This chapter outlines some of the basic regulations that govern laboratory safety, services offered by EHS, how to report injuries and incidents, laboratory self-inspections, and how to respond to fires and chemical spills.

This chapter outlines the responsibilities for laboratory safety and health that are borne and/or shared by the Principal Investigator, laboratory personnel, the academic department that houses your research group, and EHS. This chapter also describes the EHS Collaborative Laboratory Inspection Program (CLIP), key compliance issues that arise from laboratory inspections, and enforcement policies for non-compliance.

The University of North Carolina at Chapel Hill (UNC) is committed to providing a safe and healthful environment for all persons associated with the institution, including staff, students, visitors, and the community. Personnel conduct a vast array of research utilizing hazardous materials on the campus. Cooperation of all parties involved is required to ensure that the University conducts research safely with regard to workers, the community, and the environment. Environment, Health and Safety (EHS) has administrative responsibility for assisting laboratory personnel in developing safe work practices and for compliance with federal, state, and local regulations.
The Occupational Safety and Health Administration (OSHA) administers the workplace safety and health regulations in the United States. The OSHA regulation entitled “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450, commonly referred to as the “Laboratory Standard”) supersedes most general industry health standards for UNC laboratories. The Laboratory Standard requires the development of a “Chemical Hygiene Plan” which states how the University will implement the requirements of the Laboratory Standard to provide a safe and healthful work environment for its employees. The Laboratory Standard provides additional recommendations in its non-mandatory appendices extracted from Prudent Practices in the Laboratory: Handling and Disposal of Chemicals. OSHA cites this book because members of the laboratory community prepared it through sponsorship of the National Research Council, and it is widely distributed and accepted.

Although the Laboratory Standard provides some compliance flexibility, the Chemical Hygiene Plan must address specific areas. These areas include exposure monitoring, employee information and training, medical consultations and examinations, hazard identification, use of personal protective equipment, and recordkeeping.

To comply with the Laboratory Standard, your lab must have access to this Laboratory Safety Manual within the lab space, as well as a Laboratory Safety Plan that is specific for your lab operations. Chapter 2 provides detailed instructions for creating a Laboratory Safety Plan. The Laboratory Safety Plan plus the Laboratory Safety Manual equals the Chemical Hygiene Plan required by OSHA.

