PSFC Chemical Hygiene Plan

III. Chemical Hygiene Plan

  1. Preparation, Approval, Annual Review and Update

    1. The Chemical Hygiene Officer, Catherine L. Fiore, will oversee the preparation of the Chemical Hygiene Plan for the Plasma Science and Fusion Center. She is responsible for seeing that the plan meets requirements set forth in 29 CFR 1910.1450. Assistance in creating the Chemical Hygiene Plan is provided by the MIT EH&S Team.
    2. The Chemical Hygiene Officer, in concert with the Industrial Hygiene Program (IHP), is responsible for seeing that the Chemical Hygiene Plan is reviewed on an annual basis and updated to accommodate changes in 29 CFR 1910.1450, departmental procedures, personnel, MIT policy and other pertinent materials. The Chemical Hygiene Officer and IHP will also see that the Chemical Hygiene Plan is updated to include procedures regarding new hazards and processes as they are introduced.
    3. The Chemical Hygiene Officer will see that the Chemical Hygiene Plan and updates are distributed to or made available to those who are affected by it.
    4. The Chemical Hygiene Plan and Safety Plan updates will be reviewed by the directors of the MIT EH&S Team for final approval. Updates are due annually on or before January 15
    5. One copy of the Chemical Hygiene Plan and all updates will be provided to MIT EH&S for reference use in the Industrial Hygiene Program.

  2. Identification and Classification of Hazardous Chemicals

    3. See also PSFC Lab Hazards Inventory (Appendix C)

    1. Identification of Hazardous and Particularly Hazardous Chemicals

      The PSFC Safety Committee conducts an annual inventory (every summer) of the hazardous chemicals located throughout the PSFC due September 1. This information is provided to the PSFC ES&H Office, where the complete inventory for the PSFC is maintained. These chemicals include organic solvents, halogenated solvents, caustics (acids, hydroxides, and alkali cleaners), resins and hardeners, reactive metals, peroxides, toxic and flammable gases, and synthetic and petroleum-based oils. The hazards of such substances depend on their toxicity and physical characteristics such as flammability and reactivity.

      Flammability or Combustibility is the readiness with which the vapors of a liquid, or with which a gas ignite and burn.

      Toxicity may be acute or chronic, depending on the substance as well as the level and duration of exposure associated with the use of that substance.

      Acute toxic effects occur shortly after exposure and include, but are not limited to, symptoms such as chemical burns and irritation.

      Chronic toxic effects appear after repeated exposure over a long period of time and include symptoms such as chronic disease of the organ systems (e.g., liver, kidneys, lungs) including cancer.

      Reactivity is the tendency of a chemical to chemically change or breakdown, with the release of heat, energy, and possibly chemical contaminants.

      MIT EH&S has compiled a partial list of what it considers "particularly hazardous substances". This list was derived from a number of sources, including the International Agency for Review of Carcinogens (IARC), the National Toxicology Program (NTP), and the Occupational Safety and Health Administration. Any item on the PSFC chemical inventory which is also on the list of particularly hazardous substances must nearly always be designated as a particularly hazardous substance with the following exceptions:

      • The CHO may petition EH&S to change the designation of the particularly hazardous substance to a "hazardous" chemical under certain conditions. For example: a very small amount of the chemical is being used, i.e., isopropanol. Isopropyl alcohol is listed as a carcinogen by IARC and NTP. This is because manufacturing processes are thought to present a risk of cancer to workers engaged in the manufacture of isopropyl alcohol. Isopropyl alcohol may be designated as a hazardous chemical for the purposes of the PSFC without petitioning EH&S.
      • The IARC has designated mildly hydrotreated or mildly solvent-refined oils as potential carcinogens. Mild hydrotreatment is defined as hydrotreatment processes conducted using pressures of 800 pounds per square inch or less, and temperatures of 800 degrees Fahrenheit or less, independent of other process parameters. Heavily or severely hydrotreated or solvent refined oils are not designated as potential carcinogens by the IARC. The MSDS for the oil should indicate whether mild or light hydrotreatment or solvent refining methods were used to produce the oil. Thus, MSDS's for all vacuum pump and other oils used at the PSFC must be reviewed to determine whether the oil is designated as a potential carcinogen.
      • Consumer products, such as household cleaners used for the purpose for which they were intended and in small quantities, will not be included under this plan.

      Whenever a new chemical is purchased, it is the responsibility of the supervisor to confirm through the CHO that it has been added to the chemical inventory. The supervisor shall fill out a "Chemical Purchase Information Form" (see appendix G) and return it to PSFC HQ. before bringing a new chemical into the PSFC environs. The CHO shall assign the proper classification to the chemical at that time.

