Environmental Health & Safety

Using hazardous chemicals in research laboratories requires a thorough understanding of the associated health and physical risks, particularly when considering factors such as concentration, volume, temperature, and physical conditions. Researchers must review Safety Data Sheets (SDS), conduct risk and hazard evaluations, and develop Standard Operating Procedures (SOPs) for chemical use and hazardous equipment. SOPs should be included in lab-specific training and reviewed by all new personnel. Principal Investigators (PIs) are responsible for documenting safety information—including chemical inventories, hazard assessments, PPE requirements, and exposure prevention measures—as part of the Lab Safety Plan or Chemical Hygiene Plan. The resources below provide essential guidance for recognizing hazards, preventing exposure, and reducing the impact of potential incidents, and should be consulted before using any chemical, starting a new experiment, or modifying an existing one.

• ACS handbook of safety in academic chemistry laboratories is the framework of the chemical safety at JSNN and needs to be reviewed and followed by all researchers.
• The JSNN Chemical Hygiene Plan must be reviewed by all researchers at JSNN. This document, along with the Lab Safety Plan (developed by each PI) shall satisfy the OSHA 29 CFR 1910. 1480 requirements for the Chemical Hygiene Plan.
• Use the following resources for understanding reactive chemicals and chemical reactions:
• EPA Identifying Chemical Reactivity Hazards: Preliminary Screening Method
• CCPS, A Checklist for Inherently Safer Chemical Reaction Process Design and
• Essential Practices for Managing Chemical Reactivity Hazards Operation
• CCPS, Reactive Material Hazards
• List of the chemicals with a Chemical Skin Absorption Hazard notation
• Flammable Liquids must be stored in limited quantities and inside an NFPA 30 approved and UL listed flammable storage cabinet.
• Peroxide-Forming chemicals can form peroxide crystals. These crystals are extremely shock sensitive and can cause explosions. Peroxide-forming organic solvents, such as diethyl ether, shall be marked with the date they are opened and only kept for up to 12 months after opened and never beyond their expiration date.
• Safety Data Sheets must be reviewed before using a new chemical, starting a new reaction, or modifying an existing reaction.
• Emergency Eyewash and Safety Showers
• CAMEO chemical compatibility software (EPA)
• The JSNN Chemical Hygiene Plan (CHP) must be reviewed by all researchers as a reference and training tool.
• A laboratory-specific safety plan and chemical inventory are required for each research lab.

Biohazardous agents, or “biohazards” are infectious agents or hazardous biological materials that present a risk or potential risk to the health of humans, animals, or the environment. Working with biological materials for research or teaching purposes requires specific registration, approval, documentation, procurement, disposal, and training procedures. Federal and state government regulations specify safety requirements for safe and compliant research involving biohazards.

Acquiring biological material for research at JSNN requires a Biological Use Authorization (BUA) form that will be submitted to the appropriate UNCG or NCA&T Institutional Biosafety Committee (IBC) for review and approval. The following biological materials require approval prior to the procurement of the materials necessary to initiate the project:

1. Recombinant/synthetic nucleic acid molecules in organisms including their use in animals (including arthropods) and plants.
2. Human and other primate-derived substances (blood, blood products, cell lines, or tissues).
3. Organisms or viruses infectious to humans, animals or plants (e.g., parasites, viruses, bacteria, fungi, prions, rickettsia) or biological materials that may contain these microorganisms.
4. Select agent or toxins (human, animal, or plant) – refer to the list here at: http://www.selectagents.gov/SelectAgentsandToxinsList.html.
5. Biologically active agents (e.g., venoms and toxins produced by living organisms) that may cause disease in other living organisms or cause significant impact if released into the environment.

 Biological safety training

All biological material users are required to complete the annual biological safety training. Biological safety processes must be added to the lab safety plan. 

Bloodborne Pathogen Safety

The OSHA Bloodborne Pathogen Program applies to all employees and students who may have exposure to human blood, blood products, tissues, or cells. Examples include (but are not limited to):

1. Staff with job duties that require them to protect others by immediately cleaning up small blood spills or confine large spills for proper clean-up
2. Laboratory workers handling human blood, tissue, or established human cell lines or waste from such procedures
3. Designated emergency teams that perform spill clean-up response

To be compliant with OSHA Bloodborne Pathogens standards, PIs must complete the following:

1. The Model Exposure Control Plan is completed by the supervisor/principal investigator. Plans must be updated annually and be available to workers at all times.
2. Hepatitis B vaccinations must be offered to the worker within 10 days of assignment to duties covered under the Exposure Control Plan or be officially declined. Review the guidance provided by the Centers for Disease Control
3. Training requirements for bloodborne pathogens must be completed by each employee/student according to instructions provided in their specific Bloodborne Pathogens Exposure Control Plan, within 10 days of assignment to duties covered under the Exposure Control Plan, and annually thereafter.
4. Reviewing Safer Sharps Devices is a requirement of the Exposure Control Plan. Use the resources from the CDC ‘Stop Sticks’ program to help you review your sharps devices: https://www.cdc.gov/nora/councils/hcsa/stopsticks/default.html.  This CDC resource provides guidance to elicit feedback on safer sharps devices used in your work area: https://www.cdc.gov/sharpssafety/a13.html
5. A copy of the OSHA Bloodborne pathogen standard must be made available to all employees upon request. Laboratories should review the June 21,1994 OSHA interpretation letter which provides additional insight on the applicability of the OSHA BBP standard to established human cell lines. Employees must complete the training within 10 days of assignment.

