Hello, my name is FirstName Lastname and I work for Environmental Health and Life Safety at the University of Houston. Our mission is to promote a safe laboratory environment and workplace for all researchers, staff, and students at the University of Houston by taking every reasonable precaution to free laboratories and workplaces of recognizable hazards. We will assist researchers and managers in complying with applicable regulations and recommendations for handling different types of hazardous materials. We will also assist UH in achieving tier one status and professional recognition.

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Hazard communication, also known as the “Employee Right to Know Standard” requires that the University take certain precautions when an employee is working with hazardous chemicals. While the HAZCOM Act requires only chemical hazard communication, the University has an obligation to provide a safe working environment, so this process is extended to other hazards as well.

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Chemical inventories are required for any substance that requires a safety data sheet to be kept. Workplaces must maintain an up-to-date chemical inventory. Internal inventories may not provide all of the required information, so be sure to capture the information required by EHLS’ form. Even hazardous chemicals like gases belong on the inventory, whether they are contained in a cylinder, or produced as an intermediary and stored dissolved. Once a chemical is received, store the safety data sheet and add it to the inventory. Only remove chemicals from the inventory and SDS beinder once they are no-longer used. This is more than just when a stock of a chemical is temporarily depleted. Storing chemicals requires active management and should be led by a supervisor, manager, or principal investigator for each workplace.

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Safety Data Sheets are for you. They exist to inform you of chemical hazards in the workplace. Even if something isn’t a commercial product, and therefore won’t have an SDS, workers must still be informed of the hazards.SDS have a specific format, and are product-specific, not chemical specific. If UH produces one chemical, and another University produces the same chemical, they should have different SDS because the processes, raw materials, and other aspects of each may be different between the products. Every workplace must have these documents available at all times for each chemical, even if the internet goes down, or if the power goes out. Everyone can help maintain SDS but is the responsibility of the supervisor, manager, or principal investigator to do so.

Section 1 includes a product identifier (chemical name, trade name, product number, or something else to identify the product. This MUST match the product label and is a great way to coordinate between the product’s labeled container and the SDS. It will also include an emergency phone number as well as restrictions on use. Section 2 identifies the hazards including pictograms, statements, and may include other hazards not listed by regulation. Section 3 includes information on chemical ingredients, approximate concentrations, and information on trade secrets if they are claimed.

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Section 4 includes first aid measures for lay responders. Section 5 includes firefighting measures, this is not intended entirely for lay or first responders, but includes information for both. The scope of a person’s involvement in emergency response should be discussed in other areas of administration, such as SOPs. Section 6 includes information on what to do in case of an active release. This section is highly subjective, and typically geared toward industries that follow its recommended use practices. It may have information on PPE , and methods of containment and cleanup. All of these generally require specialized training, when in doubt, contact EHLS. Section 7 includes information on handling and storage of the product, including incompatibilities. Section 8 includes information on established exposure limits (if any are established), as well as engineering controls and PPE recommended for normal use. Again this part may be subjective and assume that the product will be used according to certain methods or industrial guidelines that may not apply. Section 9 includes a substance’s physical and chemical properties such as boiling point, flash point, and pH if they are known, and as the product is produced. This information may change during use of a product, for instance dilution, drying, or mixing may change these properties and/or their associated hazards. Section 10 includes information on the stability and reactivity of a chemical including potentially hazardous reactions. These may not be known for all products or combinations. Section 11 includes information on the toxicity of a product. Section 12 includes information on how a product may impact the environment in an ecological sense. Section 13 includes information on disposal restrictions and often is not specific enough to act upon- contact EHLS instead. Section 14 includes information for shipment, which can be a useful resource in getting an overview of some hazards. Section 15 includes other regulatory information, and depending on where the product is intended to be sold may have significant quantities of information, or very little at all. Section 16 includes any additional information the producer wants to provide, and will also include the date that the SDS was prepared or revised

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Training and a written program are two major requirements of Hazcom. EHLS provides the University’s written program as well as training on awareness of hazcom and the basic elements. Some limited substance- and hazard-specific training is also offered by EHLS, such as hydrofluoric acid training or compressed gas training. Everything else falls on the workplace (represented by your supervisor). They must provide training to workers based on exposure to the hazard, or potential exposure to the hazard, training for each individual chemical or classes of chemicals or classes of hazards. If training is provided on classes, it must include training on how to determine which class a chemical or product belongs to as well as understanding how to find, read, and understand information regarding hazards and protective measures not already covered by other training, understanding how to acquire and use the chemical or class in the specific workplace, as well as understanding the risks of exposure and how to properly protect themselves.

