laboratory safety inspection corrective action guidance
TRANSCRIPT
MSU LABORATORY SAFETY INSPECTION CORRECTIVE ACTION GUIDANCE DOCUMENT June 2021
Environmental Health & Safety Michigan State University 4000 Collins Road, Room B20 Lansing, MI 48910 517-355-0153 ehs.msu.edu
ehs.msu.edu June 2021 Page 2
1. TABLE OF CONTENTS Purpose/Version ............................................................................................................................................ 3 Regulatory references ................................................................................................................................... 4
Department Specific Information .............................................................................................................. 5 1. Right – to – know poster ............................................................................................................... 5
Inspection Checklist ...................................................................................................................................... 5 Administration Requirements .................................................................................................................... 5
1. Closed doors when work is in place or no one is present ............................................................ 5 2. Pest control program is in place ................................................................................................... 6 3. Warning signs and emergency contact information up to date and posted on doors .................. 6 4. Site specific training is documented annually ............................................................................... 7 5. Personnel can demonstrate how to access SDS (formerly MSDS) ............................................. 8 6. Personnel can demonstrate how to access EHS manuals (i.e.: Chem, Bio, Waste) ................... 8 7. Laboratory SOPs are available ..................................................................................................... 9 8. Exposure incident response is posted ........................................................................................ 10 Procedures in case of injury and illness ............................................................................................. 11
Facility ..................................................................................................................................................... 13 9. Benchtops and furniture are impervious ..................................................................................... 13 10. Disinfection of benchtops and equipment done daily or after equipment is used ...................... 14 11. Inventory logs are used (biological and chemical) ...................................................................... 15 12. Eyewash is present, flushed weekly (documented), unobstructed, operational ......................... 15 13. Emergency shower is present .................................................................................................... 17
Personal Protective Equipment .............................................................................................................. 18 14. Disposable gloves available, used, disposed of properly ........................................................... 18 15. Specialized protective gloves are available and in good condition ............................................ 19 16. Lab coats are available and worn ............................................................................................... 19 17. Safety glasses/goggles and face protection available and worn as appropriate ........................ 21 18. Dress code for working in laboratories is followed ..................................................................... 21 19. No food, drink, cosmetics, lotions, non-work-related plants or animals ..................................... 24 20. Broken glass procedures in place (including blood tubes) ......................................................... 24 21. Soap and paper towel readily available and used for handwashing .......................................... 25 22. Good housekeeping practices are being conducted .................................................................. 26
Chemical Storage and Handling ............................................................................................................. 26 23. All chemicals are labeled properly .............................................................................................. 26 24. Chemicals are stored according to compatibility ........................................................................ 28 25. Containers show integrity ........................................................................................................... 29 26. Storage areas are labeled .......................................................................................................... 30
ehs.msu.edu June 2021 Page 3
Compressed Gases ................................................................................................................................ 31 27. Cylinders are secured properly ................................................................................................... 31 28. Flammable and Oxidizing gases are separated ......................................................................... 31 29. There are SOP’s for toxic, pyrophoric and corrosive gases ....................................................... 32
Peroxide Forming Chemicals .................................................................................................................. 32 30. Peroxide formers dated .............................................................................................................. 32 31. Peroxides are tested regularly and documented ........................................................................ 33 32. SOP’s are present for high hazardous chemicals ...................................................................... 34
Flammables ............................................................................................................................................ 35 33. Flammables are kept away from heat, ignition, flames and stored in appropriate fridges/freezers or cabinets .......................................................................................................................................... 35
Biological Storage and Handling............................................................................................................. 36 34. Biohazard signage on equipment and materials as appropriate ................................................ 36 35. Export controlled agents and toxins are locked .......................................................................... 36 36. Biological materials are labeled properly .................................................................................... 37
Waste Management ................................................................................................................................ 38 37. Chemical waste containers are labeled and have closed lids AND ........................................... 38 38. Hazardous waste tags are completed ........................................................................................ 38 39. Biological waste containers are labeled (covered in section 40) ................................................ 39 40. Biological waste containers are labeled and have closed lids .................................................... 39 41. Regulated wastes are not stored beyond 90 days ..................................................................... 40 42. Hazardous waste tags are complete with no abbreviations ....................................................... 41 43. Sharps containers labeled, no non-sharp waste, not overfilled, not overdue ............................. 41 44. Biohazardous waste policies are followed, chemical treatment or autoclaving .......................... 42
Safety Equipment and Containment ....................................................................................................... 43 45. Biosafety cabinet properly used, disinfected and located .......................................................... 43 46. Biosafety cabinet certified annually (BSL-2) ............................................................................... 44 47. Mechanical devices are used, no mouth pipetting ...................................................................... 44 48. Vacuum system with inline filter, dual flasks, stable and disinfected immediately ..................... 45 49. Spill kits (biological and chemical) are available ........................................................................ 46 50. Safer sharps or needle locking syringe device are used for rDNA ............................................. 47
PURPOSE/VERSION This document serves as a reference guide to chemical and biological safety compliance in laboratories at Michigan State University (MSU). It contains the inspection checklist with references to regulatory and MSU recommendations linked below as well as actions laboratories (labs) should take to assure the safety of students and employees.
Issued: June 2021
ehs.msu.edu June 2021 Page 4
Revised:
REGULATORY REFERENCES • NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules April 2019
<https://osp.od.nih.gov/wp-content/uploads/NIH_Guidelines.pdf> • Biosafety in Microbiological and Biomedical Laboratories. HHS Publication No. (CDC) 21-1112, 5th
Edition <https://www.cdc.gov/labs/pdf/CDC-BiosafetyMicrobiologicalBiomedicalLaboratories-2009-P.PDF>
• MSU Biosafety Manual <https://ehs.msu.edu/_assets/docs/bio/msu-biosafety-manual.pdf> • MSU Bloodborne Exposure Control Plan <https://ehs.msu.edu/_assets/docs/bbp/msu-exposure-
control-plan.pdf> • MSU Chemical Hygiene Plan <https://ehs.msu.edu/_assets/docs/chem/msu-chem-hygiene-plan.pdf> • MSU Waste Disposal Guide <https://ehs.msu.edu/_assets/docs/waste/msu-waste-disposal-
guide.pdf> • MSU Biohazardous Waste Management Plan <https://ehs.msu.edu/_assets/docs/waste/msu-
biowaste-mgmt-plan.pdf> • MSU Radiation Safety Manual <https://ehs.msu.edu/_assets/docs/rad/msu-rad-safety-man.pdf> • OSHA Standard 1910.1450 App A <https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1450AppA> • OSHA 3111- Hazard Communication Guidelines for Compliance
<https://www.osha.gov/Publications/osha3111.pdf>
• MIOSHA o General Industry & Construction Safety & Health Standard, Part 431. Hazardous Work In
Laboratories <https://www.michigan.gov/documents/CIS_WSH_part431_35623_7.pdf> o Construction Safety Standard Part 42. Hazard Communication
<(https://www.michigan.gov/documents/CIS_WSH_part_42__47164_7.pdf> o Michigan’s Right to Know Law and Hazard Communication Standards
<https://ehs.msu.edu/_assets/docs/hazcom/miosha-right-to-know-regulation.pdf>
• The American National Standards Institute (ANSI) document ANSI Z358.1-2014. Available upon request.
• FDA document 21 CFR Parts 878, 880, and 895 <https://www.govinfo.gov/content/pkg/FR-2016-12-19/pdf/2016-30382.pdf>
• International Fire Code 2015, Part II, Section 304.1 <https://codes.iccsafe.org/content/IFC2015/chapter-4-emergency-planning-and-preparedness#IFC2015_Pt02_Ch04_Sec403>
• NFPA 55 - Compressed gases and cryogenic fluids code <https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=55>
• NFPA 45 - Standard on Fire Protection for Laboratories Using Chemicals <https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=45>
• Electronic Code of Federal Regulations
o Public Health Part 73 - Select Agents & Toxins <https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=8a4be60456973b5ec6bef5dfeaffd49a&r=PART&n=42y1.0.1.6.61>
o Animals & Animal Products Part 121—Possession, Use, & Transfer Of Select Agents & Toxins <https://www.ecfr.gov/cgi-
ehs.msu.edu June 2021 Page 5
bin/retrieveECFR?gp=1&SID=b9126e9fba23e3e7933354a1d2630d72&ty=HTML&h=L&n=9y1.0.1.5.58&r=PART>
o Agriculture Part 331 - Possession, Use, & Transfer Of Select Agents & Toxins <https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=b9126e9fba23e3e7933354a1d2630d72&ty=HTML&h=L&n=7y5.1.1.1.9&r=PART>
Additional information For additional information about the items covered in this document or if you have questions contact MSU EHS at 517-355-0153 or search the link below for complete list of personnel, contact information, and locations.
Department Specific Information
1. Right – to – know poster
Every department must display the Michigan Right – To – Know law poster in its premises, listing the location of SDSs for all hazardous chemicals used in the department’s labs.
References:
MSU Chemical Hygiene Plan Section 5.1.2.
Michigan Right-to-Know law <https://ehs.msu.edu/_assets/docs/hazcom/msu-rtk-hazcom-doc.pdf> OSHA Standard 1910.1450 App A (f)(3)(v). OSHA 3111- Hazard Communication Guidelines for Compliance.
Corrective actions:
Make sure your department has the Michigan Right – To – Know law poster <https://www.michigan.gov/documents/dleg/wsh_cet2105_219990_7.pdf> displayed. For compliance, print the signs below, fill out with the appropriate information and affix in the laboratory.
Signage can also be found on the EHS Hazard Communication website <https://ehs.msu.edu/occ/hazcom/index.html> under “postings”.
INSPECTION CHECKLIST
Administration Requirements
1. Closed doors when work is in place or no one is present
Doors have locks to restrict entrance and Principal Investigator (PI) limits access to the lab to individuals who meet specific entry requirements. Maintain doors closed during experiments and lock unattended labs. Doors should be shut as buildings are designed to maintain negative directional air flow from the corridor to the labs, if doors are left open, the building’s ability to do so may be compromised.
ehs.msu.edu June 2021 Page 6
References:
Biosafety in Microbiological and Biomedical Laboratories, 5th Edition (BMBL 5th ed). Section IV: BSL2 A.1, D.1.
MSU Chemical Hygiene Plan. Section 5.1.3.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
Always lock doors when no one is in the lab and maintain doors shut when performing work. Question anyone requesting access to the laboratory as to their purpose and require proof of identification.
2. Pest control program is in place
Many pests, such as flies and cockroaches, can mechanically transmit disease pathogens and compromise the research environment. Even the presence of innocuous insects can contribute to the perception of unsanitary conditions therefore keeping lab environments clean and free of non-research related insects is necessary.
References:
BMBL 5th ed. Appendix G—Integrated Pest Management (IPM).
