Chemical Hygiene Plan Recommendations

A lab should build a culture of safety by making safety a shared, daily responsibility for everyone from managers to new hires. The appendix recommends visible leadership support, shared safety goals, clear expectations, routine training, and involving staff in hazard identification and decision-making (Appendix A to 1910.1450).

• Hold regular safety meetings and integrate safety topics into research discussions.
• Ensure supervisors model safe behavior and enforce policies consistently.
• Encourage reporting of near-misses and lessons learned without blame so improvements can be made.

Before any lab work, you must identify the chemicals, amounts, and how they will be used; evaluate chemical and physical hazards; and select controls to minimize risk. The appendix lays out identifying chemicals and conditions, evaluating toxic/flammable/reactive hazards, considering scale-up risks, and consulting experienced personnel (Appendix A to 1910.1450).

• Ask what could go wrong and the worst-case scenario.
• Decide engineering, administrative, and PPE controls to apply.
• Document the assessment and review it with an experienced chemist when needed.

You should prioritize engineering controls (like fume hoods) first, then administrative controls and work practices, and use PPE only as the last line of defense. The appendix explicitly references the hierarchy of controls and emphasizes removing hazards where possible (Appendix A to 1910.1450).

• Examples: replace a hazardous solvent with a less hazardous one (substitution), use a properly designed hood (engineering), schedule tasks to limit exposure time (administrative), and wear appropriate gloves and goggles (PPE).

Unless you know otherwise, you should assume a mixture is at least as hazardous as its most toxic component and treat unknown substances as toxic. The appendix warns against underestimating risk and recommends consulting SDSs, LCSSs, and literature before use (Appendix A to 1910.1450).

• If data are lacking, use conservative controls and minimize exposure while obtaining hazard information.

At a minimum, you should wear safety glasses with side shields, closed-toe shoes, long pants, a lab coat, and gloves appropriate to the chemicals used. The appendix states these baseline protections and explains when splash goggles or more protective clothing are needed (Appendix A to 1910.1450).

• Use chemical splash goggles for corrosives, projectiles, or pressure/vacuum glassware.
• Match glove material and thickness to the chemical and task to ensure impermeability and dexterity.

Gloves and lab coats should be worn when working with hazardous materials, must be chemically appropriate, and must not be worn outside the laboratory or into areas where food is stored or consumed. The appendix specifically warns against taking gloves or coats outside lab spaces (Appendix A to 1910.1450).

• Change gloves promptly if contaminated or torn and remove before touching shared items (phones, door handles).
• Have designated storage for contaminated PPE and procedures for laundering or disposal.

The best protection for airborne chemicals is to prevent their release with engineering controls such as properly designed and maintained chemical hoods, and hoods should be the primary control when inhalation hazards exist. The appendix calls out the importance of hoods, testing, and choosing local exhaust appropriate to operations (Appendix A to 1910.1450).

• Do not use chemical waste evaporation in hoods; store toxic/corrosive chemicals requiring vented storage in vented cabinets instead.
• Keep hood areas clear, prevent debris from entering exhaust ducts, and have routine performance testing and maintenance.

Laboratory air should not be recirculated but should be exhausted directly outdoors. The appendix recommends continuous replacement of lab air and direct exhaust to the outdoors to avoid buildup of toxic or odorous substances (Appendix A to 1910.1450).

• Design HVAC changes carefully and consult experienced engineers to avoid degrading lab ventilation or hood performance.

A laboratory should maintain negative air pressure relative to adjoining spaces so that airborne contaminants are contained in the lab and do not leave uncontrolled. The appendix recommends negative pressure and professional design of local capture systems (Appendix A to 1910.1450).

• Monitor and maintain pressure differentials and have procedures for response to ventilation failures or power outages.

Scale-ups require additional prior review and precautions because physical and chemical hazards can change with increased scale. The appendix identifies reaction scale-ups as higher risk and recommends extra review by experienced personnel before proceeding (Appendix A to 1910.1450).

• Consider thermal runaway, mixing order, containment, and emergency shutdown needs when increasing scale.
• Document limits and operating procedures and test controls at intermediate scales.