The red arrows denote separate training requirements that this training does not cover.

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Whether it is a job requirement, or just incidental contact with cuts, scrapes, or bruises, the University of Houston requires that universal precautions are taken for contact with blood or other potentially-infectious material.

Universal precautions is the approach of treating all human blood and certain bodily fluids as if they were known to be infectious. If you cannot tell if something is contaminated with blood or OPIM, assume that it is. Use gloves, masks, and gowns or other appropriate PPE and engineering controls where available.

You might be wondering what OPIM could be, well it includes all semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva (in dental procedures), any bodily fluids visibly contaminated with human blood or where you cannot tell the difference.

Some possible consequences of exposure are HIV, Hep A, B, and C, Staph and Strep infections, gastroenteritis salmonella, shigella, pneumonia, syphilis, tuberculosis, malaria, measles, chicken pox, herpes, urinary tract infections, or blood infections.

Some workplaces may require other precautions such as standard precautions, which treat every bodily fluid, secretion, or excretion except for sweat as potentially infectious and

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adds handwashing and PPE when touching a patient is anticipated. It is prevalent in healthcare settings.

Transmission-based precautions are added based on risk assessment of patients and suspected pathogens and can include precautions to prevent airborne, droplet, or contact transmission of pathogens.

You may need this information in emergencies, but if you are performing work or studying where any of this is routine, or if it is a part of your job description to respond to emergencies, then you will require additional training.

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One of the realities of work and research is that there is inherent risk involved with any action. Hopefully we all made it here today without slipping and falling in the shower, or having an accident during transit, but if you do take a moment to think about your day, there is at least something that could have gone wrong and caused harm. You cannot completely eliminate all risk from life, but one of the biggest things you can do as a student or employee is to help manage that risk. Here you can see the hierarchy of controls and a risk management matrix. These are two things that we’ll use to illustrate measures we can take to manage our risk while here at the University. Before we move on, I want you to make a note of the first thing that comes to mind when it comes to mitigating risk and protecting yourself from hazards, I’ll ask about it later. Here you can see Shasta the second, Shasta the second is known for having a temper. This photo was taken from Shasta’s home in Lynne Eusan park, on campus. Can anyone think of a potential hazard that could arise from housing a live cougar on a public part of the campus? What could we do about it? We could eliminate the risk (on campus) by moving Shasta somewhere else. Here you can see Shasta the sixth curiously looking from Shasta’s home at the Houston Zoo. The hazard has been eliminated from the workplace. That doesn’t really work in some cases though- how can we have our cheerful mascot present for athletic events if they live at the zoo? There’s another option, substitution. In this case Shasta and Sasha (humans in cougar costumes) take the place of a live cougar.

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While I don’t doubt Shasta and Sasha’s athletic prowess, I think that the outcomes of an attack by human mascots would generally be less severe than an attack from a live cougar, no matter how tame. Elimination decreases the probability of an adverse outcome. Substitution decreases the severity of the adverse outcome.

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Now that we’ve covered elimination, which removes the source of a hazard, and substitution which replaces the source of the hazard with something less hazardous, let us talk about Engineering Controls. Engineering controls work by isolating the source of the hazard from those that are potentially exposed. You’ll see here that Shasta the third is relaxing outside of the old University Center, a hub of campus activity. Now you’ll see an image of Shasta the second in a cage, in this case our beloved mascot has been isolated from the potentially-exposed population by use of a cage. Isolating or separating a hazard from someone potentially exposed can work on both axes of the risk management matrix, they can make the hazard less probable, or they can decrease the severity. Some examples of engineering controls include: Chemical fume hood, which have standard and combination configurations. Combination configurations allow portions of the glass sash to slide back and forth to allow for manipulation with both arms, while the head and torso are shielded by the glass. Other types of hoods for special applications include hydrofluoric acid hoods, perchloric acid hoods, and radioisotope hoods. If you’re using any fume hood or working around them, you’ll need additional training. Biological safety cabinets provide a measure of safety by producing a laminar flow over the objects being manipulated, and passing this through a filtration system. Almost all BSC’s on campus recycle air and don’t provide ventilation to remove harmful chemicals, but even