    2. Inventory of Hazardous and Particularly Hazardous Chemicals by Room.

      (The PSFC Lab Hazards (chemicals) Inventory is presented in Appendix C.)

    3. Classification of PSFC Chemicals

      Chemicals presently used at the PSFC may be classified under one or more of the following categories:

      • Flammable liquid: flash point < 100 degrees Fahrenheit .
      • Combustible liquid: flash point > 100 degrees Fahrenheit.
      • Caustic liquids and solvents:capable of producing chemical burns and tissue damage
      • Halogenated solvents
      • Reactive chemicals and metals
      • Toxic chemicals
      • Non-reactive toxic metals
      • Photo processing chemicals
      • Electroplating chemicals
      • Epoxy resins and hardeners
      • Synthetic and petroleum based oils
      • Hazardous gases (flammable or toxic)

      A wide range of potential toxic effects may be indicated for chemicals within each of the categories listed above. Standard Operating Procedures (SOP's) have been developed for common usage of chemicals. In some cases, an SOP for use of a single chemical or single procedure has been developed because of unique hazards associated with that chemical or specific use of that chemical.

      The chemical inventory is periodically reviewed by the PSFC Office of Environment, Safety, and Health to determine whether there are chemicals on the MIT EH&S Particularly Hazardous Substances list.

  3. Selection of Required Control Methods, Authority for Chemical Use

    4. As described under item II.E., the use of hazardous chemical substances shall be eliminated or minimized whenever possible.

    Standard operating procedures (SOP's) must be developed to outline the procedures and precautions to be followed whenever a new chemical is introduced if that chemical is not covered by an existing SOP. New users of a chemical already covered by an SOP may be required to develop a new SOP as well, at the direction of their supervisor or the CHO. Thus, when considering the purchase of a new chemical, the supervisor must initiate the development of an appropriate SOP.

    The Fiscal Office staff will refer any purchase order involving the purchase of chemicals to the CHO or the CHO's designated representative. All purchase orders, interdepartmental requisitions and EREQ's for hazardous chemicals must be approved by the CHO or her designate. Chemicals should not be purchased with MIT credit cards without the express written prior approval of the CHO.

    This provides a mechanism for maintaining and updating the chemical inventory. The CHO shall maintain contact with the supervisor to ensure that an appropriate SOP is developed.

    If the use of a hazardous chemical cannot be eliminated or avoided, engineering controls will be used whenever feasible to minimize or prevent any uncontrolled release of hazardous chemicals. This includes:

  4. Special Provisions for Particularly Hazardous Substances

    5. Special Precautions for Work with Nanomaterials

      Nanomaterials are defined by the ASTM as a material with two or three dimensions between 1 to 100 nm. They can be composed of many different base materials (carbon, silicon, and metals such as gold, cadmium, and selenium).  They can also have different shapes:  such as nanotubes, nanowires, crystalline structures such as quantum dots, and fullerenes.  Nanomaterials often exhibit very different properties from their respective bulk materials: greater strength, conductivity, and fluorescence, among other properties. 

      The toxicity of most nanomaterials is currently unknown.  Preliminary toxicity testing has indicated that some nanoparticles may be more toxic than the corresponding micron sized particle because of their greater surface area and reactivity.  Nano-sized titanium dioxide produces 40 fold more lung inflammation than micron-sized particles.  In preliminary tests, carbon nanotubes have produced lung inflammation and fibrosis similar to crystalline quartz and asbestos.  Nanoparticles are similar in size to viruses and are easily taken up by the body’s cells, translocate around the body, and can possibly pass into the brain and through the skin.

      The MIT EHS Office considers nanoparticles that have the potential for release into the air to be handled as particularly hazardous substance because their toxicity is, for the most part, unknown and early studies have been suggestive of toxic effects.  In the future, many types of nanoparticles may turn out to be of limited toxicity but precaution should be used until more is known.  Work with nanoparticles that may release particles should be conducted in enclosures, glove boxes, fume hoods, and other vented enclosures.  All work should be done with gloves, at a minimum disposable nitrile gloves. More information on additional precautions and a review of the toxicity of some types of nanomaterials are on the EHS web site at: http://web.mit.edu/environment/ehs/topic/nanomaterial.html  

      This article also lists good reference sources for researchers to consult to keep up with toxicity information on their materials as it develops.  Currently, nanoparticles and solutions containing them are being disposed of as hazardous waste.  Please call the EHS Office at 617-253-0344 for exposure evaluation of experimental setups and additional information.

  5. Elimination or Substitution

    6. The first step in evaluating a new experiment, process or operation is to investigate the possibility of eliminating the use of hazardous materials or substituting a less hazardous material. The Industrial Hygiene Program (3-2596) should be consulted for advice.