MSU Biosafety Manual
Corrective actions:
Inspect lab for any signs of insects or pests. Manage waste appropriately. Lab windows that open to the exterior should be fitted with screens. Check the integrity of screens in windows if applicable and if you suspect there is a pest problem in your lab contact MSU IPF <https://ipf.msu.edu/> for assistance.
3. Warning signs and emergency contact information up to date and posted on doors
All lab doors must have an “Admittance to Authorized Personnel Only” label provided by EHS. This sign must contain appropriate contact information including the name and phone number of the lab supervisor or other responsible personnel. These names and numbers shall be updated when personnel change. In case of an emergency, responders use this information to contact knowledgeable personnel about specific lab hazards.
In addition, signage must have symbols that reflect the current hazards found in the lab: for example, a biohazard label is required for all areas or equipment in which BSL-2 or higher agents are handled or stored; chemical hazard symbols must be present if a lab has 10 gallons or more of a flammable or corrosive liquid or toxic gas(es) and so on.
References:
BMBL 5th ed. Section IV.
MSU Chemical Hygiene Plan. Section 5.1.2.
ehs.msu.edu June 2021 Page 7
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
OSHA Standard 1910.1450 App A.
Corrective actions:
Request door signage from EHS by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting a Lab Door Sign Request.
Review selection criteria for hazard door sign labels <https://db.ehs.msu.edu/door_sign/label_list.htm> before starting your request.
Periodically check the contact names and phone numbers on signs to make sure they are current and submit a request for a new sign as needed.
4. Site specific training is documented annually
In addition to the completion of EHS required training courses, the PI or supervisor must ensure that all lab personnel receive site-specific training. This training includes information specific to their job duties, precautions to prevent exposures, and exposure response procedures. In addition, lab personnel are to be given information about immune competence and conditions that could predispose them to infection, as appropriate.
References:
BMBL 5th ed.
MSU Biosafety Manual- Appendix K-Site Specific Training Checklist.
MSU Chemical Hygiene Plan. Section 1.5.
MSU Bloodborne Exposure Control Plan. Appendix E-Bloodborne Pathogens Site-Specific Training Checklist
MSU Bloodborne Exposure Control Plan. Appendix F-Supervisor’s Guide for Bloodborne Pathogens Site-Specific Training Checklist
Corrective actions:
Site-specific training must be documented and maintained by the unit/PI/supervisor and be available to representatives of EHS, the CHO (Chemical Hygiene Officer) members of the CHS (Chemical Hygiene Subcommittee) or other regulatory officials upon request. Checklists must be completed within 30 days of initial training, after a procedural change, when new tasks are assigned, and annually for everyone working in the laboratory including the PI. Retention for site-specific training checklists is now three (3) years.
The site-specific training form < https://ehs.msu.edu/_assets/docs/lab/lab-site-specific-training-checklist.pdf> is available on the MSU EHS website.
ehs.msu.edu June 2021 Page 8
5. Personnel can demonstrate how to access SDS (formerly MSDS)
The use of the acronym MSDS and Material Safety Data Sheet was amended to SDS and Safety Data Sheet throughout the document to reflect MIOSHA adoption of the Global Harmonization System’s terminology.
A Safety Data Sheet (SDS) is a document containing chemical hazard identification and safe handling information and is prepared in accordance with the OSHA Hazard Communication Standard and the Michigan Right-to-Know law.
The Michigan Right-to-Know law requires that units and/or P.I.s keep SDSs in a systematic and consistent manner. EHS is a central repository for SDSs and P.I.s/supervisors must ensure that employees know how to access them.
References:
MSU Chemical Hygiene Plan. Sections 5.1.5. and 5.1.2.1.
MSU EHS Hazard Communication Document <https://ehs.msu.edu/_assets/docs/hazcom/msu-rtk-hazcom-doc.pdf>. See Michigan Right-to-Know law section. OSHA Standard 1910.1450 App A. (f)(3)(v).
OSHA 3111. Communication Guidelines for Compliance.
Corrective actions:
Ensure your personnel know how to access SDSs. The system a unit uses to store them can vary from keeping them in a notebook or file cabinet to using the EHS request system. The system adopted must provide easy access to SDSs for hazardous chemicals used in the lab. Each unit must post a Michigan Right-to-Know Law poster, which indicates the location of all SDSs for hazardous chemicals used in the lab.
As EHS is a central repository for SDSs you may search the EHS SDS website <https://ehs.msu.edu/sds.html>.
For further help in determining the hazard of a chemical, contact your supervisor, instructor or EHS.
Examine the known hazards associated with the materials being used and never assume all hazards have been identified. Determine the potential hazards and use appropriate safety precautions before beginning any new operation.
If you are unable to locate an SDS on the EHS website, telephone the EHS office at 517-355-0153 and request assistance. Between the hours of 5:00 pm and 8:00 am, please contact MSU Police and at 517-355-2222. The MSU Police will contact a representative from EHS, who will provide you with a SDS as soon as you need it.
6. Personnel can demonstrate how to access EHS manuals (i.e.: Chem, Bio, Waste)
MSU has developed operations manuals that identify the hazards that will or may be encountered in laboratories, and that specify practices and procedures designed to minimize or eliminate exposures to them. These manuals include a Chemical Safety Plan, a Biosafety Manual, Bloodborne Exposure Control Plan, Waste Disposal Guide among others. Personnel working in labs must be familiar with the available
ehs.msu.edu June 2021 Page 9
manuals through their education/training sessions and must have access to them either through physical copies kept in the lab or through the web.
In addition, each lab must supplement the biosafety manual with information that is specific for the individual lab and research materials. Supplemental information may include: specific PPE practices and location of supplies, lab specific training requirements, lab specific waste handling practices and autoclave procedures, safe operation and decontamination of lab specific equipment, proper use of disinfectants specific for the lab (appropriate concentration, contact time and shelf life), etc. Written standard operating procedures are required for tasks that are performed with BSL-2 materials and unfixed human materials.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-B-2-m.
BMBL 5th Ed.
MSU Biosafety Manual. Appendix K-Site Specific Training Checklist.
MSU Chemical Hygiene Plan. Section 1.7.
MSU Bloodborne Exposure Control Plan.
MSU Waste Disposal Guide.
Corrective actions:
Instruct lab personnel on where to find the EHS Manuals. These can be downloaded from the EHS Manuals, Policies & Guidelines webpage <https://ehs.msu.edu/policy-guide.html> or through the links below.
MSU Biosafety Manual https://ehs.msu.edu/_assets/docs/bio/msu-biosafety-manual.pdf
MSU Bloodborne Exposure Control Plan <https://ehs.msu.edu/_assets/docs/bbp/msu-exposure-control-plan.pdf>
MSU Chemical Hygiene Plan <https://ehs.msu.edu/_assets/docs/chem/msu-chem-hygiene-plan.pdf>
MSU Waste Disposal Guide <https://ehs.msu.edu/_assets/docs/waste/msu-waste-disposal-guide.pdf>
MIOSHA R 325.70107(b) https://www.michigan.gov/documents/CIS_WSH_part431_35623_7.pdf
7. Laboratory SOPs are available
Standard Operating Procedures (SOPs) specific for that unit’s safety should be developed by the P.I. or laboratory supervisor to minimize the potential exposure of personnel to potentially hazardous biological and chemical materials. These written procedures must be readily available and members of the laboratory running the experiments must be trained on how to follow them.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules.
ehs.msu.edu June 2021 Page 10
April 2019. Section IV-B-7-d-(1) and (2).
BMBL 5th ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan 1.7.
MIOSHA R 325.70107(b)
Corrective actions:
SOPs are documents developed to contain safety procedures when dealing with infectious organisms, bloodborne agents and/or hazardous chemicals. They should list and explain the series of PPEs, engineering controls and measure you can take for your safety and for the safety of others while performing a lab task. Discuss with lab employees and students the SOPs for each particular task/experiment. Make paper or electronic copies readily available for consultation. While SOPs are recommended for all lab operations, it is particularly important for highly hazardous chemicals, operations or dangerous equipment. Inspectors will ask to see SOPs for items such as toxic gases, highly toxic compounds, potentially dangerous equipment, highly reactive chemicals, etc.
The use of perchloric acid is strictly controlled at MSU. Heated perchloric acid can create potentially explosive perchlorate salts that deposit on equipment and ventilation elements. All labs using or storing perchloric acid will be required to follow all of the requirements outlined in the following document:
Safe Use of Perchloric Acid All users of hydrofluoric acid must also follow MSU guidelines when using and storing this compound. This includes having a readily accessible and well-stocked HF exposure kit on hand at all times.
Other examples of SOP templates can be found below:
Toxic Gases (DOCX) <https://ehs.msu.edu/_assets/docs/chem/sop/sop-template-toxic-gas.docx>
Osmium Tetroxide (DOCX) <https://ehs.msu.edu/_assets/docs/chem/sop/sop-template-osmium-tetroxide.docx>
Blank SOP (DOCX) <https://ehs.msu.edu/_assets/docs/chem/sop/sop-template-blank.docx>
Guidelines for creating SOPs can be found here: Standard Operating Procedures <https://ehs.msu.edu/lab-clinic/chem/sop.html#SOP_Forms>
Develop and follow SOPs for work involving highly toxic compounds, potentially dangerous equipment, and highly reactive chemicals. Discuss with lab employees and students the SOPs for each task/experiment. Make paper or electronic copies readily available for consultation.
Templates are available through EHS: <https://ehs.msu.edu/lab-clinic/chem/sop.html#SOP_Forms>
8. Exposure incident response is posted
It is the responsibility of the PI prior to initiating any type of research to instruct and train lab staff in the procedures for dealing with accidents. Individual lab employees are responsible for their own safety and all individuals performing work with hazardous substances must accept a shared responsibility for operating in a safe manner once they have been informed about the extent of risk and safe procedures
ehs.msu.edu June 2021 Page 11
for their activities. They also have the responsibility to inform their supervisors of accidents and work practices or working conditions they believe hazardous to their health or to the health of others.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Section IV-B-7-d-(1), (2) and Appendix G.
BMBL 5th ed. HHS Publication No. (CDC) 21-1112, 5th Edition.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan
OSHA standard number 29 CFR 1910.1450
Corrective actions:
Print posters below and affix them in a visible area in the lab. PI must discuss the procedures to be taken in case of a biological exposure, chemical splash or physical injury and make forms below available in the lab.
Posters: Infectious Materials and Toxins <https://ehs.msu.edu/_assets/docs/bio/exposure-response-procedure-potentially-infectious.pdf>
Chemical and physical injury <https://ehs.msu.edu/_assets/docs/bio/incident-or-accident-response-procedure-poster.pdf>
Form for medical assistance <https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSU.pdf>
If employee is OUTSIDE Lansing area <https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSUnonLansing.pdf>
HR additional information <https://hr.msu.edu/benefits/workers-comp/accident-report.html>
Post-accident report <https://hr.msu.edu/ua/forms/documents/AccidentReport.pdf>
Procedures in case of injury and illness
Biological exposure
Employees who suffer a work-related illness/injury should immediately report the injury to the PI/supervisor.
