
• Neutralization agents
• Portable liquid-transfer systems
• Temporary storage containers and systems
• Vacuum trucks
• Fire-extinguishing agents and equipment (including foams for vapor suppression)
• Portable contaminant-detectors/monitors
• Contaminant sampling equipment and supplies
• Laboratory analysis services
• Communications equipment
Earth-moving equipment
• Oil skimmers
• Support boats
• Fixed-wing aircraft
• Helicopters
• Trucks, vans, and buses
• Emergency lighting
• Emergency power generators
• Fuel supplies
• Canteen services
• Temporary housing
• Portable sanitation facilities
• Work clothes and footwear
• Photography and videotaping services
• Sources of general hardware
• Other potentially required supplies and equipment not addressed here or in previous
sections
&EPA June 1998 02-25
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SHEMP Operations Manual for Laboratories
C rm G
Attachment G2-1: Elements of a Comprehensive Emergency Response Plan
Facility Pianning Basis and Hn ird Analysis
• Facility layout and maps
• Details of potentially hazardous operations
• Oil/chemical accident prevention measures
• History of accidents/incidents
• Type of expected frequency of natural hazards
• Potential impact of natural hazards
• Credible accident scenarios and associated probabilities
• Estimated accident impacts and associated safety zones
• Identification and description of environmentally sensitive areas subject to impact
• Procedures for real-time hazard assessment during emergencies
• Technical references
June 1998 G2-26
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SHEMP Operations Manual for Laboratories
CHAPTERG
Attachment G2-2: Emergency Information Farm
Purpose: To provide an example of the types of emergency information that should be
posted on the door of each laboratory.
Instructions: Use this sample as a guide to developing emergency information posting for
the laboratory, or to supplement current posting.
&EPA June 1998 G2-27
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Emergency Information Form
This laboratory contains:
(Check all that apply)
Flammable liquids
Compressed gases
Explosives
Radioactive material
Biohazards
High voltage equipment
Water reactive material
Carcinogens
Toxic chemicals
Controlled substances
Corrosives
Completed by:
Laboratory Emergency Data
Room #
Emergency contacts:
Name Ext.
Section responsible:
Date completed:
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment 02-3: Examples of NFPA Egress Requirements
Purpose: To provide a summary of some of the NFPA egress requirements.
Instructions: Use this list to familiarize laboratory staff with some of the NFPA egress
requirements.
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment G2-3: Examples of NFPA Egress Requirements
Doors: Doors should swing with exit travel flow direction (vertical or rolling doors should
not be used). The latch or locking devices should provide a knob, handle, panic bar, or other
mechanism to allow operation even in the dark. No door opening should be less than 32
inches wide.
Corridors/pathways: The minimum width of any comdor or passageway serving as an exit,
exit access, or exit discharge should have a clearance of 44 inches.
Panic hardware: Devices should be installed that permit egress and release in an emergency
with a pressure not to exceed 15 pounds, and placed not less than 30, nor more than 44,
inches above the floor.
Horizontal exits: Passages to an area of refuge (i.e., at least three square feet per person) in
nearby buildings or around a firewall or partition should be provided for.
Stairs: Inside or outside stairs should have a minimum width of 44 inches and a minimum
height of four inches, and permit exiting at a reasonable rate. (Ramps are required in place of
stairways where the difference in elevation would be less than three steps.) Stairs with a slope
depth of 11 inches, exceeding 1 in 15, should have handrails on both sides.
Exit passageways: Any use of exit components (e.g., hallways, passages, tunnels, etc.) is
prohibited if it interferes with exiting, or presents additional fire hazards (i.e., storage or
transfer of flammable materials).
Fire escape stairs: Fire escape stairs should only be used to correct exit deficiencies in
existing buildings, should not be considered during primary exit design, and should not pass
along windows or walls exposed to fire dangers. Access to fire escapes should be open at all
times.
Escalators, moving walkways, and elevators: Elevators should never be recognized as exits;
escalators or moving walkways seldom qualify as exits.
Windows: Windows should not be considered exits, but they are required for rescue and
ventilation purposes.
Vertical openings: In indusirial occupancies, vertical openings must be fully enclosed when
used for emergency exits.
Exit lighting: Where artificial lighting is used in an occupancy, exit lighting should be not
less than one foot-candle measured at the floor. Where natural light is used, exit illumination
and emergency lighting may be modified.
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CHAPTER G
Attachment G2-3: Examples of NFPA Egress Requirements
Emergency lighting: Emergency lighting should provide necessary exit floor illumination
automatically in the event of failure of normal lighting and with no appreciable interruption
of illumination during the changeover.
Exit signs: All exits and access ways must be identified by signs of such size, color, and
design as to ensure visibility. Signs that state “TO EXITS” are frequently required where
direction of travel to the nearest exit is not readily apparent. Signs that state “NOT AN
EXIT’ are important to ensure that doors, passages, or stairs that are not exits are not
mistakenly used as such in an emergency.
Alarm systems: Alarms that have distinctive pitch and quality of sound (or visual distinction
for the deal) should be manually operated.
Fire exit drills: Drills are essential in providing familiarity with exits and their orderly use.
Drills should be appropriately planned.
Exit maintenance: All exits should be maintained in a safe operating condition to prevent
loss of life in the event of tire.
6EPA June 1998 G23 1
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G3.
Emergency Action
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SHEMP Operations Manual for Laboratories
CHAFrER G
Laboratory Emergency Management
03. Emergency Systems & Equipment
1.0 Introduction
When necessary, appropriate emer-
gency actions must take place according
to the measures outlined in the Emer-
gency Action Plan and/or Occupant Emer-
gency Plan. The command center team
maintains the authority for all laboratory
responses. Employees must be trained and
encouraged to follow all command center
team instructions in the event of an emer-
gency. To ensure appropriate and effective
response to an emergency, laboratory facil-
ities must rely on personnel training and
emergency preparation. Response equip-
ment must be provided and located to
facilitate response. Also fundamental to
effective and immediate response are the
methods of emergency communication,
including internal and external notifica-
tion. Following an emergency response,
additional notifications must be made as
appropriate. This chapter outlines notifica-
tion procedures and actions for potential
laboratory emergencies.
• Providing post-emergency notification
• Developing specific emergency
response procedures
• Training employees for emergency
actions based on potential hazards and
risks
EPA Program Requirements
To facilitate and provide appropriate emer-
gency action, EPA laboratories must:
• Prepare for, and provide, appropriate
emergency notifications.
• Develop standard operating proce-
dures (SOPs) for typical emergency
responses.
• Train employees in emergency
response methods and equipment use.
Program Administration
To implement emergency response
actions, responsibilities must be assigned
for the following:
• Posting emergency notification
information
& A June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management
G3. Emergency Systems & Equipment
2.0 Notification
Notification of an emergency is to be
performed as soon as the emergency is
identified. Each laboratory should have
internal emergency notification procedures
and telephone numbers posted at each
telephone.
Often, an emergency response will involve
the notification of external organizations
(e.g., fire department, medical facilities,
etc.). All external notifications should be
handled by the command center team.
For certain emergency actions, it may be
appropriate to provide external notitication
(i.e., 911) prior to internal notification.
These situations should be outhned in
the emergency action plan. in order to
identify the applicable release reporting
obligations, the facility should know what
regulations it is subject to, what air and
wastewater permits it holds, and what haz-
ardous substances are stored and handled
on site.
Attachment 03-1 summarizes federal
safety, health, and environmental reporting
obligations, including the type of release,
the reporting obligations, the timeframe
within which the release must be reported,
and the applicable federal law. Reporting
obligations are typically dependent on the
type and quantity of a substance or sub-
stances released into the environment.
States may have additional or more strin-
gent reporting requirements.
In addition, laboratories may be asked for
specific information from the media and
must be prepared to respond. Laboratories
should ensure that they have a communi-
cation plan that discusses how to respond
to outside requests for information. Com-
munications to the media, unions, and
other organizations should be cleared by
appropriate laboratory representatives and
delivered by a designated laboratory repre-
sentative. All staff and members of the
incident command and emergency teams
must follow the communications protocol
outhned by the laboratory.
Typically, the Designated Official reports
to a member of laboratory management
or the designated spokesperson dealing
with outside distractions and emergency
organizations. However, on occasion,
team members may need to present their
findings to, and/or to work with, outside
organizations during the investigation
(e.g., arson, sabotage, workplace violence,
etc.). If the spokesperson is a team mem-
ber, care must be taken to resist the temp-
tation to offer conclusions.
3.0 General Response Procedures
Outlined below are typical response proce-
dures for potential laboratory emergencies.
These are general response measures. The
specific measures outlined in the emer-
gency action plan should include these
measures, but supersede these general
guidelines.
3.1 Fire
Every employee must know the
location of fire extinguishers
and fire blankets and be famil-
iar with the alarm system. The
first person to observe a fire
should immediately sound the tire alarm
by activating the nearest fire alarm pull
station and then report the fire to the
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CHAPTER G
Laboratory Emergency Management
G3. Emergency Systems & Equipment
SHEMP Manager. If possible, and if
trained to do so, use an appropriate fire
extinguisher to extinguish or contain the
fire. if fire extinguishment attempts fail,
evacuate the area, shut off gas supplies,
close the door to contain the fire, and
evacuate.
The following sections provide informa-
tion on response to specific types of fires:
Solvent fires can usually be extinguished
by the proper use of dry chemical or car-
bon dioxide extinguishers. Fires in small
containers of solvent can often be snuffed
out by placing the lid on the container
tightly enough to exclude air. If a lid is
not available, a piece of sheet metal or
other similar noncombustible material
will suffice.
Gas fires can be extinguished by closing
a valve in the gas supply line, thereby
shutting off the fuel supply. The building’s
gas valves should be identified by a sign
and arrow. The building manager is called
to turn off the building gas valves. Gas
fires can also be extinguished by the
proper use of carbon dioxide or dry chemi-
cal extinguishers. Serious consideration
should be given to allowing gas fires to
burn until the source of gas can be stopped
to prevent possible explosions.
Chemical fires can be of many different
types. Often special methods of tire fight-
ing must be used. For example, a metal
fire (e.g., sodium, titanium, magnesium,
potassium, lithium) should be smothered
with dry sand, graphite, salt, or inert gas
in confined areas, never with water. All
laboratory workers must be taught the
particular methods of handling these
unusual types of fire hazards located in
their work area.
Electrical fre response must begin with
turning off the power to the motor or other
electrical equipment involved in the fire.
If the power cannot be turned off, call the
building manager to turn off the power.
Use carbon dioxide or dry chemical
extinguishers on electrical equipment,
never water. Electrical equipment involved
in fires should not be returned to operation
until it has been inspected or repaired.
3.2 Chemicals
The spill procedures discussed below are
to be used by laboratory employees only
for incidental chemical releases. An inci-
dental release is a release in which the sub-
stance(s) can be absorbed, neutralized, or
otherwise controlled at the time of release
by personnel in the immediate release area,
and where there is no potential risk of
health hazards (i.e., tire, explosion, or
chemical exposure). The spill procedures
discussed in Table G3-l are to be used by
laboratory staff for incidental chemical
spills or releases.
Clean-up of incidental chemical spills is
performed once the initial response and
assessment of the extent of the spill have
been completed. Table G3-2 presents gen-
eral procedures for clean-up of incidental
chemical spills.
6EPA June 1998
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CHAPTER G
Laboratoiy Emergency Management
G3. Emergency Systems &Eq ipment
Table G3-1: Procedure for Response to Incidental Chemical Spills or Releases
Step
Action
1
Notify staff in the immediate area to leave the room immediately.
2
Determine if laboratory staff have been contaminated.
Decontaminate eyes using the nearest eyewash station and skin using the nearest
safety shower, as applicable to the extent of contamination.
Notify the SHEMP Manager, Laboratory Director and emergency medical responders
for assistance.
Discard any contaminated protective clothing (refer to Chapter C15 for waste manage-
ment information).
Assess the hazards associated with the spill or release.
Determine if the spill or release can be contained and cleaned up.
Detennine the neutralization process for the chemical spilled from material safety data
sheets.
Restrict access to the laboratory until neutralization and clean-up have been com-
pleted, unless staff are equipped with appropriate personal protective equipment.
In the event of staff exposure, medical
assistance must immediately be sought.
Personnel who are helping the exposed
staff member must be prepared to provide
the medical personnel information such
as the type of exposure (i.e., chemical),
the exposure route (i.e., skin contact, inha-
lation, ingestion), and the degree or
amount of exposure. Trained personnel
must provide immediate first aid appropri-
ate to the exposure.
33 Medical
In the event of an emergency
medical situation, the names,
phone numbers, addresses, and procedures
for contacting the emergency medical
resources should be posted conspicuously
(with duplicates near telephones). This
may include a first-aid team, a hospi-
tal/clinic, and emergency medical techni-
cians/paramedics. In case of exposure to a
hazardous material, it is advisable to take
the applicable MSDS to the emergency
room along with the exposed victim. After
a medical emergency, follow-up should be
done to ensure that accident reports are
filed and a response critique is performed.
I A
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CHAPTER 0
Laboratory Emergency Management 03. Emergency Systems & Equipment
Table G3-2: Clean-up of Incidental Chemical Spills
Step
Action
1
Conduct an initial assessment and evaluation of the spill area.
2
Gather containment, control, and clean-up supplies, materials and equipment.
3
Put on appropriate personal protective equipment.
4
Solid Spill: Carefully push a solid spill into a scoop with a sponge, pad or other
suitable device. Do not sweep the solids with a broom.
Liquid Spill: Contain and confine to an area as small as possible use sorbent booms
and absorbent particulate. Place sorbent particulate on the spilled material and let it
soak in.
5
Clean-up both liquid and solid spills using an “outside-in” approach. Practice contam-
ination avoidance.
6
Place contaminated sorbent or other contaminated material into an approved recepta-
cle.
7
Wash/wipe down the area two times with a mild detergent and water using sponges,
cloth, etc.
8
Dry the area with paper towels, cloths, rags, etc.
9
Wipe down any material, containers, or equipment that may have been contaminated
in the spill.
10
Place any waste material generated in the cleanup (rags, etc.) into approved receptacle.
11
Remove PPE and place in approved receptacle.
12
Close and seal waste receptacle.
13
Contact laboratory supervisor or other designated individual to oversee removal.
&EPA June 1998 G3-5
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CHAFFER 0
Laboratory Emergency Management
G3. Emergency Systems & Equipment
C 3.4 Bomb
The following section includes
information for response to the
identification of a suspicious
object. Suspicious objects are assumed to
be bombs until a professional assessment
proves otherwise.
3.4.1 Recognition
It is important for employees to be aware
of suspicious objects, and to know who to
contact in the event that one is received
through shipping or identified in the work
area. Some employees may receive bomb
threats over the telephone, over the
Internet. or in the mail.
Suspicious Packages in the Mail
Bombs may be received by EPA locations
through the mail or special delivery. Parcel
or letter bombs sometimes have common
traits that can be identified through visual
inspection. Points for recognizing suspi-
cious packages are presented in Table
G3-3.
EPA laboratories may have X-ray
machines or magnetometers located in
receiving areas or mail rooms to further
evaluate incoming packages. if a suspi-
cious package is detected in the X-ray
machine, it should be left inside the
chamber as the appropriate evaluation
and response procedures are being
implemented.
Bomb Threats
EPA laboratories may also be subject to
bomb threats. Bomb threats may either be
specific or nonspecific. Specific threats
may provide information on the bomb, its
placement, explanation for the attack, and
the time of detonation. Nonspecific threats
generally provide little information other
than that a bomb has been placed. Both
types of threats should be considered seri-
ously and evaluated.
3.4.2 Response
Once a potential bomb incident is
recognized, it is essential that the proper
response procedures be efficiently and
Table G3 .3: Points for Recognizing Suspicious Packages
Foreign mail, airmail, or special delivery
Incorrect titles
Confidential or personal markings
Titles, but no names
Excessive postage (usually stamps)
Oily stains or discoloration
Handwritten addresses
No return address
Poorly typed addresses
Excessive weight
Misspellings of common words
Rigid envelope
Excessive fastenings (tape, string, etc.)
Lopsided or uneven envelope
Visual distractions
Protruding wires or tinfoil
&EPA June 1998
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CHAPTER G
Laboratory Emergency Management
G3. Emergency Systems & Equ pment
accurately implemented to evaluate and
act on the situation. The following sections
provide guidance on response to suspi-
cious packages in the mail, objects in the
workplace, and bomb threats.
Suspicious Packages in the Mail
Upon identification of a suspicious pack-
age, receiving area or mail room personnel
should notify the contact designated by the
Command Center Team in the laboratory’s
emergency action plan. This contact must
be responsible for notifying laboratory
management and recording all pertinent
information on the suspicious package.
Then the designated responder should
attempt to contact the sender of the pack-
age for information on the contents. Exam-
ples of questions to be asked include:
• Is the addressee familiar with the
name and address of the sender?
• Is the addressee expecting a package
from the sender? If so, what would
be the contents of the item and an
approximate size?
• If the sender is unknown, is the
addressee expecting any correspon-
dence from the city, state, or origin
of the suspect package?
• Is the addressee aware of any friends,
relatives, or business acquaintances
currently on vacation or business trips
in the area of origin?
If the package cannot be identified,
responders should contact the local
bomb squad and notify the Command
Center Team to implement the bomb
incident plan.
Bomb Threats
Once a bomb threat is received, the
response procedures outlined in the
emergency action plan must be imple-
mented. All employees who may receive
a bomb threat (either written or over the
telephone) should be trained and drilled
on the response procedures. As part of
the response, the local agency (e.g., Fed-
eral Protective Service, Federal Bureau
of Investigation, police, etc.) outlined in
the emergency plan should be notified of
the threat. If a written threat is received,
it should be handled as little as possible.
All materials, including any envelope or
container, should be placed in a plastic
bag and given to the response organiza-
tions. Evidence such as fingerprints, hand-
writing or typewriting, paper, and postal
marks can then be used in tracing the
threat. A recipient of a written bomb threat
should attempt to note all personnel who
were involved with the movement of the
written document through the channels to
the point where discovery of its intent was
made.
Bomb threats received over the Internet
should be stored in an archive and/or for-
warded to a predesignated site. Informa-
tion specialists may be able to determine
information on the sender from reviewing
the message received. The message should
also be printed out so it can be easily used
and reviewed during the evaluation and
follow-up process.
Bomb threats received over the telephone
are more common than written threats.
A calm response over the telephone may
result in additional information, especially
if the caller wishes to avoid injuries or
fatalities. Establish specific bomb threat
&EPA June 1998
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CHAPTER G
Laboratory Emergency Management
G3. Emergency Systems & Equipment
response procedures in the incident plan
to outline the notification, communication,
and evaluation procedures. In developing
this portion of the emergency plan and the
training materials, these guidelines should
be followed for individuals receiving a
bomb threat over the telephone:
Keep the caller on the line as long as
possible.
— Notify your supervisor or security
officer by a prearranged signal
while the caller is on the line.
— Keep the caller talking. Ask the
caller to repeat the message. Pre-
tend difficulty with hearing.
— Record every word spoken by the
caller.
• Ask for the location of the bomb or
the time of possible detonation.
— If told that the building is occu-
pied or can not be evacuated in
time, the caller may be willing to
give more specific information on
the bomb’s location, components,
or method of detonation.
— Ask what type of bomb it is.
• Listen for background noises.
• Pay close attention to the voice char-
acteristics, speech, language, accent.
and manner.
3.5 Evacuation
EXIT
‘a
In the event of a facility evacua
tion, employees should be
trained in alarm methods,
evacuation routes, and meeting
locations. All personnel must follow the
directions of floor teams, since access to
some routes may be limited based on
the emergency location. The use of eleva-
tors must be avoided. Responsibility for
closing doors to laboratories should be
assigned to floor team members. All
personnel must proceed directly to the
assigned meeting location for a head
count. The facility’s emergency action
plan highlights the personnel responsible
for performing the head count. If any staff
member is not accounted for, the Com-
mand Center Team must be immediately
notified. Re-entry is not permitted unless
announced by authorized personnel.
3.6 Radiation
Emergency situations that
• can cause radioactive materi-
£ ‘ als to be spread around or
- come into contact with per-
sonnel may be encountered in
a laboratory. The following procedures
describe responses to several general radi-
ation emergency situations.
3.6.1 Minor Spill
In the event of a minor spill involving no
radiation hazard to personnel:
• Immediately notify all other persons in
the room.
• Notify the SHEMP Manager and
Radiation Safety Officer (RSO). The
RSO will verify that no radioactive
materials were involved in the spill.
• Permit only the minimum number of
persons necessary into the area to deal
with the spill.
&EPA June 1998
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Laboratory Emergency Management
G3. Emergency Systems & Equipment
• Confine the spill immediately, as
follows:
For minor spills of radioactive liquids:
• Consult the Material Safety Data
Sheets (MSDS) for required protective
clothing and equipment.
• Don protective gloves, lab coat, shoe
covers, and respirator as required (if
trained).
Dam the spill with absorbent material.
• Neutralize as required.
• Drop absorbent paper on the spill.
For a dry spill of radioactive material:
• Consult the MSDS for required pro-
tective clothing and equipment.
• Don protective gloves, coveralls, and
respirator as required (if traIned).
• Dampen thoroughly, taking care not to
spread the contamination.
•
the area.
• Monitor all persons involved with the
spill and cleanup operations.
• A complete assessment of the accident
and subsequent remedial or protective
measures must be documented and
submitted for review to the SHEMP
Manager, the RSO, and the Laboratory
Director.
3.6.2 Major Spill
For major spills involving potential radia-
tion hazard to laboratory personnel:
• Notify all persons not involved in the
spill to vacate the room at once. Limit
the movement of displaced persons to
confine the spread of contamination.
