Laboratory Safety Evaluation Codes 1. A01 A02 A03 Laboratory Security Inspector was not identified (Item of Concern): Visitors to lab should be approached and identified. TAMU Laboratory Safety Manual, Chapter 2 Section 1.2; BMBL V 2007, page 46 Unlocked cabinets (Item of Concern): Cabinets in areas outside the laboratory that contain hazardous materials must be locked. TAMU Laboratory Safety Manual, Chapter 2 Section 1.2 & Chapter 3 Section 7.1 Unlocked lab (Item of Concern): Lock laboratory doors when no one is present. TAMU Laboratory Safety Manual, Chapter 2 Section 1.1; BMBL V 2007, page 48 2. Electrical Safety (NFPA Code): Improper use of extension cords (Item of Concern): Extension cords are for temporary use and B01 should not be used to provide continuous electrical power to laboratory equipment or be placed above ceiling tiles. Replace with fuse-protected power strip or permanent wiring. Contact Area Maintenance to have permanent wiring installed. IFC 605.5; TAMU Safety Manual – Fire & Life Safety (Chapter VIII, Section 11.1) Electrical cords/outlets/plugs not in good condition (Item of Concern): Electrical repair needed. B02 Contact Area Maintenance to schedule repair. IFC 605.5.3; TAMU Safety Manual – Fire & Life Safety (Chapter VIII, Section 11.1) 3-way plugs present (Item of Concern): Discontinue use of 3-way plugs; replace with fuse-protected B03 power strip. IFC 605.4 No ground fault circuit interrupter within 6’ of wet area: (Item of Concern): Contact Area B04 Maintenance to install GFCI. NFPA 70.210.8(B)(5) Obstruction blocking electrical panel (Item of Concern): Remove items that block access to the B05 electrical panel. TAMU Safety Manual – Fire & Life Safety (Chapter VIII, Section 11.2) 3. Fire/Life Safety (NFPA Code): Lab door open (Information): Lab doors must be kept closed. C01 NFPA 45.8.3.4 Obstruction blocking extinguisher (Deficiency): Remove obstruction blocking fire extinguisher. C02 NFPA 10.6.1.3 Obstruction blocking exit/cluttering hallway (Deficiency): Keep evacuation/exit routes cleared. C03 NFPA 101.7.3.4 Damaged ceiling tiles (Item of Concern): Contact Area Maintenance to replace missing/damaged C04 ceiling tiles. NFPA 101.8.4.2.(1) Fire extinguisher is damaged or has been discharged (Information): The inspector has notified the C05 appropriate person within EHS to replace/mount/service the fire extinguisher. NFPA 10.7.2.1.2 Bunsen burner tubing deteriorated (Deficiency): Replace brittle Bunsen burner tubing. C06 Obstructed fire sprinkler heads (Item of Concern): Remove items stored within 18” of sprinkler C07 heads. NFPA 1.10.19.3 Combustibles stored within 24” of ceiling (Item of Concern): Remove combustible items stored C08 within 24” of ceiling. NFPA 1.10.19.3 Bicycles observed in building (Information): Bicycles are prohibited in buildings. C09 NFPA 101.3.3.121 4. Safe Lab Practices: Personnel eating in lab (Item of Concern): Personnel shall be prohibited from eating, drinking or D01 applying cosmetics in lab work areas. 29 CFR 1910.1030(d)(2)(ix), Prudent Practices 1995, page 82 Inadequate hand-washing facilities (Item of Concern): Provide adequate facilities for hand washing D02 (e.g. soap, paper towels, running water). 29 CFR 1910.1030 ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 1 Laboratory Safety Evaluation Codes D03 D04 D05 D06 D07 Unsecured or recapped sharps (Deficiency): Do not recap needles. Secure razors, knives, needles and microtome blades to be reused in their protective cases, or in foam or cork. Dispose of sharps in an approved sharps container. 29 CFR 1910.1030 Food and chemicals stored in the same refrigerator (Deficiency): Food and chemicals should be stored separately. Prudent Practices 1995, page 74 Food and lab utensils washed in the same sink (Deficiency): Plates, cups, and silverware for food use should not be washed in the same sink as lab utensils. Prudent Practices 1995, page 74 Empty bottles are not defaced (Item of Concern): Deface all empty bottles before re-use to prevent confusion over contents. 