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Standard Operating Procedure – Regulated Carcinogens
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Modify this template to describe your specific procedures. You may delete instructions and/or non-applicable
procedures. Mark checkboxes by double-clicking. Print out the completed form and keep a readily accessible
hard copy in the lab with original training record signatures and dates.
Date:
SOP Title:
Principal Investigator:
Room and Building:
Lab Phone Number:
Section 1 – Process
Briefly describe tasks and goals.
Section 2 – Regulated Carcinogen
13 “Listed” Cal/OSHA Carcinogens
2-acetylaminofluorene
4-aminodiphenyl
benzidine and its salts
3,3'-dichlorobenzidine and its salts
4-dimethylaminoazobenzene
alpha-naphthylamine
beta-naphthylamine
4-nitrobiphenyl
N-nitrosodimethylamine
beta-propiolactone
bis-chloromethyl ether
methyl chloromethyl ether
ethyleneimine
Other Regulated Carcinogens (not a complete list)
acrylonitrile
arsenic
benzene
butadiene
cadmium
carbon tetrachloride
formaldehyde
ethylene dibromide
ethylene oxide
methylene chloride (dichloromethane)
methylenedianiline
vinyl chloride.
Other:
Resources to check:
International Agency for Research on Cancer
(Group 1, 2A or 2B)
National Toxicology Program
“Known to be human carcinogens” or "Reasonably anticipated to be carcinogens"
Section 3 – Potential Hazards
Read the MSDS for the carcinogen, available at http://www.ehs.berkeley.edu/healthsafety/msds.html, cut and
paste pertinent hazard information here. Please note: carcinogens are chemicals that cause cancer or
tumor development, typically after repeated or chronic exposure. Their effects may only become
evident after a long latency period and may cause no immediate harmful effects.
Section 4 – Approvals Required
All handling or use of the 13 “Listed” carcinogens requires evaluation by EH&S and
reporting to Cal/OSHA, even if work is contained within a laboratory fume hood. All use of
other carcinogens outside of a closed system or laboratory fume hood must be reported to
EH&S for evaluation. Contact EH&S at 642-3073 or ehs@berkeley.edu to schedule an
evaluation.
Hands-on training by the PI or a knowledgeable designee. Work technique should be observed and
independent handling of carcinogens limited to researchers that have demonstrated competency.
Additionally, inform students and staff about safe handling of the chemical, its physical properties
(including solubility), and health effects seen in experimental studies and other applicable
sources. Review toxicological data from similar compounds if toxicological information is limited.
Explain possible routes of exposure, as appropriate: inhalation, skin absorption, accidental
injection.
Demonstrate and explain proper use of personal protective equipment and engineering controls
to prevent exposure.
Inventory must be maintained via the lab’s chemical inventory.
Section 5 – Designated Work Area
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Laboratory/Room Number:
Fume hood location:
Storage location:
Other designated work location:
Restrict access to the work area when carcinogens are in use.
This requirement applies to all handling of the 13 “listed” carcinogens and work with other carcinogens
if indicated by an EH&S evaluation, e.g. due to high concentration or volume, tasks outside of a fume
hood, etc. A designated area can be the entire laboratory, a specific laboratory workbench, or a
laboratory hood, but shall indicate a work area of limited access where special procedures, knowledge,
and work skills are required. Designated areas must be clearly marked with signs that identify the
chemical hazard and include an appropriate warning; for example:
WARNING!
AUTHORIZED ACCESS ONLY
BENZIDINE WORK AREA
Section 6 – Special Handling Procedures and Storage Requirements
Storage:
Store carcinogens in closed, labeled, chemically compatible containers, away from heat, flame,
and other reactive chemicals that may disperse the carcinogen if mixed during an accidental
release.
The label “carcinogen” should be clearly indicated on the container or shelf.
Always place large-volume containers on a low, protected shelf or in another location where they
will not be accidentally spilled or knocked over.
Containers larger than 4L (or 1 gallon) should be stored inside a deep pan or other secondary
containment.
Do not store chemical bottles in any area where a leak would flow to a drain.