Though the University of North Carolina at Chapel Hill is committed to providing a safe and healthful environment for all persons associated with the institution, this cannot occur unilaterally. A top-down approach to safety and health is ultimately less likely to succeed than a cooperative effort from all affected parties. This chapter details the responsibilities that help ensure this necessary cooperation occurs. Your cooperation is also required to ensure that UNC-Chapel Hill stays compliant with applicable federal, state, and local regulations related to safety and health in the workplace environment and the natural environment.
Principal Investigators, laboratory personnel, your department, and EHS all share responsibility for laboratory safety. Specific duties of each include the following:
  1. Ensure the department’s compliance with health and safety standards.
  2. Provide timely notification to EHS upon termination of faculty who used hazardous materials, to expedite clearance of the laboratory for the next investigator.
  3. Consider appointment of a safety committee from a cross-section of the department’s employees to address departmental safety concerns.
  1. Prepare a Laboratory Safety Plan (LSP) as described in Chapter 2, to complement the Laboratory Safety Manual (LSM). These documents constitute your Chemical Hygiene Plan as required by OSHA.
  2. Ensure that laboratory personnel meet the training requirements of the Laboratory Standard, including chemical hazard information, safety rules and good work practices.
  3. Provide initial training to laboratory personnel, upon employment, on the contents of the Chemical Hygiene Plan. Employees document this training through the online Lab Safety Plan application.
  4. Provide annual training to all laboratory employees on the contents of the Chemical Hygiene Plan. Employees document this training through the online Lab Safety Plan application.
  5. Ensure that staff and visitors observe safety rules and don proper Personal Protective Equipment (PPE) when working in or visiting the laboratory.
  6. Ensure that proper safety supplies and equipment, such as gloves, safety glasses and/or goggles, lab coats, and respirators* are available for all people in the laboratory. *Note: if respirators are required, the PI is also responsible for the cost of medical and/or pulmonary function tests that may be required for respirator use.
  7. Obtain safety data sheets (formerly known as material safety data sheets) for hazardous chemicals used in the laboratory and make these available to the laboratory staff.
  8. Post appropriate hazard information signs within the laboratory.
  9. Provide information to EHS in a timely manner so that it may post appropriate signage at laboratory entrances.
  10. Conduct an “exit interview” with laboratory workers prior to their departure to ensure that they have properly labeled and prepared hazardous materials for disposal by EHS or use by other workers.
  11. Notify EHS prior to vacating laboratory space when moving on campus and notify department chair and EHS of planned departure from UNC or discontinuance of the use of hazardous materials. Decontaminate laboratory surfaces and prepare hazardous materials for disposal by EHS or use by other laboratories. Refer to EHS guidelines on vacating laboratory space.
  1. Study the Laboratory Safety Plan, the chapters of the Laboratory Safety Manual relevant to your research, and other information provided by your supervisor.
  2. Complete appropriate training and orientation programs provided by EHS.
  3. Complete and submit a Laboratory/Radiation Worker Registration Form to EHS whenever there is a change in work location or laboratory assignment. See Appendix 1-A for instructions on how to fill out this form.
  4. Follow safety guidelines when handling hazardous materials, including the proper use of personal protective equipment.
  5. Notify EHS of accidents, spills, or conditions that may warrant further investigation and/or monitoring.
  6. Review laboratory materials to ensure that you have properly labeled and prepared all hazardous materials for disposal by EHS or use by other workers before you leave the research group.
  1. Provide training and orientation programs for laboratory personnel.
  2. Inspect laboratories regularly for safety and health hazards and for compliance with state and federal regulations.
  3. Investigate potential safety and health hazards identified by laboratory employees.
  4. Monitor personnel for over-exposures to chemical, biological, physical, and radioactive hazards.
  5. Advise laboratory personnel on proper disposal of waste chemicals and other hazardous materials.
  6. Consult with faculty, staff, students, and departmental safety committees on safety matters.
  7. Assist safety committees in organizing committee meetings.
  8. Post appropriate signage at laboratory entrances.
As one of its key responsibilities, EHS is required to inspect all research groups at least annually. To maximize program effectiveness, EHS developed the Collaborative Laboratory Inspection Program (CLIP), which includes three types of inspections: key-indicator reviews, referral inspections, and announced inspections. EHS personnel perform the key-indicator reviews annually and unannounced to get a snapshot of laboratory safety and compliance. EHS presumes that if a research group complies with the items on the key-indicator list, it has an effective safety program in place. Referral inspections are used to follow-up on issues when key-indicator reviews identify significant non-compliance or unsafe and unhealthy conditions. EHS conducts announced inspections to “audit” specific items, such as inventories of radioactive materials.

EHS sends inspection reports to the Principal Investigator within two weeks of the laboratory inspection. Principal Investigators are to correct all non-compliant issues or unsafe or unhealthy conditions identified during the inspections in a timely manner. Some citation items will require a written response in which the PI is required to outline what he or she did to correct the variances and what steps he or she will take to prevent a recurrence. The written response is due within two weeks of the date of the inspection report.

If EHS does not receive a written response within two weeks of that date, EHS will deem the laboratory noncompliant. The Chemical Hygiene Officer will send a follow-up report to the laboratory. If the violation involves radioactive materials or radiation producing devices, the Radiation Safety Section will handle the notifications, in accordance with Radiation Safety Committee procedures. EHS will suspend ordering privileges for radioactive materials for laboratories that do not respond within two weeks.

EHS gives an assessment grade based on the laboratory safety inspection results. EHS also gives laboratories authorized to use radioactive materials an assessment grade based on radiation safety inspection results. The assessment grades are Outstanding, Good, Fair, and Unacceptable. The assessment grade is calculated by the number of violations, the violation type, and/or if the violation was a repeat.

A. Compliance Issues

The health and safety of workers and building occupants is the most important factor to consider in laboratory work. In addition to these health and safety concerns, compliance with OSHA, Radiation Protection, and EPA regulations is also important because of the severe financial consequences, especially related to EPA hazardous waste regulations. Fines for seemingly minor violations, e.g., improper labeling, lids not screwed-on tight, etc., may run into the tens of thousands of dollars; therefore compliance with these regulations must receive special attention.

