EMPLOYEE INFORMATION AND TRAINING

Background

All individuals who work in laboratories who may be exposed to hazardous chemicals must be apprised of the hazards present in their work area.  THIS INFORMATION AND TRAINING AS OUTLINED BELOW MUST BE PROVIDED BEFORE INITIAL ASSIGNMENT AND BEFORE NEW EXPOSURE SITUATIONS.  Equipment necessary for the safe handling of hazardous substances must also be provided.  IT IS THE RESPONSIBILITY OF THE PRINCIPAL INVESTIGATOR TO ENSURE THAT ALL LABORATORY WORKERS HAVE BEEN PROPERLY TRAINED. 

Responsibilities

Occupational Health and Safety Department personnel provide mandatory UK Chemical Hygiene Plan/ Laboratory Safety classes quarterly as well as an online version.  Information on training can be found on our web page at https://ehs.uky.edu/classes/classes_ohs_0001.php#chemical_hygiene.  This class informs lab workers and principal investigators of the general UK Lab Safety policies and defines the roles and responsibilities of all people in the lab.  This training is required only once. Additionally, the Chemical Hygiene Plan Annual Refresher training is provided online or by request.  This training is a shorter version of the Chemical Hygiene Plan/Laboratory Safety class.  It highlights any new requirements or regulations.  It will also focus on different laboratory safety topics.  It is required annually after the Chemical Hygiene Plan training is taken initially.

However, training specific for the lab where an employee is assigned is the responsibility of that employee's supervisor.  Lab Specific training should be done initially and then again if the following conditions have changed.

• A new process, piece of equipment or chemical is introduced into the laboratory
• A new process, piece of equipment or chemical is added to an existing procedure
• A scale up of a procedure, such as increasing from 5 milligrams to 5 grams
• Remodel of the laboratory

Laboratory workers must be informed of the location and availability of the following:

• "Occupational Exposures to Hazardous Chemicals in Laboratories" (the OSHA Lab Standard - See Appendix I)
• This Chemical Hygiene Plan
• Reference materials on chemical safety (including safety data sheets)
• Permissible Exposure Limits (PELs) for OSHA regulated substances, or if there is no applicable OSHA standard, the recommended exposure limits or Threshold Limit Values (TLVs) may be provided. Contact OHS at 257-2924.
• Signs and symptoms associated with exposure to the hazardous chemicals found in the lab.

 

Training

Laboratory Worker training must include:

Detection methods that may be used to detect the presence or release of a hazardous chemical. Examples of detection methods include visual appearance, odor, detector papers, and an understanding of chemical monitoring devices

Physical and health hazards of the chemicals

Hazardous waste training

The work practices, personal protective equipment, and emergency procedures to be used to ensure that employees may protect themselves from overexposure to hazardous chemicals

Medical consultations and examinations

The manufacturer's Safety Data Sheets (SDS) will generally contain much of the above information needed to comply with the information and training requirements of the OSHA Lab Standard.  Laboratory Supervisors and employees should understand the relevant SDS and/or other comparable literature on the hazardous chemicals that are used or stored in their laboratory.  The employee’s supervisor must provide additional training for specific lab hazards such as….

 

 

GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELING OF CHEMICALS (GHS).

The GHS is a common coherent approach to defining and classifying hazards and communicating information on labels and safety data sheets. Its target audience includes workers, consumers, transport workers and emergency responders. It provides the underlying infrastructure for the establishment of international, comprehensive chemical safety programs.

The benefits to workers and members of the public include:

• Improved safety for workers and others through consistent and simplified communications on chemical hazards and practices to follow for safe handling and use.
• Greater awareness of hazards, resulting in safer use of chemicals in the workplace and at home.

 

GHS Requirements:

• State the health, physical and environmental hazard criteria for substances and mixtures
• Communicate information on labels including harmonized pictograms, hazard statements, and signals words
• Material Safety Data Sheets (MSDS) are now standardized 16-section documents that all companies must adhere to and renamed, Safety Data Sheets (SDS)

 

GHS Label Elements:

• Symbols (hazard pictograms): convey health, physical and environmental hazard information, assigned to a GHS hazard class and category.
• Signal Words: “Danger” or “Warning” are used to emphasize and indicate the relative level of severity of the hazard, assigned to a hazard class and category.
• Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard.