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those that do have additional ventilation are not designed for use with harmful or volatile chemicals. You’ll need additional training if you work in a lab or other workplace with one of these in use. Gloveboxes provide isolation of objects from the ambient atmosphere, generally to protect it from water or oxygen either to facilitate work where oxygen or water would interfere with the chemistry or when chemicals that react violently with ambient air may be manipulated. You’ll need additional training if you work in a lab or other workplace with one of these in use. Machine guarding provides a physical barrier between potentially-exposed populations and a hazard (often even physical hazards, like the belts and fan blades in this case). You’ll need additional training if you work in a workplace where these are used. Interlocks prevent the activation or operation of a device if it is not configured properly. These can be as simple as making sure that a grate providing machine guarding is closed, or as advanced as making sure that adequate shielding is in place before operating an x-ray source. You’ll need additional training if you work in a workplace where these are used. Believe it or not, in areas designated for the use of chemicals and many other hazards, the room and building itself is designed to have an appropriate air balance to isolate other building occupants as well as those in the room from exposure to hazards. This can often be found as local exhaust ventilation, air balance systems, and the walls, floors, and doors of the building itself- they’re often rated to withstand a fire for longer in some areas than others. All of these require additional training except for the building itself, but even these features should be covered by a supervisor’s introduction to the workplace- it can be as simple as “never leave this door propped open” in some cases, or in others may be significantly more involved.

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Administrative controls are often referred to as work practice controls, they are basically rules. Here you can see members of the Cougar Guard posing with Shasta. Only trained cougar attendants may pet Shasta is certainly an example of a rule, but at this point the rule is the only thing preventing someone from coming into contact with a cougar. Fortunately Shasta the first had an even temper. Some examples of administrative controls are training (like this one); policies, plans, procedures, and manuals; standard operating procedures and protocols; and emergency action planning. These all attempt to make hazardous outcomes less probable, but in some cases may also try to change the way that work is performed in order to make the outcomes less severe.

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With a show of hands, how many people thought about something along the lines of personal protective equipment (gloves, safety goggles, long-sleeved shirts, etc.) as the first thing that came to mind as far as ways to protect yourself? I’d like you to think about that for a second. Here you can see another photo of Shasta the sixth in his enclosure, and next to it a photo of Senior Airman Tristin English in PPE, a bite suit, performing training. I personally would rather take other measures than personal protective equipment, and realistically it is the last line of defense against hazards. If all you have protecting you from a hazard is PPE, step back and take a look, discuss with your supervisor if there is a better way to do this. PPE is generally geared toward preventing specific routes of exposure. Protecting you from inhalation are N95 masks, respirators, and self contained breathing apparatus. They all require additional training, medical evaluation, a fit test for the particular piece of equipment, and do not protect against everything. Protecting you from absorption and ingestion are smocks or aprons, gloves, face shields, goggles, and safety glasses. It is obvious how they could protect you from absorption, but by preventing contact with your hands (and onward to your mouth) or just by keeping your mouth protected, they can also protect against ingestion. Use requires additional training as not all gloves, aprons, smocks, or shields are appropriate for all hazards, even selecting goggles or glasses may require significantly more knowledge than you already have. Protecting you from injection and other forms of physical exposure are cut- or puncture-

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resistant gloves, hearing protection, and blast shields. Technically we think of hearing protection and blast shields as protecting against absorption of hazardous energy. They definitely require additional training as well, and possibly participation in a hearing protection program. Remember, you must be trained on the proper use and protective properties of any PPE required, as well as on the hazards it seeks to protect you from. The biggest point that will be made in any of this training is that PPE is only effective if used- safety glasses aren’t able to protect your eyes if they’re worn above your forehead. All that PPE can do is seek to minimize the severity of a hazardous outcome, it really isn’t as good as engineering controls at lowering the probability of a hazard in most cases.