B. Safety Standards

Sources of health and safety standards and key compliance issues include:

Standard Key Compliance Issues
OSHA Laboratory Standard Laboratory Safety Plan, training of staff, SDSs, emergency plan, secure compressed gas cylinders, outdated peroxide-formers
EPA/State Hazardous Waste regulations Lids, labels, mixing incompatibles, secondary containment, location
Radiation Protection regulations Radiation source control, dose limits, waste, training, personnel monitoring, labeling, and hazard information signs
Fire/Life Safety Codes 10-gallon open storage flammables limit, clear laboratory egress, hallway storage
Biological Safety, Security, and rDNA Biological agents and toxins use practices, containment, facilities, management and security.
University policies Training, prevention of injuries, personnel policies, grant proposal review
Consensus standards of good laboratory practice Hazardous material inventory minimization and storage compatibility, housekeeping, appropriate attire, food and drink within designated area

C. Violation Severity Classifications

The University uses the following categories of violations:

Imminent danger
A process, action, or condition where there is reasonable certainty a hazard exists in a UNC laboratory that can be expected to cause serious physical harm.
Serious violation
A process, action, or condition in a UNC laboratory that will probably lead to physical harm or significant exposure to biological or physical agents or violates regulatory standards (e.g. hazardous waste container management).
Non-serious violation
A process, action, or condition that has a direct relationship to health and safety in a UNC laboratory but probably would not cause serious physical harm significant exposure to biological or physical agents. Related non-serious violations may result in a serious violation where in combination they present a substantial probability of exposure, injury, or physical harm.
Documentation
Required UNC laboratory EHS documentation has not been completed, updated, submitted, and/or retained.

A comprehensive list of University citations based on the key indicators is on the EHS website.

D. Enforcement Policies

Imminent danger

EHS notifies laboratory personnel to cease operations immediately and close the laboratory, then notifies the EHS Director who in turn notifies the department head of the affected PI to request assistance in abatement of the problem. The EHS Director also notifies the Associate Vice Chancellor for Energy, Environment, Health and Campus Safety to secure the area if necessary. EHS will perform follow-up inspections to ensure compliance.

Serious violation

EHS notifies laboratory personnel and PI, if available, of the violation and sets a deadline for abatement, and may recommend that the PI shut down the operation until abated. Follow-up notification, in writing, goes to the PI and safety supervisor. EHS will perform follow-up inspections to ensure compliance if appropriate.

If EHS observes instances of noncompliance with hazardous waste container management regulations, ALL laboratory personnel, including Principal Investigators, will be required to complete an online “Hazardous Waste Refresher” training course. All lab members must complete the training course within two weeks of the laboratory safety inspection report date. If not all lab personnel complete the training within two weeks, EHS will act in accordance with the University Enforcement Policy, which requires consultation with the EHS Chemical Hygiene Officer. EHS will conduct a follow-up hazardous waste inspection in three months to verify that compliance with the regulations is being maintained.

Non-serious violation

EHS notifies laboratory personnel of the violation and requests abatement as soon as practicable. EHS sends follow-up notification in writing to the PI. EHS sends a summary report of all inspected PIs to respective department heads annually.

Documentation violations

EHS notifies laboratory personnel of the violation and requests abatement as soon as practicable. EHS sends follow-up notification in writing to the PI. EHS sends a summary report of all inspected PIs to respective department heads annually.

E. Notification of Granting Agencies

For some laboratories, EHS has signed a “Certificate of Environmental and Safety Compliance”, a requirement for some granting agencies. This certification requires EHS to notify the granting agency if that laboratory is in violation of any applicable environmental or safety law or regulation.

F. Reports to Department Heads and Laboratory and Chemical Safety Committee

EHS will send annual reports to the department head summarizing inspection activities within his or her department. The reports will list the non-serious, serious, imminent danger, and documentation violations for each PI and render a general assessment of Outstanding, Good, Fair, or Unacceptable. EHS will also report these findings at meetings of the Laboratory and Chemical Safety and Radiation Safety Committees, as appropriate.

Many factors can contribute to establishing a safer laboratory environment. The chapters of this Manual outline several of them. The most important of these factors is you.