 

The symbols, signal words, and hazard statements have all been standardized and assigned to specific hazard categories and classes, as appropriate. This approach makes it easier for countries to implement the system and should make it easier for companies to comply with regulations based on the GHS.  Below is an example of GHS chemical label:

More information about the Globally Harmonized System of Classification and Labeling of Chemicals is available at the following link: https://www.osha.gov/dsg/hazcom/global.html

Detailed information regarding definitions of the Precautionary Statement P-Codes and Hazard Codes can be found here: https://pubchem.ncbi.nlm.nih.gov/ghs/

Symbols/Pictograms

The GHS symbols have been incorporated into pictograms for use on the GHS label. Pictograms include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors which are intended to convey specific information.

 

GHS Pictograms and Hazard Classes
Oxidizers	Flammables Self Reactives Pyrophorics Self-Heating Emits Flammable Gas Organic Peroxides	Explosives Self Reactives Organic Peroxides
Acute toxicity (fatal or toxic)	Corrosive to Metals Eye Damage Skin Corrosion/Burns	Gases Under Pressure
Carcinogen Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity	Environmental Toxicity (Non-Mandatory)	Irritant (skin and eye) Dermal Sensitizer Acute toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory)

 

 

Shipping Dangerous Goods

Federal law requires that personnel who ship dangerous goods receive an Initial DOT/IATA Training Course upon hire, and a refresher training every two years for air transportation, and every three years for ground transportation.  A dangerous good includes but is not limited to the following: aerosol sprays, butane, car batteries, dry ice, gasoline, lithium batteries, liquid nitrogen, paint, chemicals, poisons and infectious substances.

 

It is the shipper’s responsibility to ensure that appropriate training has been completed and that only trained personnel prepare dangerous goods for shipment and sign the shipping documents.

 

All dangerous goods shipping documents must be maintained for a minimum of 3 years and must be readily retrievable.

 

For information on the initial training, please contact Environmental Management at 323-6280.  The refresher training can be found online at https://ehs.uky.edu/env/shipping.php.

 

Monthly Fire Extinguisher Visual Inspection Checklist

 

The University of Kentucky’s Division of Environmental Health and Safety has created a new policy to ensure the fire extinguishers in the laboratory are in good working order.

 

The policy requires the following parts of a fire extinguisher to be visually inspected monthly:

 

1. Pressure gauge needle is inside the green zone
2. The handle, gauge, and cylinder are free of damage
3. The tamper seal is present and intact
4. The pull pin is present and not bent
5. The annual inspection tag is up to date.

 

If the fire extinguisher has a deficiency, please notify the University of Kentucky’s Fire Marshal at:859-257-8590.

 

In addition to the visual inspection, please maintain an unobstructed area within three feet of the fire extinguisher.  Never conceal the fire extinguisher behind equipment nor furniture or hang items such as a lab coat on the extinguisher.

 

U.S. Drug Enforcement Administration (DEA): Controlled Substances

Researchers engaged in activities utilizing Controlled Substances are required to register directly with the DEA.  The DEA defines Controlled Substances as drugs or chemicals that have the potential to be addictive or habit-forming.  These substances are divided into 5 schedules (I-V) based on their potential to be habit-forming and medicinal usefulness. More information can be reviewed at https://www.deadiversion.usdoj.gov/schedules/.

Basic Requirements for PI Ordering Controlled Substances

Inventory (29 CFR 1304.11)

• A complete and accurate recorded inventory of all stocks of controlled substances must be established on the date you first engage in the manufacture, distribution, or dispensing of controlled substances.
• A new recorded inventory must be initiated at least every two years.

Security (29 CFR 1301.71 thru 74)

• Schedule I and II controlled substances must be stored in a “double lock” drug safe or a lockbox that is securely fastened with a security cord within a locked, substantially constructed cabinet.
• Schedules III, IV, and V are stored in a securely locked, substantially constructed drawer or cabinet.
• If there is a theft or loss of Controlled Substances, notify the DEA Field Division Office in your area, by submitting Form 106 within one business day of discovery of such loss or theft. 

• Controlled Substances should never be given to non-registrants without proper designation from the DEA.

• Areas where controlled substances are stored shall be accessible only to an absolute minimum number of specifically authorized personnel.  Furthermore, when it is necessary for employee maintenance personnel, nonemployee maintenance personnel, business guests, or visitors to be present in or pass through controlled substances storage areas, the registrant shall provide for adequate observation of the area by an employee specifically authorized in writing.

Disposal

• For disposal coordination, contact Environmental Management at 323-6280.