1. Immediately call an ambulance (9-1-1) if the illness/injury is a critical emergency. The ambulance driver will transport the individual to the nearest medical facility available for treatment.
2. When the illness/injury is not critical, the supervisor is to complete the Authorization to Invoice MSU and direct the employee to the medical facility indicated on the Authorization.
ehs.msu.edu June 2021 Page 12
3. If an employee is involved in an incident where exposure to bloodborne pathogens may have occurred, the employee should seek medical consultation and treatment expeditiously. In these instances, actions should include the following:
a. If contact with blood or other potentially infectious material occurs on non-intact skin (i.e. cuts, rashes, acne, dermatitis), wash the area for 15 minutes with soap and water.
b. If blood or other potentially infectious material splashes in the eyes or on mucus membranes, flush the area for 15 minutes with water or normal saline.
4. Print and take an “Authorization to Invoice MSU” form with you. <https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSU.pdf>
5. Report to any LANSING URGENT CARE location (Frandor location is open 24 hrs). 6. Follow‐up by completing the "Report of Claimed Occupational Injury or Illness" form with your
supervisor < https://hr.msu.edu/ua/forms/documents/AccidentReport.pdf>.
Note: In the case of contact of blood or OPIM with intact skin, the employee should clean the skin immediately with soap and water. If there is any doubt regarding the condition of the contaminated skin, the employee must be medically evaluated as described in this section.
Chemical splash
Chemicals COMPATIBLE WITH WATER 1. Immediately call an ambulance (9-1-1) if the illness/injury is a critical emergency. The ambulance
driver will transport the individual to the nearest medical facility available for treatment. 2. Flush the exposed area with water: flush eyes, nose, or mouth for 15 minutes. Bandage area if
needed to control bleeding. 3. Notify your supervisor if he or she is available. If you can let someone responsible know what
has occurred and where you will be. 4. Print and take an “Authorization to Invoice MSU” form with you:
<https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSU.pdf> 5. Report to any Lansing Urgent Care location (Frandor location is open 24 hrs). 6. Follow‐up by completing the “Report of Claimed Occupational Injury or Illness” form with your
supervisor <https://hr.msu.edu/ua/forms/documents/AccidentReport.pdf>. Available at www.hr.msu.edu.
Chemicals NOT COMPATIBLE WITH WATER:
1. Immediately call an ambulance (9-1-1) if the illness/injury is a critical emergency. The ambulance driver will transport the individual to the nearest medical facility available for treatment.
2. DO NOT RINSE WITH WATER. Refer to your SOP or call EHS at 517‐355‐0153 for instructions on how to proceed.
3. Notify your supervisor if he or she is available. If you can let someone responsible know what has occurred and where you will be.
4. Print and take an “Authorization to Invoice MSU” form with you: <https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSU.pdf>
5. Report to any Lansing Urgent Care location (Frandor location is open 24 hrs). 6. Follow‐up by completing the “Report of Claimed Occupational Injury or Illness” form with your
supervisor <https://hr.msu.edu/ua/forms/documents/AccidentReport.pdf>.
Physical injury (slip and fall, cut, burn, etc)
1. Immediately call an ambulance (9-1-1) if the illness/injury is a critical emergency. The ambulance driver will transport the individual to the nearest medical facility available for treatment.
2. Notify your supervisor if he or she is available. If you can let someone responsible know what has occurred and where you will be.
3. Print and take an “Authorization to Invoice MSU” form (link above) with you <https://hr.msu.edu/benefits/workers-comp/documents/InvoiceMSU.pdf>
ehs.msu.edu June 2021 Page 13
4. Report to any Lansing Urgent Care location (Frandor location is open 24 hrs). 5. Follow‐up by completing the “Report of Claimed Occupational Injury or Illness” form with your
supervisor.
The primary medical provider designated by MSU Human Resources Workers' Compensation is LANSING URGENT CARE.
Locations include: Frandor 505 North Clippert St Lansing, MI 48912 (open 24 hours)
Dewitt 12970 US Hwy 27 DeWitt, MI 48820
Okemos 2289 Grand River Okemos, MI 48864
Southside 320 E. Jolly Road Lansing, MI 48910
Westside 4440 West Saginaw Lansing, MI 48917
Bath 16945 Marsh Rd Haslett, MI 48840
Mason 132 S Cedar St Mason, MI 48854
For an on-campus work-related injury cases when the illness/injury is not critical and the employee cannot drive him/herself to Lansing Urgent Care, Capitol Transport Cab Service may be called anytime at 517-485-4400.
Each incident should receive prompt reconsideration of the initial risk assessment and reevaluation of current strategies to reduce the possibility of future exposures.
Facility
9. Benchtops and furniture are impervious
Furniture in the lab must be appropriate for the anticipated use. Bench tops must be impervious to water and resistant to heat, organic solvents, acids, alkalis and other chemicals. Chairs and other furniture must be covered with a non-porous material that can be easily cleaned and disinfected.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-A-4-b, c and d., L-II-C-2-b-(6) and L-II-D-2-a-(7).
BMBL 5th ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Chemical Hygiene Plan
Corrective actions:
Evaluate benchtops and chairs used in the lab. If fabric chairs are present replace them with non-porous chairs. If replacement is not possible cover chairs with impervious material such as a plastic barrier, check integrity frequently and replace when necessary.
ehs.msu.edu June 2021 Page 14
10. Disinfection of benchtops and equipment done daily or after equipment is used
Work surfaces must be decontaminated after work is finished and after a spill of potentially hazardous materials. Appropriate disinfectant with demonstrated efficacy against the target or indicator microorganisms should be used.
For BSL-2 microorganisms the chemical disinfectant must be EPA-registered for the destruction of Hepatitis B or be tuberculocidal.
The disinfectant must be applied to the contaminated surfaces in the concentration and for the time prescribed by the manufacturer to assure effective decontamination.
If bench paper or plastic backed absorbents are used, they should be discarded and the space beneath decontaminated.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
BMBL 5th ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
In the event of a spill or at the end of each workday apply (spray, squirt or pour) disinfectant at the correct concentration or use germicidal wipes so surface is visibly wet. Allow the appropriate contact time as recommended by the disinfectant manufacturer’s instructions. Remove excess residual disinfectant with paper towels after contact time is reached (if using disinfectant wipes, allow to air dry).
Examples of approved disinfectants 70% Ethanol, apply and maintain wet for 10 minutes. Ensure wet contact time is accomplished as ethanol evaporates.
10% Bleach, make fresh daily, apply and maintain wet for 10 minutes. Ensure use is within 24 hours after making solution.
Virkon™ S tablets, <http://virkon.com/products-applications/disinfectants/virkon-s-tablets/> make fresh every week, apply and maintain wet for 5 minutes. Do not soak metal objects for longer than 10 minutes as it is corrosive. The solution leaves residue that must be wiped afterward.
Sani-Cloth® Plus Germicidal Disposable Cloth, <https://pdihc.com/products/environment-of-care/sani-cloth-plus-germicidal-disposable-cloth/> apply and maintain wet for 3 minutes, dispose of wipe appropriately.
Envirocide ™, <https://www.metrex.com/en-us/products/surface-disinfectants/envirocide> ready to use within expiration date, apply and maintain wet for 3 minutes.
Cavicide™, ready to use within expiration date, apply and maintain wet for 3 minutes.
TB-Cide® Quat, <https://www.spartanchemical.com/products/product/102103#product-safety> ready to use within expiration date, apply and maintain wet for 3 minutes.
ehs.msu.edu June 2021 Page 15
PeridoxRTU®, <https://www.contechealthcare.com/products/peridoxrtu-sporicidal-disinfectant-and-cleaner/> ready to use within expiration date, apply and maintain wet for 3 minutes.
11. Inventory logs are used (biological and chemical)
An up-to-date, accurate inventory listing all chemicals stored in the lab must be available. Chemical inventories are necessary to ensure employees are aware of the hazards present in their work area, encourage management of purchased reagents and materials and provide helpful information to Emergency Responders during emergencies.
An up-to-date, accurate inventory or material management process for control and tracking of biological stocks or other sensitive materials must be present.
Material accountability procedures should be established to track the inventory, storage, use, transfer and destruction of dangerous biological materials and assets when no longer needed. The objective is to know what agents exist at a facility, where they are located, and who is responsible for them.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
OSHA Standard 1910.1450 App A.
OSHA 3111- Hazard Communication Guidelines for Compliance.
MIOSHA R 325.70101- R 325.70114, Appendix A: E.3.
Corrective actions:
Labs must maintain an up-to-date list of each purchased chemical by using paper log, an excel file, or a chemical tracking software. Update the chemical inventory upon purchase of chemicals and discarding chemical stock as waste. Be sure to include chemical name and location within the lab.
Similarly, labs must keep an inventory containing information on storage, use, transfer and destruction of biological materials. Appendix H of the MSU Biosafety Manual <https://ehs.msu.edu/_assets/docs/bio/msu-biosafety-manual.pdf> has an example of a log file outlining information regarding organism’s name, characteristics, and source.
12. Eyewash is present, flushed weekly (documented), unobstructed, operational
An eyewash station must be readily available in close proximity to workstations where employees perform tasks that produce splashes of potentially infectious materials and hazardous chemicals. Eyewash stations should meet the ANSI requirements as per the MSU Chemical Hygiene Plan. The eye wash must be flushed on a weekly and documented on a log to ensure the water quality, pressure, and temperature is adequate for decontamination. A link to an eyewash log template can be found here: Eyewash test log template (PDF) <https://ehs.msu.edu/_assets/docs/chem/eyewash-test-log.pdf>.
The intent of the weekly activation to be conducted on plumbed emergency eyewash and shower equipment is to ensure that there is a flushing fluid supply at the head of the device and to clear the supply line of any sediment build-up that could prevent fluid from being delivered to the head of the device and minimize microbial contamination due to stagnant water. The duration of this test is dependent on the volume of water contained in the unit itself and all sections of pipework that do not form part of a constant circulation system (also known as "dead leg" portions). Water in these sections is stagnant until
ehs.msu.edu June 2021 Page 16
a flow is activated by opening a valve. The goal is to flush out stagnant water in the dead leg completely. Where mixing valves are used, both the hot water and cold water supplies to the valve must be considered.
MIOSHA has adopted the American National Standards Institute (ANSI) consensus standards for eye protection and emergency shower and eyewash facilities.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan 5.3.3
ANSI Z358.1-2014. Sections 5.5.2, 6.5.2, 8.2.4.2, Appendix B(B7), sections 5.1.3, 6.1.3. and sections 4.5.2, 5.4.2, 6.4.2, Appendix B (B5).
Corrective actions:
Assure that there is an eyewash station present in your lab.