Most laboratory injuries and incidents are not the result of “someone else’s actions,” though of course the exceptions can be dramatic. Most injuries and incidents involve the laboratory worker who is directly working with the apparatus, chemical, needle, animal, etc. Therefore, the most important way for you to have a safer laboratory environment is to perform all your tasks in the safest manner possible.

The resources in this Manual plus other guidebooks such as Prudent Practices in the Laboratory: Handling and Disposal of Chemicals (National Academy Press) and the American Chemical Society’s Safety in Academic Chemistry Laboratories can guide you in how to do your laboratory work safely. Please contact EHS at 919-962-5507 if you have any questions or concerns about laboratory safety, the contents of this Manual, or suggestions for improving laboratory safety.

Figure 1.1
Figure 1.1

Several factors, many of them unintentional, can affect laboratory safety. Hazards can emerge due to complacency and familiarity, tediousness, or distraction. The requirements and recommendations of this manual and the Laboratory Safety Plan will not fully protect you unless you exercise diligence in your daily work, or at least stop periodically to assess your environment.

Step back and look carefully at your laboratory environment, looking at it as a first-time visitor would. Does it look safe, neat, and orderly? Are chemicals stored properly? Are you and other personnel taking appropriate precautions? Can you see ways to make the lab safer? You are strongly encouraged to conduct at least an annual (and preferably more frequent) assessment of your laboratory’s safety practices. Appendix 1-D at the end of this Chapter is a laboratory self-audit form that can assist with this. The items on this checklist are some of the most frequent causes of preventable laboratory accidents, and frequently cited by EHS during lab inspections. Contact EHS with any special concerns that arise from these self-audits, and repeat audits frequently in order to track whether your lab is making improvements.

When you stop to look closely at your lab environment, what potential hazards do you see? Use the self-inspection checklist (Appendix 1-D) for periodic assessments.

The Occupational Safety and Health Act of North Carolina makes provisions for employees to request an inspection or evaluation of conditions that they believe may constitute a health or safety hazard. University employees are encouraged to report such conditions to EHS and to request a special investigation into the need for corrective action. University employees who are aware of a health hazard or unsafe condition should notify EHS, 1120 Estes Drive Extension, CB #1650 or call 919-962-5507. Persons requesting an inspection by EHS (or the Department of Labor) may request confidentiality, and by law, their name will not appear on any record published, released, or made available to the public, their immediate supervisor, or department head.

UNC also offers a resource called the Compliance Line. The Compliance Line is an option for making confidential reports using either the internet or a telephone line, to report compliance concerns about EHS issues. You can also use this resource for concerns related to finances, research, or HIPAA (the Health Insurance Portability and Accountability Act). This resource is not maintained on UNC’s systems, or by UNC employees. EthicsPoint, based in Portland, Oregon, is the commercial service provider for the Compliance Line. You can file reports anonymously, and the reports are held securely and confidentially on the external systems. When you access The Compliance Line on the Internet click on “File a New Report or Follow-up on a Report”. Compliance Line telephone access: 1-866-294-8688.

After EHS has concluded its investigation, results are communicated, in writing, to the party requesting the investigation and other appropriate University personnel, with due consideration to anonymity requests. EHS will initiate corrective action if there are reasonable grounds to believe that a violation or danger exists. If EHS cannot implement corrective action within a reasonable period, EHS may terminate the operations pending corrective action.

The greatest potential for over-exposure generally occurs during transfer operations involving concentrated chemicals. Conduct these operations in a laboratory chemical hood to minimize the potential for over-exposure. Refer to Chapter 17: Laboratory Hoods for more information.

EHS will perform monitoring upon request, or if there is reason to believe that exposure levels for a substance routinely exceed the OSHA-defined Permissible Exposure Limit (PEL) or action level. Any employee may request monitoring and be notified of the results, in writing, within 15 days of the receipt of the results. To file a formal request for monitoring, complete Appendix 1-B and send, or deliver, to EHS. EHS also responds to telephone requests for evaluation of exposure to chemicals and provides monitoring if appropriate.

Report all personal injuries and accidents that occur on the job to EHS. EHS may take corrective action to minimize the probability of recurrences in your lab and others. Types of injuries may include animal bites, needle sticks, cuts from broken glass, exposure to biological agents, etc. Fill out the Employee Incident Report Form and send to EHS.

