The Chemical Hygiene Plan
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What it is
The regulation defines a Chemical Hygiene Plan as a written program setting out procedures, equipment, personal protective equipment and work practices capable of protecting employees from the health hazards of the chemicals used in that particular workplace.
The eight elements
- Standard operating procedures for safety and health.
- Criteria for implementing control measures: engineering controls, protective equipment, hygiene practices.
- Requirements that fume hoods and protective equipment function properly.
- Employee information and training.
- Circumstances requiring prior approval before an operation begins.
- Provisions for medical consultation and examination.
- Designation of responsible personnel, including a Chemical Hygiene Officer.
- Additional protections for particularly hazardous substances, including select carcinogens and reproductive toxins.
Reviewed at least annually
The employer reviews and evaluates its effectiveness at least once a year and updates it as necessary. A plan written once and filed is not what the standard asks for, and the review is the part most often missed.
Particular to your workplace
A template downloaded and filed unchanged does not describe the chemicals you use or the hoods you have. The standard is explicit that it protects employees from hazards presented in that particular workplace.
The Chemical Hygiene Officer is a named person
Designating somebody is a requirement rather than a formality, and in a small operation it will be somebody who also does other things. The point is that responsibility sits with a person rather than with the organization in general.
It sits alongside hazard communication
Labels on shipped containers and safety data sheets are the other standard, and both apply. A laboratory has the general chemical rules plus this one.
Training is part of it, not an extra
Employees have to be informed about the hazards present and trained on the measures that protect them, and that obligation recurs as people join and as the chemicals change. A plan with no training record behind it describes an intention rather than a practice.
Fume hood performance is checkable
The standard asks that hoods and protective equipment function properly, which means somebody has to verify it rather than assume it. A hood that has never been tested is the control everybody relies on and nobody has confirmed.