Chemical Hygiene Plan
The Occupational Safety and Health Administration (OSHA) has developed numerous workplace regulations designed to prevent injuries and protect the health of workers. Laboratories are unique workplaces and in order to address the worker protection needs of these facilities OSHA developed a standard, Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450).
This standard, often referred to as the OSHA Laboratory Standard, imposes many requirements, including developing a written Chemical Hygiene Plan. The complete Chemical Hygiene Plan (CHP) for all university laboratories consists of three parts: The UW-Madison Campus Chemical Hygiene Plan and Compliance Guide, a laboratory-specific CHP, and the UW-Madison Laboratory Safety Guide. These are described below.
This document outlines roles and responsibilities for key personnel, contains policies and practices applicable to the entire campus, and provides an overview of the various regulations applicable to operations in a campus laboratory. It also provides information on other regulations such as fire codes, hazardous waste regulations, chemical shipping requirements and other requirements pertaining to the use of hazardous chemicals in the laboratory.
Each Principal Investigator or their laboratory’s Chemical Hygiene Officer must prepare a laboratory-specific Chemical Hygiene Plan that includes the following information specific to their laboratory’s operations:
- Standard operating procedures (SOPs)
- Personal protective equipment (PPE) requirements
- Engineering and administrative controls
- Provisions for handling Particularly Hazardous Substances
- Provisions for designating specific operations that shall require prior approval before initiating Training prerequisites.
Some commonly asked questions and answers about the Laboratory CHP can be found in the next tab. To ease the process, a template has been developed to aid in the completion of the Laboratory CHP.
There is also a fillable version of the SOP Procedure Form found in section 4 of the above template for users that need forms for multiple SOPs.
The Laboratory Safety Guide is prepared by the Chemical Safety Office within the Environment, Health & Safety Department (EH&S). It contains a wealth of information including specific practices and procedures for the safe use and disposal of chemicals. The Chemical Safety Office also provides guidance documents on specific topics.
Chemical Hygiene Plan Frequently Asked Questions
Why do I need a chemical hygiene plan?
The chemical hygiene plan provides a basis to inform new laboratory workers about hazardous chemicals at your location. Chemical hygiene plans relieve laboratories from difficult duties required under other state and federal regulations. This template is also designed to simplify compliance with federal environmental protection laws and regulations.
Why is there are separate campus and lab-specific chemical hygiene plan?
While the lab-specific chemical safety guide is designed to document all the safety practices specific to a laboratory, it doesn't have all the elements that are required by OSHA's Laboratory Standard (such as the description of how we ensure that fume hoods are functioning, provisions for medical consultation, and our policy for handling prior approvals). The campus chemical safety guide includes the required OSHA elements, outlines specific responsibilities which were never made clear in the old lab chemical hygiene plan or the Laboratory Safety Guide, and also provides a place for documenting UW-Madison policies related to chemical safety.
Does the chemical hygiene officer need to be a manager or supervisor?
No. The chemical hygiene officer may come from anywhere on the organization chart. He or she may be anyone who is qualified by training or experience to provide technical guidance on the development and implementation of the chemical hygiene plan.
I have laboratories in several locations. How many chemical hygiene officers do I need?
The chemical hygiene officer should have the training or experience to provide technical guidance in the development and implementation of the chemical hygiene plan. One chemical hygiene officer may cover several chemical hygiene plans and a single plan may have more than one chemical hygiene officer if their duties are clearly delineated.
What about the laboratory chemical hygiene plan template that is found in the hard copies of the laboratory safety guide?
The laboratory chemical hygiene plan template found on this website supersedes the version found in Appendix E of the hard-copy versions of the Laboratory Safety Guide. The web version of the Laboratory Safety Guide has the latest template.
Does the lab chemical hygiene plan need to be submitted?
Currently we don't require automatic submission. This will likely change in the future when our online data management system is fully functional. However, the chemical hygiene plan must be submitted upon request and this can always be sent to the Chemical Safety Office for review if you want to. The fillable PDF version should make this easy. If you need assistance, please contact the Chemical Safety Office.
Our department has a chemical hygiene plan. Do I still need to fill one out for my lab?
It depends. The lab chemical hygiene plan is designed to ensure compliance with the lab standard. As long as your department CHP covers all the elements in the template, is consistent with the campus CHP (though it can be more restrictive) and covers the procedures specifically performed in your laboratory, then you should be fine. More often than not, however, the departmental CHP will likely need to be supplemented to include your specific operations.
Do I need to have a paper copy of the campus and lab chemical hygiene plans?
Maintaining a paper copy is not necessary as long as everyone has access to the documents. These are designed to be useful documents so if paper copies increase access, then they should be printed.
Why is there a separate download for Section 4 of the lab chemical hygiene plan? Do I need this?
Typically lab operations cannot be described in one SOP so generating multiple copies of the SOP form is necessary. Having a separate template for this section available makes it easier to generate multiple SOPs.
Do I need to fully describe the procedure in the chemical hygiene plan SOP form?
No, that is not the intent of the SOP form. The procedure is often described elsewhere - such as a book, journal article, or lab procedure manual. The purpose of the SOP form is to document all the required safety aspects of the procedure. You should reference the actual procedure in the chemical hygiene plan SOP form.
Do I need to fill out a laboratory SOP procedure form for each procedure or can an SOP procedure form cover multiple procedures?
Many lab procedures are simply variations on the same theme. In instances where the safety considerations are the same then it is appropriate to cover the procedures on the same form.
I'm a researcher so a lot of what I do is different every day. Do I need to complete an SOP procedure form each time?
Essentially, a hazard assessment must be done for each experiment. The safety requirements of any experiment needs to be documented. One way to do this is to document this in your laboratory notebook. We have developed a sticker that can be printed on an Avery® 6876 (or equivalent) label. This is a fillable SOP Hazard Assessment label that can be printed and placed in the lab notebook. This should only be used when allowed by the PI or lab manager.
I document my training using other means. Do I have to also document it on the template provided?
No. The CHP template provides a means to document training, but if you should have a system that already works for you then that is acceptable.
What is the real purpose of the Lab Safety Guide?
The lab chemical hygiene plan is partially about complying with the regulations, but more importantly, it is about ensuring that proper hazard assessments are performed and training is done. Documenting safety practices is important. The old days of oral tradition just doesn't work in today's academic laboratories. There have been some well-documented instances where lab-specific safety policies were not followed because they were not written down and were not really understood. These resulted in significant accidents. When completed it should be a useful document for all who work in the lab.