Send formal reports of accidents, injuries, or occupational illnesses to students, staff, faculty and visitors while on University property, or in the course of University employment or activity, to EHS on the Industrial Commission Form 19. Report accidents resulting in death or hospitalization to the Director of EHS immediately. Report accidents resulting in lost work time to EHS (919-962-5507) as soon as practicable during regular work hours (8:00 a.m. to 5:00 p.m. Monday-Friday).

It is your responsibility to notify your supervisor immediately of any job-related injury or illness. If unable to do so, a co-worker should notify your supervisor as soon as possible.

Supervisors must ensure that employees receive prompt treatment of the injury by obtaining first aid or assistance to medical treatment. If the treatment requires more than first aid, the supervisor or another person must accompany the injured person en route to treatment; do not send injured employees unescorted to seek medical attention. Take the injured employee to the University Employee Occupational Health Clinic (UEOHC) located on the second floor of 141 N. Medical Dr. Students who are also employees, such as graduate students doing research and work-study students, should go to the UEOHC to seek treatment for a work-related illness or injury. Students who do not have a work-related illness or injury should go to the UNC Campus Health Service. For severe or life-threatening injuries, go to the UNC Hospitals Emergency Room, located at the N.C. Neurosciences Hospital.

Figure 1.2
Figure 1.2
Campus map showing health care locations in case of injury:

  1. Campus Health Services (formerly Student Health)
  2. UNC Hospitals Emergency Department
  3. University Employee Occupational Health Clinic
If you work with hazardous chemicals, UNC will provide the opportunity for medical consultations and/or medical examinations. Complete the “Request” form, Appendix 1-C, and mail or deliver to EHS under the following circumstances:

  • You develop signs or symptoms associated with a hazardous chemical to which you might have been exposed in the laboratory
  • Exposure monitoring reveals an exposure level routinely above the Permissible Exposure Limit (PEL) or action level, if applicable, for an OSHA regulated substance, as prescribed by the regulations for the particular substance
  • An exposure to a hazardous chemical is likely because of a spill, leak, explosion, or other release

The UEOHC will provide you with consultation/examination as soon as practicable following notification and a written opinion to you and EHS that includes:

  • Recommendations for follow-up
  • The results of the examination and any associated tests
  • Any revealed medical conditions that may place you at increased risk
  • A statement that UEOHC consulted you on medical conditions that may require further examination or treatment. The written report will not reveal medical findings unrelated to occupational exposure
The Laboratory Standard requires that your employer advise you of chemical hazards at the time of initial assignment, and whenever new exposure situations occur. This information must cover:

  • The contents of the Laboratory Standard
  • The location and availability of the chemical hygiene plan
  • The PELs of OSHA regulated substances and recommended exposure limits to non-regulated substances
  • Physical and health hazards of chemicals in the workplace
  • The signs and symptoms associated with exposures to hazardous chemicals used
  • The location and availability of known reference material, including safety data sheets (formerly material safety data sheets), on the hazards, safe handling, storage, and disposal of hazardous chemicals
  • Measures employees can take to protect themselves, including emergency procedures and personal protective equipment

EHS provides periodic safety orientations on the Laboratory Standard and general chemical safety. Laboratory Standard training is also available online, as are several other training modules. Successful completion of the Laboratory Safety/Managing Hazardous Waste course (either in person or online) is required of all laboratory employees to meet a portion of the Laboratory Standard’s training requirement.

If you do not receive an Safety Data Sheets (formerly Material Safety Data Sheets) with the chemicals you purchase, you can:

  1. contact the chemical manufacturer
  2. contact EHS
  3. visit the EHS website for several online SDS resources

The University subscribes to the Canadian Centre for Occupational Health & Safety SDS database, which includes over 200,000 continuously updated SDSs. This site is accessible from any computer connected to the UNC TCP/IP network and is linked from the EHS Chemical Safety Page. The EHS Chemical Safety and Workplace Safety web pages contain additional SDS resources that are accessible off the UNC network.