25 TAC § 295.6 Housekeeping needed (Item of Concern): Housekeeping in this area needs to be improved. Dispose of clutter including unnecessary boxes, old equipment, and trash. 29 CFR 1910.22(a)(1) 5. Physical Hazards: Glass containers on floor (Item of Concern): Do not store glass items on the floor. If glass E01 containers must be on floor, get sufficient secondary containment to hold the entire contents of the glass container in case of breakage. Prudent Practices 1995, pages 60 and 73 Tripping hazards present (Item of Concern): Relocate or tape down electrical cords, computer E02 cables and/or hoses that present tripping hazards. Prudent Practices 1995, page 60 Gas cylinders improperly secured (Item of Concern): Properly secure compressed gas cylinder(s) E03 with a device designed for such. Secure compressed gas cylinder(s) individually, not in groups. NFPA 451.11.1 Gas cylinder safety cap missing (Item of Concern): Apply safety cap to cylinders when not in use. E04 Compressed Gas Association 2006, document P-1 Vacuum pumps operated unsafely (Item of Concern): One or more of the following items was E06 identified and needs correction: The vacuum pump is missing the belt and pulley guard; the vacuum pump is leaking oil; the vacuum pump is venting exhaust in to the lab. Prudent Practices 1995, pages 112-113 Tape glass under vacuum pressure (Item of Concern): Wrap tape around glass under vacuum E07 pressure (Rotovap and glass Dewars). TAMU Laboratory Safety Manual, Chapter 2 Section 2.5 6. Fume Hood/Biological Safety Cabinet: Hood sash open (Item of Concern): Pull down sash on fume hood when unattended. Pull down to F01 lowest working level when conducting experiments. NFPA 45.8.8.3 Items on fume hood knobs (Information): Remove items from fume hood controls. F02 Fume hood needs inspection (Information): EHSD will inspect fume hood. F03 NFPA 45.8.13 Biological safety cabinet due for certification (Item of Concern): Contact EHS for information on F04 how to arrange certification of biological safety cabinet. If cabinet is not in use or does not need to be certified, please call EHS and request it be marked “Not Certified for Pathogens”. BMBL Appendix A 2007, page 323 Fume hood/biological safety cabinet cluttered (Item of Concern): Remove clutter from fume F05 hood/biological safety cabinet. Prudent Practices 1995, page 179 Dirty fume hood/biological safety cabinet (Item of Concern): Clean dirty fume hood/biological safety F06 cabinet. Prudent Practices 1995, page 180 Open containers in fume hood/biological safety cabinet (Item of Concern): Place cap on open F07 containers in fume hood/biological safety cabinet. BMBL Appendix A 2007, page 317 ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 2 Laboratory Safety Evaluation Codes F08 F09 F10 F11 F12 F13 Chemicals stored in fume hood/biological safety cabinet (Item of Concern): Remove chemicals stored in fume hood/biological safety cabinet. Prudent Practices 1995, pages 73, 180 Loose paper in fume hood/biological safety cabinet (Item of Concern): Remove loose paper (paper towels, Kim wipes, notebook paper) from fume hood/biological safety cabinet. Paper can become lodged in the ductwork and removing it requires significant monetary and labor costs. Prudent Practices 1995, page 180 Electrical strips in hood (Item of Concern): Remove electrical strips in fume hood. Obstructions block airflow in fume hood/biological safety cabinet (Deficiency): Items should be stored at least 4’’ from the face of the fume hood and 6” from the baffles in the rear of the fume hood. Use jacks to elevate items 2-4” off the floor of