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Is Your Chemical Hygiene Plan a Living Document?

A Chemical Hygiene Plan is required for companies falling under OSHA’s Lab Standard, 29 CFR 1910.1450, while a Hazard Communication Plan fulfills the requirements found in OSHA’s Hazard Communication Standard, 29 CFR 1910.1200.  Is your Chemical Hygiene Plan (CHP) updated as hazards, procedures, and policies change, or is it a stagnant document that is reviewed annually at best?

29 CFR 1910.1450 applies to all employers engaged in laboratory use of hazardous chemicals.  Employers covered by the lab standard are required to develop and carry out the provisions of a written CHP, which protects employees from the health hazards associated with hazardous chemicals and keeps exposures below established limits.  Taking time to establish appropriate facility specific procedures, and keeping them up to date, makes a CHP a resource for laboratory employees.  The designated Chemical Hygiene Officer should be involved in developing these procedures, including your personal protective equipment policy and chemical hygiene practices.  If select carcinogens, reproductive toxins, and chemicals with a high level of acute toxicity are in use, special precautions must be established to protect employees.

29 CFR 1910.1450(e)(4) stipulates that employers must review and evaluate the effectiveness of their CHP at least annually. In addition, the CHP must be updated as new hazards are introduced to the facility, and procedures and policies change.  So remember to keep your CHP updated as you train staff on new policies and hazards.

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