• Notify the RSO and SHEMP Manager
immediately.
• Evaluate the non-radioactive hazards
associated with the spill. If required,
consult MSDS for appropriate action.
• If the spill is on the skin, flush skin
thoroughly with cold water and wash
with soap and water.
• If the spill is on clothing, monitor
and/or discard outer or protective
clothing at once.
• Take immediate steps to decontanii-
nate personnel involved, as necessary.
• Decontaminate the area.
• Document a complete assessment of
the accident and subsequent remedial
or protective measures and submit it to
the SHEMP Manager, RSO, and the
Laboratory Director for review.
Personnel involved in decontamination
must use adequate protective equipment
to avoid the risk of external and/or internal
contamination.
3.6.3 Injuries or Exposures to
Personnel
All radiation emergencies involving
injuries or exposures to personnel (e.g.,
wounds, exposure, ingestion, inhalation)
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Laboratory Emergency Management
G3. Emergency Systems & Equipment
must be reported to the RSO immediately.
If deemed necessary, a physician qualified
to treat radiation injuries will be called.
No person involved in a radiation injury
shall return to work without the approval
of the attending physician, the RSO,
and the SHEMP Manager. A complete
assessment of the accident and subsequent
remedial or protective measures must be
documented and submitted for review to
the SHEMP Manager, RSO, and the Labo-
ratory Director.
3.7 Biological
When accidents occur that
involve the mishandling or
escape of biohazardous mate-
rials, the P1 or laboratory
supervisor is to be notified immediately.
Spills of high-risk organisms (e.g., certain
Class 2 and all Class 3 organisms) should
be reported to the SHEMP Manager or
biosafety officer. All employees have an
obligation to themselves and their col-
leagues to report accidents immediately in
order to minimize potential hazards. Refer
to Chapter F2 of this manual for specific
guidelines on decontamination
of laboratory surfaces after a spill of
biohazardous materials.
Laboratory Animal BUe,
Scratch, or Splash
Laboratory personnel work
ing with animals are at risk of
contracting a variety of dis-
eases during contact. Table
G3-4 presents a summary of some diseases
that could result from types of animal con-
tact. All animal bites and scratches should
be washed promptly with an antibacterial
soap, and medical attention must be given
to the employee. Dog or cat bites require
notification of the animal facility veteri-
narian so the animal can be quarantined
for rabies observation.
I
Table G3-4: Diseases Resulting from Laboratory Animal Contact
Type of Animals
Type of Disease
General animal handling
Tetanus
Nonhuman primates
Tuberculosis
Cercopithecine Herpes virus I
Pox viruses
Salmonella
Shigella
Intestinal parasites
Carnivores (e.g., dogs and cats)
Rabies
Cats
Toxoplasmosis (women of child-bearing age)
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G3. Emergency Systems & Equipment
Nonhuman primates can present a variety
of risks to animal users. They are wild
animals and can be aggressive toward
humans. In the event of a bite, scratch or
splash of body fluids from a nonhuman
primate, follow the guidelines in Table
03-5.
3.8 Utility Failure
Utility failures, or outages, can occur
any time for a variety of reasons and for
extended periods of time. The effect an
outage will have on the facility and its
occupants is related to the type of service
lost, duration of outage, time of day,
weather conditions, and day of the week.
Employees are placed at risk when an out-
age occurs at the facility for an extended
period of time. Loss of communication
services, building environmental controls,
and elevator service and reduced visibility
could increase the risk of employee injury.
The command center team will determine
how the organization will respond to an
outage based on these factors. Information
will be provided via voicemail broadcasts
or megaphones.
Occupants should leave any area if per-
sonal safety is threatened. Utility failures
should be reported immediately to security
so that the command center team may
be alerted. The command center team, in
cooperation with security and laboratory
staff, should determine the impact of the
outage. Evacuation may be initiated if
there is a risk of injury to staff, hazardous
Table G3..5: Procedure for a Bite, Scratch, or Splash from Nonhuman Primates
Step
Action
I
Assess the situation. If you have one of the following, follow the procedures below:
• A bite or scratch that causes bleeding
• A cage scratch that causes bleeding
• A puncture by a needle that has previously been in a nonhuman primate
• Splashing of feces, urine, saliva, or blood into your eye or mouth
2
Scrub the wound for 15 minutes using a scrub brush and water.
3
For an eye splash, rinse eyes at the eyewash station.
4
Swab the wound deeply, using a viral culture swab.
5
Squeeze the bottom to break the bulb containing the transport media when replacing
the swab in its plastic tube. Do not use the swab in eyes.
6
Call for medical assistance and follow the instructions given.
June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management
G3. Emergency Systems & Equipment
material spills, etc. Only when the utilities
have been restored and the command cen-
ter team announces that it is safe to reenter
the facility, should the occupants return to
the laboratory.
3.9 Natural Disaster
indicate when and where severe thun-
derstorms and/or tornadoes are most
likely to occur. A warning is issued to
indicate when and where such storms
are occurring, based on evidence from
radar or reports from trained spotters
or other reliable sources.
At EPA laboratories, there are a variety
of natural hazards associated with adverse
weather conditions that could obscure visi-
bility, affect road conditions, or cause heat
or cold stress. The following are some
unusual and severe weather conditions
that could affect laboratories:
• Severe Thunderstorms.
Severe thunderstorms
are defined as having
winds of more than 58
miles per hour or large
hail of 3/4 inch or more
in diameter. Severe thunderstorms can
produce tornadoes, large hail, and
heavy rain with possible flooding
and lightning.
• Tornadoes. Tornadoes
do not usually affect a
large area, but they are
the most violent type of
storm that can occur.
Most tornado damage is
caused by violent winds, but most in-
juries and deaths result from wind-
blown debris. Large thunderstorms
can spawn several tornadoes, and a
major outbreak of tornadoes can cause
widespread damage. Large hail is of-
ten followed by a strong or violent
tornado. The National Severe Storms
Forecast Center will issue a watch to
• Heavy Snowfall and
Blizzards. Heavy snow-
falls and blizzards could
occur at some EPA labo-
ratory locations. As such, work should
be scheduled around adverse weather
if possible. Laboratory staff should try
to anticipate heavy snowfalls and bliz-
zards and consider potential travel
conditions on the way to the facility
from their homes.
For any natural disaster where advance
notice is given, directions obtained from
radio and television broadcasts must be
followed by the Command Center Team
and all personnel. Laboratory-specific
information should be provided to occu-
pants through broadcasts over intercoms,
voice mail, etc., as updates are available.
The primary goal of the command center
team is to assess facility damage and issue
orders to minimize the risk of occupants.
The command center team may need to
alert laboratory staff who are outdoors to
seek refuge inside the facility. If the facil-
ity is damaged during the natural disaster,
the conunand center team must determine
if evacuation of the facility is necessary to
protect staff. If it is safe to evacuate, occu-
pants should follow instructions given by
the command center team.
&EPA June 1998
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment G3-l: Environmental Notification Requirements
Purpose: To provide a list of notification requirements for safety, health, and environ-
mental incidents.
Instructions: Compare this list to the emergency procedures currently in place at the
laboratory. Determine if the procedures provide adequate notification
instruction for emergency situations.
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SHEMP Operations Manual for Laboratories
CHAPTER 0
Attachment G3-1: Environmental Notification Requirements
Type of [ uadent
Reporting Obligation
Federal Law(
Regulatory Citation
Release to air in excess of air permit
limits
Review permit (typically state-issued)
to determine notification requirements.
CAA/Permit
Release to air in excess of applicable
NSPS or NESHAP standard
Notify regulatory agency as specified in
applicable NSPS or NESHAP standard
CAAI4O CFR 60, 61,63
Release to water in excess of POTW or
NPDES permit limits
Review permit (typically state-issued)
to determine notification requirements.
CWA/Permit
A release to the environment of
CERCLA hazardous substance listed
in 40 CFR 302 that is withirifacility
boundaries and is equal to or exceeds
the reportable quantity (see 40 CFR
302 for listing of hazardous substances
and their reportable quantities)
Notify the National Response Center
immediately.
_____________________________
CERCLA/40 CFR 302
A release to the environment of a
CERCLA hazardous substance listed in
40 CFR 302 that goes outside fad hsy
boundaries and is equal to or exceeds
the reportable quantity. (See 40 CFR
302 for listing of hazardous substances
and their reportable quantities.)
Notify the National Response Center
immediately.
Notify state and local emergency plan-
ning committees immediately, and pro-
vide written notification to state and
local emergency planning commissions
as soon as practical.
CERCLA/40 CFR 302
A release to the environment of an
extremely hazardous substance listed
in 40 CFR 355 that goes outside facility
boundaries and is equal to or exceeds
its reportable quantity (see 40 CFR
355 for a listing of extremely hazardous
substances and their reportable
quantities)
Notify state and local emergency plan-
ning committees immediately, and pro-
vide written notification to state and
local emergency planning commissions
as soon as practical.
EPCIW4O CFR 355
Release of oil into navigable water
Notify National Response Center of
releases of oil in harmful quantities
(quantity that violates applicable water
quality standard or that causes a film,
sheen, or discoloration of the surface
of the water) into navigable water
quantities
CWA/40 CFR 110
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SHEMP Operations Manual for Laboratories
CHAPTER G
Discharge of hazardous waste or haz-
ardous materials during transportation,
including:
As a direct result of hazardous
materials:
—A person is killed; or
— A person receives injuries
requiring his or her hospital-
ization; or
— Estimated carrier or other
property damage exceeds
$50,000; or
— An evacuation of the general
public occurs lasting one or
more hours; or
— One or more major transporta-
tion arteries or facilities are
closed or shut down for one
hour or more; or
— The operational flight pattern
or routine of an aircraft is
altered; or
• Fire, breakage, spillage, or sus-
pected radioactive contamination
occurs involving shipment of
radioactive material
• Fire, breakage, spillage, or sus-
pected contamination occurs
involving shipment of infectious
substances (etiologic agents); or
• There has been a release of a
marine pollutant in a quantity
exceeding 450 L (119 gallons)
for liquids or 400 kg (882
pounds) for solids; or
• A situation exists of such a nature
(e.g., a continuing danger to life
• Notify the National Response
Center and report in writing to
the Director, Office of Hazardous
Materials Transportation, Materi-
als Transportation Bureau,
Department of Transportation
• Notify the nearest FAA Civil Avi-
ation Security Office, by tele-
phone at the earliest practical
moment, incidents involving ship-
ments transported by aircraft.
• Notify the Director, Centers for
Disease Control, U.S. Public
Health Service, Atlanta, Georgia
for emergencies involving etlo-
logic agents.
• Under 40 CFR 302.6, EPAO
requires persons in charge of
facilities (including transport
vehicles, vessels and aircraft) to
report any release of a hazardous
substance in a quantity equal to
or greater than its reportable
quantity, as soon as that person
has knowledge of the release, to
the U.S. Coast Guard National
Response Center.
• Notify the National Response
Center and report in writing to
the Director, Office of Hazardous
Materials Transportation, Mateii-
als Transportation Bureau,
Department of Transportation.
RCRA/40 CFR 263 and
Hazardous Materials
Transportation Law/49
CFR 171 for hazardous
waste
Hazardous Materials
Transportation Law/49
CFR 171 for hazardous
materials
Attachment G3- 1: Environmental Notification Requirements
Type of Inddent
Reporting Obligation
Federal Law!
Regulatory Citation
, p A
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SHEMP Operations Manual for Laboratories
CHAPTER G
Attachment G3- 1: Environmental Notification Requirements
iype of Inddent
Reporting Obligation
Federal Law!
Regulatory Citation
Leak or spill from an underground
storage tank
• Report spills or releases to the
environment in excess of 25 gal-
lons to the implementing agency
within 24 hours of release
Report spills or releases of haz-
ardous substances consistent with
40 CFR 302 and 355 that are
equal to or exceed the reportable
quantity
• Report petroleum spills of less
than 25 gallons or hazardous-
substance spills less than the
reportable quantity that cannot be
cleaned up within 24 hours to the
implementing agency
RCRA/40 CFR 280
Each fatality
Within 8 hours after the death of any
employee from a work-related incident.
orally report the fatality by telephone
orin person to the AreaOSHA Office,
or by using the OSI1A toll-free central
telephone number.
OSHAI29 CFR 1904.8
Hospitalization of three or more
employees occurring within 30 days
of an incident
Within 8 hours after the in-patient hos-
pitalization of three or more employees
as a result of a work-related incident.
orally report the multiple hospitaliza-
lion by telephone or in person to the
Area OSHA Office nearest to the inci-
dent, or by using the OSHA toll-free
central telephone number.
OSHA/29 CFR 1904.8
rr&EPA June 1998 G3-16
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G4.
Investigation and Analysis
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S} 1EMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management G4. Investigation and Analysis
1.0 Introduction
Incident investigations determine how and
why failures occur. By using the informa-
tion gained through an investigation, a
similar, or perhaps more disastrous, inci-
dent may be prevented. Incident investiga-
tions should be conducted with incident
prevention in mind. Investigations are
not intended to place blame. This chapter
presents information on incident investiga-
tion procedures and incident analysis
techniques.
EPA Program Requirements
To ensure that incidents are adequately
investigated and root cause(s) are deter-
mined, EPA laboratories must:
• Develop an incident investigation
program.
• Assign staff to perform incident
investigation.
• Train staff on investigation
procedures.
• Implement procedures for performing
cause analysis.
• Establish incident reporting
procedures.
Program Administration
To effectively manage incident investiga-
tion and analysis, responsibilities should
be assigned for:
• Developing an incident investigation
program
• Training staff on investigation
procedures
• Activating the investigation
• Leading the investigation
• Preparing and submitting incident
reports
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Laboratory Emergency Management
G4. Investigation and Analysis
2.0 Incident investigation
A complete incident investigation pro-
grain should investigate incidents, “near
misses,” and accidents that result in prop-
erty damage or personal injury. The
investigators should be trained in the
proper procedures for conducting an inves-
tigation.
Personnel involved in an investigation
should avoid the trap of assigning blame
to involved employees. By assigning
blame, the investigator would be creating
a negative work environment that would
most likely discourage employees from
reporting future incidents and hazardous
conditions. This approach may not
uncover all contributing factors or the
root cause of the problem. Often, a
thorough analysis will reveal that more
significant program deficiencies led to
the incident, (e.g., inadequate equip-
ment, improper training, or insufficient
supervision).
An investigation should not only be
conducted in response to insurance or
regulatory reporting requirements. The
investigation should be perfoimed as
part of the laboratory’s hazard analysis
program, with the information used to
develop appropriate corrective actions
and revise the inventory of site hazards
andlor the existing systems for hazard
prevention and control. Table G4-l
summarizes the guidelines for develop-
ing investigation program, and Attach-
ment G4-1 of this manual provides a
sample investigation form.
The actual procedures used in a particular
investigation depend on the nature and
results of the incident. In general, respon-
sible officials will appoint an individual to
be in charge of the investigation.
It is best if the team leader has received
some training, has no association with the
area where the incident occurred, and has
some knowledge of the process. Major
events may call for support from head-
quarters or outside parties. The investiga-
tor uses most of the following steps, which
are also highlighted in Table 04-2.
I. Define the scope of the investigation.
2. Select the investigators and assign
specific tasks to each (preferably in
writing).
3. Present a preliminary briefing to the
investigation team, including:
a. Description of the incident, with
damage estimates
b. Normal operating procedures
c. Maps (local and general)
d. Location of the incident site
e. Ust of witnesses
f. Events that preceded the incident
4. Visit the incident site to obtain
updated information.
5. Inspect the incident site:
a. Secure the area. Do not disturb the
scene unless a hazard exists.
b. Prepare the necessary sketches
and photographs. Label each care-
fully and keep accurate records.
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CH vrER G
Laboratory Emergency Management G4. Investigation and Analysis
Table G4-1: Elements of an Incident Investigation Program
Element
Description
Laboratory Policy
Develop a written policy. Management commitment is
essential to ensure that employees know that reporting
does not result in reprisal and blame.
Incident Definition
Define what constitutes an incident. The reporting of cer-
tain injuries, illnesses, and fatalities must be performed
according to the applicable regulatory authority. However,
the definition should also address nonregulated injuries,
illnesses, fatalities, and “near miss” incidents or exposures.
Investigation
Encourage immediate reporting of incidents so the investi-
gation can begin as soon as possible.
Incident Causes
Uncover causes or contributing factors of incidents. These
usually fall into the following categories: unsafe conditions
or acts, poor supervision, or personal factors.
Response to
Develop recommendations from the findings of the
investigation and act on these recommendations as
soon as possible.
Recommendations
Investigation Report
Do not confuse the investigation report with medical
recordkeeping or regulatory logs, such as the OSHA
200 Log.
Investigation Team Training
Ensure that all investigators have had incident investiga-
tion training. Otherwise, the results will likely overempha-
size blame, and neglect root causes.
6. Interview each victim and witness. c. When it was first noted
Also interview those who were d. How it occurred
present before the incident and those
who arrived at the scene shortly after 8. Analyze the data obtained in step 7.
the incident. Keep accurate records of Repeat any of the prior steps, if
each interview. Use a tape recorder if necessary.
desired and if approved.
9. Determine:
7. Determine: a. Why the incident occurred
a. What was not normal before the b. A likely sequence of events and
incident probable causes
b. Where the abnormality occurred c. Alternative sequences
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CHAPTER (3
Laboratory Emergency Management
04. Investigation and Analysis
10. Check each sequence against the data
from step 7.
11. Determine the most likely sequence of
events and the most probable causes.
12. Conduct a post-investigation briefing
13. Prepare a summary report. It should
include, at a minimum:
a. Date and description of the
incident
b. Factors contributing to the
incident
c. Recommendations resulting from
the investigation
d. The names of the people who con-
ducted the investigation
An investigation is not complete until all
data are analyzed and a final report is corn-
pleted. It is critical that there be closure
on all recommendations whether they are
accepted or not.
2.1 Fact-Finding
Evidence must be gathered from many
sources during an investigation. Informa-
tion is gathered from witnesses, as well as
by observation. Witnesses should be inter-
viewed as soon as possible after an inci-
dent. The incident site must be inspected
before any changes occur. Photographs
and sketches of the incident scene are also
made immediately. All pertinent data is
recorded on maps.
Documents containing normal operating
procedures, flow diagrams, maintenance
charts, or reports of difficulties or abnor-
malities are particularly useful. Complete
Table G4-2: Steps for Incident
Investigation
Step 1
Define Scope
Step 2
Select Investigators
Step 3
Present Briefing
Step 4
Visit Incident Site
Step 5
Inspect Incident Site
Step 6
Interview Victims and Witnesses
Step 7
Determine How Incident Occuued
Step 8
Analyze Data
Step 9
Determine Event Sequence
Step 10
Compare Sequence With Data
Step 11
Determine Probable Cause
Step 12
Conduct Post-Bileting
Step 13
Prepare SummaryReport
and accurate notes should be kept in a
bound notebook. Pre-incident conditions,
the incident sequence, and post-incident
conditions are recorded. In addition, the
location of victims, witnesses, machinery,
energy sources, and hazardous materials
should be documented.
In some investigations, a particular physi-
cal or chemical law, principle, or property
may explain a sequence of events. These
laws should be gathered in the notes taken
during the investigation or during the anal-
ysis of data In addition, during the investi-
gation, data should be gathered that may
lend itself to analysis by these laws, princi-
ples, or properties. The report can include
an appendix in the final report with an ex-
tended discussion.
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C PTER G
Laboratory Emergency Management
G4. Investigation and Analysis
2.2 Interviews
In general, experienced personnel should
conduct interviews, If possible, the team
assigned to this task should include an
individual with a legal background. In
conducting interviews, the team should:
• Appoint a speaker for the group.
• Get preliminary statements as soon as
possible from all witnesses.
• Locate the position of each witness on
a master chart (including the direction
of view).
• Arrange for a convenient time and
place to talk to each witness.
• Explain the purpose of the investiga-
tion (incident prevention) and put each
witness at ease.
• Listen, let each witness speak freely,
and be courteous and considerate.
• Take notes without distracting the wit-
ness. Use a tape recorder only with
consent of the witness.
• Use sketches and diagrams to help the
witness.
• Emphasize areas of direct observation.
Label hearsay accordingly.
• Be sincere and do not argue with the
witness.
• Record the exact words used by the
witness to describe each observation.
Do not “put words into a witness’
mouth.”
• Word each question carefully and be
sure the witness understands.
• Identify the qualifications of each wit-
ness (e.g., name, address, occupation,
years of experience, etc.).
• Supply each witness with a copy of his
or her statements. Signed statements
are desirable.
After interviewing all witnesses, the team
should analyze each witness’ statement.
They may wish to re-interview one or
more witnesses to confirm or clarify key
points. While there may be inconsistencies
in witnesses’ statements, investigators
should assemble the available testimony
into a logical order. This information is
analyzed along with data from the incident
site.
Not all people react in the same manner to
a particular stimulus. For example, a wit-
ness who was near the incident may have
an entirely different story from one who
saw it at a distance. Some witnesses may
also change their stories after they have
discussed it with others. The reason for
the change may be additional clues.
A witness who has had a traumatic experi-
ence may not be able to recall the details
of the incident. A witness who has a
vested interest in the results of the investi-
gation may offer biased testimony. Finally,
eyesight, hearing, reaction time, and the
general condition of each witness may
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C PT G
Laboratory Emergency Management
04. Investigation and Analysis
affect his or her powers of observation. A
witness may omit entire sequences because
of a failure to observe them or because
their importance was not realized.
3.0 Cause Analysis
There are three approaches to incident
cause analysis: simple, team, and complex.