the hood to improve airflow. Prudent Practices 1995, page 179 Bunsen burner in biological safety cabinet (Deficiency): Do not use a Bunsen burner in a biological safety cabinet. Personal protection is reduced when air curtain is disrupted by flame. Unburned gas can collect in filters, increasing explosion potential. BMBL Appendix A 2007, pages 318 Items on front grill of biological safety cabinet (Item of Concern): Items on grill of biological safety cabinet disrupt air curtain, reducing personal protection. BMBL Appendix A 2007, page 317 7. Personal Protective Equipment/Eyewash/Showers (ANSI Standards, TDH HazCom Act): Obstruction blocking shower/eyewash (Deficiency): Remove obstruction blocking shower/eyewash. G01 ANSI Z358.1-2004 Inadequate eyewash (Item of Concern): Provide a continuous-flow eyewash (a squeeze bottle G02 eyewash is not adequate). ANSI Z358.1-2004 Emergency shower/eyewash has not been tested (Information): EHSD will test the emergency G03 shower/eyewash. ANSI Z358.1-2004 Stagnant/dirty water in eyewash (Information): Flush eyewash once weekly for 3-5 minutes. It is G04 recommended to keep a log recording eyewash flushes. ANSI Z358.1-2004 Improper work attire or personal protective equipment (Item of Concern): Use appropriate PPE for G05 work being performed (safety glasses, lab coat, gloves, etc.). Ensure lab personnel are wearing appropriate clothing in lab (no shorts, bare midriffs, long hair, dangling jewelry or open-toed shoes). 29 CFR 1910.132 8. Chemical Storage (NFPA Code, TDH HazCom Act): Chemicals stored above eye level (Item of Concern): Do not store hazardous liquid chemicals H01 above eye level of the shortest person working in the lab. Prudent Practices 1995, page 72 Chemicals stored on bench-top (Item of Concern): Do not store chemicals on workbench. Return to H02 storage when not actively being used. Prudent Practices 1995, page 73 Improper storage of flammables (Item of Concern): Store flammable chemicals in flammable H03 storage cabinet. NFPA 45.10 Chemicals stored on floor (Item of Concern): Do not store chemicals on the floor. Move them in to H04 approved cabinets or store them in secondary containers large enough to hold the entire contents of the bottle in case of spill. Prudent Practices 1995, pages 60 and 73 Improper accumulation of chemicals (Deficiency): Dispose of old chemicals that are no longer used. H05 Prudent Practices, page 84 Faulty containers (Item of Concern): Repackage or dispose of chemicals in deteriorated containers. H06 Prudent Practices 1995, page 74 Segregate chemicals (Deficiency): Segregate chemicals by hazard class (flammable, corrosive, H07 oxidizer, reactive, toxic). Segregate acids and bases; then by organic (contains C-molecule) and inorganic (does not contain C-molecule). Also separate organic and inorganic solvents using the same criteria. NFPA 45.9.2.3 ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 3 Laboratory Safety Evaluation Codes H08 H09 H10 H11 H12 H13 H14 H15 9. I01 I02 I03 I04 I05 I06 Flammables found in household refrigerator/freezer or walk-in cooler (Deficiency): Remove flammables stored in household refrigerator/freezer or walk-in cooler. Flammable chemicals needing refrigeration must be kept in a flammable materials or Lab-safe refrigerator/freezer. NFPA 45.12.2.2 Improper storage of Perchloric acid (Deficiency): Perchloric acid must be stored away from organic materials and other acids. Perchloric acid fume hood is required when using 60% or greater mixtures of perchloric acid or when heating any concentration of perchloric acid. NFPA 45.9.2.3 Improper dating of chemicals (Item of Concern): Date chemicals when received and again when opened. If date of acquisition or opening is unknown, back-date to the oldest known date for a reference point, e.g. “Pre-2001”. NFPA 45.9.2.3.3, NIOSH