Moreno Valley College Riverside Community College District TO: Dr. Monte Perez FROM: Carmen Medina DATE: February 2, 2011 SUBJECT: Chemistry Stockroom Safety Issues Dear Dr. Perez, Protecting the health and safety of lab personnel SHOULD BE the FIRST priority in any laboratory facility. It is noteworthy to mention TWO areas that pertain to my working space that need to be addressed: (1) ventilation and (2) fire safety. Other prudent practices appropriate to any academic teaching laboratory would be (1) to implement a Chemical Hygiene Plan and its policies should be followed by all laboratory workers as required by OSHA standard 1910 and (2) to employ laboratory safety training for support staff. One of the single most important steps in maintaining a safe laboratory environment is to ensure that the laboratory is properly and adequately ventilated. In an effort to save money, unfortunately architects, engineers and administrators, who make the design decisions when planning a new or renovated laboratory, frequently leave out plans for proper laboratory ventilation and/or they ignore the need for proper ventilation of the science laboratories and preparation/storage areas. However, what they fail to realize is that providing a complete air change in science laboratories will greatly minimize the potential for chemical exposure. Good ventilation is important to protect everyone who uses the laboratory from short-term exposure to toxic substances and also to decrease the risks of long-term exposure to hazardous chemical vapors, aerosols and fumes. In addition, good laboratory ventilation will allow instructors and laboratory personnel to feel SAFE and comfortable in doing all of the experiments and activities needed to provide an outstanding laboratory experience for the students. Consequently, I deem it necessary to ensure that all key-decision makers are made aware of the need for good ventilation in SCI 257 and SCI 261 in order for the College to be compliant with OSHA regulations. The following information is intended to provide guidelines on how to solve the problem of poor ventilation in the laboratories and preparation/storage areas. According to OSHA Laboratory Standard 1910, it states that "4 to 12 room air changes per hour is normally adequate general ventilation". Air that is exhausted from the laboratory should always be vented to the out-of-doors and should never be recirculated. This will prevent laboratory air from being drawn back into the school building. Ideally, the ventilation system should have a complete air change in five minutes. This is the equivalent of 12 air changes per hour. Such a rapid air change is 1 Moreno Valley College Riverside Community College District needed in the event of a chemical spill, or when conducting experiments that generate a hazardous vapor or a particularly strong or long-lasting odor. In general, a five-minute air exchange can be most easily and inexpensively achieved using an auxiliary ventilation system such as a purge fan or ceiling ventilator. Whichever type is chosen, the system must move a large enough volume of air in cubic feet per minute (CFM) to provide a complete air exchange in five minutes. With any auxiliary ventilation system, it may be necessary to open the laboratory doors in order to provide enough make-up air to allow the system to provide the required air change. Make-up air is the air required from outside the room (for example, a hallway) to replace the air being removed from the laboratory by the ventilation system. In addition, the Laboratory Control and Safety Solutions Application Guide (1994) summarizes the key elements of a laboratory ventilation system: Laboratory ventilation system design is one of the most important specialties associated with the health and safety of laboratory occupants. The primary elements of a laboratory ventilation system are listed here as part of overall facility design considerations. A proper laboratory ventilation system should: Provide the necessary laboratory room ventilation rate to ensure proper indoor air quality (typically expressed as air changes per hour). Remove chemical fumes and biological airborne substances and contaminants that pose a health or safety hazard to the building occupants. Provide a proper face velocity for fume hoods and other apparatus that is intended to prevent worker contact with fumes or hazardous airborne substances. Ensure that laboratory room air and exhaust air are not recirculated or allowed to migrate into other areas of the facility. Supply conditioned air to laboratory rooms in a manner that does not cause drafts or air currents. Strong air currents could adversely affect the safety of fume hoods or other provisions for exhausting potentially hazardous fumes or airborne substances. Provide the required laboratory room environment (temperature and humidity) required to maintain occupant comfort or whatever environmental constraints are necessary for the purpose and processes taking place within a particular laboratory. Provide special modes of operation to maximize and possibly redirect the laboratory exhaust capability and ventilation air in response to a variety of emergencies including a laboratory fire, explosion, chemical spill, release of toxic fumes, etc. Provide the proper level of indoor air quality and comfort desired for nonlaboratory areas within the same building (administrative offices, support facilities, lobbies, lunchrooms, etc.). 2 Moreno Valley College Riverside Community College District Operate at an acceptable sound level so as not to be an annoyance or interfere with sounds emanating from the laboratory activities. More information on this subject can be found at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=101 07 Fire is the most common serious hazard that one faces in a typical chemistry laboratory. While proper procedure and training can minimize the chances of an accidental fire, one must still be prepared to deal with a fire emergency should it occur. For instance, if there is a fire in the stockroom, it would be more important that I get to safety than it is to put the fire out. However, if I determine that it is feasible and SAFE to extinguish the fire, I would need a fire extinguisher. Though many of the laboratory areas are equipped with a fire extinguisher, the Chemistry prep area, SCI 257, does not contain one. Rather than using the only fire extinguisher available to me in SCI 261, an appropriate portable fire extinguisher (Class A or Class B) should be securely mounted to a stationary object so that