Be familiar with the location of this emergency equipment and instruct lab personnel on how to use them. These devices are used for emergency flushing in the event of an exposure so they must be clean and unobstructed at all times. Assure that access to eyewash stations is not blocked and there is at least 6 inches clearance around it (use tape to mark the area-see picture). Document maintenance by flushing eyewash weekly and logging the date on a paper file or computer file.
The eyewash must supply a sufficient quantity of water to completely flush the eyes. A 15-minute supply of continuous free-flowing water is acceptable. The hands must be free to hold the eyelids open to aid in the complete flushing of the eyes. Therefore, if you detect any type of malfunctioning of the eyewash promptly request a repair with MSU Infrastructure Planning and Facilities <https://ipf.msu.edu/service-billing/service-catalog/building-maintenance>.
Assure that there is a clean, unobstructed eyewash station present in your lab. Instruct lab personnel on how to use the eyewash. Assure there is at least 6 inches clearance around eyewash (use tape to mark the area). Document maintenance by flushing eyewash weekly and logging the date on a paper file or computer file. Promptly request repair through MSU IPF if you detect any type of malfunctioning of the eyewash.
Be familiar with the location of this emergency equipment and instruct lab personnel on how to use them.
These devices are used for emergency flushing in the event of an exposure so they must be clean and unobstructed at all times. Assure that access to eyewash stations is not blocked and there is at least 6 inches clearance around it (use tape to mark the area-see picture). Document maintenance by flushing eyewash weekly and logging the date on a paper file or computer file.
The eyewash must supply a sufficient quantity of water to completely flush the eyes. A 15-minute supply of continuous free-flowing water is acceptable. The hands must be free to hold the eyelids open to aid in the complete flushing of the eyes. Therefore, if you detect any type of malfunctioning of the eyewash promptly request a repair with MSU Infrastructure Planning and Facilities <https://ipf.msu.edu/service-billing/service-catalog/building-maintenance>.
ehs.msu.edu June 2021 Page 17
PROCEDURES IN CASE OF an eye splash: 1. Call 911 2. Remove victim(s) from spill area to fresh air only if attempts to rescue victim(s) do not present a
danger to the rescuers. 3. Lead the victim(s) immediately to an emergency eyewash facility. 4. Hold the victim’s eye lids open. 5. Flush eyes for at least 15 minutes or longer if pain persists. 6. Inform emergency response personnel of the chemical(s) involved.
13. Emergency shower is present
Safety showers must be readily available in close proximity to workstations where employees perform tasks with hazardous chemicals or biological samples and where there is the risk of fire. Safety showers provide an immediate water drench of an affected person. MIOSHA has adopted the following ANSI standards for location, design and maintenance of safety showers: 1. Showers shall be located within 25 feet of areas where chemicals with a pH of ≤ 2.0 or ≥ 12.5 are
used. 2. Showers shall be located within 100 feet of areas where chemicals with a pH of > 2 and < 4 or ≥ 9
and < 12.5 are used. 3. The location of the shower should be clearly marked, well lighted and free from obstacles, closed
doorways or turns. 4. Safety showers should be checked and flushed periodically.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Chemical Hygiene Plan
ANSI Z358.1-2014 sections 5.5.2, 6.5.2, 8.2.4.2, Appendix B(B7), sections 5.1.3, 6.1.3. and sections 4.5.2, 5.4.2, 6.4.2, Appendix B (B5).
Corrective actions:
Be familiar with the location of this emergency equipment and instruct lab personnel on how to use them. These devices are used for emergency flushing in the event of an exposure; therefore they must be clean and unobstructed at all times.
MSU Infrastructure Planning and Facilities is responsible for testing and maintenance of safety showers.
PROCEDURES IN CASE OF a body splash: 1. Call 911 2. Remove person(s) from spill area to fresh air only if attempts to rescue victim(s) do not present a
danger to the rescuers. 3. Remove contaminated clothing while under an emergency shower. 4. Flood affected area with tepid water for at least 15 minutes or until medical assistance arrives. 5. Inform emergency response personnel of the chemical(s) involved.
ehs.msu.edu June 2021 Page 18
Personal Protective Equipment
14. Disposable gloves available, used, disposed of properly
The basic and most effective forms of Personal Protective Equipment (PPE) from chemical and biological exposure are gloves and lab coats.
Gloves must be selected based on the hazards involved and the activity to be conducted. Gloves must be worn when working with biohazards, toxic substances, hazardous chemicals and other physically hazardous agents. Temperature resistant gloves must be worn when handling hot material or dry ice. Delicate work requiring a high degree of precision dictates the use of thin walled gloves.
When latex gloves have been chosen, alternatives should be made available. Gloves should be changed as soon as possible after they have become contaminated, when their integrity has been compromised or when necessary. Hands should be properly washed with soap and water after removing gloves. Disposable gloves must not be washed or reused and should be disposed of as soon as removed.
Gloves should be removed, and hands washed when work with potentially infectious materials is complete or when leaving the lab. If you are transporting potentially infectious materials (i.e., cultures, waste, etc.) to another part of the building use the one glove rule: use one gloved hand for handling the materials and use the other ungloved hand for touching common surfaces such as door knobs and elevator buttons.
The US Food and Drug Administration has issued a ban on all powdered gloves. Exposure to starch powder from gloves can cause undesirable reactions, which vary from well-known allergy symptoms and upper respiratory-tract disorders to surgical adhesions and infections. The presence of glove powder can also result in many other undesirable effects, such as interference in lab testing causing false results (i.e. PCR – Polymerase Chain Reaction, enzyme immunoassay or some HIV tests).
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan
OSHA Standard 1910.1450 App A
FDA document 21 CFR Parts 878, 880, and 895
Corrective actions:
Gloves are designed to protect hands from a particular set of hazards and reduce the chance of skin contamination but do not provide absolute protection. As many chemicals can pass through or damage disposable gloves it is imperative to select the appropriate type of gloves to be used for your lab activities. If you have questions about glove selection contact EHS at 517-355-0153.
Gloves must be worn when employees anticipate hand contact with potentially infectious materials and when handling or touching contaminated items or surfaces.
ehs.msu.edu June 2021 Page 19
Disposable gloves must be replaced when their ability to function as a barrier is compromised, for example after contamination or immediately when torn, punctured, or are otherwise rendered unable to function as an exposure barrier.
Non-latex gloves must be provided to employees who are allergic to latex.
Never reuse disposable gloves. After removal, dispose of them in appropriate waste container. Do not leave used gloves on benchtops.
Gloves must be removed before leaving the lab and hands must be washed.
When transporting samples to another part of the building, use a secondary container. If gloves must be worn, use the one glove method to avoid touching common use areas/surfaces with your gloves, such as doorknobs, elevator buttons, etc. See Gloves in Common Areas flyer <https://ehs.msu.edu/_assets/docs/bio/gloves-posting.pdf>.
15. Specialized protective gloves are available and in good condition
Gloves must be worn to protect hands from exposure to hazardous materials, heat and cold substances. Glove selection should be based on an appropriate risk assessment.
As mentioned above many chemicals can pass through or damage disposable gloves and they are not designed to protect hands from heat and cold so it is imperative to select the appropriate type of gloves to be used for your lab activities.
For example, gloves used to manipulate cryogens should be impervious, offer thermal protection and sufficiently large to be readily thrown off should a cryogen spill; rubber gloves should always be used when handling corrosive materials and heat resistance gloves should be used when removing items from an autoclave.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Chemical Hygiene Plan 2.1 (G), 5.3.1 and 5.3.2.
OSHA Standard 1910.1450 App A
Corrective actions:
Take the time to do a risk assessment and select the appropriate glove for use in the lab. Instruct lab personnel on the different types of gloves and when to use a particular type. Replace reusable gloves at first sign of cracks, tears or wholes as they don’t offer protection any longer.
More information on PPE can be found in the MSU manual <https://ehs.msu.edu/_assets/docs/ppe/msu-ppe-manual.pdf>.
For assistance on glove selection go to EHS Chemical Hygiene webpage <https://ehs.msu.edu/lab-clinic/chem/index.html> and see the “Chemical Resistance Guides” accordion, or contact EHS at 517-355-0153 to set up a consultation.
16. Lab coats are available and worn
Protective lab coats, gowns, or uniforms are recommended to prevent contamination of skin and personal clothing with chemical and biological splatter and spills. A lab coat is recommended for all work at BSL-1
ehs.msu.edu June 2021 Page 20
and it or other suitable protective clothing is required when handling potentially infectious materials at BSL-2 or higher. Additional criteria for selecting clothing include: comfort, appearance, closure types and location, antistatic properties and durability.
Although, most lab coats are not designed to be fireproof or impermeable they represent a barrier to chemical and biological substances and retard exposure of skin and clothing to hazards.
Disposables should be available for visitors, maintenance and service workers in the event it is required or when risk assessment determines it is the best option. In circumstances where it is anticipated that splashes may occur, the garment must be resistant to liquid penetration. If the garment is not disposable, it must be capable of withstanding sterilization, in the event it becomes contaminated. The garment should be flame resistant when working with or around open flames or high temperature heat sources.
Lab coats must be removed before exiting the lab for non-lab areas (e.g., cafeteria, library, administrative offices).
Protective clothing must be removed and left in the lab before leaving for non-lab areas.
Dispose of protective clothing appropriately, or deposit it for laundering by the institution. Lab clothing must not be taken home as it could result in the contamination of your family’s clothing.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-B-2-f.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan 5.3.2.
OSHA Standard 1910.1450 App A
Corrective actions:
Make sure appropriate lab coats are available and are worn by all personnel working in the lab. If working with open flames or near high heat sources, purchase flame-resistant lab coats.
More information on PPE can be found in the MSU manual <https://ehs.msu.edu/_assets/docs/ppe/msu-ppe-manual.pdf>.
Remove lab coats when leaving the lab. These garments should not leave the work site.
Launder reusable lab coats when visibly soiled or when a splash occurs. Laundry will be done by MSU’s laundry facility – Spartan Linen Services <https://spartanlinen.rhs.msu.edu/>.
IN CASE OF A SPILL OR SPLASH Unless a lab coat is made of fluid-resistant material (i.e. Tyvek), it should not be assumed to be an effective fluid barrier. If a lab coat becomes contaminated with blood or other potentially infectious materials, it should be removed as soon as possible. Clothing and skin should be examined for possible contamination. If contamination has reached the skin, the affected area should be immediately washed and assessed for potential of bloodborne pathogens exposure. Contaminated lab coats should be placed in a biohazard bag and sent to the MSU designated laundry service.
ehs.msu.edu June 2021 Page 21
17. Safety glasses/goggles and face protection available and worn as appropriate
There are several types of eye and face protection (goggles, mask, face shield or other splatter guard) that should be used for anticipated splashes or sprays of infectious or other hazardous materials. Appropriate selection must be made based on risk assessment.