Which approach is used depends on the
severity of the incident that has occurred
in the laboratory. A laboratory’s incident
investigation program should specify the
approach and requirements to be met
regarding analysis for each class of
incident.
For example, a simple root cause analysis
can be perfonned if the investigator con-
tinually asks the question “Why did the
incident happen?” This line of questioning
is completed until all possibilities are
exhausted. A more systematic approach
is to provide a list of simple yes/no ques-
tions that deal with four major areas:
equipment. environment, people and
management. The investigator responds
to each question, and a yes answer is con-
sidered to be a cause of the incident.
As the incident classification scale
increases, the analysis becomes more
formal. The more complex analyses
usually involve inductive analyses (as
discussed in section 3.3.2 of this chapter),
or some other system-safety method of
cause analysis. In some cases, these meth-
ods may be used by a facilitator trained
in the selected method for analysis of an
incident.
Once the laboratory has adopted an
approach to analysis of incidents, specific
training in the chosen methods should take
place. This provides the investigator, who
is usually the SHEMP Manager or princi-
pal investigator, a guide to completing the
analysis. As a result, systems are reviewed
for possible root causes.
The following sections discuss analysis
approaches in greater detail.
3.1 Simple Root Cause Analysis
Simple root cause (SRC) analysis
does not imply a less concerted effort
to uncover and identify root causes. It
does, however, provide a quick-and-easy
systematic approach to cause analysis for
low-consequence incidents. Simple root
cause analysis is typically performed by
the principal investigator or SHEMP
Manager when an incident or “near miss”
occurs.
SRC requires the principal investigator or
SHEMP Manager to repeatedly ask three
questions:
• Why did the incident or “near miss”
occur?
• What was the underlying cause?
• Was there a system-related deficiency
or weakness?
The first thing to do after gathering and
analyzing the evidence is to develop a
chronological list of the events leading
up to the incident. Another helpful tool
is to use a logic tree. A logic tree is similar
to a fault tree in that you place events and
causes in boxes starting with the top
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CHAFrER 0
Laboratory Emergency Management
04. Investigation and Analysis
vent—the consequence (e.g., injury)— and
work backwards, tracing the causes lead-
ing to the injury.
3.2 Team Root Cause Analysis
A team approach to determining incident
cause is performed using the issues analy-
sis root cause technique. This technique
applies structured logic to finding the root
causes of an incident by:
• Asking “What is the critical question
in the investigation?”
• Focusing on the logic of the answer
• Providing a framework for manage-
ment action
By breaking down the overall incident
issue into separate issue topics, the prob-
lem of identifying root causes becomes
more manageable. It also keeps the analy-
sis team from overlooking key issues by
rushing down a deductive tree.
The issue breakdown will depend on the
situation. Each issue topic should answer
the question raised at the next higher level.
The issues-as-questions structure can be
taken down several levels. After the first
two to three sublevels, deductive processes
begin to identify specific causes for indi-
vidual issues.
The team should focus on answering the
question “Why did this occur?” until all
the fundamental system problems have
been identified. Questions should suggest
a hypothesis, and that hypothesis should
focus on the root causes once the team has
finished identifying all of the issues and
individual issue topics. The team then
develops fact/hypothesis matrices for
each issue.
Issues should then be used to develop
hypotheses that orient the evidence.
Should evidence disprove the hypothesis,
the issue is not considered a true cause.
If there is insufficient evidence to prove
or disprove the hypothesis, the team needs
to go back and gather additional evidence
or rethink the logic, If the evidence proves
the hypothesis, a root cause results is
determined.
The team should now perform three tests:
• The first test is for completeness. At
this stage, answer the question, “Does
it look complete?”
• The second test is to answer the
question, “Are the causes related to
systems?”
• Finally, answer the question, “Are
there any othet causes you had in mind
that are not shown?”
If the answer to any of the three tests is
yes, the evidence should be reexamined,
more evidence gathered, and/or answers to
the questions checked to confirm the logic.
If the tests are answered no, corrective
actions should be developed, follow-up
performed, and a report prepared.
3.2.1 Team Meeting Pre.Work
The first step after the gathering and analy-
sis of evidence is to complete some pie-
work prior to the first team meeting. The
following is a short list of materials that
should be available in the team room:
• Chronology of events (time line)
• Schematic diagram of the physical
layout, plot plan, and elevations as
needed to show location and events
• Flow sheets, loop sheets, operating
instructions, job safety analyses, etc.
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Laboratory Emergency Management
G4. Investigation and Analysis
• Photographs and video footage
• Documentation logs for evidence
3.2.2 Team Meeting
Next, the team meeting is called. The
meeting should be held in a room with
minimal outside distractions. The room
should be set upto facilitate team interac-
tion. It should also have flip charts, note
pads, tape, self-stick removable notes, etc.
The team leader should kick off the meet-
ing by presenting an overview of the inci-
dent, the sequence of events, and major
facts.
Once this is completed, the team can select
a facilitator for the meeting to keep the
process moving and on track. The facilita-
tor should be a person trained in root cause
analysis techniques. Once the team has
identified all issue topics and tested the
hypothesis against the facts, the agreed-
upon root causes should be listed. Before
progressing to identification of corrective
actions, the three tests for completeness
should be done. Finally, the report should
be drafted, reviewed, and approved by all
team members.
The easiest way to proceed is to use self-
adhesive removable notes to lay out the
issues tree. The facilitator should ask the
team to identify the key issue at the top
of the tree and each subsequent level by
developing yes/no questions that must
be answered to prevent the incident from
happening again.
Some people like to complete a bullet list
of key issues before the team meets. This
can help to move the process along and
get the team comfortable with the logic.
Remember that the first two to three levels
should be inductive, meaning independent,
of each other. This will provide the big
picture and keep the investigation from
missing other possible root causes. In
certain complex investigations, it may be
wise to use issues analysis during the gath-
ering of evidence as a check on where the
investigation is going.
After all of the major issues have been
identified, select one issue and complete
a deductive analysis by continuing to ask
“why?’ Once the team feels they have
exhausted all the possibilities, use the
completeness tests as a quick check on
the issues tree. A quick check is whether
or not a hypothesis can be developed from
the key-issue level of the tree.
During the meeting, the leader may need
to facilitate the team. Total quality man-
agement (TQM) tools can be helpful. If
the team gets stuck on an issue, try brain-
storming and group voting. Use of fish-
bone diagrams (see example in Figure
(34-1), flow charts, and selection grids
can all aid in the analysis process.
Fact/hypothesis matrices should be com-
pleted next for all of the issues on the flip
chart; one page for each issue. Once the
fact/hypothesis matrices are complete, the
completeness test is conducted on the
whole process. Finally, corrective actions,
report writing, and follow-up are per-
formed. Team participation is key during
the analysis. This process requires time. It
may take as little as a few hours or as long
as a couple of days.
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Laboratory Emergency Management
Figure G4-1: Example of a Fishbone Diagram
G4. Investigation and Analysis
MATERLAL
3.3 Complex Analysis
The principal objective of the investigation
and analysis process is to find root causes
by applying systematic methods for col-
lecting information about the cause. Two
systems-oriented techniques that are used
for complex analysis of an incident are
deductive analysis and inductive analysis,
as described below.
3.3.1 Deductive Analysis
Deductive analysis begins at the occur-
rence of the incident and works backward
in time to determine the root causes of the
incident. Examples of deductive analysis
techniques include Fault-tree Analysis
(FFA) and Management Oversight and
Risk Tree (MORT) analysis.
Fault-Tree Analysis
A fault-tree is a symbolic logic diagram
that shows the cause-and-effect relation-
ship between an undesirable event and
one or more contributing causes. The
undesired event appears as the top event
on the tree, and is linked to the basic logic
gates (the “and” gate and the “or” gate). A
rectangular box denotes a “failure” event,
and a circle designates a “basic” event. To
solve the fault-tree one must find the root
cause(s) or a group of basic events that
will cause the top event to occur. This set
of root cause(s) is known as a “minimal
cut set.” Figure G4-2 shows an example of
a fault-tree.
OPERATOR 1
Minor Bones are
Subdivisions of
Major Categories
Fish Head
Major Bones are Major Categories
&EPA June 1998
04-9
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SFIEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management
Figure G4-2: Example Fault-Tree
04. Investigation and Analysis
Management Oversight and Risk Tree
Analysis
The basic MORT diagram consists of four
elements presented in Table 04-3.
The MORT technique is based on a tree
structure laid out vertically and is usually
associated with a checklist. As with most
of the analytical techniques for incident
investigation and analysis, MORT is not
considered to be a field technique. It is
used as a tool to review evidence brought
in from the site.
3.3.2 Inductive Analysis
Inductive analysis uses an overview
method of evaluating the entire situation
with techniques such as a Hazard and
Operability Study (HAZOP). The HAZOP
analysis technique is used to identify and
evaluate safety, health, and environmental
(SHE) hazards and to identify operability
problems throughout the entire laboratory.
In the HAZOP technique. a team uses a
structured, systematic brainstorming ses-
sion to identify hazards and operability
problems.
EVENT
NORMAL EVENT
- - EVENT-
COMPLETE
A CONNECFO
T EANSFER
‘AND GATE
IlL
• - AND GATE
OR GATE
SLWAT
OUTSIDE
DOOR
• —
IN ATTENTION .-‘ATrEmo -.
TO WAIZING . TO WALK1NG
LOW VRICTION
:• coRinLE)
HIGHLY 1 WET
WAXEDj
Ic _
[ .• i L!
June 1998
G4- 10
-------
SHEMP Operations Manual for Laboratories
CHAPTER 0
Laboratory Emergency Management
Table G4-3: Elements of MORT Diagram
04. Investigation and Analysis
Element I
Investigation of potentially harmful energy flows or environmental
conditions
Element 2
People or objects vulnerable to an unwanted energy flow
Element 3
Failure or lack of bathers and controls that are designed to keep
potentially harmful energy away from people or objects
Element 4
Precursor event
The final conclusions of the discussions
concerning the causes, effects, and safe-
guards for deviations in each section of
the process should be completely docu-
mented to facilitate further review.
The overall results of a HAZOP analysis
are the findings, which include identifica-
tion of hazards and operating problems,
and recommendations for changes in
design procedures to improve safety.
4.0 Reporting
An incident investigation is not complete
until a report is prepared and submitted to
proper authorities. The final report must
be clear, concise, and able to summarize
the investigation by:
• Processing findings
• Analyzing conclusions
• Identifying the most probable cause(s)
• Outlining what has been or is being
done to prevent a similar incident
Special report forms arc available in
many cases. Other instances may require
a more extended report. Such reports are
often very elaborate and may include a
cover page, a title page, an abstract, a
table of contents, a commentary or narra-
tive portion, a discussion of probable
causes, and a section on conclusions and
recommendations. Table 04-4 includes
useful information to be included in the
report.
Finalized copies of the report should be
submitted to the following without delay:
• Laboratory Director
• SHEMP Manager
• Principal Investigator
EPA June 1998
G4-1 I
-------
SHEMP Operations Manual for Laboratories
CHAPTER G
Laboratory Emergency Management G4. Investigation and Analysis
Table G4-4: Information for Accident/Incident Investigation Report
1. Background Information
• Where and when the incident occurred
• Who and what were involved
• Operating personnel and other witnesses
2. Account of the Incident (What Happened?)
• Sequence of events
• Extent of damage
• Incident type
• Agent or source (of energy or hazardous material)
3. Discussion (Analysis of the Incident—How; Why)
• Direct causes (energy sources; hazardous materials)
• Indirect causes (unsafe acts and conditions)
• Basic causes (management policies; personal or environmental factors)
4. Recommendations for immediate and long-range action
EPA June 1998 04-12
-------
SHEMP Operations Manual for Laboratories
CHAPTER 0
Attachment G4-1: Sample Incident Investigation Form
Purpose: To perform a causal analysis of laboratory incidents.
Instructions: Select an independent review team to conduct an evaluation of an incident.
All team members should first receive training on how to conduct an effec-
tive incident investigation.
EP 6 June 1998 04-13
-------
INCiDENT INVESTIGATION REPORT
CASE NUMBER
EPA LABORATORY
DEPARThIENT
ADDRESS
LOCATION
1. Name of Injured
2. Social Secunly Number 3. Sex
oMcn
7 Employee’s Usual Occupation
4. Age 5. Date of Incident
8. Occupation at Tune of Incident
& Home Address
Street Apt. #
9. Length of Employment
ti Less than 1 mo. 0 6 moe. SoS s.
C I SoS moe. 0 More than 5 yrs.
10. Tune in Occup. as Tune of Incident
C Less than I mo 06 moe. to 5 yTS.
0 ito 5 moe. C More than 5 yrs.
City State Zip Code
11. Employment Category
o Regular, full-time 0 Teinpcral7
0 Non-employee 0 Seasonal
o Regular, part-time
12. Case Numbers and Names of Others Injured in Same Incident
Case Number Name
13. Nature of lnjwyand Part of Body
CaseNumber Name
Case Number Name
14. Name and Address of Physician
16. rum of lnjwy
A. A.MJP.M.
B. lime within shift 0 Yes 0 No
C. Type of shift:___________
17. Seventy of Injury
0 Fatality
O Lost workday
O Restricted work activity
0 Medical u’eaunent
0 First aid
() • Specify
Name
Address
15. Name and Address of Hospital
Name
Address
I L Specific Location of Incident 19. Phase of Employee’s Workday at Time of injury
Building/Room 0 During rest period 0 Entering or leaving plant
0 During meal period C Performing work duties
On Employer’s Premises? 0 Yes 0 No 0 Working overtime 0 Other
20. Describe How the Incident Occurred
-------
CASE NUMBER
EPA LABORATORY
DEPARTh1ENT
ADDRESS
LOCATION
21. Incident Sequence: Describe, in reverse order of occurrence, the events preceding the incident. Starting with the
injuiy and moving backward in time, reconstruct the sequence of events that led to the injury.
A. Injury Event
B. Incident Event
C. Preceding Event #1
D. Preceding Event #2, #3, etc.
22. Task and Activity at Time of Incident
A. General type of task
B. Specific activity
C. Employee was working
D Alone D With crew or fellow worker
0 OthC sP CifY
23. Posture of Employee
24. Supervision at Time of Incident
I D Directly supervised I D Not supervised
0 Indirectly supervised ID Supervision not feasible
25. Causal Factors (events and conditions that coniributed to the incident):
26. Corrective Actions: Those that have been, or will be taken to prevent recurrence.
Prepared By
Approved
Title____________________________
Department Date
Title Dare_______
ApproVcd —
-------
Bibliography
-------
SHEMP Operations Manual for Laboratories
Bibliography
US. Federal Regulations
Department of Transportation (DOT)
49 CFR Part 172
Hazardous Materials Table, Special Provisions, Hazardous Materials Coinmuni-
cations, Emergency Response Information, Training Requirements
49 CFR Part 173
Shippers—General Requirements for Shipments and Packaging
49 CFR Part 177
Carriage by Public Highway
Environmental Protection Ag
ency (EPA)
General Provisions
Standards of Performance for Industrial/Commercialllnstitutional Steam Generat-
ing Units
Standards of Performance for Small Industrial/Commercial/ Institutional Steam
Generating Units
General Provisions
National Emission Standards for Radionucide Emissions from Federal Facilities
Other than Nuclear Regulatory Commission Licensees and Not Covered by
Subpart H
National Emission Standard for Asbestos
Risk Management Program
Federal Opeianng Permit Program
State Operating Permit Program
Protection of Stratospheric Ozone
Clean Water Act
Oil Pollution Prevention
EPA Administered Permit Programs: The National Pollutant Discharge Elimina-
tion System
Resource Conservation and Recovery Act
Hazardous Waste Management System: General
Identification and Listing of Hazardous Waste
Standards Applicable to Generators of Hazardous Waste
Clean Air Act
40 CFR 50-80
40 CFR 60, Subpart A
40 CFR 60, Subpart Db
40 CFR 60, Subpart Dc
4OCFR6I, Subpart A
4OCFR6I, Subpart I
40 FR61, SubpartM
40 CFR 68
40 CFR 70
40 CFR 71
40 CFR 82
4OCFR 100-140, 400-470
40 FR 112
4OCFR 122
40 CFR 240-271
40 CFR 260
40 CFR 261
40 CFR 262
EPA June 1998
Bibliography-i
-------
SHEMP Operations Manual for Laboratories
Bibliography
U.S. Federal Regulations
Environmental Protection Agency (EPA) (continued)
40 CFR 263
40 CFR 264
Standards Applicable to Transporters of Hazardous Waste
Standards for Owners and Operators of Hazardous Waste Treatment, Storage,
and Disposal Facilities
40 CFR 265
40 CFR 266
40 CFR 268
40 CFR 270
40 CFR 272
40 CFR 300
Interim Status Standards for Owners and Operators of Hazardous Waste Treat-
ment, Storage, and Disposal Facilities
Standards for the Management of Specific Hazardous Wastes and Specific Types
of Hazardous Waste Management Facilities
Land Disposal Restrictions
EPA Administered Permit Programs: The Hazardous Waste Permit Program
Approved State Hazardous Waste Management Programs
National Oil and Hazardous Substances Pollution Contingency Plan
Food and Drug Administration (FDA)
50 CFR 161
21 CFR 1020.40
21 CFR Chapter 1
Performance Standard for Laser Products, 1985
Cabinet X-ray Systems
Regulations for the Administration and Enforcement of the Radiation Control
For Health and Safety Act of 1968 (Lasers), 1968
Nuclear Regulatory Commi on (NRC)
10 CFR 19
10 CFR 20
10 CFR 30
10 CFR 71
Notices, Instructions and Reports to Workers; Inspection and Investigations
Standards for Protection Against Radiation
Rules of Genera] Applicability to Domestic Licensing of Byproduct Material
Packaging and Transportation of Radioactive Materials
Occupational Safety and Health Administration (OSRA)
29 CFR 1904
29 CFR 1910
29 CFR 1910.20
29 CFR 1910.38
29 CFR 1910.95
29 CFR 1910.97
Recording and Reporting Occupational Injuries and Illnesses
Occupational Safety and Health Standards for the General Industry
Access to Employee Exposure and Medical Records
Employee Emergency Plans and Fire Prevention Plans
Occupational Noise Exposure
Ionizing Radiation Standards
EPA June 1998 Bib liography-2
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SHEMP Operations Manual for Laboratories
29CFR 1910.119
29 CFR 1910.120
29 CFR 1910.132
29 CFR 1910.133
29 CFR 1910.134
29CFR 1910.135
29CFR 1910.136
29 CFR 1910.157
29 CFR 1910.159
29 CFR 1910.1000
29CFR 1910.1001
29CFR 1910.1003-16
29 CFR 1910.1017
29 CFR 1910.1018
29 CFR 1910.1025
29 CFR 1910.1027
29 CFR 1910.1028
29CFR 1910.1030
29 CFR 1910.1044
29CFR 1910.1045
29CFR 1910.1047
29CFR 1910.1048
29 CFR 1910.1050
29CFR 1910.1051
29 CFR 1910.1052
29CFR 1910.1096
29CFR 1910.1450
29CFR 1910.1200
Asbestos
Carcinogens (specific chemicals)
Vinyl Chloride
Arsenic (inorganic)
Lead
Cadmium
Bibliography
U.S. Federal Regulations
Occupational Safety and Health Administration ( OSHA) ( continued )
Process Safety Management Standard
Hazardous Waste Operations and Emergency Response
General Requirements: Personal Protective Equipment
Eye and Face Protection
Respiratozy Protection
Head Protection
Foot Protection
Portable Fire Extinguishers
Automatic Sprinkler Systems
General Air Contaminants
Benzene
Occupational Exposure to Bloodborne Pathogens
1 2.dibromo-3-chloropropane (DBCP)
Acry lonitiile
Ethylene Oxide
Formaldehyde
Methylenedianiline (MDA)
I ,3-Butadiene
Methylene Chloride
Nonionizing Radiation Standards
Occupational Exposure to Toxic Substances in Laboratories
Hazard Communication
&EPA June 1998
Bibliography-3
-------
SHEMP Operations Manual for Laboratories
Bibliography
US. Federal Regulations
29 CFR 1926
Safety and Health Regulations for Construction
29 CFR 1960
Basic Program Elements for Federal Employee OSH Programs and Related
Matters
Occupational Safety and Health Administration ( OSBA) ( continued )
June 1998
Bib liography-4
-------
SHEMP Operations Manual for Laboratories
Bibliography
Regulatory Guidelines
Center for Disease Control/National Institutes of Health (CDC/NIH)
Biosafety in Microbiological and Biomedical Laboratories, Second Edition, May 1988.
Class fi cation of Etiologic Agents on the Basis of Hazard, U.S. Department of Health, Education and Welfare,
Public Health Service, 1976.
Department of Energy (DOE)
DOE/EH-0053-1987 The Environmental Survey Manual
Department of Health and Human Services
Biosafery Guidelines for Use of FITL V-Ill and Related Viruses, Federal Register, Vol. 49,40556, 1984.