OSHA regulations require maintenance of monitoring and medical records for a period of thirty years following termination of employment. The records that EHS maintain include:

  • Copies of Laboratory Safety Plans
  • Laboratory worker biographical data and laboratories in which they work (PI and dates)
  • Monitoring results
  • Medical examination and consultation records
  • Reports and investigations of accidents in laboratories
It is the responsibility of each laboratory unit to establish emergency plans in the events of fire, chemical spills or other emergencies resulting from accidents within their laboratories. You also need to be familiar with the emergency plans and evacuation routes for your building. Plans may vary slightly, depending on the design of the building, but generally will incorporate the following features:

Purpose

How you react in the event of fire depends on how well you have prepared for a fire emergency. Therefore, departments should ensure that all employees are familiar with the procedure to follow in the event of an emergency as outlined in the University’s Emergency Plan.

Procedure to Follow

Departments that need a special fire emergency procedure due to unique operations should contact the Fire Safety Section for assistance. Most departments can follow the basic building evacuation procedure outlined below.
In the event of an alarm, remember RACE.

  • R: Remove anyone from immediate danger
  • A: Activate the building fire alarm system and call 911.
  • C: Confine the fire by closing all windows and doors.
  • E: Evacuate and leave the building.

Extinguish the fire, if you can do it safely and have received training from EHS. You are NOT required to use fire extinguishers; however, you are required to receive fire extinguisher training from EHS if you want to use fire extinguishers in the event of an incipient-stage fire in your lab. See Chapter 10: Fire Safety for more information.

How to Survive a Building Fire

  • Crawl, if there is smoke.
  • Feel doors before opening.
  • Go to the nearest exit.
  • Always use an exit stair, not an elevator.
  • Close doors.
  • Use a fire extinguisher if the fire is very small and you know how to use it safely.
  • If you are on fire – Stop, Drop and Roll.
  • If you get trapped:
    • Close the door.
    • Seal cracks.
    • Open the windows if safe.
    • Signal for help and phone 911.
    • Do not jump.
    • The fire department will reach you.

If You are Physically Impaired

If you are disabled (even temporarily), you should do the following:

  • Learn about fire safety.
  • Plan for fire emergencies.
  • Be aware of your own capabilities and limitations.

Look for “areas of refuge” like stair enclosures or other side of corridor fire doors. Elevators are not safe during fires. Sometimes it may be safer to stay in your room. If there is an immediate threat to safety, ask others near you for assistance. If no help is available, seek refuge in a room with a window or stairway. If possible, call 911 to report your location and receive instructions from the Emergency Operator.

Many laboratory spills are of limited hazard potential, and laboratory personnel can clean up safely. Your laboratory should be equipped to handle small low-hazard spills. You should call EHS (919-962-5507) if a spill situation involves any of the following:

  • a respiratory hazard
  • a threat of fire or explosion
  • more than 100 mL of an OSHA regulated chemical carcinogen or a highly toxic chemical
    (see appendices to Chapter 7)
  • more than 1 liter of a volatile or flammable solvent
  • more than 1 liter of a corrosive (acid or base) liquid
  • elemental (liquid) mercury spills; refer to section C below

Chemical Spill Response Kit

Your laboratory should be equipped with protective clothing and spill cleanup materials to respond to small low-hazard chemical spills. Specialized chemical and corrosives spill kits are commercially available. In addition, you may obtain these materials to make your own spill kit.

Description

  • 1 Pail, Plastic, 2.5 Gallon
  • 2 Oil Dri, Bentonite Clay, 5LB Bag
  • 2 Plastic Bags, Black, 3ml 23x20x48
  • 1 Dust Pan with Brush, Polypropylene
  • 4 Bags, Zip-lock
  • 1 Pair Disposable, Nitrile Gloves (Large)
  • 2 Tags with Ties for Bags
  • 2 Pairs of Shoe Covers, Disposable Tyvek
  • 1 Label (sticker) “Chemical Spill Kit” for bucket
  • 1 Sign “Spill Area – Keep Out”
  • 1 Instruction sheet “Clean up of Laboratory Spills”
  • 1 Pair Safety Goggles
  • 2 Pair Gloves Neoprene 11″, Long
  • 2 Coveralls Tyvek®, Large

Response Steps for Chemical Spills

Step 1: Leave and Control Spill Area

  • Evacuate personnel from the immediate spill area.
  • Block off immediate spill area – close corridor doors, use lab carts, wastebaskets, etc.
  • Eliminate any fire hazard, especially if spill is flammable or combustible- turn off burners, electrical equipment, etc.
  • Post sign, “Spill Area – Keep Out”.
  • Alert other personnel in laboratory and adjacent areas of a chemical spill including the PI or Instructor.