Publication 2007-107 Improper dating of chloroform (Deficiency): Chloroform should be used within 1 year of purchase or 6 months of opening because it can form phosgene gas. Dispose of any unused chloroform once these time limits have passed. NFPA 45.9.2.3 Improper dating of peroxide-forming or oxidizing chemicals (ethyl ether, THF, perchloric acid, cyclohexene, butadine, isopropyl ether and dioxanes) (Deficiency): Explosive peroxide forming chemicals and oxidants such as ethyl ether, THF, perchloric acid, cyclohexene, butadine, isopropyl ether and dioxanes must be used within 1 year of purchase or 6 months of opening and must be disposed of before the expiration date. Test peroxide-forming chemicals before distillation or purification. Do not attempt to open or move peroxide-formers with chemical crust on lid, stratification of liquid, discoloration, crystallization, or layering of liquids. Tag these chemicals for disposal immediately if past these time constraints or if the substance exhibits any of these traits. NFPA 45.9.2.3 Improper venting of flammables cabinet (Deficiency): If vented, flammables cabinet does not vent directly to outside. NFPA 30.9.5.4.2 Duct on flammables cabinet made of non-approved material (Deficiency): Flammable storage cabinet exhaust duct shall be constructed of non-combustible material and should be of the same material as the flammable storage cabinet. NFPA 91.4.2.1 Vents on flammables cabinet improperly installed (Item of Concern): If vented, flammables cabinets should vent from the bottom of the cabinet, with make-up air supplied at the top of the cabinet. NFPA 30.A9.5.4.2 Waste Disposal (EPA/ TCEQ Regulations): Uncapped waste (Item of Concern): Place tight cap on open waste container. Recommend using screw-on funnel with cap for waste containers. 40 CFR 265(i) Old chemicals present (Deficiency): Dispose of old chemicals/samples/waste/ lecture bottles. NFPA 45.9.2.3 Improper disposal of metal sharps (Deficiency): Dispose of uncapped needles, knives and razors in a rigid covered container that can be encapsulated with plaster or paraffin after it is full. Dispose of encapsulated container in the trash. 30 TAC § 330.1219 Improper disposal of glass (Deficiency): Dispose of broken glass in a covered sturdy box marked “BROKEN GLASS”. Glass should not protrude over lip of disposal container. 30 TAC § 330.1219 Old lecture bottles present. (Deficiency): Dispose of old lecture bottles. NFPA 45.9.2.3 Improperly labeled waste (Item of Concern): Label waste container "HAZARDOUS WASTE" with contents listed, or tie a Hazardous Waste Disposal tag on the container with string and list chemical contents. DO NOT date the tag. EHSD will date the tag at time of pick-up. 30 TAC § 330.1207 ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 4 Laboratory Safety Evaluation Codes 10. Cryogenic Cylinder Safety: Cryogenic cylinder is due for service (Item of Concern): Cryogenic cylinder is due/past due for K01 maintenance. Contact EHS to arrange for service. 29 CFR 1910.101, Compressed Gas Association 2007 S-1.1 Pressure relief valve on cryogenic cylinder has been removed or otherwise compromised K02 (Deficiency): The pressure relief valve is an important safety feature of the cylinder. Do not plug or otherwise compromise this safety feature. Please contact EHS to arrange for repair. NFPA 55.8.2.4 Blow-out disc on cryogenic cylinder has been removed or otherwise compromised (Deficiency): K03 The blow-out disc is an important safety feature of the cylinder. Do not plug or otherwise compromise this safety feature. Please contact EHS to arrange for repair. NFPA 55.8.2.4 11. Warning Signs/Labels (TDH HazCom Act): Improper labeling of secondary containers (Item of Concern): Ensure that all containers are labeled L01 to indicate contents, even those that contain water or are a part of equipment or experiments. 