Laboratories should post emergency phone numbers prominently, train staff on spill/fire procedures, and ensure everyone knows the locations of safety equipment, fire alarms, and telephones. The appendix emphasizes preparedness, clear postings, and training for contingencies (Appendix A to 1910.1450).

• Include evacuation routes, spill kits, eyewash/shower locations, and contacts for local emergency response in visible locations.
• Train new and current staff on these procedures regularly.

Toxic or corrosive chemicals that require vented storage should be stored in vented cabinets rather than inside chemical hoods. The appendix advises using appropriate vented storage for toxic or corrosive materials to protect workers and hood performance (Appendix A to 1910.1450).

• Keep incompatible chemicals separated, store in secondary containment if needed, and label cabinets clearly.

No — chemical waste should not be disposed of by evaporation in a chemical hood. The appendix explicitly advises against using hoods as a waste disposal method (Appendix A to 1910.1450).

• Follow institutional waste management procedures and consult environmental health and safety for approved disposal methods.

Laboratory personnel should be trained before beginning work and receive ongoing training covering hazard recognition, experiment planning, use of controls (like hoods), emergency procedures, and specific CHP policies. The appendix emphasizes initial and continuing training as core elements of a good safety program (Appendix A to 1910.1450).

• Training should include hazard communication, PPE selection, ventilation use, spill response, and how to find SDSs and local procedures.
• Document training and provide refresher sessions after incidents or when procedures change.

Risk assessments and safety plans should be reviewed by the person conducting the work and by other experienced scientists or safety professionals to ensure sufficient expertise and identify overlooked hazards. The appendix calls for consultation with experienced scientists during evaluations (Appendix A to 1910.1450).

• Include institutional environmental health and safety (EHS) staff, principal investigators, and qualified engineers for specialized controls.

Treat substances of unknown toxicity as if they are toxic and minimize exposures until hazard information is obtained. The appendix advises conservative treatment of unknowns and consulting SDSs, LCSSs, and literature for hazard data (Appendix A to 1910.1450).

• Use engineering controls, limit quantities, and use PPE appropriate for potentially toxic materials while you gather hazard information.

Keep hood areas clean and free of debris, prevent solid objects from entering exhaust ducts, and routinely test and maintain hoods for proper performance. The appendix stresses cleanliness and regular maintenance to preserve exhaust effectiveness (Appendix A to 1910.1450).

• Avoid storing chemicals or equipment that block airflow and establish a hood testing schedule with documented results.

A CHP should be a comprehensive program designed to minimize exposures, injuries, illnesses, and incidents and include procedures for hazard identification, controls selection, training, emergency response, and specialized policies for high-risk materials. The appendix outlines that a CHP must be facility-specific and comprehensive (Appendix A to 1910.1450).

• Address storage, waste disposal, PPE, ventilation, training, risk assessment processes, and procedures for particularly hazardous operations.

When servicing requires temporary re-energization (for testing or positioning), implement a strict sequence of safeguards including clearing tools, removing employees from hazard areas, and using effective protections while energized. The appendix endorses prudent precautions; for detailed LOTO procedures consult 1910.1450 related standards such as 1910.147 and applicable guidance (see lockout/tagout interpretations for sequencing). (Appendix A to 1910.1450).

• Document and follow a written procedure when temporary energization is necessary and resume energy control measures when finished.

Before modifying building HVAC, labs should assess how changes will affect laboratory and hood ventilation and consult experienced engineers to prevent degrading source capture and containment. The appendix warns to consider HVAC impacts on lab ventilation before making changes (Appendix A to 1910.1450).

• Perform engineering review and revalidate hood performance after HVAC changes are implemented.

Labs can limit exposure by scheduling tasks to minimize the time a person spends near hazards and by rotating duties when appropriate, but these must be supported by other controls like engineering measures and PPE. The appendix identifies administrative controls such as employee scheduling as ways to reduce exposure time (Appendix A to 1910.1450).

• Track exposure durations, ensure workers understand limits, and evaluate administrative controls for effectiveness.

