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Chapter 45
CHEMICAL HYGIENE AND SAFETY PLAN

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Work Process Z. Hazard Communication Requirements for Chemicals Produced in LBNL Laboratories

1. General Requirements. Chemicals produced in laboratories must, at a minimum, be evaluated for their hazards. Other requirements such as training, and the production of SDSs and labels vary depending on whether the materials will be shipped off site or used on site. Details are provided in the following section. Table Z-1 is a summary of these requirements.
2.  Chemicals Produced in LBNL Laboratories and Shipped Off Site

1. LBNL is regarded as a chemical manufacturer or distributor by Cal/OSHA if chemicals produced in laboratories are shipped off site. Therefore, LBNL is required to comply with the requirements to identify chemical hazards of the materials produced and to communicate them through SDSs and container labels that are shipped with the chemical.  There is no exemption based on quantity.  Select toxins, regulated by the Centers for Disease Control and biological materials are exempt from these requirements.
2. Hazard classification, and the creation of SDSs and labels are greatly simplified for chemicals which have already been evaluated by another party. For example, if benzene is produced in an LBNL laboratory, its SDS and label can be downloaded and used from LBNL’s SDS provider, ChemWatch®.
3. For new or unique chemicals, hazard classification and the creation of new SDSs and labels are required and must be done in accordance with Cal/OSHA’s mandated prescriptive methodology. The process for classifying chemical hazards is described in Work Process E, Work Process Y and Work Process X list the required content and elements for labels and SDSs, respectively.
4. Due to the complex and prescriptive requirements for classifying new chemicals, and for developing SDSs and labels, researchers may consult with the CHSP manager for assistance.
5. For SDSs and labels that are shipped with chemicals, line managers shall ensure that:

1. The recipient is contacted (e.g., via e-mail) prior to shipping.
2. Shipping is coordinated with Facilities Material Services (ext. 5084).

Only qualified individuals in Facilities Material Services may pack and ship these materials off site.

3. SDSs and labels are updated with any new information regarding the hazards of a chemical or ways to protect against the hazards.

3. Chemicals Produced in Laboratories and 🚩Actively🛑Used On Site. The following requirements apply to chemicals that are produced in LBNL laboratories but will be used on site use, as opposed to shipping them to an off site location. This applies to chemicals that are saved for future 🚩on site🛑 use or that are shared with others on site. “On site” includes the main LBNL campus and its satellite locations.

1.  The chemical must be evaluated to determine if it is hazardous using the protocol outlined in Section 2, above.
2. SDSs are not required.
3. Labels are required. Minimum information includes product information such as chemical name or structure and at least general information regarding the hazards of the chemicals. Note: the Cal/OSHA primary container label elements, including signal word, pictogram, hazard statement, precautionary statement and contact information are not required.
4. If the composition is unknown, label the container with some other means of identification such as researcher name, date, and reference to a lab notebook page.
5. 🚩There may be practical limitations for labeling small vials or multiple containers kept in a rack, tray or cassette.  Refer to Work Process Y for additional information and guidance on labeling.🛑
6. There may be practical limitations for labeling small vials or multiple containers kept in a rack, tray or cassette.  Refer to Work Process Y for additional information and guidance on labeling.
7. Training is required. At a minimum, complete Chemical Hygiene and Safety Training (EHS0348) and Safe Handling of Engineered Nanoscale Particulate Matter (EHS 0344), if the chemical is an engineered nanomaterial.
8. Address the hazards and controls of the chemical in the WPC Activity for which it is used.

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4. Hazard Communication Requirements for Transporting Research Samples. Employees who transport research samples either by hand or in a passenger vehicle for use by another person must follow the hazard communication requirements described above and the packaging requirements in Work Process C, Transporting Hazardous Materials.

Table Z-1 Hazard Communication Requirements for Chemical Substances Produced in Laboratories

9. Determine the chemical hazards in accordance with Cal/OSHA’s hazard classification and categorization process outlined in Work Process E.
10. Produce an SDS for the chemical. See Section 2.
11. Label in accordance with the Cal/OSHA HCS. See Section 3.
12. “On site” includes the main LBNL campus and its satellite locations.
13. Label with the chemical name and principal hazard. See Section 3.
14. Training courses EHS 0348 and 0344 (for engineered nanomaterials) are required, plus any information on the hazards and controls associated with the substance produced in the laboratory.
15. Address the hazards and controls of the chemical in a WPC Activity.
16. Transportation by hand or in a passenger vehicle for use by either the sender or other LBNL personnel. See Work Process C.
17. In addition to chemical name and hazard, list the name and phone number of the sender and recipient. See Work Process C for additional information and requirements.
18. If a substance will be used by non Berkeley Lab personnel, the hazard classification, labeling and SDS requirements of the Cal/OSHA Hazard Communication Standard apply.

5.  🚩🚩Chemicals Produced in Laboratories Not in Active Use (Archived Samples). Refer to Work Process Y for additional information and guidance on labeling. 🛑

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