Safe Work Practices (applies to ALL work with carcinogens):
Use the smallest amount of chemical feasible.
Chemicals are clearly labeled with the chemical’s name and hazards.
Line work surfaces with removable plastic-backed absorbent paper.
Double-contain carcinogens in chemical-resistant trays. Contain lab instruments within pans or
trays to contain spills.
As with any laboratory chemical, do not mouth pipette solutions.
Do not eat, drink, or smoke where chemicals are handled, processed, or stored.
Always wash hands thoroughly after handling carcinogens after gloves are removed.
Use containment devices (such as lab fume hoods or glove boxes) when open handling is
required. Ensure your laboratory fume hood is functioning properly.
Use ventilated containment to weigh out solid chemicals. Alternatively, the tare method can be
used to prevent inhalation of the chemical. While working in a laboratory hood, the chemical is
added to a pre-weighed container. The container is then sealed and can be re-weighed outside of
the hood. If chemical needs to be added or removed, this manipulation is carried out in the hood.
In this manner, all open chemical handling is conducted in the laboratory hood.
If handling one of the 13 “Listed” carcinogens (or if indicated by an EH&S evaluation for work
with other carcinogens, e.g. due to high concentration or volume, tasks outside of a fume hood,
etc.), special controls are required per 8 CCR 5209 (c)(6):
N/A (e.g. not working with a “listed carcinogen)
Fume hood checks every six (6) months [call EH&S at 642-3073 if your fume hood indicated more
than six (6) months have passed since the last check]
Daily change of personal protective equipment (when handling carcinogens): researchers are
required to remove and leave protective clothing and equipment at the point of exit from the designated
work area and, at the last exit of the day, to place used clothing and equipment in impervious containers
for decontamination or disposal (e.g. laundry barrel or waste bin for disposables).
Designated work areas (described above)
Use high efficiency particulate air (HEPA) filters, carbon filters, or scrubber systems with
containment devices to protect effluent and vacuum lines, pumps, and the environment.
Researchers are required to wash hands, forearms, face and neck upon each exit from the designated
carcinogen work area.
Unique disposal procedures
Section 7 – Personal Protective Equipment
Lab coat, fully-buttoned Describe method and frequency of cleaning:
Disposable lab coat, solid-front gown, or surgical scrubs
Long pants
Closed-toe shoes
Eye protection required:
Safety glasses
Chemical goggles (appropriate for processes where splash or spray is foreseeable)
Face shield (appropriate if carcinogen is toxic via skin contact/absorption and chemical contact with
the body/skin is foreseeable
For proper selection of glove material, review:
http://www.ehs.berkeley.edu/healthsafety/gloveusage.html
nitrile exam gloves (dilute solutions only)
medium or heavyweight nitrile gloves
neoprene gloves
natural rubber gloves
PVC gloves
If carcinogen is toxic via skin contact/absorption and chemical contact with the body/skin is
foreseeable:
Apron
Over-sleeves
Section 8 – Engineering/Ventilation Controls
Closed system Please describe:
Fume hood
Glove box
Other local exhaust
General room ventilation (negative air pressure, no recirculation allowed)
Other:
Section 9 – Spill and Accident Procedures
Emergency Procedures
In any life-threatening situation, call 911 for immediate medical attention. As with all accidents, report
any exposure or injuries as soon as possible to your supervisor. For regulated carcinogens, suspected
exposure incidents must also be reported to EH&S immediately at 642-3073 to initiate required
reporting to Cal/OSHA and follow-up evaluation.
Spills
If a carcinogen is spilled outside of a chemical fume hood, evacuate the area, close the laboratory doors,
and post the area to prevent others from entering. If the incident occurs during regular work hours
(Monday to Friday, 8 a.m. to 5 p.m.), call EH&S (642-3073) for assistance in cleaning up the spill. After
hours, call UCPD (642-6760); they will contact EH&S responders. Provide information or other
assistance to emergency responders as requested. Small spills should only be cleaned up by trained
employees in the laboratory if the proper PPE and clean up materials are available. Waste should be
labeled and contained with the fume hood until picked up by EH&S. Contact EH&S for assistance as
needed.