Training must teach personnel how to identify and assess hazards, plan experiments, and consider worst-case scenarios; it should be ongoing and supported by management. The appendix makes hazard recognition and assessment core elements of chemical education and training (Appendix A to 1910.1450).

• Use hands-on exercises, peer review of procedures, and mentorship by experienced staff to build competence in hazard assessment.

Solid debris can reduce airflow and impair ventilation effectiveness, so keep solids out of exhaust ducts to maintain capture and protect workers. The appendix warns that paper and other solids can reduce airflow and compromise hood performance (Appendix A to 1910.1450).

• Implement housekeeping controls and prevent storage of materials that can become airborne into ductwork.

A Chemical Hygiene Plan (CHP) is a written program the employer must develop and implement to protect employees from health hazards of hazardous chemicals used in the laboratory, and a CHP is required whenever hazardous chemicals are used in the workplace. The Laboratory Standard requires a CHP: 1910.1450(e)(1) and the definition and role of the CHP are explained in 1910.1450AppA.

• The CHP must list procedures, equipment, PPE, and work practices that protect employees from chemical health hazards.
• It should be tailored to your facility and kept readily available to lab workers.
• See the requirement language at 1910.1450(e).

The CHP must be reviewed at least annually and updated whenever new processes, chemicals, or equipment are implemented. This is stated in 1910.1450AppA.

• Perform a formal annual review and document any updates.
• Update sooner if you introduce new hazardous chemicals, procedures, or equipment that change exposure risks.

The Chemical Hygiene Officer (CHO) is responsible for establishing, maintaining, and revising the CHP and for monitoring how chemicals are procured, used, stored, and disposed. 1910.1450AppA lists the CHO duties.

Key CHO duties include:

• Creating and revising safety rules and the CHP.
• Conducting regular inspections of labs, prep rooms, and chemical storage rooms and submitting inspection reports.
• Maintaining inspection, training, and inventory records.
• Assisting supervisors to ensure adequate facilities and seeking program improvements.

The Department Chairperson or Director must assume responsibility for personnel using hazardous chemicals and provide the CHO with the support needed to implement and maintain the CHP. This is specified in 1910.1450AppA.

Expectations include:

• Reviewing CHO inspection reports with supervisors and ensuring timely corrective actions.
• Providing budgetary support for health and safety measures.
• Ensuring the department remains in compliance with applicable codes and regulations.

The Laboratory Supervisor or Principal Investigator is responsible for chemical hygiene in their lab, ensuring personnel follow the CHP and are trained and authorized before handling hazardous chemicals. 1910.1450AppA outlines these responsibilities.

They must, for example:

• Ensure workers have proper training and authorization before operating equipment or handling hazardous chemicals.
• Provide and enforce appropriate PPE use and set a safety example.
• Maintain safe lab practices, conduct regular inspections (including emergency equipment), and ensure ventilation/fume hoods are functioning.

Laboratory personnel must read, understand, and follow safety rules and conduct operations per institutional chemical hygiene procedures. 1910.1450AppA states their responsibilities.

Practical actions include:

• Planning and conducting work to minimize exposures.
• Using appropriate PPE for each procedure.
• Practicing good housekeeping and notifying supervisors of hazards or unsafe work practices.

Wet chemical spaces and higher-hazard areas should be separated from lower-hazard spaces by walls or protective barriers when possible to limit exposures. 1910.1450AppA provides this guidance.

Additional design features to consider:

• Chemically resistant, smooth work surfaces and slip-resistant impermeable flooring in wet labs.
• Doors with view panels that open in the direction of egress.
• Avoid operable windows in spaces with chemical hoods or local ventilation systems.

No — operable windows should not be present in laboratories, especially where chemical hoods or other local ventilation systems are present. This recommendation appears in 1910.1450AppA.

Reason:

• Operable windows can interfere with designed ventilation flows and fume hood performance, increasing exposure risk.

Hand-washing sinks used for hazardous materials may require hands-free controls such as elbow, foot, or electronic actuators to prevent contamination and reduce exposure. This guidance is in 1910.1450AppA.

