Chemistry: Safety and Regulatory Agencies

Chemistry 407 7/15/01 ....Web version: 8/17/01

Section : I. F. ii

Some external Web sites. (Operational as of August 18, 2001 but linkages like these often change without notice.)
Agencies and Acronymns

There are a number of Federal and State agencies which regulate the use of chemicals. These regulations affect the way in which laboratory work is carried out and you should be familiar with the general nature of the regulations.

OSHA stands for the U.S. Occupational Safety and Health Administration; there is also a state agency, Ohio-OSHA.

EPA stands for the U. S. Environmental Protection Agency

A comparable state agency also exists, the Ohio-EPA.

  • The EPA has a broad responsibility to enact and enforce rules to protect the environment.
  • The EPA has many well known areas of activity. It regulates landfill operation, sewage processing plants, municipal water supplies, the approval and use of pesticides, automobile exhausts, power plant operations (smokestack emission and thermal pollution), and the use of wet land areas. It is also in charge of the Superfund for cleaning up unsafe disposal sites.
  • The EPA has many regulations which specifically govern the discharge of chemicals to the environment. This includes disposal (landfill or incineration), discharge into ground water systems, and losses in the manufacturing process.
  • Many manufacturing chemicals are subject to "Birth to Grave reporting." To reduce the possibility of illegal dumping, manufacturers and some purchasers are required to maintain records showing purchases, use, transfer, and eventual disposal of regulated chemicals.
  • EPA also enforces regulations to reduce the risk of accidental spills. These rule may, for example, severely restrict the storage of a chemical.
  • EPA also tests air, water, and some food and sets standards for the maximum concentrations of specific species.
  • The EPA maintains list of specific chemicals which are subject to regulations.
  • From a practical standpoint, the EPA controls the disposal of laboratory wastes and the treatment of serious chemical spills. This will be covered in greater depth later.
Other Agencies

There are many other agencies with a finger in the pie. There is also considerable overlap in the regulations (both OSHA and EPA have regulations concerning air quality.)

  • The NRC, Nuclear Regulatory Commission, enforces regulations on the use of radioactive materials. Laboratories which use radioactive isotopes must be licensed and file reports.
  • The FDA, Food and Drug Administration, is responsible for drugs (prescription and over the counter medications), medical devices (pacemakers and surgical lasers), and food additives.
  • The Public Health Service sets standards for municipal water supplies; in practice the EPA generally enforces such regulations.
  • The DEA, Drug Enforcement Agency, enforces regulations with respect to illegal drugs. In this form the DEA restricts access to chemicals which are used in the production of illegal drugs. This includes some common chemicals such as acetone and toluene as well as drug precursors. This can increase the paperwork required for the purchase of some laboratory chemicals.
  • The Treasury Department, specifically ATF (Alcohol, Tobacco and Firearms), regulates the use of ethanol in the laboratory. Denatured alcohol (with additives to make it unsuitable for drinking) is easily acquired, but pure ethanol is tightly controlled. The most important consequence is that the stockroom inventory must be maintained under lock and key and carefully inventoried.
  • The state fire marshal and the local fire department have regulations on the storage of flammable materials, safety equipment, alarm systems, and the design of buildings.
Regulations affecting our laboratories

The maze of regulations can be overwhelming and it has caused a bureaucracy to arise, both within the government and in the regulated organizations. Some of the regulations apply only to large producers but many apply equally well to a small research or teaching laboratory. On the positive side, there are many opportunities for employment in the environmental/ regulatory/ testing area.

In Ohio, there is a peculiar situation with respect to governmental agencies, such as state universities. When the federal EPA and OSHA regulations were introduced, the states had the alternative of setting up their own programs to regulate governmental agencies. Ohio selected that option and created the Ohio-EPA and Ohio-OSHA. OhioOSHA has adopted the same rules as the US-OSHA, but the enforcement is within a different organization. In particular this requires Ohio state universities to formally train their employees in the use of hazardous chemicals and it will requires adherence to the Right to Know regulations. Ironically this does not affect students in the laboratory but it would affect teaching assistants in the same laboratory.