EPA Orders
EPA Order 3500.1 Training and Development for Compliance Inspectors /Field Investigators
EPA Safety, Health and Environmental Management (SHEM) Guidelines
SHEM Guide 23
SHEM Guide 24
SHEM Guide 37
SHEMGu1de4 I
SHEM Guide 53
Chemical Handling and Storage
Chemical Hygiene
Occupational Noise
Mixed Waste
Workplace Inspections
Occupational Safety and Health Adnthiictratlon (OSHA) Instructions
FAPI .3
CPL 2-2.20B
CPL 2.103
CPL 2.243
Federal Agency Safety and Health Programs
Technical Manual
Field Inspection Reference Manual (FIRM)
Chemical Information Manual
National Council on Radiation Protection and Measurements (NCRP)
NCRP 54-July 1977 Medical Radiation Exposure of Pregnant and Potentially Pregnant Women
National Fire Protection Association (NFPA)
NFPA 10-1994
NFPA 11-1994
NFPA IIA-1994
NFPA 12-1993
Standard for Portable Fire Extinguishers
Standard forLow-Expansion Foam
Standard for Medium- and High-Expansion Foam Systems
Standard on Carbon Dioxide Extinguishing Systems
q,Eg4 June 1998
Bibliography-5
-------
SHEMP Operations Manual for Laboratories
Bibliography
National Fire Protection Association (NFPA) (continued)
Regulatory Guidelines
NFPA 13-1996
NFPA 17-1994
NFPA 30-1996
NFPA 45-1996
NFPA 72-1996
NFPA 77-1993
NFPA 91-1995
NFPA 99-1996
NFPA 101-1997
NFPA 325-1994
Standard for the Installation of Sprinkler Systems
Standard for Dry Chemical Extinguishing Systems
Flammable and Combustible Liquids Code
Standard on Fire Protection for Laboratories Using Chemicals
National Fire Alarm Code
Recommended Practice on Static Electricity
Standard for Exhaust Systems for Air Conveying of Materials
Standard for Health Care Facilities
Life Safety Code
Fire Hazard Properties of Flammable Liquids, Gases, and Volatile Solids
National Institute for Occupational Safety and Health (NIOSH)
Development of Performance Criteria for Protective Clothing Used Against Carcinogenic Liquids, 1978.
Occupatitmal Exposure Sampling Strategy Manual, U.S. Department of Health, Education, and Welfare, DHEW
Publication No. 77-173, current edition.
Recommended Industrial Ventilation Guidelines, U.S. Dept. of Health, Education and Welfare, DHEW Pub. No.
76-162, January 1976.
Nuclear Regulatory Commission Regulatory Guides
Guide 8.29-1981 Instruction Concerning Risks From Occupational Radiation Exposure
Guide 8.13- 1987 Instruction Concerning Prenatal Radiation Exposure
Underwriters Laboratories, Inc. (UL)
UL 1740-1995 Standard for Industrial Robots and Robotic Equipment
aEPA June 1998
Bibliography-6
-------
SHEMP Operations Manual for Laboratories
Bibliography
Industry Standards
American Conference of Governmental Industrial Hygienists ( ACGIH )
Air Sampling Ins:rwnents for Evaluation of Atmospheric Contaminants, ACGIH, 6th Edition, 1983.
Industrial Ventilation: A Manual of Recommended Practice, ACGIH, 22nd Edition, 1995.
Guidelines for the Selection of Chemical Protective Equèpment, ACGUI, 2nd Edition, 1985.
Threshold Limu Values for Chemical Substances and Physical Agenr.t and Biological Exposure Indices, ACGIH,
1992.
American Industrial Hygiene Association (AIHA)__________________________
Biosafety Reference Manual, Second Edition, 1995.
Direct Reading Colorimetric Indicator Tubes Manual, current edition.
Air Pollution Manual, Volumes I and II, current editions.
Chemical-Resistance Guide, ARA1 4SCO Safety Supplies and Equipment for the Hazardous Environment.
American National Standards Institute ( ANSI )
ANSI Z9.5-1992 Laboratory Ventilation
ANSI 241.1-1991 Men’s Safety-Toe Footwear
ANSI N43. 1-1978 Radiological Safety in the Design and Operation of Particle Accelerators
ANSI N43.2-1978 Radiation Sakty for X-ray Diffraction and Fluorescence Analysis Equipment
ANSI N43.3-1993 Installations Using Non-Medical X-ray and Sealed Gamma-Ray Sources,
Energies Up to 10 MeV
ANSI 287-1989 Occupational and Educational Eye and Face Protection
ANSI 289.1-1986 Protective Headwear for Industrial Workers
ANSI 101-1985 Men’s Limited-Use and Disposable Protective Coveralls—Size and Labeling
Requirements
ANSI Z358.1- 1998 Emergency Eyewash and Shower Equipment
ANSI 2136.1-1993 Safe Use of Lasers
ANSI 2136.2-1988 Safe Use of Optical Fiber Communication Systems Utilizing Laser Diode and
LED Sources
ANSI Z136.3 -1988 Safe Use Lasers in the Health Care Environment
June 1998 Bibliography-i
-------
SHEMP Operations Manual for Laboratories
Bibliography
Industry Standards
Amencan Society for Testing and Mateiials (ASTM)
ASTM STP 900
ASTM STP 900
Perfonnance of Protective Clothing: Effectiveness of Selected Work Fabrics as
Barriers to Pesticide Penetration
Performance of Protective Clothing: Influence of Film Thickness on the Perme-
ation Resistance, Properties of Unsupported Glove Films
Compressed Gas Association (CGA)
Soft Handling of Compressed Gases in Containers, 1984.Compressed Gas Association (CGA) Manual
&EPA June 1998
Bib liography-8
-------
SHEMP Operations Manual for Laboratories
Bibliography
Publications
Carroll, T.R., and Schwope, A.D., “The Selection and Measurement of Physical Properties for Characterization of
Chemical Protective Clothing,” Final Report, U.S. EPA, 1989.
Chamberlin, R.L, and Leahy, J.E., “A Study of Laboratory Fume Hoods,” U.S. EPA, 1978.
Collins, C.H., Laboratory-Acquired infections, Butterworths, Boston, 1983.
DiBerardinis, Louis 3, et. al., Guidelines/or Laboratory Design: Health and Safety Considerations. JohnWiley
& Sons, New York, 1987.
Doyle, D.J. and Kokosa, J.M., “Hazardous By-Products of Plastics Processing with Carbon Dioxide Lasers.” in:
Laser Welding, Machining and Materials Processing: C. Aibright, Ed. Proceedings of ICALEO, IFS LTD.,
Bedford, U.K., 1985.
Eastern Environmental Radiation Facility, EERF89, Sue Safety Plan For Desert Glow Operations, Eastern
Environmental Radiation Facility, U.S. Environmental Protection Agency, Office of Radiation Programs,
Montgomery, AL, June 1, 1989.
Eastman Kodak Company, Human Factors Section, Ergonomic Design/or People. Vol. I and Vol. U, Van
Nostrand Reinhold Co., New York. NY, 1986.
EPA/RTP Safety Manual, Office of Research and Development, Research Triangle Park. NC, March 1995.
“Field Standard Operating Procedure (FSOP) Number 4- Site Entry,” Office of Emergency and Remedial
Response, Hazardous Response Support Division, 1985.
Forsberg, K., and Keith, L.H., Chemical Protective Clothing Performance index, Wiley Interscience, New York,
1988.
“Framework for Environmental Health Risk Management,” The Presidential/Congressional Commission on Risk
Assessment and Risk Management, Final Report, Volume 1, 1997.
Franke, V.H., and Nordin, M., Basic Biomechanics of the Skeletal System. Lea and Febiger: Philadelphia, PA,
1980.
Fuller, F.H., and Etchells, A.W., “The Rating of Laboratory Hood Performance,” ASHRAE Journal, pp. 49-53,
October 1979.
Fundamentals of industrial Hygiene, Third Edition, P10g. B. ed., National Safety Council, 1988.
Fuscaldo, A.A., Erlich, BJ., and Hindman, B. (eds.), Laboratory Safety - Theory and Practice, Academic Press,
New York, 1980.
Gaffiiey, L.F., et al., “Field Testing and Performance Certification of Laboratory Fume Hoods,” presented at
Industrial Hygiene Conference, May 1980.
Grandjean, E., Fitting the Task to the Man: A Textbook of Occupational Ergonomics, Taylor and Francis,
Philadelphia, PA, 1988.
Guidelines/or Research Involving Recombinant DNA Activity, Federal Register, Vol. 51, 1986, pp. 16957-16985.
Hatayazna, H.K., et al., A Method for Determining the Compatibility of Hazardous Waste, EPA Document 60012-
80-076, U.S. Government Printing Office, Washington, D.C., 1980.
EPA June 1998 Bibliography-9
-------
SHEMP Operations Manual for Laboratories
Bibliography
Publications
Hatch and Gross, AIHA-AEC, Pulmonary Deposition and Retention of inhaled Aerosols, Academic Press,
McLean, VA, 1964.
Hazardous Waste Handling and Disposal Procedures, Appendix S, EPA NHEERL Gulf Ecology Division.
Henry Dreyfiiss Associates, Humanscale, Massachusetts Institute of Technology Press: Cambridge, MA, 1974.
Hesketh, Fine Particles in Gaseous Media, Lewis Publishers, 1986.
industrial Hygiene Engineering; Recognition, Measurement, Evaluation, and Control, Tally, JR. Noycs Data
Corporation, New Jersey, 1988.
Jackson, uS., McCormack W.B., Rondestvedt, G.S., Smeltz, K.C., and Viele, I.E., “Safety in the Chemical
Laboratory,” Journal of Chemical Education, Vol.47, No.3, A176, March 1970.
Mandatory Training Requirements for OSCs Area RPMs, OSWER Directive 9285 .9-05.
Mandatory Community Relations Training—Superfund Management Review implementation Project, OSWER
Directive 9285.9-06.
Keith, L.H., Gloves +, An Expert System, Lewis Publishers, Chelsea, MI, 1990.
Konz, S., Work Design; industrial Ergonomics, 4th ed., Publishing Horizons Inc., 1995.
limiting Values of Radionuclide intake and Air Concentration and Dose Conversion Factors for inhalation,
Submersion, and ingestion, Federal Guidance Report No. 11, US EPA 520/1-88-020, September 1988.
Lodge, Methods of Air Sampling and Analysis, Lewis Publishers, Chelsea, MI, 1988.
Loennil at al., Journal of Virology, Vol. 66, No. 3, 1992, pp. 1649-1654.
Long, MU., Chapter 700, “Emergency Planning and Response,” Chemical Process Safety Report, Thompson
Publishing Group, Inc., 1992.
Long, M.H., “Fire Protection of Laboratories Using Chemicals,” Fire Protection Handbook, 18th edition, 1997.
Long, MU, and Larocque, G.R., “Business Interruption Risk Assessment: A Multidisciplinary Approach,”
Presented at the 4th Annual Corporate Contingency Planning Seminar, Palm Springs, California, March 1993.
Long, M.H., Chapter 12, “Emergency Response Planning.” Guidelines for Aud iting of Process Safety Manage-
ment Sys:em.s, Center for Chemical Process Safety (AIChE), 1993.
Long, M.H., “Risk-based Disaster Management” Presented at the 50th Annual Federal Safety and Health
Conference, Dallas, Texas, November 1995.
McDermott, Hi., Handbook of Ventilation for Contaminant Control, Second Edition, Bunerworth Publishing,
1985.
Michelsen, R.L, Roder, MM., and Berardinelli, S.P., “Permeation of Chemical Protective Clothing by Three
Binary Solvent Mixtures,” Journal of the American industrial Hygiene Association Vol. 47, pp. 236-240, 1986.
Mickelsen, R.L. and Hali, R.C., “A Breakthrough Time Comparison of Nithie and Neoprene Glove Materials
Produced by Different Glove Manufacturers,” Journal of the American industrial Hygiene Association, Vol. 48,
pp. 941-947, 1987.
a EPP June 1998 Bibliography-b
-------
SHEMP Operations Manual for Laboratories
Bibliography
Publica Ions
Miller, C.D., Songer, J.R., and Sullivan, J.F., “A Twenty-Five Year Review of Laboratory-Acquired Human
Infections at the National Animal Disease Center,” American industrial Hygiene Association Journal, Vol. 48,
No. 3, 1987 pp. 27 1-275.
Miller, R.L., The industrial Hygiene Handbookfor Safety Specialists, Hanrow Press, Columbia, MD, 1984.
Mond, C., Jantz, C., Schwope, A.D., and Stricoff, R.S., Predicting Dexterous Performance of a Gloved Hand,
Report to Radian Corporation, National Institute for Environmental Health and Scienc, 1987.
National Sanitation Foundation Standard No. 49 for Class!! (Laminar Flow) Biohazard Cabinetry, The National
Sanitation Foundation, Ann Arbor, Michigan, Fifth Draft, May 1991.
Pepitone, D.A., Ed., Safe Storage of Laboratory Chemicals, John Wiley and Sons, New York, 1984.
“Personnel Protection and Safety Course-165.2,” Course Manual, July 1988.
Pheasant, S., BodySpace, Taylor and Francis: Bristol, PA, 1986.
“Procedure for Certifying Laboratory Fume Hoods to Meet EPA Standards,” SHEMD-TSEB, July 9, 1997.
Prudent Practices frr Handling Hazardous Chemicals in Laboratories, National Research Council, Washington,
D.C., 1983.
Putz-Anderson, V., Cumulative Trauma Disorders: A Manual for Musculoskd eta! Disorders of the Upper Limbs,
Taylor and Francis. Philadelphia, PA, 1988.
Radiation Safety Manual, National Air and Radiation Environmental Laboratory, Office of Radiation Programs,
US EPA, January 1991 (Rev.1).
Rockwell, R. James, Jr. and Moss, C.E., “Optical Radiation Hazards of Laser Welding Processes, Part II; Carbon
Dioxide Laser,” The Journal of The American Industrial Hygiene Association, 50(8): 419-427, August 1989.
Rockwell, R. and James, Jr., “Laser accidents: are they all reported and what can be learned from them?” Journal
of Laser Applications, Laser Institute of America, Toledo, Ohio, pp. 53-57, October 1989.
Rockwell, R. James, Jr., Ed., Laser Safety Training Manual - Sixth Edition, Rockwell Associates, Inc., Cincinnati,
Ohio, 1989.
Rockwell, R. James, Jr. and Moss, C.E., “Optical radiation hazards of laser welding processes, part I: Nd:YAG
laser,” The Journal of The American Industrial Hygiene Association, 44(:8): 572-579, August 1983.
Rockwell, R. James, Jr., “Ensuring safety in laser robotics,” Lasers and Applications, 3(11): 65-69, November
1984.
Rockwell, R. James, Jr., ‘Pundanientals of Industrial Laser Safety” Industrial Laser Annual Handbook, M. Levitt
and D. Belforie, Eds. Penn Well Books, Tulsa, OkIa., pp. 131-148, 1986.
Safe Vessel Specification Manual, US EPA Manual, March 1992 (Draft)
“Safety Information on Electrical Hazards,” Laser News, Laser Institute of America, 6(5): 8-14, September 1984.
Sansone, E.B., and L.A. Jonas, “The Effect of Exposure to Daylight and Dark Storage on Protective Clothing
Material Permeability,” Journal of the American Industrial Hygiene Association, Vol. 42, pp. 841-843, 1981 .
EPA June 1998 Bibliography-i I
-------
SHEMP Operations Manual for Laboratories
Bibliography
Publications
Sansone, E.B., and YB. Tewan, “Differences in the Extent ol’ Solvent Penetration through Natural Rubber and
Nitrile Gloves from Various Manufacturers,” Journal of the American industrial Hygiene Association, Vol. 41,
pp. 527-528, July 1980.
Schwope, A.D., Preliminary Assessment of Life-cycle Costs of Protective Clothing, Final Report, U.S. Environ-
mental Protection Agency, Office of Research and Development, Contract No. 68-03-3293, Work Assignment 1-
06-5.1, Cincinnati, Ohio, 1989.
Schwope, AD., et al., Guidelines for the Selection of Chemical Protective Equipment, 2nd Edition, American
Conference of Governmental Industrial Hygienists, Cincinnati, OH 45211, 1985.
Schwope, AD., et aL, “Gloves for Protection from Aqueous Formaldehyde: Permeation Resistance and Human
Factors Analysis,’ Journal of Applied industrial Hygiene, Vol. 3, No.6, pp. 167-176, June 1988.
Sunny, David H. and Wolbarsh, Myron L., Safety Wtih Lasers and Other Optical Sources. New York, Plenum,
1980.
Stricoff, R.S., Walters, D.B., Handbook of Laboratory Health and Safety, Second Edition, John Wiley & Sons,
Inc., New York, 1995.
Stuart, D.G., et al., “Comparison of Chemical Vapor Handling by Three Types of Class II Biological Safety
Cabinets,” Particulate and Microbial Control, Vol. 2, No. 2, pp. 18-24, 1983.
Trott, P.W., CRC Handbook of Laboratory Safety, Second Edition, Steere, N.V., editor. CRC Press, Inc., Boca
Raton, Florida 1971.
U.S. Coast Guard, CHRIS Hazardous Chemical Data - Commandant instruction M.16465J2A., US. Govern-
ment Printing Office O-479.762:QL3, Washington, D.C.; U.S. Department of Transportation, 1985.
U.S. Department of Health, Education, and Welfare, The Industrial Environment - Its Evaluation and Control,
1973.
U.S. Department of Health, Education and Welfare, Biohazards Safety Guide, 1974.
U.S. Department of Health, Education, and Welfare, Safety Standards for Research Involving Oncogenic Viruses.
National Cancer Institute (Nd), Publication No. (NIH) 78-790, 1974.
U.S. Department of Health, Education, and Welfare, Applied industrial Hygiene, 1980 .
&ERA June 1998 Bib liography-12
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
A
AA-OARM Assistant Administrator for the Office of Administration and Resources
Management
AAs Assistant Administrators
ABET Accreditation Board for Engineering and Technology
ABSL Animal Biosafety Level
ACG1H American Conference of Governmental Industrial Hygienists
ACL Administrative Control Level
AEA Atomic Energy Commission
AFFF Aqueous Film-Forming Foam
AIDS Acquired Immunodeficiency Syndrome
ALARA As Low As Reasonably Achievable
AL! Annual Limit on Intake
AN Acrylonithie
ANSI American National Standards Institute
APC Air Pollution Control
APCA Air Pollution Control Association (Now AWMA)
AQCR Air Quality Control Region
ARAR Applicable or Relevant and Appropriate Requirement
ASHRAE American Society of Heating, Refrigeration, and Air Conditioning
ASME American Society of Mechanical Engineers
ASSE American Society of Safety Engineers
ASTM American Society for Testing and Materials
AIHA American Industrial Hygiene Association
ATSDR Agency for Toxic Substances and Disease Registry
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
B ___________________________________
BACT Best Available Control Technology
BBP Bloodborne Pathogens
BAT Best Available Technology
BCG Bacillus Calmette-Guerin
BF 3 Boronlrifluoride
BL Biosafety Level
BMP Best Management Practice
BOD Biochemical Oxygen Demand
BSC Biological Safety Cabinet
BSL Biological Safety Level
BSO Biological Safety Officer
BTL Barner Threshold Limit
BTU British Thermal Unit
C ___________________________________
CAA Clean Air Act
CAAA Clean Air Act Amendments
CBA Cost/Benefit Analysis
CBT Computer Based Training
CDC/NIH Centers for Disease Control/National Institutes of Health
CDRH Center for Devices and Radiological Health
CEDE Committed Effective Dose Equivalent
CEMP Code of Environmental Principles
CEM Continuous Emission Monitors
CEMs Continuous Emissions Monitoring Systems
CERCLA Comprehensive Environmental Response Compensation and Liability Act
&EPP June 1998 Acronyms-2
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
C ( cont. )
CESQG Conditionally-Exempt Small Quantity Generator
CFC Chiorofluorocarbon
cfm Cubic feet per minute
CFR Code of Federal Regulations
CHC Chemical Hygiene Committee
CGA Compressed Gas Association
CGIMS Gas ChromatographylMass Spectrocopy
CHO Chemical Hygiene Officer
CHP Chemical Hygiene Plan
Ci Curie
cm Centimeter
cm 2 Square Centimeter
CMA Chemical Manufacturers Association
CNC Contamination Nuclei Counter
CNP Controlled Negative Pressure
cpm Counts per minute
CPG Comprehensive Procurement Guide
CPC Chemical Protective Clothing
CPR Cardiopulmonary Resuscitation
CWA Clean Water Act
D
DAC
Derived Air Concentration
dB
Decibels
DHHS
U.S. Department of Health and Human Services
DBCP
I ,2-Dibromo-3-Chloropropane
&EPA June 1998
Acronyms-3
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Acronyms
Acronyms
D (cont.)
DHR
DIS
DMR
DOD
DOE
DOL
DOT
DOP
DSHEMO
Design Hazard Review
Decay in Storage
Discharge Monitoring Report
U.S. Department of Defense
U.S. Department of Energy
U.S. Department of Labor
U.S. Department of Transportation
Dioctylphthalate
Designated Safety, Health, and Environmental Management Official
E
ECAO
EDE
EPA
EPCRA
ESLI
Enviromnental Criteria and Assessment Office
Effective Dose Equivalent
U.S. Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
End-of-Service-Life Indicator
F
FDA
FID
FMSD
FIFRA
fpm
FPMP
FR
FSOP
ft
U.S. Food and Drug Administration
Flame-Ionization Detector
Facility Management and Service Division
Federal Insecticide, Fungicide, and Rodenticide Act
Feet per minute
Federal Property Management Regulations
Federal Register
Facility Standard Operating Procedure
Foot
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
F (cont.)
FTA
Fault-tree analysis
G
g
gal
GC
GFCI
GM
GIS
gpm
GSA
Gy
Gram
Gallon
Gas Chromatography
Ground-Fault Circuit interrupter
Geiger-Mueller
Geographic Information Systems
Gallons per minute
U.S. General Services Administration
Gray
H
HAP
HAZOP
HBV
HEG
HeNe
HEPA
HF
HM
HMR
HMTA
HSL
HSWA
HVAC
Hazardous Air Pollutant
Hazard and Operability Study
Hepatitis B Virus
Homogeneous Exposure Group
Helium-Neon
High Efficiency Particulate Air
Hydrofluonc Acid
Hazardous Material
Hazardous Materials Regulations
Hazardous Materials Transportation Act
Hazardous Substances List
Hazardous and Solid Waste Amendments
Heating, Ventilation, and Air Conditioning
6ER June 1998
Acronyms-5
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
H (cont.)