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We already know what we’re going to do in order to avoid emergencies, but what do we do if we find ourselves in one? Well, we should have already started by having (and knowing, and practicing) for evacuation of the workplace. Your workplace must have a posted evacuation route and rally location. Why a rally location? Imagine that you’re the supervisor for your workplace and there are two employees that aren’t with you after everyone’s out of the building. Do you ask a firefighter (or two, or more) to go in after them, or try and wait a few minutes to see if they find your group among the other groups present? This dilemma can be averted by having everyone show up at the same place after evacuating. If an emergency occurs, use a fire alarm pull station on your way out (they are required along egress routes) to notify others in the building that an evacuation is necessary. There’s no penalty for using one in good faith. Whether it is the building’s fire alarm or other emergency communication devices like toxic gas monitors, or UH Alert system (composed of warning sirens, mass text messages, and emails) follow the instructions provided even if you think that you’re not in danger, especially for things like sheltering in place or evacuating a building. Sometimes your workplace processes may change, like having visitors, meeting participants, or human or animal research subjects in the workplace, there may be people with disabilities that require accommodation during evacuation, process controls for shutdown or standby may change, and work locations (including the addition or withdrawal

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of additional hazards from other workplaces) may necessitate updating your evacuation planning. Follow rally point and accountability procedures for your workplace, if you don’t understand them or cannot find them, ask your supervisor. Rehearse (and take place in rehearsals) prior to an emergency, like fire drills.

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Fires are a big deal, with big buildings, flammable materials, and other risks, they do happen at the University. Fire can be described with a triangle or tetrahedron. Heat, oxygen, and fuel are a common component of each model, the fire tetrahedron incorporates the chain reaction that the heat from the fire can cause that facilitates the continued burning of a material. Plan ahead knowing at least 2 exit routes as well as the location of pull stations, fire extinguishers, and other equipment. These may be important to make sure you don’t get lost when evacuating, don’t get trapped by fire, and can notify others of an emergency. Keep exits, egress routes, and corridors clear and unobstructed. In this photo you can barely see the exit sign for the emergency exit door over the towering pile of office furniture being stored. There are different classes of fire, and different classes of fire extinguishers to match them. Unless you have been assigned to assist in putting out a fire, they are for use in facilitating egress (getting away) or putting out a fire on a person only. This does require additional training. Briefly class A is for debris like paper, cloth, wood, rubber, or plastics, Class B is for fires in flammable liquids, Class C is for electrical fires, Class D is for combustible metals like lithium, aluminum, magnesium, etc., and Class K is for cooking liquids like vegetable oil. You will find around campus that Class ABC are the only ones provided by the University in order to minimize confusion, areas that have Class K or D provide their own and will provide additional training to personnel.

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To use a fire extinguisher (A, B, C, or ABC types), Pull the pin (it may have a tamper seal that breaks, this is fine), aim it at the base of the fire, squeeze the trigger, and sweep back and forth around the base of the fire. Fire extinguishers do have limitations. Class A ratings give an equivalence of water (the number is 1.25 gallon units), so a Class 4A extinguisher can put out a fire that could be put out by 5 gallons of water. Class B and C are given as square feet of coverage, so a 20B:C extinguisher can cover approximately 20 square feet. If you cannot approach the fire close enough to use the extinguisher without feeling heat on your exposed skin, it is too large for the extinguisher. Additional training is needed to use a fire extinguisher for anything other than saving your life to escape or putting out a fire on yourself or someone else. If an ABC extinguisher doesn’t work, or you know that metals or cooking liquids are involved, get out. If you have any doubts about using an extinguisher, get out.

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There is a large amount of equipment you could need in order to respond to an emergency, and not all of it will be pertinent to your workplace. Some examples of emergency response supplies and equipment are: Safety showers. Some have an integral eyewash stations, some do not. Often they are not plumbed to a drain, meaning that they will create a large puddle on the floor. The University has resources to handle this large puddle, it should never be a reason to discontinue use or avoid use if a person is exposed to a harmful chemical. They should be inspected annually, and should have a tag that indicates the last annual inspection date. Generally you should stay under the shower, removing clothing as necessary, for at least fifteen minutes, but an SDS or label may indicate a longer duration. Obtain location-specific training on use as many different models are present on campus, and knowing the closest location is important when one is exposed to a harmful chemical. Eyewash stations can be stand-alone units, self-contained units, or other configurations. They can irrigate the eyes, or the eyes and face depending on the design. They must be tested weekly by simply allowing them to run for a few minutes to assure that fresh (not stagnant) water is present in the pipes. They may or may not be plumbed for drainage, but just like the safety showers this should never be a deterrent. Flush your eyes for five minutes, or as long as the SDS indicates, whichever is longer. Remove your contact lenses (which you should not wear if you are working around harmful chemicals). Just like the safety shower, you’ll need location-specific training for eyewash stations.