Inhalation Exposure
If someone inhales a high concentration of vapor, aerosol or dust, immediately move the person to fresh
air and call Tang Center’s Urgent Care Clinic (642-3188). When the Tang Center is closed, contact Alta
Bates Medical Center (204-1303) or go to their emergency room at 2450 Ashby Avenue, Berkeley. If the
person is having trouble breathing, call 911 for immediate medical attention.
Splash to Eyes or Skin
For eye or skin exposure, immediately flush with plenty of water in an eyewash or safety shower for at
least 15 minutes. Remove contaminated clothing and contact the Tang Center (642-3188). In case of
ingestion, call 911 for immediate medical attention.
Section 10 – Waste Disposal
PPE: Gloves (and other disposable PPE) that have not been contaminated with chemical may be
discarded in the regular trash. Disposable gloves contaminated with chemicals must be thoroughly
rinsed before being discarded in the regular trash. Heavily contaminated gloves must be disposed of as
chemical waste.
Carcinogen waste: Place in a chemically-compatible impervious container with a sealed lid and label
clearly. Decontaminate outside of container prior to removal from the work area; store within a fume hood
until pick up by EH&S. When feasible, carcinogens shall be inactivated prior to disposal. Complete an
electronic MPL online and submit at mpl.ehs.berkeley.edu. Drain disposal of dilute aqueous solutions
containing carcinogens is only allowed as described in the Campus Drain Disposal Guidelines available at
http://www.ehs.berkeley.edu/pubs/guidelines/draindispgls.html. Call EH&S (642-3073) if you need
assistance or see the EH&S Fact Sheet, “Unwanted Hazardous Chemicals,” for general instructions on
disposing of hazardous materials.
Section 11 - Decontamination
After each use, wipe down the immediate work area and equipment to prevent accumulation of
chemical residue.
Upon leaving the designated work area, remove any personal protective equipment worn and
wash hands.
At the end of each project, thoroughly decontaminate the designated area before resuming
normal laboratory work in the area and removing carcinogen warning signs.
Section 12 – Process Steps
Use this section to specify tasks chronologically or to note potentially high risks tasks and their appropriate
controls/safety measures.
Process Steps
e.g. Pick up bottle of X from the storage room
Safety Measures
e.g. Wear PPE, use a cart, use freight elevator;
remove glove to touch doorknobs, elevator buttons,
etc.
Section 13 – Further Resources
Chemical Hygiene Plan
Research protocols or references:
Exposure monitoring results (if applicable):
EH&S Assistance:
EH&S staff are available to help train your employees on the hazards and precautions for working with
regulated carcinogens or review written SOPs. EH&S can also perform exposure monitoring in your
laboratory at no charge. Call the general EH&S number at 642-3073, email ehs@berkeley.edu or visit our
website at www.ehs.berkeley.edu for assistance.
Other related EH&S links:
If working with formaldehyde, please also review the EH&S Fact Sheet available at:
http://www.ehs.berkeley.edu/pubs/factsheets/49formaldehyde.html.
Material Safety Data Sheets: http://www.ehs.berkeley.edu/healthsafety/msds.html
SOP Template: http://www.ehs.berkeley.edu/healthsafety/sop.html
Glove Selection Guidance: http://www.ehs.berkeley.edu/healthsafety/gloveusage.html.
Drain Disposal Guidelines: http://www.ehs.berkeley.edu/pubs/guidelines/draindispgls.html.
Unwanted Hazardous Materials (disposal guidance):
http://www.ehs.berkeley.edu/pubs/factsheets/52hazchems.html
Related Cal/OSHA Regulations:
http://www.dir.ca.gov/title8/5209.html - Regulated Carcinogens, section 5209(c)(6) applies to
laboratories
http://www.dir.ca.gov/title8/5191.html - General Laboratory Standard
http://www.dir.ca.gov/title8/5217.html - Applies to use of formaldehyde in anatomy, histology and
pathology laboratories
Training Documentation
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