Eye and face protection must be decontaminated before reuse. Persons who wear contact lenses in laboratories should also wear eye protection.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan 5.3.1
OSHA Standard 1910.1450 App A
Corrective actions:
Select appropriate eye and face protection and educate lab personnel about their use. More information can be found at EHS Eye and Face Protection webpage <https://ehs.msu.edu/occ/ppe/eye-face-protection-chem.html>.
Always wear safety glasses with side shields or goggles when handling hazardous chemicals or infectious agents. If there is a chance of a splash or spray, including when manipulating cryogens, a full-face protection shield is recommended.
Check the integrity of lenses and plastic straps periodically and replace them when necessary. For decontamination wash eye protection with soap and water and disinfect with 70% ethanol. Alternatively use EPA registered (list N) disinfection wipes for decontaminating eye protection.
18. Dress code for working in laboratories is followed
Employees working with hazardous chemicals in laboratories must wear closed-toe shoes, long pants or skirts which fully cover the legs, and a lab coat. The same way dangling jewelry or scarves should be removed, and long hair contained.
References:
MSU Chemical Hygiene Plan 5.3.2
Corrective actions:
Make sure personnel working in the lab are dressed appropriately for protection and deny entry if attire is not suitable for work. Share the figures below with employees and discuss the importance of being dressed properly for their safety.
ehs.msu.edu June 2021 Page 24
19. No food, drink, cosmetics, lotions, non-work-related plants or animals
The following statement is the accepted practice for food and drink items in campus labs and should be abided by at all times:
“There shall be no food, drink, smoking or applying cosmetics in laboratories which have radioactive materials, biohazardous materials or hazardous chemicals present. There shall be no storage, use or disposal of these ‘consumable’ items in laboratories (including refrigerators within laboratories). Rooms which are adjacent, but separated by floor to ceiling walls, and do not have any chemical, radioactive or biological agents present, may be used for food consumption, preparation, or applying cosmetics at the discretion of the principal investigator responsible for the areas.”
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-A-1-e. and C-1-d.
MSU Biosafety Manual.
MSU Bloodborne Exposure Control Plan. Appendix C.
MSU Chemical Hygiene Plan 2.3
OSHA Standard 1910.1450 App A.
Corrective actions:
Eating, drinking, smoking, applying cosmetics or manipulating contact lenses is not permitted in laboratories.
Remove even empty containers as they could be interpreted as food or drink items. Food may be stored in cabinets or refrigerators outside the lab space designated and used for this purpose only.
20. Broken glass procedures in place (including blood tubes)
Broken glassware must not be handled directly by hand but must be removed by gloved hands and mechanical means such as a brush and dustpan, tongs, or forceps.
Separate containers must be used if broken glass is non-hazardous or contains biological hazards, for example contaminated blood.
Plastic ware should be substituted for glassware whenever possible.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Biosafety Manual.
MSU Bloodborne Exposure Control Plan.
MSU Chemical Hygiene Plan 2.4 (c)
ehs.msu.edu June 2021 Page 25
MSU Waste Disposal Guide
Corrective actions:
Broken Glass Containers • Non-hazardous non-contaminated broken glass: Container should be labeled “Broken Glass Only’
and will be picked up by MSU custodial services during their routine trash disposal. • Hazardous broken glass should be placed in sharps containers and must be disposed of via the MSU
EHS as hazardous waste. To request pickup go to the EHS Safety Portal < https://ehs.msu.edu/safety-portal.html> and submit a Hazardous waste pickup form.
21. Soap and paper towel readily available and used for handwashing
Hand washing protocols must be rigorously followed by lab personnel. Persons must wash their hands after handling animals and before leaving the areas where infectious materials and/or animals are housed or are manipulated, and chemicals are used. Hand washing should occur after the removal of gloves.
Hands must be washed after handling biohazardous materials and animals, and before leaving the laboratory.
In most situations, thorough washing of hands with ordinary soap and water is sufficient to decontaminate them, but the use of germicidal soaps is recommended in high-risk situations. Hands should be thoroughly lathered with soap, using friction, for at least 20 seconds, rinsed in clean water and dried.
Foot- or elbow-operated faucets are recommended. Where not available, a paper towel should be used to turn off the faucet handles to avoid re-contaminating washed hands.
Waterless antiseptic hand cleansers such as alcohol-based hand-rubs or antiseptic towelettes must be available to employees at risk of exposure if running water is not readily available. If waterless cleansers or towelettes must be used, the employee must follow-up with a soap and water wash as soon as feasible.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-A-1-h. and Appendix K-II-C.
MSU Biosafety Manual.
MSU Bloodborne Exposure Control Plan.
MSU Chemical Hygiene Plan
MSU Waste Disposal Guide
Corrective actions:
All labs must have soap and paper towels adjacent to sinks for handwashing. Wash hands thoroughly with soap and water after removing gloves used for handling animals, biohazards and chemicals, before leaving the lab and before eating or drinking and touching common use surfaces (i.e., computers, telephones, etc.).
If no running water/soap is available use antiseptic hand cleanser but follow-up with a wash with soap and water wash as soon as possible.
ehs.msu.edu June 2021 Page 26
22. Good housekeeping practices are being conducted
Regular housekeeping reduces injuries and accidents in the workplace. Good housekeeping includes appropriate storage of chemicals, safe and regular cleaning of the facility, disinfection of benches, sterilization of biohazardous waste and proper arrangement of lab equipment.
Access to fire exits, emergency equipment and hallways must be maintained at all times.
Benchtops or fume hoods with multiple containers of open, unneeded or unused chemicals can create dangerous conditions if a fire occurs in the laboratory. Spills and accidents are more likely when a benchtop is overloaded with equipment and chemicals.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-A-1-h. and Appendix K-II-C.
MSU Biosafety Manual.
MSU Bloodborne Exposure Control Plan.
MSU Chemical Hygiene Plan 2.4 (E) and 2.5 (H)
MSU Waste Disposal Guide
International Fire Code 2015, Part II, Section 304.1
Corrective actions:
Remove all unnecessary items from biosafety cabinets, chemical fume hoods and benches. Organize and disinfect your working area and coordinate sterilization of accumulated biohazardous waste before leaving the laboratory for the day. Also limit the amount of paper, boxes, fabrics or unnecessary materials in the lab to facilitate cleaning and avoid blockage of exits and hallways and to prevent spread of fire.
MSU EHS can assist you in removing and disposing of old, unneeded or outdated chemicals in your lab. Contact MSU EHS Hazardous Waste Coordinator at 517-432-4454 for more information.
Chemical Storage and Handling
23. All chemicals are labeled properly
PIs/supervisors must ensure that labels on incoming containers of hazardous chemicals for lab use are not removed or defaced. These original labels contain information on the identity of the chemical(s) in the container and the hazard identification of the chemical(s). It is recommended that incoming containers be labeled with the PIs name and date of receipt.
Labels on containers used for storing hazardous chemicals must include the chemical identification and appropriate hazard warnings.
If chemicals from commercial sources are repackaged into transfer vessels, the new containers must be labeled with all essential information on the original container.
Identifying the specific hazard associated with a chemical greatly reduces chances of misuse by regular lab employees, new users, or visitors to the lab. The label and SDS will indicate, for example, if a chemical is shock sensitive or explosive.
ehs.msu.edu June 2021 Page 27
Groups of vials, small bottles or samples can be labeled as a group with a common ticket for all items. If the lab members wish to use abbreviations instead of full chemical name, provide an abbreviation chart in plain view in the lab.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Chemical Hygiene Plan 3.4.1.1 (B) and 3.4.1.2 (A)
OSHA Standard 1910.1450 App A.
Corrective actions:
Label all reagents, solutions, stocks, etc. with the appropriate name of the contents and hazard. If abbreviations are used instead of full chemical names, make sure to provide an abbreviation chart in plain view in the lab.
MSU has developed a comprehensive guide for labeling of chemicals in the laboratory that can be found in the link below.
Proper Labeling of Hazardous Chemicals (PDF) In addition labels can be requested from EHS by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting a Lab Label request. Familiarize yourself with these recommendations and make sure they are followed in the laboratory.
Container Labels All containers of hazardous chemicals must be labeled with the name of the chemical and the hazard(s), if not provided by the manufacturer. If a chemical has more than one hazard, it must be labeled with both hazards. For example, acetaldehyde is both a flammable and a carcinogen, and must be labeled appropriately. Additionally, the subsequent guidelines shall be followed:
Labeling Basics For containers labeled by the manufacturer
• Inspect the labeling on incoming containers. • Replace damaged or semi-attached labels.
For transferred products or prepared solutions labeled by the user • Label each chemical container with the chemical name and hazard warning. • Refer to the Safety Data Sheet (SDS) for hazard warning
Alternate Method for Labeling Multiple Small Containers • Legend Method
• Label containers with abbreviated chemical name and a hazard warning. • Provide a key in a visible location in the lab with complete chemical name. • Document that employees are trained on the labeling system.
• Box or Tray Method: • Put containers in box or tray. • Label tray with chemical name and hazard warning • If containers are removed from the box/tray they must be properly labeled or returned to
the box or tray within the work-shift. • Document that employees are trained on the labeling system
Labeling Peroxide Forming Chemicals • Peroxidizable chemicals are listed in APPENDIX G of the MSU Chemical Hygiene Plan and must be
labeled with:
ehs.msu.edu June 2021 Page 28
• Date Received • Date Opened • Date Tested • Test Results
• Consumer Products • Anything available over the counter to the general public is exempt from labeling
requirements if it has already been labeled by the manufacturer. • This includes consumer products such as cans of spray paint or turpentine.
• Stationary Containers • Stationary process containers such as tanks may be identified with signs, placards,
process sheets, batch tickets or other written materials instead of actually affixing labels to process containers.
• The sign or placard must convey the same information that a label would and be visible to employees throughout the work shift.
• Portable Containers • Portable containers into which hazardous chemicals are transferred from labeled
containers and which are intended to be under the use and control of the person who transferred it, within the work shift in which it was transferred, are exempt from labeling.
• However, it is recommended that a temporary label identifying the chemical and its primary hazard be affixed to the container.
• Refrigerators and Freezers • All refrigerator and freezer units used in labs must be marked as “SAFE FOR
FLAMMABLE STORAGE” or “UNSAFE FOR FLAMMABLE STORAGE” on the exterior surface of the unit as appropriate.
• All cold rooms must be marked “UNSAFE FOR FLAMMABLE STORAGE”.
24. Chemicals are stored according to compatibility
Storage of chemicals in the lab must be done according to compatibility to assure safety of lab personnel and prevent accidents. To prevent unintended reactions between incompatible compounds, chemical containers need to be segregated into compatible groups when in storage. The use of secondary containment (such as bus tubs, buckets, etc.) under containers is encouraged.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Chemical Hygiene Plan, Appendix B
OSHA Standard 1910.1450 App A.
Corrective actions:
MSU and NIH have extensive guidelines about storing chemicals that should be followed by laboratories. If you have questions, contact MSU EHS at 517-355-0153.