Step 2: Help Injured Personnel

Take care of injured personnel- move from spill, remove contaminated clothing, flush skin with water, use eyewash and/or safety shower, etc. If there is a chemical splash to the eyes and/or there are burns or respiratory problems, seek medical attention.

Step 3: Evaluate Hazard

Make preliminary evaluation of hazard and identification of risks and decide whether you should call EHS. If it can be handled without respiratory protection, continue with clean up.

Step 4: Clean Up Spill

  • Contain the spill using absorbent clay to stop spill from spreading under refrigerators, cabinets, equipment, drains, or corridors. Then spread clay around the perimeter, damming the spill.
  • Use the clay to absorb the rest of the liquid.
  • Scoop the clay/absorbed chemical mixture into a plastic pail lined with a plastic bag.
  • Seal plastic bag and containerize for disposal.
  • Wash and deactivate the spill surfaces of trace amounts of the spilled chemical. Contact EHS for advice.
  • Fill out Electronic Hazardous Material Pick-Up Request for collected spill material or call EHS for disposal instructions.
  • Replace used materials in spill kit.

Step 5: Review Incident

Review incident to prevent further spills and improve response procedures.

Mercury pollution is one of the most significant environmental toxins found in the United States. The Environmental Protection Agency (EPA) and a variety of public health organizations have identified mercury elimination as one of their highest priorities in recent years. Over an eight-year period (2001-2008), roughly seventy percent of chemical spill- response/clean-up has involved mercury. As a result, University personnel involved in the remediation of mercury spills expend a significant amount of resources each year. In addition, improper disposal and/or unrecognized or unreported releases of mercury are a threat to the community and can lead to significant regulatory consequences for the University. As a generator of hazardous chemical waste, UNC Chapel Hill has an obligation under federal and state regulations and to the community to reduce the volume and quantity of mercury waste generated on campus. The University recognizes the threat presented by mercury and is committed to the reduction/elimination of mercury on campus.

Principal Investigators and laboratory Safety Supervisors are responsible for identifying mercury containing devices in their laboratory that should be eliminated. Departments are responsible for providing sufficient resources to provide alternatives and implement reduction/elimination of mercury from departmental laboratories. The Department of Environment, Health and Safety (EHS) is responsible for properly disposing of mercury waste from laboratories and educating the campus about alternatives.

Campus laboratories were to eliminate all non-essential uses of elemental mercury by December 31, 2009. EHS defines “Essential Use” as a circumstance where no acceptable alternative for the current use can be located or where it is found that implementation of an alternative would create a significant long-term financial hardship to the department or research project. Laboratories wishing to maintain inventories of mercury can request an exception via EHS. In the event of a disagreement over the requested exception, the Laboratory and Chemical Safety Committee will review and make a decision regarding the request. EHS works in a cooperative fashion with any department found to have an unusually large inventory of mercury-based items to allow phase-ins of alternatives. Examples of laboratory devices that contain elemental mercury include, but are not limited to thermometers, barometers, and manometers. Mercury waste being eliminated should be referred to EHS for proper disposal.

EHS began citing mercury reduction/ elimination non-compliance during Collaborative Laboratory Inspection Program (CLIP) inspections in 2010.

EHS and the Laboratory and Chemical Safety Committee will serve as technical resources for the implementation of this program. EHS will also serve to oversee the development and implementation of mercury educational materials.

Figure 1.3
Figure 1.3 Mercury spill kit. Contents include mercury-absorbing sponges, amalgamating powder, and containment bags.

If your lab uses any devices that contain liquid elemental mercury, such as thermometers, manometers, or sphygmomanometers, you must have a small mercury spill kit available to contain the spill. The example to the right (Figure 1.3) is available from Fisher Scientific, catalog #19021910. Use the contents of the mercury spill kit for initial containment.

Contact EHS for assistance during or immediately after completing initial containment. Prior to EHS arrival, seal off the immediate spill area so that no one can walk on spilled mercury.