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Fire blankets may be used to put out fires, but only if it is part of your assigned duties and you have received training on how to safely do so. If you haven’t received training, they should only be used when necessary to put out fires on personnel. They should be NFPA-rated and may require servicing, inspection, or replacement according to the manufacturer’s specification. They’re usually shipped folded for quick release, and may not work well if they aren’t replaced according to the manufacturer specification. Spill kits are specific to the materials making up the spill as well as the size of the spill. This should be covered in training for anyone required to use the spill kit. There may also be requirements for its upkeep like replacing certain chemicals periodically, this would also be covered in training. Untrained users, or those experiencing a spill outside of the limitations of their spill kit should contact EHLS or UH Police immediately for assistance. All uses of the kit should be reported to EHLS for removal of the material as well as to maintain data on near misses. First aid kits may be general kits purchased as-is, or may be tailored as necessary to the specific needs of an area. If an assignment requires an individual to provide first aid to others they should receive appropriate training. Use of first aid kits in an incidental manner by bystanders or other workers does not require training (but it wouldn’t hurt). Kits or items may expire, and should be regularly inspected. Always keep the areas around these items clear. Emergencies always happen at the least-convenient time.

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Whenever an emergency or near-miss happens, you have a duty to notify the University. Notify EHLS for spills during university business hours by phone, or after-hours by contacting UH Police for on-call service. If an injury is involved, file a First Report of Injury with Risk Management. For near-misses and other incidents that may not require an immediate response, you can also report by email (but reporting is still mandatory).

In the event of an emergency, contact UH Police directly, they will work with EHLS and other first responders such as Houston Fire Department.

Finally, if an accident involves property damage, contact Risk Management.

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Generally speaking, everything has a place when it isn’t being used. We’ll refer to this as storage. When it comes to storing harmful chemicals and chemical products, materials that may be harmful, and equipment that may be harmful or contain harmful chemicals there are certain precautions that must be taken. Take care to segregate incompatible items. You can see a container of sodium hydroxide drain cleaner next to a container of nitric acid for water quality testing. You can also see a container of hydrochloric acid, designed to vent to relieve overpressure that isn’t properly segregated from a metal container- yes, container compatibility matters for proper segregation. Here is an excerpt from a general chemical incompatibility chart, it should be augmented with knowledge from safety data sheets and other resources. Your workplace should already have a plan for the proper storage of each item there, consult your supervisor when adding new or different items- an ideal time is when you update your chemical inventory. Some materials may expire. In many cases, this means that it is no longer certified to be as good at its intended purpose, however in some cases it can also mean that the degraded material can be hazardous. You can see a container of picric acid, which had dried around the cap thread, presenting an explosive hazard if a worker tried to open it, and a can of diethyl ether that had expired and had to be opened remotely in case explosive peroxide crystals had formed inside. Manufacturers generally provide this information, however

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EHLS also assists with identifying these chemicals when they are submitted as part of the chemical inventory. Chemicals being stored must be labeled appropriately and must be in compatible containers. Here you can see a container of hazardous waste that had produced hydrochloric acid from an unintended reaction of the waste. It has corroded the container in a line where the acid had stratified while accumulating. You also see a container that was later determined to be zinc phosphide, pay special attention to the warning: “Danger! May ignite spontaneously with air, especially when damp…”Some areas simply are inappropriate for storage in general- egress routes, corridors, shelves above eye level, and fume hoods. These spaces are kept empty for a reason when they aren’t being used for their intended purpose. Others areas like flammable safety cabinets and corrosives cabinets are ideal, but many require specialized equipment rated for the hazard like flammable storage refrigerators. Flammable storage cabinets are great for flammable and combustible materials, acid cabinets are great for acids or caustics as long as proper segregation can be practiced. Shelves, storage closets, and cabinets are great for non-hazardous items. Gas cylinder racks are great for gas cylinders, and propane cylinders have their own version that must be outdoors when not in use. Never store things in corridors, especially whent hey could pose a hazard or just get in the way during emergencies. Don’t store items too close to the ceiling, this will vary by building-your supervisor can find out from UH Fire Marshal if they don’t already know. Don’t store harmful chemicals above eye-leve or in fume hoods- splashing and spills are more dangerous at heights, and fume hoods are for reactions and work, storing materials in there places them in the way of a hazardous reaction. Don’t store flammable materials inside normal refrigerators (there are special kinds just for this) and don’t commingle food storage and anything that is not for use with food. Depending on the construction of a building, a room, its height above- or below-ground, there are likely limits to the quantity of materials stored. You can see that for instance there is no flammable material storage below the first floor, and after the seventh floor of a building, even with the best-built construction, a 1,000 sq ft laboratory could hold a maximum of 10 gallons of flammable liquid in storage and use. Consider equipment containing harmful material for storage the same way you would the chemical itself, accounting for any changes in the type of container. Mercury thermometers should be stored just like a fragile container of elemental mercury. Consult your supervisor to better understand all of these restrictions and your location’s plan for storage.