General guidelines 1. Chemicals should be separated and stored according to hazard category and compatibility. 2. SDS and label information should be followed for storage requirements. 3. Toxic or corrosive chemicals that require vented storage should be stored in vented cabinets instead
of in a chemical hood. 4. Peroxide formers should be dated upon receipt, again dated upon opening, and stored away from
heat and light with tightfitting, nonmetal lids.
ehs.msu.edu June 2021 Page 29
5. Open shelves used for chemical storage should be secured to the wall and contain 3/4-inch lips. Secondary containment devices should be used as necessary. Storage of chemicals at the lab bench or other work areas shall be kept to a minimum. Minimize storage of chemicals or apparatus in the hood.
6. Oxidizers, reducing agents, and fuels should be stored separately to prevent contact in the event of an accident.
7. Chemicals should not be stored in the chemical hood, on the floor, in areas of egress, on the benchtop, or in areas near heat or in direct sunlight.
8. Laboratory-grade, flammable-rated refrigerators and freezers should be used to store sealed chemical containers of flammable liquids that require cool storage. Do not store food or beverages in the laboratory refrigerator.
9. Highly hazardous chemicals should be stored in a well-ventilated and secure area designated for that purpose.
10. Flammable chemicals should be stored in a spark-free environment and in approved flammable-liquid containers and storage cabinets. Grounding and bonding should be used to prevent static charge buildups when dispensing solvents.
11. Chemical storage and handling rooms should be controlled-access areas. They should have proper ventilation, appropriate signage, diked floors, and fire suppression systems.
12. Chemicals should not be stored on high shelves, and large bottles should be stored no more than two feet from floor level.
When certain hazardous chemicals are stored or mixed together, violent reactions may occur because the chemicals are unsuitable for mixing or are incompatible. Classes of incompatible chemicals should be segregated from each other during storage, according to hazard class. Use the following general guidelines for hazard class storage:
• Flammable/Combustible Liquids and Organic Acids
• Flammable Solids
• Mineral Acids
• Caustics
• Oxidizers
• Perchloric Acid
• Compressed Gases
For chemical compatibility see EHS Chemical Compatibility Table <https://ehs.msu.edu/_assets/docs/chem/chem-compatibility-table.pdf>. Or contact EHS for a consultation.
25. Containers show integrity
When receiving chemicals inspect package for any breakage or leakage.
Containers and bottles used to store chemicals in the laboratory should show no signs of damage or leakage.
Biohazard waste containers as well as chemical hazard waste containers must also prevent leakage or release of the contents during storage, handling, and transport.
References:
MSU Biosafety Manual.
ehs.msu.edu June 2021 Page 30
MSU Chemical Hygiene Plan 3.4.1.1 (A)
MSU Waste Disposal Guide.
OSHA Standard 1910.1450 App A.
Corrective actions:
Chemical shipments should be inspected upon receiving and if any breakage or leakage is detected it should be refused or opened in a chemical hood.
Inspect chemicals stored in the lab for integrity of the container as well as labels periodically.
Store biohazards and chemical hazards in MSU approved containers, follow guidelines for volume stored and check for leakage. If labels are damaged or semi-attached, replace them
26. Storage areas are labeled
Storage areas must be appropriately labeled as determined by the hazards present.
References:
MSU Chemical Hygiene Plan 5.1.4
OSHA Standard 1910.1450 App A.
Corrective actions:
Chemical storage areas within the lab must be clearly marked. This includes cupboards, cabinets, drawers and other closed storage areas.
Assure that the following areas are labeled, and chemicals are stored properly:
1. Carcinogens
2. Corrosives
3. Flammable Liquids
4. Flammable Solids
5. Oxidizers
6. Perchloric Acid
7. Biosafety Level 2 or higher
8. Compressed Gas Storage
Large stickers can be requested from EHS by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting a Lab Label request.
Additionally, storage areas for biohazardous agents and radioisotopes should be appropriately labeled. Please contact the Biological Safety Officer or the Radiation Safety Officer at 517-355-0153 for more information.
ehs.msu.edu June 2021 Page 31
Compressed Gases
27. Cylinders are secured properly
Compressed gas cylinders must be stored upright and secured to an unmovable surface to prevent them from tipping by means of by a chain link or strap that is approximately two thirds up the cylinder.
References:
MSU Chemical Hygiene Plan 2.7 (A), (C) and (I)
OSHA Standard 1910.1450 App A.
NFPA 55 - Compressed Gases. Chapter 7 - 7.1.10.2
Corrective actions:
Special systems are needed for handling materials under pressure. Cylinders pose mechanical, physical and/or health hazards, depending on the compressed gas in the cylinder. Cylinders with obvious corrosion and/or cylinders greater than 10 years old should be returned to the gas supplier immediately.
• Cylinders with regulators must be individually secured. Only cylinders with valve protection caps securely in place may be safely gang-chained (chained in groups).
• When storing or moving a cylinder, have the valve protection cap securely in place to protect the stem.
• Cylinders must be secured in an upright position at all times. Use suitable racks, straps, chains, or stands to support cylinders against an immovable object, such as a bench or a wall, during use and storage. Do not allow cylinders to fall or lean against one another.
28. Flammable and Oxidizing gases are separated
Flammable gases must be kept at least 20 feet from oxidizing gases or separated by a 2-hour fire rated wall.
References:
MSU Chemical Hygiene Plan 2.7 (A), (C) and (I)
OSHA Standard 1910.1450 App A.
NFPA 55 - Compressed Gases. Chapter 7 - 7.1.10.2
Corrective actions:
Familiarize yourself and lab personnel on the definitions of flammable and oxidizing gases.
Flammable gas means a gas having a flammable range with air at 20°1(a)C and a standard pressure of 101.3kPa:
Categories 1(a): are ignitable when in a mixture of 13% or less by volume in air.
1(b): Have a flammable range with air of at least 12 percentage points regardless of the lower flammable limit.
ehs.msu.edu June 2021 Page 32
Oxidizing gas means any gas which may, generally by providing oxygen, cause or contribute to the combustion of other material more than air does (pure gases or mixtures with an oxidizing power greater than 23.5%).
Follow NFPA 55 recommendation that states that oxidizing gases must be kept at least 20 feet away from flammable gases or separated by a 2-hour fire wall.
29. There are SOP’s for toxic, pyrophoric and corrosive gases
Toxic, pyrophoric or corrosive gases must be used and stored in a gas cabinet or a fume hood. An SOP is required for toxic, pyrophoric and corrosive gases.
References:
MSU Chemical Hygiene Plan 2.7 (A), (C) and (I)
OSHA Standard 1910.1450 App A.
NFPA 55 - Compressed Gases. Chapter 7 - 7.1.10.2
Corrective actions:
See a list of these gases here: Gases Requiring Approval (XLSX) <https://ehs.msu.edu/_assets/docs/chem/toxic-gas-preapproval.xlsx>
Contact Genevieve Cottrell at 517-432-8715 or [email protected] for gases requiring approval.
Elaborate a SOP for working with such gases and discuss with lab personnel all safety steps required for properly handling them.
Peroxide Forming Chemicals
30. Peroxide formers dated
Certain classes of compounds will form potentially explosive peroxide crystals upon extended storage. Common examples of peroxide-forming compounds include isopropyl ether, diethyl ether, tetrahydrofuran, dioxane, potassium metal.
These compounds must be used in a timely manner or tested on a regular basis to ensure peroxide formation is not occurring.
In addition, peroxide formers should be dated upon receipt, again dated upon opening, and stored away from heat and light with tight fitting, nonmetal lids. Expired containers of peroxide-forming chemicals must be immediately disposed of properly through EHS.
References:
MSU Chemical Hygiene Plan 3.6.6
OSHA Standard 1910.1450 App A.
NPFA 45 9.2.3.4
ehs.msu.edu June 2021 Page 33
Corrective actions:
Organic peroxide means a liquid or a solid organic chemical which contains the bivalent –O-O- structure and is such is considered a derivative of hydrogen peroxide, where one or both of the hydrogen atoms have been replaced by oxygen radicals. Organic peroxides are thermally unstable chemicals, which may undergo exothermic self-accelerating decomposition. In addition, they may have one or more of the following properties:
• Be liable to explosive decomposition.
• Burn rapidly.
• Be sensitive to impact or friction.
• React dangerously with other substances.
Some chemicals can form explosive peroxides when stored; exposure to light and heat increase the rate of peroxide formation. Other chemicals form peroxides that become hazardous when concentrated, such as by distillation.
A list of peroxide-forming compounds can be found here: Chemical Hygiene Plan, Appendix G (PDF) <https://ehs.msu.edu/_assets/docs/chem/msu-chem-hygiene-plan.pdf#page=48>
• Date all peroxidizables upon receipt and upon opening. Dispose of or check for peroxide formation after the recommended time; 3-months or one year depending on the chemical. See APPENDIX G.
• Do not open any container which has obvious solid formation around the lid. • Addition of an inhibitor to quench the formation of peroxides is recommended.
Peroxide forming compounds that are very old, have obvious container problems, or show visible crystallization inside the bottle or cap require immediate, specialized management. Call MSU EHS directly at 517-355-0153 for immediate assistance. Leave the container in place until MSU EHS arrives.
31. Peroxides are tested regularly and documented
It is recommended to chemically test for peroxides periodically.
A label affixed to the outside of the container should indicate date of last test, and test results.
References:
MSU Chemical Hygiene Plan 3.6.6
OSHA Standard 1910.1450 App A.
NPFA 45 9.2.3.4
Corrective actions:
Test peroxide formers periodically. Record testing dates and test results.
Peroxide-forming labels to record testing date and results are available from EHS by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting a Lab Label request.
ehs.msu.edu June 2021 Page 34
Detection and Inhibition of Peroxides: Basic Protocols Ferrous Thiocyanate Detection Method Ferrous thiocyanate will detect hydroperoxides with the following test:
1. Mix a solution of 5 ml of 1% ferrous ammonium sulfate, 0.5 ml of 1N sulfuric acid and 0.5 ml of 0.1N ammonium thiocyanate (if necessary, decolorize with a trace of zinc dust)
2. Shake with an equal quantity of the solvent to be tested
3. If peroxides are present, a red color will develop
Potassium Iodide Detection Method 1. Add 1 ml of a freshly prepared 10% solution of potassium iodide to 10 ml of ethyl ether in a 25 ml glass-stoppered cylinder of colorless glass protected from light (both components are clear)
2. A resulting yellow color indicates the presence of 0.005% peroxides
Inhibition of Peroxides 1. Storage and handling under an inert atmosphere is a useful precaution
2. Addition of 0.001% hydroquinone, diphenylamine, polyhydroxyphenols, aminophenols or arylamines may stabilize ethers and inhibit formation of peroxides.
3. Dowex-1® has been reported effective for inhibiting peroxide formation in ethyl ether.
4. 100 ppm of 1-naphthol is effective for peroxide inhibition in isopropyl ether.