29 CFR 1910.1200(f)(9) Missing or deteriorated label on primary container (Deficiency): Replace missing or deteriorating L02 labels on chemical containers. 25 TAC § 295.6 Emergency contact information is not posted (Item of Concern): Post emergency contacts and offL03 hour phone numbers on all outer doors. TAMU Laboratory Safety Manual, Chapter 5 Section 1.1 Inadequate signage (Item of Concern): Post specific warning signs (biohazard, radioactive, LASER, L04 etc.) on lab door. 29 CFR 1910.145, 21 CFR 1040.10 Unlabeled microwave (Information): Label microwave “Lab Use Only” or “Food Only”. L05 Prudent Practices 1995, page 74 Unlabeled freezer (Information): Label freezer “Not Safe for Flammable Storage”, “Food Only”, or L06 “Lab Use Only”. Prudent Practices 1995, page 74 Unlabeled refrigerator (Information): Label refrigerator “Not Safe for Flammable Storage”, “Food L07 Only”, or “Lab Use Only”. Prudent Practices 1995, page 74 12. Laser Safety: LASER not registered (Item of Concern): Class IIIb and class IV LASERs should be registered with M01 EHS. 25 TAC § 289.301 No LASER eyewear (Item of Concern): Ensure laboratory personnel have and use the proper M02 protective eyewear while operating the LASER. 25 TAC § 289.301 No LASER training (Item of Concern): Ensure laboratory personnel have attended the LASER M03 Safety Training course at EHS. Texas A&M University Rule 24.01.01.M5 13. Teaching Laboratories Student Acknowledgement Form not on file (Item of Concern): Provide students with written notice N01 of laboratory hazards and safety rules. Retain copy of signed acknowledgement on each student for current semester plus one year (three semesters on hand). TAMU Laboratory Safety Manual, Chapter 5 Section 1.4 N02 Teaching Assistant training documentation not on file (Item of Concern): Training documentation for Texas Hazard Communication/TAMU Laboratory Safety and site-specific training must be available for current Teaching Assistants. TAMU Laboratory Safety Manual, Chapter 5 Section 1.2 Periodic departmental safety self-evaluations not conducted/documented (Item of Concern): N03 Conduct periodic self-evaluations of teaching labs (e.g. weekly, monthly, quarterly). TAMU Laboratory Safety Manual, Chapter 5 Section 1.4 ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 5 Laboratory Safety Evaluation Codes N04 Noted lack of departmental oversight (Item of Concern): Noted teaching staff or students not following safety policies and procedures. TAMU Laboratory Safety Manual, Chapter 5 Section 1.4 KEY: Deficiency – Significant hazard and/or in violation of safety codes Item of Concern - in conflict with TAMU safety manual and/or good lab practices Information – Can make the work area safer for lab personnel and emergency responders ANSI American National Standards Institute http://www.ansi.org BMBL Biosafety in Microbiological and Biomedical Laboratories (BMBL) 5th Edition United States Department of Health & Human Services Centers for Disease Control and Prevention and National Institutes of Health January 2007 http://www.cdc.gov/od/ohs/biosfty/bmbl5/bmbl5toc.htm CFR Code of Federal Regulations http://www.gpoaccess.gov/CFR/INDEX.HTML NFPA National Fire Protection Association http://www.nfpa.org Prudent Practices Prudent Practices in the Laboratory, Handling and Disposal of Chemicals National Academy of Sciences National Research Council 1995 TAC Texas Administrative Code http://www.sos.state.tx.us/tac TAMU Rules Texas A&M University System Rules http://rules.tamu.edu TAMU Laboratory Safety Manual Texas A&M Laboratory Safety Manual http://ehsd.tamu.edu/LaboratorySafety.aspx TAMU Safety Manual Texas A&M Safety Manual http://ehsd.tamu.edu/documents/TAMUSafetyManual/0-TOC.HTM ENVIRONMENTAL HEALTH & SAFETY TEXAS A&M UNIVERSITY 6