Objectives

These notes are intended to meet several objectives:

  • To make you, as a chemistry student, aware of the general scope of such regulations as they apply to chemistry and routine laboratory operations.
  • To provide a reference for specific safety rules and procedures to be followed in this instructional laboratory. We generally expect you to comply with OHSA/EPAA rules as well as some rules specific to instructional laboratories.
  • To provide you with experience in reading MSDS (Material Safety Data Sheets.
  • To provide an experience which might be cited on your professional vitae when you seek employment.
    • We will not, of course, covers all of the regulations. For example, we will only provide a general outline of regulations which affect the purchasing and stockroom activities of the department.
Hazardous Materials

The phrase hazardous materials is broad and it includes many common materials. The designation applies to substances which, by their nature, pose the risk of producing personal injury or damage to ones health. This generally involves physical exposure to the material: skin contact, ingestion, inhalation. It does not cover the usual dangers associated with large quantities of the material-- you can be killed or injured by a large falling bag of sugar or drown in water but sugar and water would not automatically be considered hazardous materials. It also does not cover materials (such as iron) in the context of dangerous devices such as knives.

It should also be noted early that we all encounter hazardous materials on a regular basis (gasoline, natural gas, paint thinner, or laundry bleach.) The proper use of such materials (including safety precautions) can minimize the risk they present.

It is easier to list the most common categories of hazardous materials. In fact, no complete list of such materials exists.

  • flammable liquids (many common solvents fall into this category-- acetone, hexane, ethanol, ether.)
  • explosive compounds (e.g., perchlorates)
  • strong oxidizing materials (such as nitrates and peroxides)
  • caustic materials, capable of causing chemical burns on contact with the skin. (examples would include strong acids and concentrated bases, hydrogen peroxide, liquid bromine, and even relatively dilute solutions of HF.)
  • compressed gases. There is the mechanical danger due to the high pressure in gas cylinders. There is also dangers associated with flammable gases (H2 or propane) or with affixation or displacement of oxygen (He, Ar, N2.) Some gases are also toxic at low concentrations (CO, H2S) of affect respiration (CO2.)
  • Chemicals are also classified as hazardous if they are toxic or poisonous. The OSHA classification uses several test criteria:
    • if the LD50 for ingestion is less then 500 mg/kg of body weight. (This means that half of the rats tested died when the ate this amount.) If extrapolated to a 75 kg adult this corresponds to consuming about 35 grams.
    • if the LD50 for injection is less than
    • if there exists a body of medical evidence showing sufficient toxicity.
    • Carcinogens or cancer producing/inducing agents (including suspected carcinogens) The list includes some common materials (benzene, chloroform...)
    • Chemicals which are known to produce strong reactions, even if no serious lasting damage results. This includes lacrymators (induce tears.)
    • Materials which are known to produce strong allergic reactions in a significant portion of the population. (Individuals may, of course, become allergic to a much wider range of compounds.)
    • Teragenic Materials-- materials known or suspected of producing birth defects
Mixtures are subject to the same regulations as well defined chemical species. In general the law favors testing of the mixture itself, but it will accept classification of the mixture by the materials it contains.

Material Safety Data Sheets (MSDS)

Federal law requires all manufacturers and suppliers of chemicals to give its customers a Material Safety Data Sheet for that substance when it is first ordered. In our department the sheets are received by the stockroom and they are kept on file there. A copy of the data sheet is also sent to the individual who requested the material. It is expected that each laboratory will maintain a file of MSDS for materials in the room, but the official (and complete) collection is maintained by the stockroom.

The MSDS should list all known hazards (including conflicting evidence.) It should provide advice on storage and appropriate safety equipment. The legal climate frequently reduces the value of the MSDS by making everything sound catastrophic; beach sand is labeled as a hazardous material. (If sand is finely ground the dust can be inhaled leading to a lung disease known as silicosis.)

We've appended an example of a MSDS (abbreviated for space.) This is for a flammable liquid which poses risks of fire and inhalation of vapors.

MSDS for Cyclohexane

Right to Know Regulations

OSHA requires employers to inform its employees of the materials they will be exposed to in their work. A formal training program (written) must exist and special training is required for all new employees. This training should include information about the materials being used, proper procedures, safety equipment and how to use it, and a summary of the rights the employee has under the law.

OSHA requires that all containers containing hazardous materials to be properly labeled. This is an extremely difficult problem in teaching and research labs where many people prepare a wide variety of samples and solutions. If the labels are not understandable by others, they are not legally acceptable.

OSHA requires that employees have free access to a complete set of MSDS for materials used in their work. Under the law the employee is free to refuse to perform activity he feels is unsafe (subject to some limitations.)