Hz
IAA
IAEA
Hertz
Isoamyl Acetate
International Atomic Energy Agency
I
IBC
ICNRP
ICRP
IDLH
!PFF
in
IR
IRPA
ISO
ISWA
institutional Biosafety Committee
International Council on Nonionizing Radiation Protection
International Council on Radiation Protection
Immediately Dangerous to Life and Health
Institute of Electrical and Electronic Engineers
Inch
Infrared
International Radiation Protection Association
International Standards Organization
International Solid Waste Association
JHA Job Hazard Analysis
keV Kilo electronVolts
kg Kilogram
kHz KiloHertz
kW Kilowatts
L
LAER
LAR
LASER
Lowest Achievable Emission Rate
Laboratory Animal Research
Light Amplication by Stimulated Emission of Radiation
aEPA June 1998
Acronyms-6
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
L ( cont. )
IbIm Pounds Per Meter
LCA Life Cycle Analysis
LDR Land Disposal Restriction
LEAP Laboratory Exposure Assessment Program
LDR Land Disposal Restriction
LEL Lower Explosion Limit
LEV Local Exhaust Ventilation
LLRW Low-Level Radioactive Waste
LOEL Lowest Observed Effect Level
LQG Large Quantity Generator
LSC Liquid Scintillation Counter
LSF Liquid Scintillation Fluid
I SV Liquid Scintillation Vial
M
m Meter
MACT Maximum Achievable Control Technology
MCL Maximum Contaminant Levels
mCi Milhicurie
MDA Methylendianiline
mg Milligram
MGC Million gallons per day
mm Minutes
mL Milliliters
MORT Management Oversight and Risk Tree
MOU Memorandum of Understanding
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
M ( cont. ) ___________________________________
MPE Maximum Permissible Exposure
mRem Milli-rem
MSDS Material Safety Data Sheet
mSv Millisievert
MSW Municipal Solid Waste
MUC Maximum Use Concentration
mW Mill Wan
MW Microwave
N _______________
NAAQS National Ambient Air Quality Standards
NAREL National Air and Radiation Environmental Laboratory
NCRP National Council on Radiation Protection and Measurement
NEC National Electric Code
NESHAPs National Emission Standards for Hazardous Air Pollutants
NHP Nonhuman Primates
NHZ Nominal Hazard Zone
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety and Health
MR Near Infrared
NIST National Institute of Standards and Technology
nm Nanometer
NMR Nuclear Magnetic Resonance
NOAA National Oceanic and Atmospheric Administration
NPDES National Pollution Discharge Elimination System
NRC U.S. Nuclear Regulatory Commission
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
T (cont.)
NSF
National Sanitation Foundation
NSPS
New Source Performance Standard
NSR
New Source Review
OA
Office of Administration
0
OEP
OPIM
OARM
ORIA
OSC
OSH
OSHA
Occupant Emergency Plan
Other Potentially Infectious Material
Office of Administration and Resources Management
Office of Radiation and Indoor Air
On-Scene Coordinator
Occupational Safety and Health
Occupational Safety and Health Administration
P
PBS
PCBs
PEL
P1
PF
PID
PM
POHCs
POTW
PP
ppb
PPE
Public Buildings Service
Polychiorinated Biphenyls
Permissible Exposure Limits
Principal Investigator
Protection Factor
Photoionization Detector
Preventive Maintenance
Principal Organic Hazardous Constituents
Publicly-Owned Treatment Works
Piiority Pollutants
Part per billion
Personal Protective Equipment
June 1998
Acronyms-9
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
P (cont.)
ppm
PSD
psi
psia
psig
Part per million
Prevention of Significant Deterioration
Pounds per square inch
Pounds per square inch (absolute)
Pounds per square inch (gage)
Q
QA/QC
QLFT
QNFT
Quality Assurance/Quality Control
Qualitative Fit-Testing
Quantitative Fit-Testing
R
RAs
RCRA
rDNA
REACTFS
REL
RF
RFI
RHIB
RPC
RPF
RSO
RSC
RSP
Regional Administrators
Resource Conservation and Recovery Act
recombinant DNA
Radiation Emergency Assistance Center!Fraimng Site
Recommended Exposure Limits
Radio Frequency
RCRA Facility Investigation
Rigit-Hill, Inherent-Buoyancy
Radiation Protection Committee
Respirator Protection Factor
Radiation Safety Officer
Radiation Safety Committee
Radiation Safety Program
S
SARA Superfund Amendments and Reauthorization Act
&EFA June 1998 Acronyms-lO
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
S ( cont. ) ___________________________________
SCBA Self Contained Breathing Apparatus
SDWA Safe Drinking Water Act
SHE Safety, Health, and Environmental
SHEM Safety, Health and Environmental Management
SHEMD Safety, Health and Environmental Management Division
SHEMG Safety, Health and Environmental Management Guidelines
SHEMP Safety, Health, and Environmental Management Program
SIC Standard Industry Code
SOP Standard Operating Procedure
SQG Small Quantity Generator
SPCC Spill Prevention, Control, and Countermeasures
SRC Simple Root Cause
STS Standard Threshold Shift
STEL Shoit-Terin Exposure Limit
Sv Sievert
SWMU Solid Waste Management Unit
SW ! ’ 3 Stormwater Pollution Prevention Program
T
TCLP Toxicity Characteristics Leaching Procedure
TEDE Total Effective Dose Equivalent
TLD Thermoluminescent Dosimeter
TRI Toxic Release Inventory
TLV Threshold Limit Value
TQM Total Quality Management
TSCA Toxic Substance Control Act
&EPA June 1998 Acronyms-il
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SHEMP Operations Manual for Laboratories
Acronyms
Acronyms
T ( cont. )
TSD Treatment, Storage, and Disposal
TSDF Treatment, Storage, and Disposal Facility
TSS Total Suspended Solids
TWA Time-Weighted-Average
U.S. United States
U
U.S.
USGS
UST
UV
VIS
WL
WLM
WMA
WMSD
WPCF
United States
United States Geological Survey
Underground Storage Tank
Ultra-violet
{Visible
Working Level
Working Level Month
Waste Management Association
Work-related musculoskeletal disorders
Water Pollution Control Federation (Now WEF)
Y
YAG
iCi
Yttrium Aluminum Garnet
Microcurie
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Glossary
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SHEMP Operations Manual for Laboratories
Olossazy
A ____________________________________
Absorbent A substance that takes in or absorbs other material.
Accident/Incident A systematic method for determining the direct and contributing causes of an accident
Investigation or incident.
Acclimatization The process of becoming adjusted to new climatic conditions (i.e., heat, cold).
Accumulation area Area where hazardous wastes are accumulated for a period of less than either 90 days
(large quantity generators) or 180 days (small quantity generators).
Acoustic, Acoustical Containing, producing, arising from, actuated by, related to, or associated with sound.
Action Level Term used by the U.S. Occupational, Safety and Health Administration and the National
Institutes of Occupational Safety and Health to express the level of toxicant that
requires medical surveillance, usually one half the permissible exposure limit.
Acute Toxicity The acute adverse effects resulting from a single dose of, or exposure to, a substance.
Acute Exposure A dose that is delivered to the body in a single event or in a short period of time.
Acute Effect An adverse effect on a humans or animals, with several symptoms developing rapidly
and coming quickly to a crisis.
Administrative Methods of controlling employee exposures by job rotation, varying tasks, work
Controls assignment, operationa] procedures, or time periods away from the hazard(s).
Adsorption The condensation of gases, liquids, or dissolved substances on the surfaces of solids.
Adverse Weather The weather conditions that make it difficult for response equipment and personnel to
cleanup or remove spilled oil, and that will be considered when identifying response
systems and equipment in a response plan for the applicable operating environment.
Aerosol A gaseous suspension of fine solid or liquid particles.
Air Monitoring Process by which airborne concentrations of contaminants are sampled and quantified.
Air-Purifying Respirators that use filters or sorbents to remove harmful substances from the air.
Respirator
Air-Supplied Respirator that provides a supply of breathable air from a clean source outside of the
Respirator contaminated work area.
Airborne Radioactiv- Any area within a radiological area where the gross alpha or gross beta airborne
ity Area concentrations significantly exceed the background concentration.
Alpha Particle A small positively charged particle made up of two neutrons and two protons.
Ambient Noise The all-encompassing noise associated with a given environment, usually a composite
of sounds from many sources.
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SHEMP Operations Manual for Laboratories
Glossary
A ( continued ) ___________________________________
Anemometer A device to measure air velocity.
Annual Limit On The quantity of a single radionucide which, if inhaled or ingested in one year, would
Intake (AL!) irradiate a person represented by reference man to the limiting value for control of the
workplace.
Annual Capacity The ratio between the actual heat input to a steam generating unit from the fuels listed in
Factor 40 CFR 60.42b(a), 60.43b(a), or 60.44b(a), as applicable, during a calendar year and
the potential heat input to the steam generating unit had it been operated for 8,760 hours
during a calendar year at the maximum steady state design heat input capacity. In the
case of steam generating units that are rented or leased, the actual heat input shall be
determined based on the combined heat input from all operations of the affected fucility
during a period of 12 consecutive calendar months.
Anthropometry The science of measuring the human body for differences in various characteristics.
Article A manufactured item (1) which is fonned to a specific shape or design during manufac-
ture, (2) which has end use function(s) dependent in whole or in part upon its shape or
design during end use, and (3) which has either no change of chemical composition
during its end use or only those changes of composition which have not commercial
purpose separate from that of the article, and that result from a chemical reaction that
occurs upon end use of other chemical substances, mixtures, or articles; except that
fluids and particles are not considered articles regardless of shape or design.
As Low As Reason- An approach to radiation protection to control or manage exposures (both individual
ably Achievable and collective to the work force and general public) as low as social, technical, eco-
(ALARA) nornic, practical, and public policy considerations permit. ALARA is not a dose limit
but a process which has the objective of achieving dose levels as far below applicable
limits as reasonably achievable.
Asbestos The asbestiform varieties of serpentmite (chrysotile), riebeckite (crocidolite),
cumniingtonite-grunerite, anthophyllite, and actinolite-tremolite.
Asphyxiant A vapor or gas that can cause unconsciousness or death by suffocation (lack of oxygen).
Atomic Absorption An analytical instrument used to identify an unknown substance (typically metals) by
Specirophotometer measuring its absorption spectra when it is decomposed in a flame.
Audiogram A record of hearing loss of hearing level measured at several different frequencies-.
usually 500 to 6,000 Hz. The audiograni may be presented graphically or numerically.
Audiometer An instrument that measures a person’s ability to hear a pure tone at various frequen-
cies.
Audit A methodical examination and review.
&EPA June 1998 Glossary-2
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SHEMP Operations Manual for Laboratories
Noise coining from sources other than the particular noise source being monitored.
The radiation in man’s natural environment, including cosmic rays and radiation from
the naturally radioactive elements, both outside and inside the bodies of humans and
animals. it is also called natural radiation.
Adjustable panels at the back of a laboratory fume hood used to ensure uniform air
distribution across the face of the hood.
Acompound that reacts with an acid to form a salt. it is another term for alkali.
The SI unit of activity: 1 Becquerel = I disintegration per second =27 picocuries.
Capable of being broken down into innocuous products by the action of living things.
My area (a complete operating complex, a single facility, a room within a facility, etc.)
in which work has been, or is being, performed with biohazardous agents or materials.
Any set of equipment and procedures utilized to prevent or minimize the exposure of
humans and their environment to biohazardous agents or materials.
A biological hazard. Organisms or products of organisms that present a risk to humans.
A specific type of hood used to control exposures to highly hazardous materials (e.g.,
viruses, extremely toxic chemicals, etc.).
Standards prescribing requirements for the design, construction, testing, and installation
of boilers and unfired pressure vessels.
Imaginary globe of two-foot radius suaounding the head.
Any radioactive material, except special nuclear material, made radioactive by exposure
to the radiation incident to the process of producing or utilizing special nuclear material,
and the tailings and wastes produced by the extraction or concentration of uranium and
thorium from ore.
A chemical substance produced without a separate commercial intent during the
manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s).
Glossary
B
Background Noise
Background Radiation
Baffle
Base
Becquerel (Bq)
Biodegradable
Biohazard Area
Biohazard Control
Biohazard
Biological Safety
Cabinet
Boiler Codes
Breathing Zone
Byproduct Material
Byproduct
C’
.,;
Capture Velocity
Air velocity at any point in front of the exhaust hood necessary to overcome opposing
air currents and to capture the contaminated air by causing it to flow into the exhaust
hood.
Carcinogen
A substance or agent that can cause a growth of abnormal tissue or tumors in humans or
animals.
Carcinogenic
Cancer-producing.
BEPA June 1998
Glossary-3
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SHEMP Operations Manual for Laboratories
Glossary
C ( continued )
Cardiovascular Relating to the heart and the blood vessels or the circulation.
Carpal Tunnel Syn- An affliction caused by compression of the median nerve in the carpa.l tunnel.
drome
Carpal Tunnel A passage in the wrist that the median nerve and many tendons pass to the hand from
the forearm.
CAS Number Identifies a particular chemical by the Chemical Abstract Service, a service of the
American Chemical Society that indexed and compiles abstracts of worldwide chemical
literature called “Chemical Abstracts.”
Category I Nonfriable Asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing
Asbestos-Containing products containing more than 1 percent asbestos as determined using the method
Material (ACM) specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, Polarized Light
Microscopy.
Category II Nonfriable Any material, excluding Category I nonfriable asbestos-containing material, containing
Asbestos-Containing more than one percent asbestos as determined using the methods specified in appendix
Material (ACM) E, Subpart E, 40 CFR Part 763, section 1, Polarized Light Microscopy that, when dry,
cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Ceiling Limit © In ACGIH terminology, an airborne concentration of a toxic substance in the work
environment that should never be exceeded.
Centrifuge An apparatus that uses centrifugal force to separate or remove particulate matter
suspended in a liquid.
Chemical Cartridge A chemical cartridge is used with a respirator for removal of low concentrations of
specific vapors and gases.
CHEMTREC Chemical Transportation Emergency Center.
Chronic Exposure Low doses repeatedly received by the body over along period of time.
Circuit Breaker A device that automatically interrupts the flow of an electrical current when the current
becomes excessive.
Coal All solid fuels classified as anthracite, bituminous, sub-bituminous, or lignite by the
American Society of Testing and Materials in ASTM D388-77, Standard Specification
for Classification of Coals by Rank, coal refuse, and petroleum coke. Coal-derived
synthetic fuels, including but not limited to solvent refined coal, gasified coal, coal-oil
mixtures, and coal-water mixtures, are also included in this definition for the purposes
of NSPS, Subparts Db and Dc.
Combustible Liquids Liquids having a flashpoins at or above 100°F (378 °C).
Combustible Able to catch fire and burn.
Committed Effective The effective dose equivalents that will be accumulated over SO years following the
Dose Equivalent intake. Does not include contributions from external dose.
( CEDE )
& A June 1998 Glossary-4
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S HEMP Operations Manual for Laboratories
Glossary
C ( continued ) ___________________________________
Cardiovascular Relating to the heart and the blood vessels or the circulation.
Communicable Refers to a disease whose causative agent is readily transferred from one person to
another.
Complex A f cility possessing a combination of transportation-related and non-transportation-
related components that is subject to the jurisdiction of more than one Federal agency
under section 311(j) of the Clean Water Act.
Compressed Gas Cyl- A cylinder containing vapor or gas under higher than atmospheric pressure.
inder
Conditionally Exempt A generator who generates less than or equal to 100 kilogram, or less than or equal to
Small Quantity Gener- one kilogram of acute hazardous waste, in a calendar month.
ator (CESQG)
Conductive Hearing Type of hearing loss; not caused by noise exposure, but due to any disorder in the
Loss middle or external ear that prevents sound from reaching the inner ear.
Confined Space Any area that has limited openings for entry and exit that would make escape difficult in
an emergency, has a lack of ventilation, contains known and potential hazards, and is
not intended nor designated for continuous human occupancy.
Contact Dermatitis Dermatitis caused by contact with a substance—gaseous, liquid, or solid. May be due to
primary irritation or an allergy.
Containment Area A hazardous waste management unit that is used to store or treat hazardous waste.
Contamination Area Any area in which the removable surface contamination exceeds 20 dprn(100 cm 2 or
200 dpmFiOO cm 2 gross alpha or gross beta activity, respectively, or total surface
contamination (removable and fixed) that exceeds 500 disintegrations per second/I 00
cm 2 or 1,000 dpmf 100 cm 2 gross alpha or gross beta activities, respectively.
Contingency Plan Document that establishes an organized, planned, and coordinated course of action to be
followed in case of a fire, explosion, or release of hazardous waste or hazardous waste
constituents which could threaten human health or the environment.
Continual improve- Process of enhancing the environmental, safety, and health management systems to
meat achieve improvements in the overall safety, health, and environmental performance
year-to-year.
Controlled Area Any area to which access is secured and posted in order to protect individuals from
exposure to radiation or radioactive materials.
Corrosivity Characteristic of having a p14 less than or equal to 2 (acidic) or greater than or equal to
12.5 (basiclcaustic).
Cost Benefit Analysis A method by which the cost of an improvement is contrasted with the expected benefit
from the improvement.
Cryogenics The field of science dealing with the behavior of matter at very low temperatures .
&EPA June 1998 Glossary-S
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SHEMP Operations Manual for Laboratories
Glossary
C (continued)
Cumulative Trauma
Disorder
Customer
CWA and Regulations
A disorder caused by one or more of the following: repetitive motion of a body pan,
excessive force, or awkward body posture.
Any person to whom a manufacturer, or importer, or processor directly distributes any
quantity of a chemical substance, mixture, mixture containing the substance or mixture,
or article containing the substance or mixture, whether or not a sale is involved.
The Clean Water Act (CWA) and applicable regulations promulgated thereunder. In
the case of an approved State program, it includes State program requirements.
D
Damper A valve or plate typically placed in the ductwork for regulating the flow of air.
CIBA Sound level in decibels read on the A-scale of a sound level meter. The “A” scale
discriminates against very low frequencies (as does the human ear) and is therefore
better for measuring general sound levels.
Decibel (dB) A unit used to express sound power level (Lv). Sound power is the total acoustic output
of a sound source in watts (W). By definition, sound power level, in decibels, is: L =
10 log WIW 0 where W is the sound power of the source and W 0 is the reference sound
power.
Decontaminate To make safe by eliminating poisonous or otherwise harmful substances, such as
noxious chemicals or radioactive material.
Default Value A value used in a computation when the actual (true) value is unknown (unmeasured).
Demolition The wrecking or taking out of any load-supporting structural member of a facility
together with any related handling operations or the intentional burning of any facility.
Derived Air Concen- The average concentration of a radionuclide in air that, if inhaled for a 2000-hour
tration (DAC) working year, would result in an intake of one AL l. The DAC is determined by dividing
the ALl for any given radionticlide by the volume of air breathed by an average worker
during a working year (2,400 m 3 ). In most cases, an exposure of I DAC-hour may be
assumed to be equivalent to a committed effective dose equivalent of 2.5 millirem.
Dermatitis Inflammation of the skin from any cause.
Dike A barrier constructed to control or confine substances and prevent their movement.
Direct Discharge The “discharge of a pollutant.”
Direct-Reading Those instruments that give an immediate indication of the concentration of aerosols,
Instrumentation gases, or vapors or magnitude of physical hazard by some means such as a dial or
meter.
Discharge Includes but is not limited to, any spilling, leaking, pumping, pouring, emitting,
emptying or dumping. The term “discharge” shall not include any discharge of oil
which is authorized by a permit issued pursuant to section 13 of the River and Harbor
Act of 1899 (30 Stat. 1121, 33 U.S.C. 407), or sections 402 or 405 of the FWPCA
Amendments of 1972 (86 Stat. 816 et seq., 33 U.S.C. 1251 et seq.). Used without
___________________ qualification means the “discharge of a pollutant.”
aEPA June 1998 Glossary-6
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SHEMP Operations Manual for Laboratories
Glossary
D ( continued ) ______________________________
Discharge Monitoring The EPA uniform national form, including any subsequent additions, revisions, or
Report (DMR) modifications for the reporting of self-monitonng results by permittees. DMR.s must be
used by “approved States” as well as by EPA. EPA will supply DMRs to any approved
State upon request. The EPA national forms may be modified to substitute the State
Agency name, address, logo, and other similar information, as appropriate, in place of
EPA’s.
Discharge of a Pollut- (a) Any addition of any “pollutant” or combination of pollutants to “waters of the
ant United States” from any “point source,” or (b) Any addition of any pollutant or conibi-
nation of pollutants to the waters of the “contiguous zone” or the ocean from any point
source other than a vessel or other floating craft which is being used as a means of
transportation.
Disposal Facility A facility at which hazardous waste is intentionally placed into or on any land or water
and at which such waste will remain after closure.
Disposal The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid or
hazardous waste into or on any land or water so that such waste, or any constituent of
such waste, may enter the environment or be emitted into the air or discharged into any
waters (including groundwaters).
Domestic Within the geographical boundaries of the 50 United States, including the District of
Columbia, the Commonwealth of Puerto Rico, the Virgin islands, Guam, American
Samoa, the Northern Mañana Islands, and any other territory or possession of the
United States.
Dose A term used (1) to express the amount of a chemical or of ionizing radiation energy
absorbed in a unit volume or an organ or individual. Dose rate is the dose delivered per
unit of time; (2) Used to express amount of exposure to a chemical substance.
