Writing a Chemical Hygiene Plan

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American workers can be exposed to a variety of chemicals in their workplaces.American workers can be exposed to a variety of chemicals in their offices, factories, laboratories, and other workspaces. Some substances, particularly those in laboratories and industries such as manufacturing or chemical processing, are toxic.

Others, including cleaning products, glues, paint, and even toner for the copier, may be mostly beneficial – though any of them can be dangerous if misused or mishandled, according to Global Safety Management, which focuses on safety management and compliance.

AllOne Health, a leader in occupational health and employee assistance programs, notes that chemical exposure can put workers at risk of allergies, asthma, cancer, attention deficit disorder, heart disease, chronic fatigue, infertility, inflammatory bowel disease, and many other disorders.

Protecting workers from harm caused by hazardous chemicals begins with a chemical hygiene plan (CHP). According to the Occupational Safety and Health Administration (OSHA), a CHP is “a written program developed and implemented by the employer which sets forth procedures, equipment, personal protective equipment and work practices that are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace.”

Courses in safety management, such as the ones in the Occupational Safety concentration of Eastern Kentucky University’s online Master of Science in Safety, Security and Emergency Management program, can help professionals develop the knowledge and skills needed to formulate CHPs. EKU’s online emergency management degree is also designed to provide preparation for leadership roles and greater responsibility in the occupational safety field.

What is a Chemical Hygiene Plan?

OSHA’s requirements for CHPs are covered in the agency’s Occupational Exposure to Hazardous Chemicals in Laboratories standard 29 CFR 1910.1450.

CHPs, which focus on laboratories, are formal written documents designed to minimize worker contact with hazardous substances.

OSHA’s definition of a health hazard, the online training company Safety Skills explains, is “a chemical that is classified as acutely toxic, poses an aspiration hazard, or can cause skin corrosion and irritation, serious eye damage or irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity or specific target organ toxicity.”

According to Safety Skills, plans should list and explain a facility’s:

  • Hazard identification strategies
  • Hazard controls
  • Equipment inspection and maintenance protocols
  • Employee training requirements
  • Medical consultation and examination
  • Containment equipment
  • Procedures that require prior approval
  • Designated chemical hygiene officer

A chemical hygiene plan checklist can help facilities be sure they are protecting workers according to procedures, policies, and responsibilities set by OSHA. The 8 required elements of a CHP are:

  1. Establishment of standard operating procedures that cover safety and health considerations for each activity involving the use of hazardous chemicals.
  2. Criteria for determining and implementing measures to reduce exposure to hazardous substances
  3. Requirements to ensure proper performance of fume hoods and other protective equipment.
  4. Appropriate dissemination of safety information provided to laboratory personnel
  5. Explanation of conditions under which a lab operation or procedure would require the employer’s approval.
  6. Designation of personnel to implement the CHP, including a chemical hygiene officer or, where appropriate, a chemical hygiene committee.
  7. Provisions for worker protection—including designated areas, use of devices such as fume hoods or glove boxes, procedures for waste removal, and decontamination procedures—when dealing with particularly hazardous substances.
  8. Annual revaluation of the CHP and plans for updates as needed.

The Importance of Communication and Employee Training

In OSHA’s most recent annual list of most frequently cited violations, hazard communication comes in at the No. 2 spot, after fall protection. Safety+Health magazine reported 4,537 total violations for fiscal 2017, the latest year for which figures are available. In fact, it has been the second most cited standard since 2013.

OSHA’s Hazard Communication Standard covers both chemicals produced at a workplace and those brought in and mandates communication of those hazards to the workers.

Worker training is key to the successful execution of any chemical or hazard protection plan.

But, as Occupational Health & Safety magazine points out, “while employee training is a critical part of OSHA’s Hazard Communication Standard (HazCom), it’s also an area where employers often fall short and struggle with the basic elements that make training effective, engaging, and, most of all, compliant.”

In some workplaces, all employees need HazCom training, Occupational Health & Safety notes. In others, training may be focused on a specific group of workers. Contract and temporary workers also may need hazard training.

Companies should conduct training in a language that workers understand, the magazine points out, and also take into account variations in literacy and vocabulary. Information the training should cover includes:

  • How to detect the release or presence hazardous chemicals.
  • Understanding how chemicals in the work area can affect physical and overall health.
  • How workers can protect themselves from hazards, including understanding work and emergency procedures and the best use of personal protective equipment.
  • Understanding the standards and details of the employer’s written CHP.

OSHA’s HazCom Standard also notes that employers who have hazardous chemicals in the workplace must have labels and safety data sheets available for employees and should provide training in safe handling of chemical materials.

About Eastern Kentucky University’s Online Master of Science in Safety, Security and Emergency Management Program

Students enrolled in EKU’s online emergency management degree program learn the essential components of safety, security, and emergency management.

The program allows students to customize their experience through a Multidisciplinary Track or concentrations in Corporate Security Operations, Occupational Safety, or Emergency Management and Disaster Resilience. The concentrations are also available as stand-alone graduate certificates, independent of a master’s degree.

EKU is accredited by the Southern Association of Colleges and Schools Commission on Colleges. For more information, contact Eastern Kentucky University now.

Recommended Reading:

The Safety and Health Achievement Recognition Program

Workers’ Rights in the United States

Production Versus Safety in the Workplace


Workplace chemicals: Global Safety Management

Chemical exposure disorders: AllOne Health

Chemical hygiene plan definition: OSHA

What is a Chemical Hygiene Plan and Why Does Your Lab Need it?: Safety Skills

Chemical hygiene plan checklist: OSHA fact sheet

OSHA violations: OSHA

Employee Training: OHS Online

OSHA Hazard Communication: OSHA