Practical points:

• Install hands-free controls where possible.
• Locate sinks conveniently so workers can wash promptly after handling hazardous chemicals.

Laboratories should provide an adequate number and proper placement of safety showers, eyewash units, and fire extinguishers, and routinely inspect emergency equipment. This recommendation is stated in 1910.1450AppA.

Best practices:

• Ensure showers and eyewashes deliver tepid flushing fluid and are unobstructed.
• Inspect and document checks on emergency equipment on a regular schedule.
• Consider sprinkler systems despite concerns over water and electronics; they generally reduce overall fire risk.

A CHP must include topics such as individual chemical hygiene responsibilities, standard operating procedures, PPE and engineering controls, laboratory and safety equipment, chemical management, housekeeping, emergency procedures, waste management, training, exposure monitoring, and medical consultation. These required topics are listed in 1910.1450AppA and flow from the Laboratory Standard 1910.1450(e)(1).

• Make the CHP facility-specific and keep it readily available to workers.

Good procurement practices include ordering only the minimum amount needed, ensuring receiving personnel know handling/storage/disposal requirements in advance, and refusing or opening leaked shipments inside a hood. These practices are recommended in 1910.1450AppA.

Practical tips:

• Use a central receiving location for chemicals when possible.
• Require that only adequately labeled containers be accepted.
• Have PPE and handling procedures in place before accepting high-risk shipments; consider CHO approval for high-risk purchases.

Chemicals should be separated and stored by hazard category and compatibility, kept in properly labeled containers, and not stored in hoods, on floors, egress areas, benchtops, or near heat or direct sunlight. These requirements and recommendations are in 1910.1450AppA.

Additional specifics:

• Maintain SDS and follow label storage instructions.
• Date shipments on receipt and rotate stock.
• Peroxide formers should be dated on receipt and opening, stored away from heat/light with tight nonmetal lids.
• Use chemical-grade flammable storage refrigerators for flammables needing cool storage and never store food in them.

Highly hazardous chemicals should be stored in a well-ventilated, secure area designated for that purpose, and flammable chemicals should be stored in spark-free environments in approved containers or flammable cabinets with grounding and bonding when dispensing. This guidance appears in 1910.1450AppA.

• Storage rooms should be controlled-access, ventilated, signed, and provide secondary containment and appropriate fire suppression as needed.
• Ground and bond drums and receiving vessels when transferring flammable solvents to prevent static charge.

Use secondary containment and break-resistant transport containers, avoid high-traffic areas, and use adequate ventilation such as a fume hood when transferring particularly hazardous substances—even in small amounts. These recommendations are in 1910.1450AppA.

Practical points:

• Use trays/carts with lip and secondary containment for spills.
• When decanting flammable liquids from drums, ground and bond the drum and receiver.
• Repackage only into labeled containers including all essential original information.

A waste management plan should be in place before work begins; it should emphasize reducing waste generation, reusing materials when safe, recycling where possible, and proper disposal methods. This hierarchy and planning are described in 1910.1450AppA.

Actions to take:

• Evaluate whether you can scale down reactions or substitute less hazardous materials.
• Coordinate with your institution’s EHS office on acceptable disposal methods (incineration, treatment, or land disposal) and permitting.

Chemical waste should be accumulated at or near the point of generation, stored in compatible, sealed containers clearly labeled with waste type and accumulation start date, and incompatible wastes must be segregated. These requirements are in 1910.1450AppA.

• Keep wastes segregated by how they will be managed and store them in designated locations that do not block operations or egress.
• Use ventilated storage and secondary containment when appropriate.

An accurate chemical inventory helps manage hazards and reduce waste; unneeded items should be discarded or returned to the storeroom. This recommendation is in 1910.1450AppA.

Practical tips:

• Track dates of receipt and opening for reactive chemicals (e.g., peroxide formers).
• Remove surplus or obsolete chemicals promptly to reduce storage hazards and avoid accumulation of incompatible or unstable materials.

No — you must not store food or beverages in laboratory refrigerators used for chemical storage, and flammable liquids needing cool storage should be kept in laboratory-grade, flammable-rated refrigerators. This is stated in 1910.1450AppA.