Chemical Labeling

All chemical containers must be labeled. The label must, as a minimum, identify the contents by its full name and must include brief statements of any known risks. Single words on the label (flammable, toxic, lachrymator) may meet the second requirement. Virtually all chemicals purchased today bear such labels. Older bottles may need additional labeling to meet the requirements. Repackaged materials, including solvents in metal safety cans, will require careful labeling.

The rules apply equally well to labeling prepared solutions and waste materials. This is good procedure in any event; poorly labeled solutions are responsible for many laboratory mistakes and many very difficult disposal problems.

See also Chem 407-408 policies on sotrage, labeling and disposal

Air Quality

OSHA regulations limit the exposure of an individual to air borne chemicals (mostly vapors although in some cases aerosols and dust can be a major source of exposure.) In the laboratory this is generally controlled by the choice of work location. Work performed in a hood protects the user from most of the vapors and fumes from the process; the ventilation also helps to prevent the accumulation of potentially explosive vapors. If a hood is not available or suitable, care should be taken to work in areas with good air circulation.

In many laboratories the storage of chemicals poses a serious source of exposure. One technique to minimize exposure is to store volatile materials in a ventilated metal storage cabinet. In fact, the use of such cabinets may be required by law for all but small quantities. Another procedure (hard to learn) is to limit the amount of material stored in the laboratory. Additional amounts can be stored in the stockroom or can be ordered as required (delivery time of 1-3 days is quite common.)

In an industrial setting the employer would be expected to regularly monitor the air quality in the workplace. If the exposure level exceeds the allowable limits the procedure must be modified .

The exposure levels usually involve several different criteria.

  • prolonged exposure-- the maximum level of 8 hour exposure. This will generally be much smaller than the peak level.
  • integrated exposure-- the law may permit exposure at moderately high level for brief periods followed by assignment to an area of very low level exposure.
  • peak exposure-- the maximum level permissible for even brief instances (for example, when filling a storage tank.)
In academic laboratories (teaching and research) few processes are repeated on a regular basis so periodic tests are not as useful as in an industrial setting. It is easier to determine safe conditions for a typical operation and to conduct occasional checks of background levels.

Air Quality Testing

This can be a difficult analytical problem. The usual approach is to use a small (portable) monitoring pump to sample the air. The sampled air is passed through an adsorbing tube (often filled with activated charcoal) to collect the active components. This allows averaging over an extended period and it permits concentration by collecting volatile organics from a large volume of air. The sample tube is then taken back to the laboratory where the materials are desorbed (by heat or by solvent extraction) and analyzed by GC or HPLC.

There are a number of specific test methods for on-site use. A number of tubes are available which will produce a color reaction with a specific material; air is drawn through the tube and concentrations are measured against a printed scale. On the more expensive side there are single species analyzers, often based on infrared or visible absorption; CO, CO2 and Hg vapor are often monitored in this manner.

Specific Policies-- Chem 407-408

  • 1. A collection of MSDS is maintained in the laboratory. Preparation for an experiment includes consulting this file.
  • 2. Chemical storage reflects federal regulations. Flammable materials are kept in room 26 in a fireproof storage cabinet. Solid chemicals are separated and oxidizing materials are stored in a separate area. This includes nitrates, perchlorates (few of them), persulfates, and peroxides.
  • 3. Chemical disposal is an integrated part of each experiment. Disposal of materials down the drain or in the trash is prohibited as a general rule. Waste collection bottles must be completely labeled as to contents.
  • 4. Disposable gloves are available for use when handling materials which pose a hazard. Additional safety equipment may be provided in other cases.
  • 5. The ventilation in the instrument rooms and in the main laboratory (Overman 28) is not of laboratory quality. Work with volatile solvents or similar materials should be conducted in room 26, using the hoods when appropriate.
  • 6. Any materials stored overnight or longer must be completely labeled with your name and the contents. (I don't want to encounter a volumetric flask labeled "solution #2" and try to figure out a safe and legal disposal procedure.)
  • 7. Food and Beverages are not permitted in the laboratory.
  • 8. Safety glasses are to be worn at all time.
  • 9. Laboratory work is not to be conducted alone. Laboratory work is not permitted outside of scheduled laboratory periods, unless explicitly authorized by the instructor.
  • 10. Any spills, injuries, or malfunctioning equipment should be reported promptly to the instructor.
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(7/15/01)