Dose Equivalent (H) The product of absorbed dose in tissue (D) (in rads or grays), a quality factor (Q), and
any other modifying factors (N), where H = DQN. The dose equivalent is expressed in
units of rem or sieverts.
Draft Permit A document prepared under 40 CFR 124.6 indicating the Director’s tentative decision
to issue or deny, modify, revoke and reissue, terminate, or reissue a “permit” A notice
of intent to terminate a permit, and a notice of intent to deny a permit, as discussed in
40 CFR 124.5, are types of “draft permits.” A denial of a request for modification,
revocation and reissuance, or termination, as discussed in 40 CFR 124.5, is not a “draft
permit.” A “proposed permit” is not a “draft permit.”
Dry Chemical A powdered fire extinguishing agent usually composed of sodium bicarbonate,
monoammonium phosphate, potassium bicarbonate, etc.
Dusts Solid particles generated by handling, crushing, grinding, rapid impact, detonation, and
decrepitation of organic or inorganic materials, such as rock, ore, metal, coal, wood,
and grain. Dusts do not tend to flocculate, except under elecirostatic forces; they do not
diffuse in air but settle under the influence of gravity.
&ER6 June 1998 Glossary-7
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SHEMP Operations Manual for Laboratories
Glossary
E __________________________________
Effective Dose The sum over specified tissues of the products of the dose equivalent in a tissue (l{ )
Equivalent (HE) and the weighting factor (W. 1 ) for that tissue, i.e., HE = W . 1 .H 1 (expressed in units of
rem or sieverts).
Effluent Limitation Any restriction imposed by the Director on quantities, discharge rates , and concentra-
tions of “pollutants” which are “discharged” from “point sources” into “waters of the
United States,” the waters of the “contiguous zone,” or the ocean.
Egress A means of exit.
Elephant Trunk A flexible section of duct with a flanged or unflanged opening.
Emergency Shower A water shower for an employee when the employee has had chemical exposure that
needs to be washed off quickly.
Emergency Stop A switch or other device that when activated quickly stops the controlled mechanisms.
(Switch)
Emergency Plan A plan of action for a disaster.
Emission The release of some undesirable byproduct or product from an operation.
Energy-Isolating A mechanical device that prevents the release or transmission of energy. Some exam-
Device pies of energy-isolating devices include: a manually operated circuit breaker, a discon-
nect switch, a line valve, a block, and other similar devices. The following are not
energy-isolating devices: push buttons. selector switches, and other circuit control
devices.
Engineering Controls Methods of controlling employee exposures by modifying the source or reducing the
quantity of hazards.
Environmental Im- Any change to the environment, whether adverse or beneficial, resulting from an
pacts organization’s activities, products or services (e.g., contamination of water or the
depletion of natural resources).
Environmental As- Parts of an organization’s activities, products or services that can interact with the
pects environment. Aspects include discharges, emissions and consumption of resources.
Environmental Toxic- lnlbrniation obtained as a result of conducting environmental testing designed to study
ity the effects on aquatic and plant life.
EPA Worker Any full-time, pan-time, temporary, and permanent EPA employee; any federal, state or
local government employee assigned or detailed to the EPA; any enrollee in the EPA’s
Senior Environmental Employment (SEE) Program; any student assigned to the EPA;
any EPA stay-in-school program participant; any intern or fellow assigned to the EPA;
and others who are designated on a case-by-case basis by the SHEMD Director.
Emission Standards The maximum amount of pollutant permitted to be discharged from a single polluting
source.
&ER June 1998 Glossary-8
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SHEMP Operations Manual for Laboratories
Glossary
E ( continued )
Epidemiology The branch of biostatistics and medicine concerned with the study of diseases.
The study of human characteristics for the appropriate design of living and work
environments.
The removal of air (usually by mechanical means) from any space. The flow of air
between two points is due to the occurrence of a pressure difference between the two
points. This pressure difference will cause air to flow from the high pressure to the low
pressure zone.
Explosive Limit See Lower Explosive Limit and Upper Explosive Limit.
Exposure Contact with a chemical, biological, or physical hazard.
External Exposure The dose of radiation received by an individual from a source of ionizing radiation
outside the body.
The flreflghnng substance to be used to control a material in the event of a fire. Jr is
usually referred to by its generic name, such as foam, waxer, etc .
¼ .
,-‘.i :‘;•: t . . —
Average air velocity into the exhaust system measured at the opening into the hood or
booth.
Activity Any NPDES “point source” or any other facility or activity (including land or appurte-
nances thereto) that is subject to regulation under the NPDES program.
Analysis A methodology to identify combinations of equipment failures and human errors that
result in an accident or event.
Facility Any facility owned or operated by any department, commission, agency, office, bureau
or other unit of the government of the United States of America except for facilities
owned or operated by the Department of Energy.
(1) A device for separating components of a signal on the basis of its frequency. It
allows components in one or more frequency bands to pass relatively unanenuated, and
it attenuates greatly components in other frequency bands. (2) A fibrous medium used in
respirators to remove solid or liquid particles from the airstream entering the respirator.
(3) A sheet of material that is interposed between patient and the source of x-rays to
absorb a selective part of the x-rays. (4) A fibrous or membranous medium used to
collect dust, fume, or mist air samples.
High-efficiency particulate air filter that is at least 99.97 percent efficient in removing
thermally generated monodisperse dioctylphthalate smoke particles with a diameter of
0.3 micrometers.
An organized group trained in firefighting operations.
Ergonomics
Exhaust Ventilation
Extinguishing Media
&EPA June 1998
Glossary-9
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SHEMP Operations Manual for Laboratories
Glossary
F ( conlinued ) _____________________________________
Fire Doors Doors rated and tested for resistance to various degrees of fire exposure and used to
prevent the spread of fire through horizontal and vertical openings.
Fire Resistant See Flameproof.
First Aid The immediate care given to the injured or suddenly ill person.
Flameproof Material incapable of burning. The term “fireproof” is false. No material is immune to
the effects of fire possessing sufficient intensity and duration. The term is commonly,
although erroneously, used synonymously with “fire resistive.”
Flammable Any substance that is easily ignited, burns intensely, or has a rapid rate of flame spread.
Flammable and inflammable are identical in meaning; however, the prefix “in” indicates
negative in many words and can cause confusion. Flammable, therefore, is the preferred
term.
flammable Liquid Any liquid having a flash point below 100°F ( 37.8°C).
Flammable Range The difference between the lower and upper flammable limits, expressed in terms of
percentage of vapor or gas in air by volume, and is also often referred to as the
“explosive range.” See Lower Explosive Limit and Upper Explosive Limit.
Flash Point The lowest temperature at which a liquid gives off enough vapor to form an ignitable
mixture with air and produce a flame when a source of ignition is present.
Frequency (in hertz Rate at which oscillations are produced. One hertz is equivalent to one cycle per
or Hz) second.
Friable Asbestos Any material containing more than 1 percent asbestos as determined using the method
Material specified in appendix E, Subpart E, 40 CFR part 763 section 1, Polarized Light
Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand
pressure. If the asbestos content is less than 10 percent as determined by a method other
than point counting by polarized light microscopy (PLM), verify the asbestos content
by point counting using PLM.
Fume Hood A shaped inlet designed to capture contaminated air and direct it into an exhaust system.
Fume Airborne particulate formed by the evaporation of solid materials (e.g., metal fume
emitted during welding). Usually less than one micron in diameter.
G . S . .
Gas
A stare of matter in which the material has very low density and viscosity; can expand
and contract greatly in response to changes in temperature and pressure; easily diffuses;
and is neither a solid nor a liquid.
General Exhaust
A system for exhausting air containing contaminants from a general work area, usually
accomplished via dilution.
&EPA June 1998 Glossary-lO
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SHEMP Operations Manual for Laboratories
Glossary
& (Continued)
A ventilation system designed to supply air to an occupied space (e.g., office, labora-
toiy, etc.).
An NPDES “pernut” issued under 40 CFR 122.28 authorizing a category of discharges
under the CWA within a geographical area.
System of ventilation consisting of either natural or mechanically induced fresh air
movements to mix with the dilute contaminants in the workroom air.
Any person/&ility whose act or process produces hazardous waste or whose act first
causes a hazardous waste to become subject to regulation.
A sealed enclosure in which all handling of items inside the box is carried out through
long impervious gloves sealed to ports in the walls of the enclosure.
A sample that is taken within a very short time period during which atmospheric
concentration is assumed to be constant throughout the sample.
The unit of absorbed dose: 1 Gy 100 rads.
A contact with the ground that becomes part of the circuit.
A device that measures the amount of current flowing to and from an electrical source.
When a difference is sensed, indicating a leakage of current that could cause an injury,
the device very quickly breaks the circuit.
The procedure used to carry an electrical charge to ground through a conductive path.
An enclosure that prevents enny into the point of operation of a machine or renders
contact harmless with any substance or object.
H
“.. -
Halogenated
Hydrocarbon
A chemical material that has carbon plus one or more of these elements: chlorine,
fluorine, bromine, or iodine.
Hand Protection
Specific type of gloves or other hand protection required to prevent harmful exposure to
hazardous materials.
Hazard
An unsafe condition that, if left uncontrolled, may contribute to an accident.
Hazardous Agent
A biological or chemical substance that has the potential for causing harm to people,
property, or the environment.
Hazard Analysis
An analysis performed to identify hazardous conditions and gather hazard and failure
data for the purpose of their elimination or control.
Hazard Control
Development of a program to recognize, evaluate, and eliminate the destructive efforts
of hazards arising from human error and conditions in the workplace.
General Dilution
Ventilation
General Permit
General Ventilation
Generator
Glove Box
Grab Sample
Gray (Gy)
Ground
Ground Fault Circuit
Interrupter (GFCI)
Grounding
Guard
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Glossary-Il
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SHEMP Operations Manual for Laboratories
Glossary
H ( continued ) ___________________________________
Hazardous Material Any substance or compound that has the capability of producing adverse effects on the
health and safety of humans.
Hazardous Waste Materials that are solid, semi-solid, or Liquid that meet the following criteria:
- Discarded, abandoned, accumulated, stored, or treated for recycling
Ignitable, reactive, corrosive, or meet the TCLP
- Listed by the EPA
HAZOP Hazard and Operability Study used to identify process hazards and operability problems
in design and procedures.
Hearing Conservation The prevention or minimization of noise-induced deafness through the use of hearing
protection devices; the control of noise through engineering methods, annual audiomet-
tic tests, and employee training.
Heat Input Heat derived from combustion of fuel in a steam generating unit and does not include
the heat input from preheated combustion air, recirculated flue gases, or exhaust gases
from other sources, such as gas turbines, internal combustion engines, kilns, etc.
HEPA Filter See Filter, HEPA.
High Radiation Area An area, accessible to individuals, in which radiation levels could result in an individual
receiving a dose equivalent in excess of 0.1 rem (1 milhisievert) in 1 hour at 30 centime-
ters from the radiation source or from any surface that the radiation penetrates.
Hood (1) Enclosure, part of a local exhaust system; (2) a device that completely covers the
bead, neck, and portions of the shoulders.
Human-Equipment Areas of physical or perceptual contact between man and equipment. The design
Interface characteristics of the human-equipment interface determine the quality of information.
Poorly designed interfaces may lead to excessive fatigue or localized trauma (e.g.,
calluses).
I
-
Immediately Danger.
ous to Life or Health
(IDLH)
Used to describe very hazardous atmospheres where employee exposure can cause
serious injury or death within a short time or serious delayed effects.
Imminent Danger
Any condition or practice in any EPA workplace or at any EPA field site that could
reasonably be expected to cause death or serious physical harm either immediately or
before the danger could be eliminated through normal administrative procedures.
impervious
A material that does not allow another substance to pass through or penetrate it.
import in Bulk Form
To import a chemical substance (other than as pan of a mixture or article) in any
quantity, in cans, bottles, drums, barrels, packages, tanks, bags, or other containers, if
the chemical substance is intended to be removed fivm the container and the substance
has an end use or commercial purpose separate from the container.
EPA June 1998 Glossary-12
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SHEMP Operations Manual for Laboratories
Glossary
I ( continued ) ______________________________________
import for Commer- To import with the purpose of obtaining an immediate or eventual commercial advan-
cial Purposes rage for the importer, and includes the impartation of any amount of a chemical
substance or mixture. If a chemical substance or mixture containing impurities is
imported for commercial purposes, then those impurities also are imported for commer-
cial purposes.
Importer Any person who imports any chemical substance or any chemical substance as part of a
mixture or article into the customs territory of the United States.
Inches of Mercury A unit used in measuring pressures. One inch of mercury column equals a pressure of
Column 1.66 kilopascal (0.49 1 pounds per square inch).
Incident An undesired event that may cause personal hami or other damage. In the United States,
OSHA defines the criteria for recordkeeping purposes.
Incineration The controlled process by which combustible solid, liquid, or gaseous wastes are
burned and changed into noncombustible gases.
Industrial Waste Waste generated by industrial processes and manufacturing activities.
Industrial Hygiene The science (or art) devoted to the recognition, evaluation, and control of those
environmental factors or stresses (i.e., chemical, physical, biological, and ergonomic)
that may cause sickness, impaired health, or significant discomfort to employees or
residents of the community.
Inert Gas A gas that does not normally combine chemically.
Infrared Radiation Electromagnetic energy with wavelengths from 770 nanometers to 12,000 nanometers.
Ingestion (1) The process of taking substances into the stomach, as food, drink, medicine, etc., (2)
With regard to certain cells, the act of engulfing or taking up bacteria and other foreign
matter.
Inhalation The breathing in of a substance in the form of a gas, vapor, fume, mist, or dust.
Injury A measurable adverse change, either long- or short-term, in the chemical or physical
quality or the viability of a natural resource resulting either directly or indirectly from
exposure to a discharge of oil, or exposure to a product of reactions resulting from a
discharge of oil.
Insoluble Incapable of being dissolved.
Inspection Monitoring function conducted in an organization to Locate and report existing and
potential hazards having the capacity to cause accidents in the workplace.
Installation Any building or structure or any oup of buildings or structures at a single demolition
or renovation site that are under the control of the same owner or operator (or owner or
_________________ operator under common control).
&EPA June 1998 Glossary- 13
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SHEMP Operations Manual for Laboratories
Glossary
I (continued)
A device that interacts with another device or mechanism to govern succeeding
operations. For example, an interlocked machine guard will prevent the machine
from operating unless the guard is in its proper place.
The dose of radiation received by the internal organs of the body from radionuclides
ingested, inhaled, or absorbed into the body.
The specialized international agency for standards’ with membership of over 90
countries.
Any electromagnetic or particulate radiation capable of displacing electrons from atoms
or molecules, directly or indirectly on its passage through maner, thereby producing
ions. Alpha and beta particles, gamma rays, x-rays, and neutrons are examples of
ionizing radiation.
The exposure of something to radiation.
A substance that produces an irritating effect when it contacts skin, eyes, or respiratory
system.
Interlock
Internal Exposure
International Stan-
dards Organization
(ISO)
Ionizing Radiation
Irradiation
Irritant
J
Job Safety Analysis
Job Hazard Analysis
A method for studying a job in order to I) identify hazards or potential accidents
associated with each step or task and 2) develop solutions that will eliminate, nullify,
or prevent such hazards or accidents. Sometimes called Job Hazard Analysis.
A systematic method for identifying the hazards of a particular task or job.
L
Land Disposal
Landfill
Large Quantity
Generator (LQG)
Laser
Local Exhaust
Local Exhaust
Ventilation
LockoutlTagout
Includes, but is not limited to, any placement of hazardous waste in a landfill, surface
impoundment, waste pile, injection well, land treatment facility, salt dome formation,
underground mine or cave, or placement in a concrete vault or bunker intended for
disposal purposes.
An area of land or an excavation in which wastes are placed for pennanent disposal and
which is not a land application unit, surface impoundment, injection well, or waste pile.
A generator who generates greater than or equal to 1,000 kilograms of hazardous waste,
or greater than 1 kilograms of acute hazardous waste, in a calendar month.
The acronym for Light Amplification by Stimulated Emission of Radiation.
A system for capturing and exhausting contaminants from the air at the point where the
contaminants are produced.
A ventilation system that captures and removes contaminants at the point they are being
produced before they escape into the workroom air.
A program or procedure that prevents injury by eliminating unintentional operation or
release of stored energy within machinery or processes during set-up, start-up, or
maintenance repairs.
EPA June 1998
Glossary- 14
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SHEMP Operations Manual for Laboratories
A process which prevents parts of the body from contacting moving machinery at its
point of operation.
Clean, tempered outdoor air supplied to a work space to replace air removed by exhaust
ventilation or some industrial process.
The organizational sm.icture, planning activities, responsibilities, practices, procedures,
processes and resources for developing, implementing, achieving, reviewing and
maintaining the safety, health and environmental policies.
The EPA shipping document Form 8700-22 and, if necessary, 8700-22A, which must
be onginated and signed by a hazardous waste generator prior to hazardous waste
shipmenL
Instrument for measuring pressure; essentially a U-tube partially filled with a liquid
(usually water, mercury, or a light oil), so constructed that the amount of displacement
of the liquid indicates the pressure being exerted on the instument.
Acronym for Microwave Aniplication by Stimulated Emission of Radiation.
These concentrations are set by the National Committee on Radiation Protection
(NCRP). They axe recommended maximum average concentrations of radionucides to
which a worker may be exposed, assuming that he works 8 hours a day, 5 days a week,
and 50 weeks a year.
The ability of a steam generating unit to combust a stated maximum amount of fuel on a
steady state basis, as determined by the physical design and characteristics of the steam
generating unit.
A permissible dose is defined as the dose of ionizing radiation that, in the light of
present knowledge, is not expected to cause appreciable bodily injury to a person at any
time during their lifetime.
The limitations used to determine oil spill planning resources and response times for on-
water recovery, shoreline protection, and cleanup for worst case discharges from
onshore non-transportation-related facilities in adverse weather.
The ability of a steam generating unit to combust a stated maximum amount of fuel (or
combination of fuels) on a steady state basis as determined by the physical design and
characteristics of the steam generating unit.
Glossary
L (continued)
Loss Prevention
Lower Explosive
Limit (LEL)
Lumen
A before-the-loss program designed to identify and correct potential accidental prob-
lems before they result in fatality, injury, property damage and/or business interruption.
The lower limit of flammability of a gas or vapor at ordinary ambient temperatures
expressed in percent of the gas or vapor in air by volume. (See Upper Explosive Limit
and Flammable Range.)
The flux on one square foot of a sphere, one foot in radius, with a light source of one
candle at the center that radiates uniformly in all directions.
M -
Machine Guarding
Makeup Air
Management System
Manifest
Manometer
Maser
Maximum Permissible
Concentration (MPC)
Maximum Heat Input
Capacity
Maximum Permissible
Dose (MPD)
Maxinuim Extent
Practicable
Maximum Design
Heat Input Capacity
aER4 1 June 1998
Glossary- 15
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S HEMP Operations Manual for Laboratories
Glossary
M (continued)
A respirator used to protect against airborne particulate matter like dusts, mists, metal
fume, and smoke. Mechanical filter respirators do not provide protection against gases,
vapors, or oxygen-deficient atmospheres.
A powered device, such as a motor-driven fan or vacuum hose attachment, for exhaust-
ing contantinants from a workplace, vessel, or enclosure.
Unit of measurement (either positive or negative) used to express air pressure.
Suspended liquid droplets generated by condensation from the gaseous to the liquid
state or by breaking up a liquid into a dispersed state, such as by splashing, foaming, or
atomizing.
Regulations that require non-hazardous waste combined with hazardous waste, and
solid waste resulting from the combination of hazardous waste and other materials, to
be managed as a hazardous waste.
Testing to determine if the parameters being measured are within acceptable limits. This
includes environmental and medical (biological) monitoring in the workplace.
Material Safety Data Sheet. A document prepared by a chemical manufacturer, desciib-
jug the properties and hazards of the chemical.
Residential and commercial solid waste generated wIthin a community.
A substance having properties which cause changes within the chromosomes or genes.
The product of the protection factor of the respiratory protection equipment and the
permissible exposure limit.
Maximum Use Con-
centration (MUC)
Mechanical Filter
Respirator
Mechanical
Ventilation
Millimeters (mm)
water gauge
Mist
Mixture and Derived
from Rules
Monitoring
MSDS
Municipal Solid
Waste
Mutagenic
N
National Pollutant
The national program for issuing, modifying, revoking and reissuing, terminating,
Discharge Elimination
monitoring and enforcing permits, and imposing and enforcing pretreatment require-
System (NPDES)
meats, under sections 307,402,318, and 405 of CWA.
Natural Gas
(I) a naturally occurring mixture of hydrocarbon and nonhydrocarbon gases found in
geologic formations beneath the earth’s surface, of which the principal constituent is
methane; or (2) liquid petroleum gas, as defined by the American Society for Testing
and Materials in ASTM D1835-82, Standard Specification for Liquid Petroleum Gases.
Navigable Waters of
the United States
“Navigable waters” as defined in section 502(7) of the FWPCA, includes:
(1) All navigable waters of the United States, as defined in judicial decisions prior to
passage of the 1972 Amendments to the FWPCA (Pub. L 92-500), and tributaries of
such waters
(2) Interstate waters
(3) Intrastate lakes, rivers, and streams which are utilized by interstate travelers for
recreational or other purposes
(4) Intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in
interstate commerce
EPA June 1998
Glossary-16
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SHEMP Operations Manual for Laboratories
Glossary
N (continued)
New Chemical
Substance
Noise-Induced
Hearing LOSS
Nonflammable
Nonfriable Asbestos-
Containing Material
Nonionizing Radiation
Nonradiological Area
Nonsparking Tools
Noise Reduction
Rating (NRR)
Nuisance Dust
Any chemical substance which is not included in the chemical substance list compiled
and published under TSCA Section 8 (i.e., the TSCA Inventory).