5. Hydroquinone is effective for peroxide inhibition in tetrahydrofuran.
6. Stannous chloride or ferrous sulfate is effective for peroxide inhibition in dioxane.
Peroxides Test Strips These test strips are available from EM Scientific, cat. No. 10011-1 or from Lab Safety Supply, cat. No. 1162. These strips quantify peroxides up to a concentration of 25 ppm. Aldrich Chemical has a peroxide test strip, cat. No. Z10,168-0, that measures up to 100 ppm peroxide. The actual concentration at which peroxides become hazardous is not specifically stated in the literature. A number of publications use 100 ppm as a control value for managing the material safely.
Please note that these methods are BASIC protocols. Should a researcher perform one of these methods, all safety precautions should be thoroughly researched.
Any compound testing positive for peroxide formation must be disposed of via MSU EHS.
32. SOP’s are present for high hazardous chemicals
To ensure that the safety of lab members is a priority PIs need to develop SOPs when working with high hazardous chemicals and train personnel on performing safe experiments.
References:
MSU Chemical Hygiene Plan 5.1.4
OSHA Standard 1910.1450 App A.
ehs.msu.edu June 2021 Page 35
Corrective actions:
Elaborate a SOP for working with such gases and discuss with lab personnel all safety steps required for properly handling them. EHS has a template for writing these SOP that can be found on the website. <https://ehs.msu.edu/lab-clinic/chem/sop.html>
If consultation is needed contact MSU EHS directly at 517-355-0153.
Flammables
33. Flammables are kept away from heat, ignition, flames and stored in appropriate fridges/freezers or cabinets
Flammable chemicals should be stored in a spark-free environment and in approved flammable-liquid containers and storage cabinets. Grounding and bonding should be used to prevent static charge buildups when dispensing solvents. Laboratory-grade, flammable-rated refrigerators and freezers should be used to store sealed chemical containers of flammable liquids that require cool storage.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual.
MSU Chemical Hygiene Plan 3.6.1 (A) and (C)
OSHA Standard 1910.1450 App A.
Corrective actions:
Flammable materials can include flammable liquids, solids, gases and aerosols. When handling flammable materials, observe the following guidelines:
A. Eliminate ignition sources such as open flames, hot surfaces, sparks from welding or cutting, operation of electrical equipment, and static electricity. 15
B. Store flammable liquids in NFPA approved flammable liquid containers or storage cabinets, in an area isolated from ignition sources or in a special storage room designed for flammable materials that will help to protect the materials from fire.
C. Ensure there is proper bonding and grounding when it is required, such as when transferring or dispensing a flammable liquid from a large container or drum. Assure bonding and grounding is checked periodically.
D. Assure appropriate fire extinguishers and/or sprinkler systems are in the area.
E. Flammable gases must be kept at least 20 feet from oxidizing gases or separated by a 2-hour fire rated wall.
F. Flammable chemicals may not be stored in household-type refrigerators, freezers and cold rooms. When refrigeration is required store flammable or volatile liquids in laboratory-grade, flammable-rated refrigerators and freezers. (marked with sticker “SAFE FOR FLAMMABLE STORAGE”).
Flammable chemicals should not be used in Class II, Type A1 or A2 biosafety cabinets since vapor buildup inside the cabinet presents a fire hazard.
ehs.msu.edu June 2021 Page 36
Biological Storage and Handling
34. Biohazard signage on equipment and materials as appropriate
The universal biosafety sign shall be posted on each closed system and primary containment equipment when used to contain viable organisms containing recombinant or synthetic nucleic acid molecules, bloodborne pathogens, human derived materials and other potentially infectious materials.
The following items must be labeled:
• Containers of regulated waste. • Refrigerators, freezers, incubators, or other equipment containing blood or other potentially
infectious materials. • Sharps disposal containers. • Containers used to store, transport or ship blood and other potentially infectious materials (When
a secondary container holds a number of smaller items containing the same potentially infectious substance, only the secondary container needs to be labeled).
• Laundry bags/containers holding contaminated items (Laundry may be placed in a red hamper without a label, a red laundry bag, or a biohazard bag).
• Contaminated equipment.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules.
April 2019. Appendix K-IV-K, L, L-II-C-1-f-(3), O-5.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
Label all equipment that contain or contact biosafety hazards.
Required labels consist of a red or fluorescent orange colored background with the traditional biohazard symbol in a contrasting color. Labels can be an integral part of the container or affixed by a method that prevents the loss of labels or the unintentional removal of labels. You may use clear tape over the label in order to keep it in place and prevent discoloration when using disinfectant solutions.
EHS will maintain a supply of the required biohazard labels and signs, which are available from EHS by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting Lab Label and Lab Door sign requests.
35. Export controlled agents and toxins are locked
Certain biological agents and toxins have been determined to have the potential to pose a severe threat to both human and animal health, to plant health, or to animal and plant products. The Centers for Disease Control and Prevention (CDC) regulates the possession, use, and transfer of select agents and toxins that have the potential to pose a severe threat to public health and safety. The CDC Select Agent
ehs.msu.edu June 2021 Page 37
Program oversees these activities and registers all labs and other entities in the United States of America that possess, use, or transfer a select agent or toxin. The United States Department of Health and Human Services (HHS) and the United States Department of Agriculture (USDA) have established regulations for the possession, use and transfer of these select agents and toxins (see 42 CFR Part 73, 7 CFR Part 331 and 9 CFR Part 121).
On the EHS website, a list of commerce control for exports <https://ehs.msu.edu/lab-clinic/shipping/commerce-control-list.html> can be found.
An attenuated strain of a select agent or an inactive form of a select toxin may be excluded from the requirements of the Select Agent Regulations. The list of excluded agents and toxins < https://www.selectagents.gov/SelectAgentsandToxinsExclusions.html> can be found on the Federal Select Agent Program website.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
Make sure that export controlled agents and toxins are stored in locked cabinets, fridges or freezers at all times in order to protect them from theft, loss, or misuse.
36. Biological materials are labeled properly
In addition to an up-to-date, accurate inventory or material management process for control and tracking of biological stocks labs must pay special attention on labeling those samples (vials, plates, dried stocks) in a manner that allow non-lab members to quickly identify the microorganism stored.
Material accountability procedures allow that dangerous biological materials and assets are not misplaced, misused or improperly disposed.
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
OSHA Standard 1910.1450 App A.
OSHA 3111- Hazard Communication Guidelines for Compliance.
MIOSHA R 325.70101- R 325.70114, Appendix A: E.3.
Corrective actions:
Properly label biological samples utilizing materials that will withstand long periods of storage and low temperatures such as freezer labels or permanent markers.
ehs.msu.edu June 2021 Page 38
Waste Management
37. Chemical waste containers are labeled and have closed lids AND
38. Hazardous waste tags are completed
Proper disposal of chemical wastes is mandatory in labs at MSU. Chemical waste should not be disposed of by evaporation in a chemical hood.
Chemical waste should be accumulated at or near the point of generation, under the control of lab workers and must be identified from all other materials.
Each container of hazardous waste must be labeled with the words “Hazardous Waste,” and have a completed waste tag attached. An exception to this rule is individual small bottles of discarded commercial chemical product; however, if the discarded commercial product is not in the original container, it must also have a waste tag (pictured below).
References:
MSU Waste Disposal Guide
MSU Biosafety Manual
OSHA Standard 1910.1450 App A.
Corrective actions:
Collect small volumes of process waste in your own containers. Collect larger volumes in 5-gallon cans. Collect solid waste e.g., contaminated gloves, glassware, paper, etc., in cardboard boxes lined with two plastic bags. Keep liquid and solid wastes separate.
ehs.msu.edu June 2021 Page 39
Date and label the container with the words “Hazardous Waste” and attach an MSU Materials Pick-up Tag (Appendix A) to each and every container. In the contents section of the tag, enter the volume and composition of all the waste as it is added to the container. For solutions, list the solute and solvent concentrations (include the amount of water present.) Be as accurate as possible in your description of wastes.
For instructions on how to properly fill out the tags go the “Completing a Waste Pickup Request Form” <https://ehs.msu.edu/waste/completing-pickup-form.html> or contact EHS.
Separate wastes into the different waste categories. That is, collect acids in a separate container from solvents etc.
Do NOT mix incompatible materials in the same container.
Do NOT put corrosive or reactive chemicals in metal cans.
For liquids, fill containers to about 90% of container volume. Do NOT fill containers to the top. Leave at least 2 inches of space in 5-gallon liquid waste containers to allow for liquid expansion and pumping. Make sure the caps on all cans and bottles have gaskets and are tightly secured before the pickup.
Request waste tags by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html> and submitting a Lab Label request. Hazardous waste pickup requests can also be submitted in the Safety Portal. For more specific information regarding hazardous wastes, reference the MSU Hazardous Waste Disposal Guide.
39. Biological waste containers are labeled (covered in section 40)
40. Biological waste containers are labeled and have closed lids
All biohazardous waste is to be collected and separated from other types of waste generated in the laboratory, it also must be packaged, contained and located in a manner that prevents and protects the biohazard release at the producing facility at any time before ultimate disposal.
Biohazard bags used for collecting and autoclaving waste must be placed in solid waste containers to prevent ripping and tearing, which may result in releasing of the biohazards.
These containers must be labeled with a biohazard sticker and kept closed except when adding waste to minimize exposure to lab personnel.
Temporary containers can be used on the benchtops and inside biosafety cabinets and should be emptied into main containers at the end of the day.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Section IV-B-7-d-(1), (2) and Appendix G.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Waste Disposal Guide
ehs.msu.edu June 2021 Page 40
Corrective actions:
Select appropriate container for the size of the biohazard bag. These are examples of acceptable temporary containers:
A. Plastic container with swing lid B. Metal (autoclavable) container with swing lid C. Lab plastic beaker with large petri dish as lid
Place biohazard stickers on side and lid of container. Keep containers closed when not in use. Empty temporary container at the end of each working day. Ideally containers should have hands-free lids.
41. Regulated wastes are not stored beyond 90 days
No biohazardous waste can be accumulated for more than 90 days at MSU.
The same way chemical waste container tags shall be labeled with a collection start date and chemical constituents when waste is first added to the container and shall not be accumulated for longer than 90 days.
References:
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Waste Disposal Guide
MSU Chemical Hygiene Plan
MSU Biohazardous Waste Management Plan
Corrective actions:
Appropriately dispose of biohazard waste before 90 days of accumulation.
ehs.msu.edu June 2021 Page 41
Write start date of a chemical container in the waste tag and request pick up by EHS before 90 days of first use. Hazardous waste pickup requests can be submitted by logging into the EHS EHS Safety Portal <https://ehs.msu.edu/safety-portal.html>.
42. Hazardous waste tags are complete with no abbreviations
Hazardous waste container tags shall be labeled with a collection start date and chemical names unabbreviated.