• Keep separate refrigerators for food and chemicals to prevent cross-contamination and exposures.

The Laboratory Supervisor or Principal Investigator is responsible for ensuring visitors follow laboratory rules and assumes responsibility for laboratory visitors. This responsibility is outlined in 1910.1450AppA.

• Supervisors should brief visitors on hazards, required PPE, and escort them when necessary.

The CHP must include training and the CHO should maintain training records and inspection records to document that personnel have received necessary chemical hygiene training. Training is a listed CHP topic in 1910.1450AppA and the CHO duties include maintaining personnel training records.

• Provide initial and refresher training when procedures, chemicals, or personnel change.
• Keep documentation showing who was trained, the topics covered, and dates.

The Chemical Hygiene Officer should conduct regular inspections of laboratories, preparation rooms, and chemical storage rooms and submit detailed inspection reports to administration, as described in 1910.1450AppA.

• Inspection reports should identify hazards, required corrective actions, and timelines.
• Department leadership and supervisors should review reports and ensure timely corrective action.

Refuse shipments with breakage or leakage or open them inside a chemical hood to protect personnel, according to the procurement and receiving recommendations in 1910.1450AppA.

• Have PPE and spill-response materials available at the receiving area.
• Notify the CHO or EHS office and follow spill-response and disposal procedures.

Purchases of high-risk chemicals should be reviewed and approved by the CHO to ensure proper controls, PPE, storage, and disposal are in place before the chemical arrives, as recommended in 1910.1450AppA.

• This pre-approval helps prevent uncontrolled hazards, ensures availability of necessary engineering controls, and reduces the chance of unsafe storage or use.

Employers must provide affected laboratory staff with exposure monitoring results within 15 working days after the employer receives the results. This is required by 1910.1450(d)(4).

• Keep in mind that exposure and medical records must be retained in accordance with 29 CFR part 1904 and 1910.1450(j).
• If you maintain your injury/illness or exposure records electronically, ensure the electronic records meet the Part 1904 requirements for equivalent forms and availability; OSHA has explained that software-generated records that are equivalent to OSHA forms may be used if they meet the requirements in 29 CFR 1904 (see OSHA’s interpretation on software-generated OSHA recordkeeping forms).

The employer must provide an opportunity for medical attention and any follow-up examinations whenever an employee develops signs or symptoms associated with a hazardous chemical exposure or whenever a spill, leak, explosion, or other occurrence makes hazardous exposure likely. All medical consultations and examinations must be performed by or under the direct supervision of a licensed physician and must be provided at no cost to the employee, without loss of pay, and at a reasonable time and place, as required by 1910.1450(d).

• When arranging the medical evaluation, employers should give the physician the identity of the hazardous chemical, a description of the incident, and any signs or symptoms the employee is experiencing, as recommended in the Chemical Hygiene Plan guidance (1910.1450AppA).
• Maintain and retain all related medical and exposure records in accordance with 1910.1450(j) and 29 CFR part 1904.

Employers must provide laboratory personnel with information and training at the time of their initial assignment to a work area where hazardous chemicals are present and before assignments that involve new exposure situations. This training must ensure employees understand the hazards in their work area and how to protect themselves, as required by 1910.1450(f).

Training should, at a minimum, cover:

• the facility’s specific Chemical Hygiene Plan and standard operating procedures (1910.1450AppA);

• methods and observations for detecting hazardous chemical releases (employer monitoring, continuous monitors, visual appearance or odor);

• the physical and health hazards of chemicals in the work area;

• engineering controls, safe work practices, and required personal protective equipment (PPE); and

• emergency and shut-off procedures, and the availability of Safety Data Sheets (SDSs).

• For PPE selection and hazard evaluation, follow the requirements in OSHA’s PPE standard, 1910.132, as suggested by the Chemical Hygiene guidance (1910.1450AppA).

Employers should also determine the frequency of refresher training based on workplace changes and employee needs, and ensure supervisors and responsible staff are trained to provide or supplement training when necessary.