The slowly progressive inner ear hearing loss that results from exposure to continuous
noise over a long period of time as contrasted to acoustic trauma or physical injury to
the ear.
Not easily ignited, or if ignited, not burning with a flame (smolders).
Any material containing more than 1 percent asbestos as determined using the method
specified in Appendix E, Subpart E, 40 CFR 763. Section 1, Polarized Light Micros-
copy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand
pressure.
Electromagnetic radiation that does not cause ionization. Includes ultraviolet, laser,
infrared, microwave, and radiofrequency radiation.
Any area within the laboratory which is kept free of surface contamination and/or
radiation fields that exceed background levels.
Tools made from beryllium-copper or aluminum-bronze that produce no sparks, or low
energy sparks, when used to strike other objects.
As applied to ear protection, the number of decibels that the device reduces in transmis-
sion to the ear.
Has a long history of little adverse effect on the lungs and does not produce significant
organic disease or toxic effect when exposures are kept under reasonable control.
0
Occupationally
Exposed Workers
Offshore Facility
Oil
Oil Spill Removal
Organization
Onshore Facility
Own or Control
Owner or Operator
Individuals who have a significant potential for exposure to radiation.
Any facility of any kind located in, on, or under any of the navigable waters of the
United States, which is not a transportation-related facility.
Crude oil or petroleum or a liquid fuel derived from crude oil or petroleum, including
distillate and residual oil.
An entity that provides oil spill response resources, and includes any for-profit or not-
for-profit contractor, cooperative, or in-house response resources that have been
established in a geographic area to provide required response resources.
Any facility of any kind located in, on, or under any land within the United States, other
than submerged lands, which is not a transportation-related facility.
Ownership of 50 percent or more of a company’s voting stock or other equity rights, or
the power to control the management and policies of that company.
Any person owning or operating an onshore facility or an of1 hore facility, and in the
case of any abandoned offshore facility, the person who owned or operated such facility
immediately prior to such abandonment.
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SHEMP Operations Manual for Laboratories
Glossary
0 (continued)
Owner or Operator
of a Demolition or
Renovation Activity
Any person who owns, leases, operates, controls, or supervises the facility being
demolished or renovated or any person who owns, leases, operates, controls, or
supervises the demolition or renovation operation, or both.
Oxidation
Process of combining oxygen with some other substance; technically, a chemical change
in which an atom loses one or more electrons whether or not oxygen is involved.
Opposite of reduction.
Oxygen Deficiency
An atmosphere having less than the percentage of oxygen found in normal air.
.
: . .
Particulate Matter A suspension of fine solid or liquid particles in air, such as dust, fog, fume, mist, smoke,
or sprays. Particulate matter suspended in air is commonly known as an aerosol.
Pathogen A specific causative agent (as a bacterium or virus) of disease.
Permissible Exposure The legally enforced exposure limit for a substance established by the U.S. Occupa-
Limit (PEL) tional Safety and Health Administration. The PEL indicates the permissible concentra-
tion of air contaminants to which nearly all workers may be repeatedly exposed eight
(8) hours a day, forty (40) hours a week, over a working lifetime (30 years) without
adverse health effects.
Permit An authorization, license, or equivalent control document issued by EPA or an
“approved State” to implement the requirements of this part and Parts 123 and 124.
“Permit” includes an NPDES “general permit” (40 CFR 122.28). Permit does not
include any permit which has not yet been the subject of final agency action, such as
a “draft permit” or a “proposed permit.”
Personal Protective Devices worn by the worker to protect against hazards in the environment.
Equipment (PPE)
Pesticide Any substance or mixture of substances intended for preventing, destroying, repelling,
or mitigating any pest, or intended for use as a plain regulator, defoliant, or desiccant.
Pesticides General term for that group of chemicals used to control or kill such pests as rats,
insects, fungi, bacteria, weeds, etc., that prey on man or agricultural products. Pesticides
include insecticides, herbicides, fungicides, rodenucides, ntiticides, funiigants, and
repellents.
Point Source Any discernible, confined, and discrete conveyance, including but not limited to, any
pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock,
concentrated animal feeding operation, landfill leachate collection system, vessel or
other floating craft from which pollutants are or may be discharged. This term does not
include return flows from irrigated agriculture or agricultural storm water runoff.
Pollutant Dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage,
sewage sludge, munitions, chemical wastes, biological materials, radio active materials
(except those regulated under the Atomic Energy Act of 1954, as amended (42 U.S.C.
2011 et seq.)), heat, wrecked or discarded equipment, rock, sand, cellar dirt and
industriaL municipal, and agricultural waste discharged into water.
Pollution Synthetic contamination of soil, water, or atmosphere beyond that which is natural .
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SHEMP Operations Manual for Laboratories
Glossary
P (continued)
Pollution Prevention
Polychiorinated
Biphenyl (PCB)
Preventive Mainte-
nance
Process for Coinmer-
cial Purposes
Process Wastewacer
Propose to Manufac-
ture, Import, or
Process
Protective Factor (PF)
Publicly Owned Treat-
meat Works
(“POTW”)
Methods prohibiting contamination of the environment with man-made waste.
Any halogenated organic compound identified in 40 CFR Part 761.
The systematic actions performed to maintain equipment in normal working condition
and prevent failure.
The preparation of a chemical substance or mixture after its manufacture for distribution
in commerce with the purpose of obtaining an immediate or eventual commercial
advantage for the processor.
Any water which, during manufacturing or processing, comes into direct contact with or
results from the production or use of any raw material, intermediate product, finished
product, byproduct, or waste product.
A person has made a firm management decision so commit financial resources for the
manufacture, import, or processing of a specified chemical substance or mixture.
With respiratoxy protective equipment—the ratio of the ambient airborne concentration
of the contaminant to the concentration inside the facepiece.
Any device or system used in the treatment (including recycling and reclamation) of
municipal sewage or industrial wastes of a liquid nature which is owned by a “State” or
“municipality.’, This definition includes sewers, pipes, or other conveyances only if
they convey wastewater to a POTW providing treatment.
Q
Quality Assurance
(Quality Control)
Quality Factor
A management function to assure that the products or goods are produced as intended.
A principal modi1 ’ing factor which is used in radiation protection for deriving the dose
equivalent (H). from absorbed dose. The quality factor is a linear-energy-transfer (LET)
dependent factor selected to account for the relative biological effectiveness of the
radiation in question, and is independent of the tissue or organ under consideration.
R
Rad
Radar
Radiation Source
Radiation (Nuclear)
Radiation (Thermal)
The conventional unit for absorbed dose of ionizing radiation. 1 Red = 0.01 gray.
A radio detecting instrument, able to measure distance and/or speed of an object.
An apparatus or a material emitting, or capable of emitting, ionizing radiation.
The emission of atomic particles or electromagnetic radiation from the nucleus of an
atom.
The transmission of energy by means of electromagnetic waves longer than visible light.
Radiant energy of any wavelength may, when absorbed, become thermal energy and
result in the increase in the temperature of the absorbing body.
&EI June 1998 Glossary-19
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S HEMP Operations Manual for Laboratories
Glossary
R ( continued )
Radiation Area An area in which the external radiation exposure is 0.25 millirem per hour (2.5
nucrosieverts per hour) or greater.
Radiation Safety The EPA person, often a health physicist, qualified by virtue of education, n aining
Officer (RSO) and/or professional experience, who ensures that all work activities are conducted in
accordance with the requirements of the Radiation Safety and Health Protection
Program and any applicable facility licenses.
Radiator That which is capable of emitting energy in wave form.
Radioactive The property of an isotope or element that is characterized by spontaneous decay and
emission of radiation.
Radiological Area Any area within a plant, facility, or work site in which radioactive materials or elevated
radiation fields are present or in which access is continUed to protect individuals from
radiation or radioactive materials, but where operations and job activities result in only
limited potential for non-work surface contamination. Radiological areas may include
radiation areas, high radiation areas, contamination areas, and airborne radioactIvity
areas.
Radionuclide A type of atom which spontaneously undergoes radioactive decay.
Radon Progeny The radioactive decay products of radon-222, principally the short-lived radioactive
decay chain from polonium-218 to polonium-214.
RCRA The Solid Waste Disposal Act as amended by the Resource Conservation and Recovery
Act of 1976.
Reactivity Characteristic of undergoing violent changes (e.g., reacting violently with water,
becoming explosive, reacting violently with sulfide- and cyanide-bearing wastes, etc.).
Reagent A substance used (as in detecting or measuring a component, in preparing a product, or
in developing photographs) because of its chemical or biological activity.
Recycling The effective reuse of a waste as a substitute for a commercIal product or as an indus-
vial process; this means use, reuse, or reclamation of a waste, either on- or off-site, after
it is generated by a process. It also refers to reclaiming useful constituent fractions
within a waste material or removing contaminants from a waste to allow it to be reused.
Reference Levels Limits which may be expressed in terms of any useful parameter. They are used to
determine a course of action, such as recording, investigation, or intervention, when the
value of a parameter exceeds or is projected to exceed the reference level.
Regulated Asbestos- (a) Friable asbestos material, (b) Category I nonfriable ACM that has become fliable,
Containing Material (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding,
(RACM) cutting, or abrading, or (d) Category U nonfriable ACM that has a high probability of
becoming or has become crumbled, pulverized, or reduced to powder by the forces
expected to act on the material in the course of demolition or renovation operations
regulated by this Subpart.
Reliability The degree to which an insuument, component, or system retains its performance
characteristics over a period of time.
EPA June 1998 Glossary-20
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SHEMP Operations Manual for Laboratories
Glossary
R (continued)
The unit of dose equivalent (H) for any type of ionizing radiation absorbed by body
tissue in terms of its estimated biological effect, relative to an absorbed dose from
exposure to one roentgen of high energy gamma or x-rays.
Altering a facility or one or more facility components in any way, including the
stripping or removal of RACM from a facility component. Operations in which
load-supporting structural members are wrecked or taken out are demolitions.
Particles in the size range that permits them to penetrate deep into the lungs upon
inhalation.
A device to protect the wearer from inhalation of harmful contaminants.
Devices that will protect the wearer’s respiratory system from overexposure by inhala-
tion to airborne contaminants.
Consists of (in descending order)—the nose, mouth, nasal passages, nasal pharyns,
pharynx, larynx, trachea, bronchi, bronchiole, air sacs (alveoli) of the lungs, and
muscles of respiration.
Any area for which access is controlled for purposes of protection of individuals from
exposure to radiation and radioactive materials.
The use of a product more than once in the same form for the same purpose (e.g., when
a soft drink bottle is returned to the bottling company for refilling).
The process by which the results of a risk analysis (i.e., risk estimates) are used to make
decisions, either through relative ranking of risk reduction strategies or through
comparison with risk targets.
The combination of the expected frequency (e.g., events/year) and consequence
(e.g., effects/events) of a single accident or a group of accidents.
A systematic method by which the underlying factor(s) leading to an event are
determined.
Rent
Renovation
Respirable Size
Particulates
Respirator
Respiratory Protection
Respiratory System
Restricted Area
Reuse
Risk Assessment
Risk
Root Cause
s
- : - ‘S.
Safely Can
An approved container, of not more than five gallon capacity, having a spring-closing
lid and spout cover, and so designed that it will safely relieve internal pressure when
subjected to fire exposure.
Sample Container
The inner container of a shipping package that provides the primary containment of the
radioactive material or sample.
Sampling
A process consisting of the withdrawal or isolation of a fractional part of a whole.
Sanitize
To reduce the microbial flora in or on articles, such as eating utensils, to levels judged
safe by public health authorities.
Satellite Accumulation
Area
Accumulation area located near the point of generation where up 1055 gallons of
hazardous waste, or one quart of acute hazardous waste, can be accumulated.
&E June 1998
Glossary-21
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SHEMP Operations Manual for Laboratories
Glossary
S ( continued ) ____________________________________
Schedule of Compli- A schedule of remedial measures included in a “permit,” including an enforceable
ance sequence of interim requirements (for example, actions, operations, or milestone events)
leading to compliance with the CWA and regulations.
Secondary Industry Any industry category which is not a “primary industry category.”
Category
Self-Contained A respiratory protection device that consists of a supply or a means of respirable air,
Breathing Apparatus oxygen, or oxygen generating material, carried by the wearer.
(SCBA)
Septage The liquid and solid material pumped from a septic tank, cesspool, or similar domestic
sewage treatment system, or a holding tank when the system is cleaned or maintained.
Sewage Sludge Any solid, semi-solid, or liquid residue removed during the treatment of municipal
waste water or domestic sewage. Sewage sludge includes, but is not limited to, solids
removed during primary, secondary, or advanced waste water treatment, scum, septage,
portable toilet pumpings, type Ill marine sanitation device punipings (33 CFR Part
159), and sewage sludge products. Sewage sludge does not include grit or screenings,
or ash generated during the incineration of sewage sludge.
Sewage From Vessels Human body wastes and the wastes from toilets and other receptacles intended to
receive or retain body wastes that are discharged from vessels and regulated under
section 312 of CWA, except that with respect to commercial vessels on the Great
Lalces this term includes graywater. For the purposes of this definition, “graywater”
means galley, bath, and shower waler.
Shipping Package The outer container in which radioactive material or a potentially contaminated sample
is received at the laboratory.
Short-Term Exposure See TLV.
Limit (STEL)
Sievert (Sv) The unit of dose equivalent: I Sievert = 100 rem = I Joule per kilogram.
Sludge Accumulated semi-liquid suspension of settled solids deposited from wastewasers or
other fluids in tanks or basins.
Small Quantities Quantities of a chemical substance manufactured, imported, or processed or proposed to
Solely for R&D be manufactured, imported, or processed solely for research and development that are
not greater than reasonably necessary for such purposes.
Small Quantity Gener- A generator who generates between 100 to 1,000 kilograms, or less than or equal to one
ator (SQO) kilogram of acutely hazardous waste, in a calendar month.
Smoke An air suspension (aerosol) of particles, originating from combustion or sublimation.
Smoke Tube A glass tube packed with a chemically treated sorbent which releases a “chemical
smoke” when moist air is passed over it.
Solid Waste Garbage, refuse, sludge, and other discarded solid material resulting from industrial and
commercial operations and from community activities.
S (continued)
&EPA June 1998 Glossary-22
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SHEMP Operations Manual for Laboratories
Glossary
Solvent A substance that dissolves another substance.
Sorbent(s) (1) A material that removes toxic gases and vapors from air inhaled through a canister
or cartridge. (2) Material used to collect gases and vapors during air-sampling. (3)
Nonreactive materials used to clean up chemical spills. Examples: clay and vermiculite.
Sound Pressure Level The level, in decibels, of a sound is 20 times the logarithm to the base 10 of the ratio of
(SPL) the pressure of this sound to the reference pressure. The reference pressure must be
explicitly stated.
Sound Level A weighted sound pressure level, obtained by the use of metering characteristics and the
weighing A, B, orC specified in ANSI 51.5.
Sound An oscillation in pressure, stress, particle displacement, particle velocity, etc., that is
propagated in an elastic material, in a medium with internal forces (e.g., elastic,
viscous), or the superposition of such propagated oscillations.
Sound-Level Meter Instmments for measuring sound pressure levels in decibels referenced to 0.0002
and Octave-Band microbars.
Analyzer
Source Reduction The minimization, to the extent feasible, of waste that is generated or subsequently
treated, stored, or disposed. It includes and activity undertaken by a generator that
results in (I) the reduction of the total volume or quantity of waste; (2) the reduction of
toxicity of the waste; or (3) both (1) and (2), as long as the reduction is consistent with
the goal of minimizing present and future threats to human health and the environment
Source The specific operation(s) at a facility that generate a waste steam.
Special Waste Solid waste requiring handling other than that normally required for municipal solid
waste.
Specific Gravity The weight of a material compared to the weight of an equal volume of water; an
expression of the density (or heaviness) of the material.
Specific Weight The weight per unit volume of a substance; same as density.
Spent Solvents Solvents no longer fit for use without being regenerated, reclaimed, or otherwise
reprocessed.
Spill Event A discharge of oil into or upon the navigable waters of the United States or adjoining
shorelines in harmful quantities, as defined at 40 CFR Part 110.
Standard Methods Detailed procedures for implementing the requirements of the Radiation Safety and
Health Protection Program and its Standard Operating Practices.
Standard Man A theoretical physically fit man of standard (average) height, weight dimensions, and
other parameters (e.g., blood composition, percentage of water, mass of salivary glands,
etc.).
Static Pressure The potential pressure exerted in all directions by a fluid at rest .
$ ft June 1998 G lossary-23
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SHEMP Operations Manual for Laboratories
Glossary
S (continued)
A device that combusts any fuel or byproductiwaste to produce steam or to heat water
or any other heat transfer medium. This term includes any municipal-type solid waste
incinerator with a heat recovery steam generating unit or any steam generating unit that
combusts fuel and is part of a cogeneration system or a combined cycle system. This
term does not include process heaters as they are defined in NSPS, Subparts Db and Dc.
A 24-hour period between midnight and the following midnight during which any fuel is
combusted at any time in the steam generating unit. It is not necessary for fuel to be
combusted continuously for the entire 24-hour period.
The process of malcing sterile; the killing of all forms of life.
The interim contaimnent of solid waste after generation and prior to collection for
ultimate recovery or disposal.
Air line respirators or self-contained breathing apparatus.
A material that is believed to be capable of causing cancer but for which there is limited
scientific evidence.
Mverse effects caused by a substance that affects the body in a general rather than local
manner.
Steam Generating
Unit
Steam Generating
Unit Operating Day
Sterilization
Storage
Supplied-Air
Respirators
Suspect Carcinogen
Systemic Toxicity
:1’
-
Tank System
A hazardous waste storage or treatment tank and its associated ancillary equipment and
containment system.
Tank
A stationary device, designed to contain an accumulation of hazardous waste which is
constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic),
which provides structural support.
Tenosynovitis
inflammation of the connective tissue sheath of a tendon.
Teratogen
A substance or agent to which exposure of a pregnant female can result in malforma-
tions in the fetus. An example is thalidomide.
Teratogenic
Any substance having properties which cause malformations of the fetus.
Thermolumin-
escent Dosimeter
(FL
A device used for monitoring whole body personal radiation exposure.
& A June 1998
Glossary-24
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SHEMP Operations Manual for Laboratories
Glossary
T ( continued ) _____________________________________
Threshold Limit Threshold limit value; a term used by ACGIH to express the airborne concentration of a
Values (TLVs) material to which nearly all persons can ben exposed day after day, without adverse
effects. ACGIH expressed TLVs in three ways:
TLV-C. The Ceiling limit—the concentration that should not be exceeded even instanta-
neously.
TL V-S TEL The Short-Term Exposure Limit, or maximum concentration for a continu-
ous 15-minute exposure period (maximum of four such periods per day, with at least 60
minutes between exposure periods, and provided that the daily TLV-TWA is not
exceeded).
TLV-7WA. The allowable Time Weighted Average concentration for a normal 8-hour
work day or 40-hour work week.
Threshold The level where the first effects occur; also the point at which a person just begins to
notice the tone is becoming audible.
Time-Weighted Refers to concentrations of airborne toxic materials that have been weighted for a
Average Concentra- certain time duration, usually 8 hours.
tion (TWA)
Total Effective Dose The sum of the deep-dose equivalent (for external exposures) and the committed
Equivalent (TEDE) effective dose equivalent (for internal exposures).
Toxic Substance Any substance that can cause acute or chronic injury to the human body, or which is
suspected of being able to cause diseases or injury under some conditions.
Toxicity A relative property of a chemical agent, refers to a harmful effect on some biologic
mechanism and the condition under which this effect occurs.
Toxicology Branch of science which studies the poisonous effects of substances.
Toxin A poisonous substance that is derived from an organism.
Trade Name The commercial name or trademark by which a chemical is known.
Trade Secret Any confidential formula, pattern, process, device, information or compilation of
information (including chemical name or other unique chemical identifier) that is used
in an employer’s business, and that gives the employer an opportunity to obtain an
advantage over competitors who do not know or use it.
Transport The off-site transportation of wastes by air, rail, highway, or water.
Transportation-related Defined in the Memorandum of Understanding between the Secretary of Transportation
and non-transportation and the Administrator of the Environmental Protection Agency, dated November 24,
-related as applied to 1971,36 FR 24080.
an onshore or offshore
facility
&EPA June 1998 Glossary-25
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SHEMP Operations Manual for Laboratories
Glossary
T (continued)
Treatment
Treatment, Storage
and Disposal Facility
(TSDF)
Any method, technique, or process (including neutralization) designed to change the
physical, chemical, or biological character or composition of any hazardous waste so
as to (1) either neutralize such wastes or recover energy or material resources from the
waste; (2) render such waste non-hazardous or less hazardous; (3) make it safer for
transport, storage, or disposal; (4) make it amenable for storage; or (5) reduce its
volume.
A facility that treats, stores, or disposes of hazardous waste(s) received from
generator(s).
U
.
Ultraviolet
Uncontrolled Area
Unidentifiable Waste
United States
Upper Explosive
Limit (UEL)
Those wavelengths of the electromagnetic spectrum that are shorter than those of visible
light and longer than x-rays, lU cm to io cm wavelength.
Any area in which access is not controlled for purposes of protection of individuals
from exposure to radiation and radioactive materials.
A w4ste of unknown composition or characteristics.
The States, the District of Columbia, the Commonwealth of Puerto Rico, the Canal
Zone, Guam, American Samoa, the Virgin Islands, and the Trust Territory of the Pacific
Islands.