References:
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Waste Disposal Guide
MSU Chemical Hygiene Plan
MSU Biohazardous Waste Management Plan
Corrective actions:
Spell out the names of chemicals in the hazardous waste tag and request pick up by EHS before 90 days of first use. Hazardous waste pickup requests can be submitted by logging into the EHS Safety Portal <https://ehs.msu.edu/safety-portal.html>.
43. Sharps containers labeled, no non-sharp waste, not overfilled, not overdue
Sharps are defined as needles, syringes, scalpels, and intravenous tubing with needles attached scalpels, as well as any contaminated object that can penetrate the skin such as: Pasteur pipettes, razor blades, capillary tubes, etc. regardless of whether they are contaminated or not.
Place discarded needles and syringes into an approved MSU sharps container. An approved sharps container is one that is leakproof, puncture – resistant, closable, bears the biohazard symbol and is manufactured as a sharps container. Sharps containers used on campus should also be labeled with the EHS “Sharps” label to facilitate proper treatment and disposal of containers. Do not clip, bend break, or recap sharps. A sharps container must be permanently closed and disposed of through the EHS when:
• It is ¾ full and/or • Within 90 days of the date that the first sharp was placed in it, whichever comes first
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
ehs.msu.edu June 2021 Page 42
MSU Waste Disposal Guide
MSU Biohazardous Waste Management Plan
Corrective actions:
Purchase MSU-approved containers from University Stores and record date of first use in the EHS provided label.
Add used sharps until is ¾ full and/or within 90 days of first use, whichever comes first.
Close lid permanently, and request a hazardous waste pickup by logging into the EHS EHS Safety Portal <https://ehs.msu.edu/safety-portal.html>. Additional waste tags can also be requested in the Safety Portal.
44. Biohazardous waste policies are followed, chemical treatment or autoclaving
A method for decontaminating all lab wastes should be available in the facility (e.g., autoclave, chemical disinfection, incineration, or other validated decontamination method).
It is the responsibility of the generating department to decontaminate all solid non-sharps biohazardous waste and all liquid biohazardous waste. The EHS is responsible for the removal and proper treatment of sharps waste.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Section IV-B-7-d-(1), (2) and Appendix G.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Waste Disposal Guide
MSU Biohazardous Waste Management Plan
Corrective actions:
Select appropriate method of decontamination.
If using autoclaving:
Solid waste should be autoclaved in approved orange biohazard bags with a heat sensitive "Autoclaved" indicator and placed in a secondary container.
Liquid waste should be autoclaved in container where originally produced if heat resistant or transferred to a heat resistant container for autoclavation (for example laboratory glassware). The containers should be capped with aluminum foil or have the caps loosely attached. All bottles/containers must be placed in secondary containers.
Use caution to transport waste from the laboratory to the autoclave room. The use of a cart for transportation is strongly recommended.
ehs.msu.edu June 2021 Page 43
• Prior to autoclaving, a biohazard bag containing waste must be kept closed to prevent airborne contamination and nuisance odors. However, when autoclaving, the bag must be open to allow the steam to penetrate.
• Follow the guidelines set by the posted autoclave parameter signs when setting the cycle time. • Add one cup of water to each bag of solid waste and keep the bags open. Steam cannot
penetrate closed bags. • To prevent spills and accidents, be sure that the exhaust setting is appropriate for the type of
material you are autoclaving. Fast exhaust should be used for solid items and solid waste and slow exhaust for liquids and liquid waste.
• After the cycle is complete, let the bag cool before removing it from the autoclave. • Securely close the orange autoclave bag. • Place treated autoclave bags into opaque black bags and close them securely before disposing.
If using liquid chemical disinfection:
The appropriate liquid disinfectant should be chosen after carefully assessing the biohazardous agent and the type of material to be decontaminated. Liquid disinfectants are preferably used for solid surfaces and equipment.
NEVER AUTOCLAVE DISINFECTED LIQUID WASTE
Safety Equipment and Containment
45. Biosafety cabinet properly used, disinfected and located
A series of recommendations on how to select the appropriate biosafety cabinet for your type of work and how to properly use it is provided in the MSU Biosafety Manual.
The interior surfaces of BSCs should be decontaminated before and after each use.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Section IV-B-7-d-(1), (2) and Appendix G.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
All items within BSCs, including equipment, should be surface-decontaminated and removed from the cabinet when work is completed, since residual culture media may provide an opportunity for microbial growth.
The interior surfaces of BSCs should be decontaminated before and after each use. The work surfaces and interior walls should be wiped with a disinfectant that will kill any microorganisms that might be found inside the cabinet. At the end of the workday, the final surface decontamination should include a wipe-down of the work surface, the sides, back and interior of the glass. A solution of bleach or 70% alcohol should be used where effective for target organisms. A second wiping with sterile water is needed when a corrosive disinfectant, such as bleach, is used.
It is recommended that the cabinet is left running. If not, it should be run for 5 min in order to purge the atmosphere inside before it is switched off.
ehs.msu.edu June 2021 Page 44
46. Biosafety cabinet certified annually (BSL-2)
The functional operation and integrity of each BSC should be certified to NSF Standard 49 at the time of installation and annually thereafter by qualified technicians. Certification includes tests for cabinet integrity, HEPA filter leaks, downflow velocity profile, face velocity, negative pressure/ventilation rate, air-flow smoke pattern, and alarms and interlocks. Optional tests for electrical leaks, lighting intensity, ultraviolet light intensity, noise level and vibration may also be conducted. Special training, skills and equipment are required to perform these tests. Annual certification is required for BSCs that are used for work with human pathogens, recombinant DNA or human derived materials (e.g., cell lines, blood, etc.).
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Section IV-B-7-d-(1), (2) and Appendix G.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
Corrective actions:
Provisions to assure proper safety cabinet performance and air system operation must be verified. BSCs should be certified at least annually to assure correct performance. To request service or certification contact the EHS at 517-355-0153.
47. Mechanical devices are used, no mouth pipetting
Mouth pipetting is prohibited; mechanical pipetting devices must be used
References:
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan
OSHA Standard 1910.1450 App A
Corrective actions:
Pipetting aid must always be used for pipetting procedures. Mouth pipetting must be strictly forbidden. The most common hazards associated with pipetting procedures are the result of mouth suction. Oral aspiration and ingestion of hazards associated with pipetting procedures are the result of mouth suction. Oral aspiration and ingestion of hazardous materials have been responsible for many laboratory-associated infections.
ehs.msu.edu June 2021 Page 45
48. Vacuum system with inline filter, dual flasks, stable and disinfected immediately
Vacuum lines must be protected by High Efficiency Particulate Air (HEPA) filters. A dual flask system should be utilized. Flasks should be stabilized within a vessel that can contain a potential spill. Flask should contain appropriate disinfectant to decontaminate waste and be emptied at the end of work that day.
Alternatively, vacuum canisters with automatic shut-off valves may be used.
References:
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019. Appendix G-II-C-2-o.
BMBL 5th Ed. HHS Publication No. (CDC) 21-1112.
MSU Biosafety Manual
Corrective actions:
Make sure HEPA filters and a dual flask system is utilized as well as a secondary container to avoid any potential spill. Add disinfectant to the vessels daily and empty at the end of the working day.
An example of a suitable disinfectant is bleach at final concentration of at least 10% (use concentrated bleach and calculate volume necessary based on volume of the flask).
If using vacuum canisters with automatic shut-off valves, make sure it is properly installed.
ehs.msu.edu June 2021 Page 46
49. Spill kits (biological and chemical) are available
All BSL-2 labs should have a biological spill kit available in addition, ready access to a chemical spill kit is required in labs that work with hazardous chemicals.
Spill kits must be checked every 6 months to ensure all components are present, in good condition and within expiration date and date of verification recorded.
All spills must be cleaned by personnel who are properly trained and have the proper equipment to handle infectious materials and hazardous chemicals.
References:
MSU Biosafety Manual
ehs.msu.edu June 2021 Page 47
MSU Bloodborne Exposure Control Plan
MSU Chemical Hygiene Plan
OSHA Standard 1910.1450 App A
Corrective actions:
Ensure a chemical spill kit and a biological spill kit is available and that employees know how to use it.
Check spill kits every 6 months to ensure all components are present, safety goggles are in good condition and disinfectants are not expired. Replace components as necessary (contact EHS for replacements).
Write down the date the kits were verified.
Since spills of biological materials will happen, it is important to be prepared prior to dealing with the problem. Labs working with biohazards should have a basic biological spill kit ready to use at all times. For most instances the basic kit can be assembled with materials already used in the laboratory. All labs operating at BSL-2 or higher must have an assembled spill kit available in the lab. In BSL-1 labs, although it is preferable to have the contents of the spill kit in one location, as long as the materials are easily accessible to everyone in the lab, prior assembly might not be necessary. Ready assembled spill kits are available for a fee through the EHS.
The following is a list of items that should go into a basic biological spill kit. It should be enhanced to meet the needs of your unique situation.
• Disinfectant bottle (e.g., bleach 1:10 dilution, prepared fresh) • Absorbent material (e.g., paper towels, absorbent powder) • Waste container (e.g., biohazard bags, sharps containers) • Personal protective equipment (e.g., gloves, eye and face protection) • Mechanical tools (e.g., tongs, dustpan and broom) • Spill clean-up procedures • Barrier tape
Chemical spill kits should, minimally, contain:
• splash resistant goggles • chemical resistant gloves • plastic bags • multi-chemical sorbent (enough for 2-gallon spill) • scooper
The following procedures are provided as a guideline to biohazardous spill clean-up and will need to be modified for specific situations.
As with any emergency situation, stay calm, call 911 if necessary, and proceed with common sense. Call the EHS at 517-355-0153 if further assistance is required, especially if the spill outgrows the resources in the laboratory.
For large chemical spills, i.e. greater than 1 cc, contact EHS for spill cleanup, instructions or assistance.
50. Safer sharps or needle locking syringe device are used for rDNA
A safer sharp is a non-needle sharp or a needle device with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident.
ehs.msu.edu June 2021 Page 48
Only needle-locking syringes or disposable syringe-needle units (i.e., needle is integral to the syringe) are used for the injection or aspiration of fluids containing organisms that contain recombinant or synthetic nucleic acid molecules.
Labs that use human derived materials or work with bloodborne pathogens are subject to the requirements of the Bloodborne Infectious Diseases Standard. This standard requires that available safer sharps devices be used and that those devices be reviewed annually in consideration of newly marketed ones.
References:
MSU Biosafety Manual
MSU Bloodborne Exposure Control Plan
NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. April 2019
Corrective actions:
For additional information on safer sharps refer to the MSU Bloodborne Pathogens Exposure Control Plan or contact the Biosafety Office at 517-355-0153.
Examples of safer sharp devices can be view at the CDC website <https://www.cdc.gov/sharpssafety/pdf/sharpssafety_poster3.pdf>