    The Institute has a program administered by the Environmental Programs Office to reduce the purchase of large quantities of chemicals. A "large quantity" is an amount which will not be consumed and therefore must be stored for a period of 6 months or longer. A sample form is included. See Appendix H.

  6. Enclosure, Isolation, and Regulated Areas

    7. All particularly hazardous substances shall only be used in designated areas.

  7. Education and Training

    8. The Chemical Hygiene Officer (CHO) in conjunction with the supervisor shall provide information and training concerning handling of hazardous chemicals in the laboratory.

    The Industrial Hygiene and Safety Programs are available to assist the CHO in developing and implementing training procedures and policies. The Industrial Hygiene Program conducts training sessions for the CHO's at the Institute.

    Employees shall be informed of the presence of hazardous chemicals when assigned to a work area and prior to new exposure situations. This information must include contents of the OSHA Lab Standard, the applicable details and location of the Chemical Hygiene Plan; physical and chemical properties of hazards used in the workplace; proper handling procedures to minimize exposure; signs and symptoms of exposure associated with specific chemicals; the location and availability of reference material; emergency and personal protective equipment training. Employees shall also receive training about the information provided on Material Data safety sheets (MSDS's). The training should be provided immediately for new employees in affected work areas and annually for other personnel.

    Training shall be directed by the Chemical Hygiene Officer in conjunction with the laboratory supervisor and Industrial Hygiene and Safety Programs' representative. A training outline shall be prepared by the Industrial Hygiene Program and used as the basis for lectures and demonstrations. Training is provided by Andrew Kalil, Bill Trabilcy, or a designated representative of IHP for the PSFC and is also available as web training at http://web.mit.edu/environment/training/. Training records are maintained in a central database by MIT EHS for each PSFC employee.

  8. Work Practices and Standard Operating Procedures for Classes of Chemicals

    9. The following SOP's are included in Appendix M:

    (*) These procedures are no longer relevant and have been retired; either the processes are no longer used or the experiment has been removed from the PSFC.

  9. Personal Protective Equipment

    10. The use of personal protective equipment is subject to specific lab requirements and shall be indicated in the SOP's. The type and level of equipment can be determined with the aid of MIT EH&S. Any use of personal protective equipment should only be implemented after the options of reducing the hazards have been considered.

    Respirators

    The use of respirators shall be determined by the Employee, Laboratory Supervisor and the Industrial Hygiene Program. The MIT respirator policy must be followed. The complete MIT written Respirator Program appears in Appendix D. The following elements must be adhered to:

    Other Personal Protective Equipment

    Other personal protective equipment shall be used, if needed. Its use shall be included in the SOP.

  10. Ventilation, Fume Hoods, and Proper Operations

    11. Local exhaust ventilation is the primary method used to control inhalation exposures to hazardous substances. The laboratory fume hood is the most common local exhaust method used in laboratories. Other types of local exhaust include vented enclosures for large pieces of equipment or chemical storage, and snorkel types of exhaust for capturing contaminants near the point of release. Local exhaust systems consist of some type of hood, duct work, and a fan located on the roof. Some systems are equipped with air cleaning devices (HEPA filters or carbon adsorbers). In most cases individual fans service each hood.

    A laboratory fume hood (see Figure J-1 ) should be used when working with hazardous substances as described in section III.C. A properly operating and correctly used fume hood will control the vapors released from volatile liquids as well as dust and mists.

    Do not make any modifications to hoods or duct work without calling the Industrial Hygiene Program first (3-2596). It is Institute policy that any changes made to local exhaust systems must be approved by the Industrial Hygiene Program.

    Do not use a fume hood for large pieces of equipment unless you intend to dedicate the fume hood for this use since it will change the airflow patterns and render the fume hood unsafe for other uses. It is generally more effective to install a specially designed enclosure for large equipment.

    Do not use a fume hood for chemical storage. Store chemicals in a chemical storage cabinet since a hood cluttered with bottles may not contain releases effectively.

    The EH&S's Industrial Hygiene Program conducts the fume hood survey program (See Appendix E for a description of this program). Before you begin using a fume hood, check to see that the hood is labeled (See Figure J-2) as appropriate for use with toxic chemicals and has been recertified within the last year. If this is not the case or if you have any doubts about the fume hood operation, contact the Industrial Hygiene Program (3-2596). Also use the proper work practices listed below:

    Figure J-1

    Laboratory Fume Hood

     

    Figure J-2

    Laboratory Fume Hood Survey Forms

  11. Housekeeping

    12. General

    Spill Procedures

Continue to Chapter III.L of the PSFC Chemical Hygiene Plan

This page maintained by Catherine L. Fiore FIORE@PSFC.MIT.EDU
Updated 1/7/2008