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Believe it or not, many of us will have a roll in transporting, shipping, and moving materials, some of which could be harmful. Always use secondary containment when transporting chemicals and chemical products. You can see secondary containment trays, and even a bucket can be used for this purpose. When possible, use carts with side rails or trays to prevent accidents. Not only does this prevent you having to carry heavy items, it also helps to reduce the chance of spills or loss of materials. Some workplaces may designate a cart for this to prevent contamination. Never transport harmful chemicals or chemical products in personally-owned vehicles, even in small quantities. There can be tremendous fines involved for the improper transportation of some materials. Transporting them un university vehicles will require coordination with EHLS and your supervisor among other parties to determine the best course of action. Shipping chemicals, chemical products, and even some devices (containing some kinds of batteries, harmful chemicals, or other substances) requires additional training on top of the coordination with your supervisor and EHLS. Yes, the pictured trash container, is considered shipping when it is sent to the landfill, so be careful with harmful chemicals.

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Waste can be regulated in a number of ways, from normal refuse like candy wrappers to radioactive or hazardous chemical wastes. For the most part, workplaces deal with satellite accumulation, which is where (in a workplace) you collect hazardous waste (or wastes you’re uncertain about) until they are removed by trained personnel. Laboratory accumulation is a special kind of satellite accumulation- hazardous waste labels are replaced by “unwanted materials” labels, and the rules are slightly different. Universal waste accumulation is for certain really-common wastes, specifically paint and paint related waste, some batteries, lamps or “bulbs” and mercury containing devices like thermostats, switches, and thermometers. It is only used under certain conditions. Equipment that has come into contact with harmful chemicals or other hazards, or that has components that may be hazardous or harmful may require decontamination or disinfection prior to disposal. Biomedical waste (outside of labs) is generally sharps (used or unused) and blood and/or other potentially-infectious materialUsed oil has its own special rules, as doSome other regulated materials such as antifreeze, silica, and solid corrosives. All of these require additional training to dispose of (or in many cases to work in a way that would create such waste products). If you’re confused, EHLS is here to help with training and support.

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Handwashing is an important part of safety inside and outside of the workplace. Wash hands frequently before eating, drinking, applying cosmetics, taking medication, or putting them near your mouth, nose, eyes, or other places that could facilitate transmission of disease or exposure to chemicals. Wash hands after contact with hazardous chemicals, chemical products, objects or equipment that may come into contact with or contain hazardous chemicals, after touching other people, human blood, or other potentially-infectious material. Wash your hands even if you’re uncertain that you’ve had that kind of contact, or whenever you just feel like it too. Washing hands helps prevent ingestion or absorption of chemicals as well as exposure to germs. Please enjoy this excerpt from the video, “Fight Germs. Wash Your Hands!” produced by the Centers for Disease Control and Prevention.

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You have responsibilities too, just like those above you in the organizational hierarchy. Be aware of hazards, policies, and procedures in the workplace. Wear proper attire and all personal protective equipment as required. Follow instructions, policies, and procedures. Report any safety or environmental concerns not resolved by your supervisory chain. Complete all required training, and if additional training is required, notify your supervisor before beginning work. Ask questions whenever you’re unsure. Do you have any questions now?

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