it is easily located in this room and it cannot be knocked over. Like many other academic institutions across the country, Moreno Valley College should be committed to providing a safe laboratory environment for its faculty, staff, students and visitors. The goal of the College Laboratory Safety Program is to minimize the risk of injury or illness to laboratory workers by ensuring that they have the training, information, support and equipment needed to work safely in the laboratory. The Laboratory Safety Program should comprise of three basic elements: The departmental safety program led by the Chemical Hygiene Officer(s) Laboratory safety support and training by Environmental Health and Safety Instruction and oversight by a Laboratory Supervisor All laboratory workers, including faculty, staff and most students, would be required to attend Laboratory Safety Training given by Environmental Health and Safety (EHS) staff. This training would give an overview of general laboratory safety principles, references and resources for more specific safety information, and details about several support programs, such as the hazardous waste disposal program. The training would supplement instruction given by a Laboratory Supervisor regarding safe work practices for specific chemicals and equipment. EHS would provide training, resources and consultation for a variety of laboratory safety issues, including chemical safety , biological safety, electrical safety and other topics. The Occupational Safety and Health Administration (OSHA) promulgated a regulation entitled Occupational Exposure to Hazardous Chemicals in Laboratories, otherwise known as the Laboratory Standard. 3 Moreno Valley College Riverside Community College District The goal of the Lab Standard is to ensure that laboratory workers are informed about the hazards of chemicals in their workplace and are protected from chemical exposures exceeding allowable levels (e.g., OSHA Permissible Exposure Limits). All individuals who work with hazardous chemicals in science laboratories are obligated to comply with the Lab Standard. A particular department, in this case, the science department, would have its own Departmental Chemical Hygiene Plan and would comply with policies instituted therein. This plan should include information about: Roles and responsibilities for laboratory safety in the department Laboratory Security Policies Chemical Hazard Identification Controlling Chemical Exposures Fume Hood Evaluations Information and Training Emergency Action Plans Prior Approval for Laboratory Procedures Medical Examinations and Consultations Particularly Hazardous Substances Laboratory Inspections and Audits Department Facility Systems As guidance for the College’s development and application of an appropriate laboratory Chemical Hygiene Plan, the following recommendations are provided for the roles and responsibilities of the persons accountable for managing it. Environmental Health and Safety (EHS) Chief Executive Officer Ultimate responsibility for chemical hygiene within an institution and must, with other administrators provide continuing support for institutional chemical hygiene. Conducts exposure monitoring, as needed. Provides general training. Audits the departmental program periodically. Provides safe working guidelines for laboratory workers through the EHS web page. Reviews the model Chemical Hygiene Plan at least annually. 4 Moreno Valley College Riverside Community College District Inspects fume hoods annually. Provides consultation for safe work practices for hazardous chemicals. Conducts limited laboratory safety inspections annually. Develops and maintain the Laboratory Safety Manual. Departmental Chemical Hygiene Officer, whose appointment is essential and: Is responsible for chemical hygiene in a department. Establishes and implements a Chemical Hygiene Plan. Reviews, updates, and seeks way to improve the Chemical Hygiene Plan at least annually. Investigates accidents and chemical exposures within the department. Acts as a liaison between the department and EHS for laboratory safety issues. Monitors procurement, use and disposal of chemicals used in the labs. Maintains records examinations. of training, exposure monitoring and medical Knows the current legal requirements concerning regulated substances. Sees that appropriate audits are maintained. Helps project directors develop precautions and adequate facilities. Ensures laboratory workers receive chemical and procedure-specific training. Reviews and approves use of particularly hazardous substances. Approves laboratory worker's return to work following a chemical exposure requiring medical consultation. Laboratory Supervisor, whose overall responsibility for chemical hygiene in the laboratory consists of: Ensuring that workers know and follow the chemical hygiene rules. Ensuring laboratory workers attend general training given by EHS. Ensuring laboratory workers understand how to work with chemicals safely. Provide chemical and procedure-specific training, as needed. Providing laboratory workers with appropriate engineering controls and personal protective equipment needed to work safely with hazardous materials. Ensure such equipment is used correctly. 5 Moreno Valley College Riverside Community College District Providing regular, formal chemical hygiene and housekeeping inspections including routine inspections of emergency equipment. Determining the required levels of protective apparel and equipment. Reviewing and approving work with particularly hazardous substances. Laboratory Technician(s) who is/are responsible for: Attending laboratory safety training. Reviewing the Chemical Hygiene Plan. Following procedures and laboratory practices outlined in the Chemical Hygiene Plan and Laboratory Safety Manual and as provided by the laboratory supervisor and the Chief Executive Officer. Developing good personal chemical hygiene habits. Using engineering controls and personal protective equipment, as appropriate. Reporting all incidents, accidents, potential chemical exposures and near miss situations to the Laboratory Supervisor and the Chemical Hygiene Officer. Documenting specific operating procedures for work with particularly hazardous substances, including carcinogens, reproductive toxins and chemicals with high acute toxicity. It is my hope that the administration will follow these guidelines in order to provide a safer working and learning environment for teachers, laboratory personnel, and students at Moreno Valley College. Sincerely, Carmen Medina, Lab Technician II 6