The highest concentration (expressed in percent vapor or gas in the air by volume) of a
substance that will burn or explode when an ignition source is present. (See Lower
Explosive Limit and Flammable Range.)
•v
Vapor
Vapors
Velometer
Ventilation
Very Low Sulfur Oil
Vessel
Similar to gas, but can be liquefied by increased pressure.
The gaseous form of substances that are normally in the solid or liquid state (at room
temperature and pressure).
A calibrated instrument used to measure air velocity.
Circulating fresh air to replace contaminated air. Dilution ventilation is airflow designed
to dilute contaminants to acceptable level. Mechanical ventilation is air movement
caused by a fan or other air moving device. Natural ventilation is air movement caused
by wind, temperature difference, or other nonmechanical factors.
An oil that contains no more than 0.5 weight percent sulfur or that, when combusted
without sulfur dioxide emission control, has a sulfur dioxide emission rate equal to or
less than 215 nanograms perjoule (0.5 pounds per million British thermal units) heat
input.
Every description of watercraft or other artificial contrivance used, or capable of being
used as a means of transportation on water, other than a public vessel.
SEPA June 1998 Glossary-26
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SHEMP Operations Manual for Laboratories
Glossary
V
Vibration
Volatile
Volt
An oscillating motion about an equilibrium position produced by a distributing force.
Percent volatile by volume; the percentage of a liquid or solid (by volume) that will
evaporate at an ambient temperature of 70°F (unless some other temperature is stated).
Examples: butane, gasoline, and paint thinner (mineral spirits) are 100 percent volatile;
their individual evaporation rates vary, but over a period of time each will evaporate
completely.
The practical unit of electromotive force or difference in potential between two points
in an electrical field.
w
-
Walk-through survey An activity whose purpose is to identify potential safety and/or health hazards.
Waste Any material discarded as worthless, defective, or of no further use which, when
disposed of, may pose a threat to human health or the environment.
Waste Generation The act or process of producing a waste.
Waste Shipment The shipping document, required to be originated and signed by the waste generator,
Record used to track and substantiate the disposition of asbestos-containing waste material.
Waste Storage Receptacle used for the temporary storage of waste while it awaits collection.
Container
Waste Steam A specific type of waste leaving a facility or operation.
Waters of the United (a) All waters which are currently used, were used in the past, or may be susceptible to
States or Waters of the use in interstate or foreign commerce, including all waters which are subject to the ebb
U.S. and flow of the tide
(b) All interstate waters, including interstate “wetlands”
(c) All other waters such as intrastate lakes, rivers, steams (including intermittent
streams), rnudflats, sandilats, “wetlands,” sloughs, prairie potholes, wet meadows, playa
lakes, or natural ponds the use, degradation, or destruction of which would affect or
could affect interstate or foreign commerce
(d) All impoundments of waters otherwise defined as waters of the United States under
this definition
(e) Tributaries of waters identified in paragraphs (a) through (d) of this definition;
(f) The territorial sea
(g) ‘Wetlands” adjacent to waters (other than waters that are themselves wetlands)
identified in paragraphs (a) through (f) of this definition
Watt (w) A unit of electrical power, equal to one joule per second.
Weighting Factor A factor indicating the relative risk of cancer induction or hereditary defects from
(W 1 ) irradiation of a given tissue or organ, used in calculating the effective dose equivalent.
Wood Wood, wood residue, bark, or any derivative fuel or residue thereof, in any form,
including, but not limited to, sawdust, sander dust, wood chips, scraps, slabs, millings,
__________________ shavings, and processed pellets made from wood or other forest residues .
GERA June 1998 Glossary-27
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SHEMP Operations Manual for Laboratories
Glossary
W ( cont. )
Work When a force acts against resistance to produce motion in a body, the force is said to
work. Work is measured by the product of the force acting and the distance moved
through against resistance. The units of measurement are the erg (the joule is I x 10’
ergs) and the foot-pound.
Work Stress Biomechanically, any external force acting on the body during the performance of a
task. Application of work stress to the human body is the inevitable consequence of
performance of any task, and is, therefore, only synonymous with “stressful work
conditions” when excessive. Work stress analysis is an integral part of task design.
Workers’ M insurance system under law financed by employers that provides payment to injured
Compensation and diseased employees or relatives, regardless of the cause.
Working Level (WL) A unit of concentration of radon-222 and its alpha-emitting progeny, equivalent to 100
picocuries per liter of radon-222 in secular equilibrium with its short-lived progeny.
Working Level A unit of exposure to radon-222 and its progeny. One WLM is an exposure to a
Months (WLM) concentration of one WL for one working month (170 hours).
Worst Case Discharge The largest foreseeable discharge in adverse weather conditions as determined using the
for an Onshore Non- worksheets.
Transportation-
Related Facility
aEPPI June 1998 Glossary-28
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Subject Index
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SHEMP Operations Manual for Laboratories
Index
A
Accelerators D5-9
Accident/Incident Investigation A3-l0, A4-4, B2-9
Air Cleaning Equipment D4-13
Air Emissions
Asbestos C 10-12
Inventory C 10-2
Limits ClO-9
Monitoring C10-6, C10-9
Nitrogen Oxide C 10-6
Ozone-Depleting Substances C10-1 1
Particulate Matter Cl0-5
Permit C10-3,C10-11
Prevention C 10-2
Program C10-2
Radionuclide C10-9
Recordkeeping and Reporting C10-7, ClO-lO
Regulations C 10-2
Sulfur Dioxide C 10-5
Air Quality (Environmental) C10-l
Air Velocity Measurement D4-13
Alarm Systems D5-1O
Alpha Particles C6-13
Animal Research C2-8, C3-16
Assistant Administrator A2-7
Audit A5-3, A5-5
B
Baseline Survey B2-3
Best-Practice Technology C9-15
Beta Particles C6-15
Bioassay C6-35
Biological Emergency 02-9,02-18, 03-10
Biological Hazard Control D5-6
Biological Monitoring C5-6
Biological Safety Cabinet D4-4, F2-28
Biomechanics C8-7
Blender F2-9
Bloodbome Pathogens C3-15
Body Protection E2-7
Bomb Emergency G2-8, 02-16, G3-6
Bypass Condition C12-6
&EPA June 1998 Index-i
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SHEMP Operations Manual for Laboratories
Index
C
Cause Analysis 04-6
Centrifuge F2-ll
Change Management B4-1
Change of Scale D3-3
Chemical Hygiene Officer A2-12, C4-10
Chemical Hygiene
Hygiene Management Systems C4- 12
Hygiene Plan C4-7
Hygiene Training C4-9
Program C4-1
Chemical
Emergency G2-7, 03-3
Export C15-4
Fire G3-3
import C15-4
Procurement F3-2
Purchasing B4-2
Resistance E2-l0
Storage F3-17
Transportation F3-19
Waste D5-4, F3-19
Chloroform F3-7
Collateral Duty A2-14
Command Center Team 02-5
Complex Analysis (Root Cause)
Deductive Analysis G4-9
Inductive Analysis 04-10
Compressed Gas F3-ll
Conditionally-Exempt Small Quantity Generator C14-22
Containment C13-4, D5-5, F2-5
Contamination Survey, Radiation C6-44
Contingency Plan C14-16
Contractor Evaluation A3-7
Contractor Selection A3-7
Corrosive Materials D5-3, F3-3
Cost/Benefit Analysis B2-12, B3-5
Ciyogenic F3-14
Cyanide F3-7
EPA June 1998 Index-2
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SHEMP Operations Manual for Laboratories
Index
D
Damage Control Coordinator G2-6
Decay-in-Storage Cl 4-27
Decontamination
Biological F2-25
General F2-22
Glassware F2-24
Design Hazard Review (DHR) D2-3
Designated Official G2-5
Dewar Flask F2-8
Dioxin F3-6
Discharge Monitoring Report C 12-7
Disinfection F2-18
Document Control A4-1O
Dose-Response C5-4
Dry Chemical Extinguishers D5-12
Ductwork D4-13
E
Electrical Fire G3-3
Electrical Safety F2-1 1
Electron Microscopes C6-20
Emergency
Equipment 03-I
Notification 03-2
Plan G2-4
Preparation 02-7
Prevention 02-9
Regulations G2-2
Emergency Coordinator 02-6
Emergency Preparation
Animal 02-9
Biological G2-9
Bomb G2-8
Chemical 02-7
Evacuation G2-8
Fire G2-7
Medical 02-7
Radiation G2-9
Emergency Response 03-2, G3-20
Biological G3-1O
Bomb G3-6
Chemical G3-3
Evacuation 03-8
aEPA June 1998 lndex-3
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SHEMP Operations Manual for Laboratories
Index
Fire 03-2
Medical 03-4
Natural Disaster 03-12
Radiation 03-8
Utility Failure 03-11
Employee Responsibilities A2-6
Enclosures D3-3, D4-8
Energy Conservation C9-12
Energy Efficient Equipment C9-14
Energy Management Techniques C9-14
Engineering Controls D l- ]
EPCRA CU-i
Release Reporting Cl 1-5
Tier Jfl’ier I I Reporting Cl 1-1
Toxic Release Inventory C11-6
Ergonomics C3-18, CS-i
Guidelines C8-3
Hazard Prevention and Control C8-1O
Job Design C8-8
Material Handling C8-13
Surveys C8-lO, C8-13
Tool Design CS - b
Work Postures CS-14
Workplace Design CS -S
Ether Peroxide F3-1O
Evacuation 02-8,03-8
Exhaust Fan D4-13
Exposure Assessment C5-4
Exposure Controls C4-9
Exposure Monitoring C5-4
Exposure Routes B2-lO
External Monitoring C6-34
Extinguishing Systems D5-13
Eye Protection E2-5
Eyewash E4-l
Inspection E4-5
Labeling E4-4
Location E4-3
Maintenance E4-5
Specifications E4-6
Training E4-5
Use E4-4
Water Flow and Control E4-4
SERA June 1998 Index-4
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SHEMP Operations Manual for Laboratories
Index
F
Face Protection E2-5
Face Velocity D4- 11
Facility Construction C9- 13
Failure Analysis C 13-4
Fault Tree Analysis B3-1, G4-9
Fetal Protection, Radiation C6-29
Film Badges C6-33
Fire G3-2
Chemical G3-3
Electrical G3-3
Gas G3-3
Solvent G3-3
Fire Detection C3-19, D5-lO
Fire Emergency Preparation G2-7
Fire Extinguisher D5-13
Fire Prevention G2-1 I
First Aid F3-5
Fishbone Diagram G4-8
Fit-Check E3-7
Fit-Test E3-4
Flammable Materials D5-2, F3-4
Floor Team G2-6
Foam Extinguisher D5-14
Foot Protection E2-8
Formaldehyde C2-lO, C3-1 1, F3-6
Fume Hood D4-3, F3-5
C
Gamma Rays C6-15
Gas Fire G3-3
Geiger-Mueller (GM) Survey Meter C6-41
General Ventilation 1)4-3
Glassware F2-15
Guarding F2-13
H
Hand Protection E2-6
Hazard Communication A3-7
Hazard Communication Standard C4-3
Hazard Consequence B3-3
Hazard Identification B2-3, C4-5
Hazard Probability B3-3
Hazard Reporting B2-8
Hazardous Waste C14-1 1
EPA June 1998 Index-5
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SHEMP Operations Manual for Laboratories
Index
Hazardous Waste Treatment C 14-20
HAZOP B3-1
Head Protection E2-7
Hearing Protection C2-16 E2 -9
Heating Equipment F2-1 I
HEPA Filter D4-4
Hepatitis B Vaccination C2-7
Hood Inspection and Maintenance D4-9
Housekeeping F2-2, F3-8, G2-15
Hydrogen Generator F3-17
:i
Illumination D5-19
Incentive Programs A2-16
Incident Investigation G4-1
Incident Investigation Report 04-11
Incompatible Chemicals F3-17
Industrial Hygiene B2-5, C5-1, C6-25
Area Monitoring C5-5
Employee Notification C5-1O
Evaluation of Sampling Results C5-9
Monitoring Equipment C5-6
Recordkeeping C5-1O
Sampling Collection Difficulties C5-9
Sampling Plan C5-7
Sampling Strategy C5-8
Infectious Waste C14-22
Inspections A5-3, B2-8
Interviews, Incident Investigation G4-5
Ionizing Radiation C6-2
Isolation of Operations D3-3
J
Job Hazard Analysis B2-6, C8-lO
Job Performance Measure A2-15
L
Laboratory Design D2- I
Laboratory Director A2-l0
Laboratory Equipment F2-6
Laboratory Exposure Assessment Program C4-7
Laboratory Hygiene F2-2
Laboratory Manager A2-1O
Land Disposal Restrictions C14-17
Large Quantity Generator C14-16, C14-2l
&ER June 1998 Index-6
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SHEMP Operations Manual for Laboratories
Index
Laser C6-6, D5-6
Laser Beam Hazards C6-24
Lever System C8-7
Lifting C8-14
Light Measurement D5-20
Liquid Scintillation Counting C6-43
M
Management Oversight and Risk Tree Analysis (MORT) 04-10
Manifest C14-19
Material Handling Techniques C8-13
Material Safety Data Sheet (MSDS) C4-5
Mechanical Safety F2- 13
Medical Coordinator G2-6
Medical Emergency 02-7, G2-16, 03-4
Medical Treatment C2-4
Medical Surveillance
Animal Research C2-8
Bloodborne Pathogens C2-6
Ergonomics C8- 12
Examinations C2-2
Formaldehyde C2-9
Hearing Protection C2-16
MetbyleneCh.loride C2-13, C3-1 1
Program C2-l
Recordkeeping C2- 18
Respiratory Protection C2-16, E3-4
Surveillance Reauirements C2-6
Methylene Chloride C2-13, C3-I 1, F3-6
Microwave Sample Preparation F 10-2
N
Natural Disaster 03-12
Needs Assessment C3-3, D2-3
NESHAPs C:l0-3
Noise Control D5-16
Non-Beam Hazards C6-25
Nonhazardous Waste C14-10
Nonionizing Radiation C6-5
NPDES C12-4
NPDES Pennit Conditions C 12-8
NSPS C10-3
0
Occupant Emergency Plan C3-19, 02-4
Opportunity Assessment. Pollution Prevention C9-4
&EPA June 1998 lndex-7
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SHEMP Operations Manual for Laboratories
Index
Organic Peroxide F3-9, F3-19
OSHA 200-F Form A4-4
OSHA Laboratory Standard C4-2 C5-3
Overnight Operations F2-4
Oxidizers D5-4
Ozone Generator F3-16
P
Particle Accelerator C6-20
PCBs C15-4,F3-8
Recordkeeping C 15-6
Spill C15-6
Storage C15-5
Survey and Labeling C15-5
Waste C14-31
Perchioric Acid F3-10
Personal Exposure Monitoring C5-5, C6-33
Personal Protective Equipment C6-47, E2-l
Durability/Flexibility E2-1 1
Hazard Assessment E2-3
Performance Requirements E2-9
Selection E2-4
Types E2-5
Personnel Involvement B2-1 1
Pesticides F3-8
Placard C14-19
Pollution Prevention C9-1
Pollution Prevention Program C9-3
POTW C12-4
Power Generation G2-10
PPE C3-16,F3-5
Pretreatment C12-4
Process Change D3-l
Process Safety Management B2-6
Procurement C9-6, C9-12
R
Radiation Control D5-6
Radiation Damage C6-21
Radiation Effects C6-23
Eye C6-23
Skin C6-24
Radiation Emergency G2-9, G2-17, G3-8
Radiation-Generating Devices C6-7
Radiation Safety C6-i
6 June 1998 Index-8
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SHEMP Operations Manual for Laboratories
Index
Committee C6-9
Exposure Limits C6-28
Exposure Monitoring C6-3
Hazards C6-20
Ionizing Radiation C6-2
Lasers C6-6
Maximum Permissible Doses C6-28
Medical Surveillance C6-37
Monitoring C6-33
Nonionizing Radiation C6-5
Officer C6-9
PostinglLabeling C6-37
Program C6-33
Program Effectiveness C6-39
Regulations and Guidelines C6-2
Responsibilities C6-8
Survey C6-41
Training C6-37
Transport C6-40
Work Practice Controls C6-39
Radiation Sources C16-3
Radiation Survey
Lasers C6-47
Radiation-Generating Devices C6-46
Radiation Survey Equipment C6-42
Radioactive Waste C14-23
Radiosensitivity C6-2 I
Reactives D5-4, F3 -9
Recordkeeping A4-l
Recycling C9-8
Recycling Resources C9-1O
Refrigerator F2-9
Regional Administrator A2-9
Research Protocol B4-3
Respirator
Cleaning E3-9
Fit-Check E3-7
Inspection E3-8
Maintenance E3-8
Protection Factor E3-6
Selection E3-5
Storage E3-1O
Use E3-7
&EPA June 1998 Index-9
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SHEMP Operations Manual for Laboratories
Index
Respiratory Protection C2-16, E3-l
Fit-Test E3-4
NIOSH E3-3
Medical Evaluation E3-4
Program E3-3
Recordkeeping E3-1O
Training E3-5
Risk Analysis B 1-1
Risk Assessment B3-1
Risk Screening B3-2
Root Cause B2-l1, 04-6,04-7
S
Safety Shower E4-1
Inspection E4-5
Labeling E4-4
Location E4-3
Maintenance E4-5
Specifications E4-6
Training E4-5
Use E4-4
Water Flow and Control E4-4
Sampling
Area C5-5
Personal C5-5
Wipe C5-6
Security A3-6, C13-5
SHE
Contractor A3-l
Committee A2-19
Goals A2-4
Policy A2-2, A3-4
Visitor A3-1
SHEM Director A2-8
SHEMP Manager A2-lO
Signage F2-4, F3-6, F3-9
Simple Root Cause Analysis G4-6
Small Quantity Generator C14-17, C14-21
Smoke Tube Testing D4- 12
Solvent Fire G3-3
sPcc C3-21, C13-1
Amendments C 13-7
Plan Contents C13-3
Plan Requirements C13-2
&EPA June 1998 Index-lO
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SHEMP Operations Manual for Laboratories
Index
State Programs C13-7
Training C13-6
Special Waste C 14-30
Spill
PCB C 15-6
Prevention G216
Toxic F3-5
Spill Prevention Control and Countermeasure Plan C 13-1
Spill History C 13-3
Sprinkler Systems D5-12
Standard Operating Procedures (SOPs) A4-3, B2-5, B2-7
Steam Generating Units C1O-4
Sterilization F2-18
Storage
Chemical Waste D5-4
Chemicals D5-2
Corrosives D5-3
Flammables D5-2
Oxidizers D5-4
Reactives D5-4
Stormwater C12-I, C12-4, C12-8
Substance-Specific Standards C5-3
Substitution D3-2
Process D3-2
Materials D3-2
Substitution Equipment D3-3
Syringe _____ _____ ____________ F2 - 17
Tank Inspection C13-4
Team Root Cause Analysis 04-7
Thermoluminescent Dosimeters C6-37
Tier IlTier II Reporting Cli -3
Torque C8-7
Toxic Gas Detection D5-1 I
Toxic Materials F3-5
Toxic Substance Control Act C15-l
Toxic Substance Control Requirements C15-3
Tracking(rrending B2-9
Training C3-1
Animal Research C3-16
Biosafety C3-14
Bloodborne Pathogens C3-15
Chemical Hygiene C3-8
&EPA June 1998 Index-li
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SHEMP Operations Manual for Laboratories
Index
Chemical-Specific C3- 10
DOT C3-22
Emergency Response C3-20
Ergonomics C3-18, C8-13
Fire Safety C3- 19
Hazardous Waste C3-20
Occupant Emergency Plan C3-19
Protective Clothing and Equpment C3- k6
Radiation Safety C3-1 1
Respiratory Protection C3-17, E3-5
SHE Refresher C3-7
SPCC C3-22
Training Conduct C3-6
Training Evaluation C3-6
Training Guidelines C3-3
Training Methods C3-5
Training Program C3-4
Training Records A4-8, C3-23
Training Requirements C3-7
Training Resources C3-23
TRI Reporting Cl 1-6
TSCA C15-1
U
Ultraviolet Radiation C6-32
Unattended Operations F2-4
Upset Condition C12-6
Utility Failure 02-10, 03-12
V
Vacuum Pump F2-8
Vacuum Vessel F2-8
Ventilation
Design D4-6
Performance 1 )4-7
Work Practices D4-7
w
Walk-Through Survey B2-4
Waste Management C 14-1
Disposal C14-8, C14-20
Documentation C14-10
Hazardous C 14-11
Identification/Characterization C 14-4
Infectious C 14-22
Laboratory C 14-6
June 1998 Index-12
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SHEMP Operations Manual for Laboratories
Index
Large Quantity Generator C 14-16, C14-21
Manifest C14-19
Minimization C 14-9
Nonhazardous C14-1O
PCB C14-31
Process C 14-3
Radioactive C14-23
Small Quantity Generator C 14-17, CI 4-21
Special C14-30
Storage C14-7, C14-20
Recordkeeping C 14-20
Treatment C14-20
Transportation C 14-8
Wastewater C12I
Discharge Inventory C 12-3
Discharge Prevtntion C 12-3
Monitoring C12-6
Work Postures C8-14
Work Practice Controls C6-39, C8-12, F3-1
Chemicals F3-2
Coffosives F3-3
Flammables F3-4
General F2-3
Toxics F3-5
Reactives F3-9
Compressed Gases F3-11
Work-Related Musculoskeletal Disorders C8-3, C8-13
Work Surfaces D5-2
Working Along F2-6
Worksite Analysis C88
x
Xrays C645
X-Ray Equipment C6-20, D5-9
&EPA June1998 lndex-13
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