FAQs: SOPs for Particularly Hazardous Substances (PHS)
Q. What’s an SOP?
A:
- A Standard Operating Procedure (SOP) document is a set of instructions that
document a routine activity and provides safety, health, and environmental
information to perform a job safely.
Q: When would I need an SOP?
A:
- For new tasks or procedures where there is medium to high risk for an exposure
or injury to occur
- For a group of chemicals identified by OSHA as “Particularly Hazardous
Substances” (PHS) which require special handling procedures. These include
carcinogens, reproductive toxin, embryotoxins, mutagens, teratogens, and highly
toxic agents.
Q: What paperwork is required for these PHSs?
A:
- The user and his supervisor should complete the Generic ISEM SOP template
found in http://www.ehs.uci.edu/labres.htm.
- In addition, if a PHS is an Article 110 (See: Laboratory Safety Guidelines,
Appendix E, Common Carcinogens), then complete Supplemental Information
Form and submit to EH&S; or if working with a Select Agents toxin, then
complete an Institutional Biosafety Committee (IBC) protocol instead.
Q: Why is this important?
A: SOP provides a documents that can be used :
 To provide for user training.
 To ensure procedures are followed consistently in a safe manner and complies
with UCI guidelines
 To serve as a record of the process that can be reviewed during incident
investigations and for process improvements
 To address lab-specific details when working with PHS. The Registration Form
for Article 110 chemicals allows EH&S to register your use with governing
agencies.
Q: Why is all this necessary?
A:
PIs are accountable for training and documenting training of staff with regard to
lab safety and in this case chemical safety. CCR Title 8 requires specific training
for PHSs used by staff. There are thousands of such substances, so it is not
practical for EH&S to offer a class on each of them.
Q: Many procedures involving PHSs are common lab techniques, so why can't EH&S or
develop generic SOPs and give them to me?
A:
When generic SOPs or specific SOPs are available, EH&S will provide them or
help you develop one that you can use. While a generic SOP or one developed by
another lab will prove a very useful starting point, it will not likely contain labspecific details like the location of designated use areas, spill supplies, PPE, and
disposal locations. So "borrowed" SOPs will need to be reviewed and modified to
reflect actual operations in your lab.
Rev. 07/07
Q: Why do these SOPs have to be lab-specific?
A:
Whereas the CHP provides SOPs for working with hazardous chemicals, the
higher hazard level associated with PHSs warrants training staff on safely
handling PHSs as it is actually/specifically used by the lab. As in most areas,
additional training leads to better practice. It is believed that training staff on labspecific safety details lowers the risk of harmful exposure when the benchmark
for achieving safety is raised as it is when working with PHSs.
Suggested Strategy for Getting SOPs in Place and Improving Them Over-Time
1. Size up the situation (some labs use none, others many)
a. At next lab meeting, ask staff to review labels of chemicals they use now, looking
for PHS keywords. Have them make a list of the PHSs they use. Here is a suggested
format for the list.
User
Name
PHS
Name
Type
(C,R,HP,
U)1
Article
1102 or
Select
Agent
3
(Y/N)
Max %
Conc.
handled
Typical
working
% Conc.
Location
used
Waste
Stored
1. Compile master list for lab.
2. Check the EH&S SOP Library for published SOPs related to your needs.
3. If no SOP is available, user can proceed to develop an SOP using the Generic ISEM
SOP template. User can seek assistance from the EHS Coordinator.
4. During periodic lab meetings and lab audits, ask around whether new PHS use has
begun (prompt users with PHS keywords to look for). If so, begin with Step 3 by
asking EHS Coordinator if SOP exists.
5. Email your SOPs to the EH&S Chemical Hygiene Officer to add it to the Campus
SOP Library.
1
(C) Carcinogen; (R) Reproductive Toxin; (HP) Highly Poisonous; (U) Unstable Reactive, Explosive,
Pyrophoric, Water-reactive.
2
Article 110 carcinogens are a subset of carcinogens with special Cal-OSHA requirements.
3
Select Agents are biological agents restricted by United States Department of Human Health Services.
Rev. 07/07
Protocol
Name