Some spills may be more hazardous and laboratory personnel should not attempt clean up. As stated earlier, call EHS if the spill is more than 100 mL of an OSHA regulated chemical carcinogen or a highly toxic chemical; more than 1 liter of a volatile or flammable solvent; or, more than 1 liter of a corrosive (acid or base) liquid. In such cases, evacuate the room and call EHS immediately.

These more hazardous spills may only involve the EHS HazMatTeam, or the UNC Emergency Response Plan might need to be activated which involves the Chapel Hill Fire Department, UNC Public Safety, local hazmat teams, and North Carolina Regional Response Team #4. In the event of major uncontrolled incidents such as fire, major releases of hazardous chemicals to the environment, or life threatening injuries, call 911 immediately.

Communication between the laboratory, department, EHS, and other response personnel is very important. The Principal Investigator and other laboratory personnel who know the hazardous materials involved and/or the particular circumstances of the accident must be present at the incident command site. Obtain safety data sheets for the chemicals involved to bring to the incident command site.

Appendix 1-A: Completing the Laboratory/Radiation Worker Registration Form

The Laboratory/Radiation Worker Registration Form is required for all personnel who work in a laboratory environment, regardless of whether they actually handle hazardous materials.

The Form can be completed and submitted online. Follow the instructions below to fill out the form.

If you have an ONYEN and password, use these to login. If you do not have an ONYEN and password, or cannot remember it, click on the indicated field to log on with your PID and date of birth.
If you do not have an existing form in the system, the next screen will ask you for the type of registration sought: Laboratory Only, Laboratory and Radiation, or Radiation Only. Choose the registration option corresponding to your anticipated work within UNC laboratories or UNC Hospitals.
If you already have a form in the system, you are taken to the Registration Menu screen after login.

  • Select VIEW to view and/or print your current registration information.
  • If you wish to edit the information on your current registration, select EDIT. After confirming your choice, you go to the Registration Type screen described above*.
  • To delete your current registration form, select DELETE. This places a request to EHS for deletion.
  • To enter a new registration (with a different Principal Investigator), select either TRANSFER PI or NEW REGISTRATION FORM. Both of these choices lead to the Registration Type screen*.

*Though three different fields (Edit, Transfer PI, and New Registration Form) lead to the Registration Type screen and the subsequent Demographic Information screen described below, you cannot change the Principal Investigator field in the Demographic Information screen if you choose Edit. This can only be changed by selecting Transfer PI or New Registration Form in the Registration Menu.

  • Employer: Select your appropriate employer category from this list of five. You can only select one per form. If you select Contract Agency or Other, use the text box to describe this entity.
  • Department Name: This is pre-populated form the HR database and will update automatically if changes occur.
  • Campus Box Number: Use the look-up link to the right if you do not know your campus box number.
  • Phone Number: This is a contact number for your laboratory. For campus numbers, you must enter all seven digits after the area code. If your laboratory suite does not have a landline phone, you can enter a mobile phone or pager number. The default area code is 919; you must erase this if your laboratory contact number is out of the 919 area code.
  • Principal Investigator: This field cannot be changed if you selected EDIT on the Registration Menu. Select your PI from the drop-down menu. If your PI is not on this menu (or you are the PI and your name is not on this menu), contact EHS for further information. New PIs cannot be added to the EHS data system until they complete and submit a Laboratory Safety Plan (see Chapter 2 for information and instructions).
  • Supervisor is not PI: Complete these if your supervisor is not the Principal Investigator listed in the previous section.
  • Work Will Involve: Select all that apply to your work, or that could apply. Contents of this section vary, based on what option you selected (Lab Only, Lab/Rad, Rad Only) on the Registration Type screen. Use the links if you have questions about animal handlers or the requirements for bloodborne pathogen training.
  • If you work in a production laboratory or shop that produces hazardous waste, select the Hazardous Waste box at the end of the form. DO NOT select this if you work in a research laboratory.

Click on CONTINUE when finished. If you are registering as a laboratory worker only, this completes the registration.

If you are registering as a radiation worker, you will go through additional screens. These screens require you to list the radionuclides or radiation-producing equipment you will work with, your previous experience with radiation, dominant hand, and previous employment with radiation exposure.

Contact EHS at 919-962-5507 if you have any problems or questions about completing the Laboratory/Radiation Worker Registration Form.

Additional Appendices