Biological waste disposal

Biological waste must be autoclaved before disposal. Autoclave safety training is required for all autoclave users. See the JSNN biological waste disposal flow chart for more information on  proper disposal of different types of biological wastes. Mixture of the hazardous chemicals and biological material shall not be autoclaved. Use chemical disinfection with proper contact time and dispose of based on your IBC approval. 

Requirements for using an autoclave

1. Autoclave use log is posted
2. Autoclave user manual is available
3. SOPs for maintenance and malfunction are posted
4. Vendor has trained end users
5. Autoclave use is listed as a process on lab safety plan
6. All autoclaves greater than 5 cubic feet meet boiler certification requirements which includes being posted according to the NC DOL Boiler Safety Bureau (see laws regarding boiler certification requirements)
7. Proper Use of a Steam Autoclave is posted at the autoclave
8. Users have received hands-on training from their supervisor or lab designee on each autoclave device unit they use.
9. The Safe Use of Autoclaves training has been developed to supplement hands-on training for users. It covers the basics of how to safely operate an autoclave. 

Shipping biological materials

Shipping hazardous materials, including biologicals, will require DOT/IATA training. Please contact ROEHS for more information.

Biological materials spill

Contact ROEHS at 336-285-2878 (normal working hours) or 919-357-1134 (after hours) for assistance with biological spills clean up. Do not attempt cleaning up spilled material without ROEHS approval. Make sure that your IBS spill clean up procedure is available and followed.

The Ionizing Radiation Safety Program at JSNN is developed to ensure that X-ray generating devices are installed and operated properly and uphold Federal and State regulatory agencies safety requirements. Users of the X-ray producing devices and those working around such equipment at JSNN are required to fulfill specific training and monitoring requirements. This program also offers a specific monitoring program for declared pregnant women.

General

Users of equipment or devices producing ionizing radiation including X-rays, must comply with State and Federal regulatory requirements as well as the JSNN internal procedures. All procedures must be current and in compliance with 10A NCAC 15 rules. Current X-ray generating devices covered under this program at JSNN include a Gemini X-ray diffractometer and a Nikon XT H 225 ST 2x Computed Tomography (CT) Scanner.

General user compliance and safety responsibilities

PIs, supervisors, and all other users of the X-ray producing devices are required to:

1. Review the “JSNN Ionizing Radiation Safety Manual” as part of their safety training before they are granted access and allowed to use the equipment.
2. Understand and conduct operations in an acceptable manner to minimize hazards to himself/herself and others.
3. Wear a dosimeter badge while working with the X-ray producing devices.
4. Report any concerns and malfunctions to their supervisor.

PI responsibilities

1. The principal investigator (PI) is responsible for ensuring that all personnel in his/her area/group are properly instructed and trained about the nature of the X-rays, ionizing radiation hazards, and the necessary radiation safety procedures in the laboratory.
2. PIs must make sure that students or other personnel under their supervision follow all safety requirements for exposure prevention and assessment.

ROEHS responsibilities

The JSNN Research Operations and Environment Health and Safety (ROEHS) is responsible for:

1. Assisting all users and PIs by providing consultation, training, and certain services in matters of ionizing radiation safety compliance.
2. Establishing and reviewing policies and program elements in conjunction with the  Safety Committee X-ray safety working group.
3. Implementing and maintaining the X-ray exposure to As Low As Reasonably Achievable (ALARA) levels.
4. Developing and implementing Ionizing Radiation Safety protocols, including annual training, surveys, dosimeter badge reporting, equipment interlock checks, and maintaining required compliance-required documents.

Equipment manager’s responsibilities

1. Maintaining and sharing an updated copy of the JSNN Ionizing Radiation Safety Manual in the lab.
2. Ensuring safe operation of the equipment, including interlocks and password protection.
3. Providing and documenting annual equipment training for all users.
4. Developing written Standard Operating Procedures (SOPSs) including safety requirements and making it available to personnel before operating equipment.
5. Reporting safety mechanism malfunctions and shortcomings to ROEHS.

Requirements for becoming an authorized user

To be considered an authorized user and/or gain and maintain access to the X-ray generating equipment, user must satisfy the following requirements:

Requirement	Frequency	Provided by	Applies to
JSNN Lab Safety/CHP Training	Annually	ROEHS	All users
JSNN Hazardous Waste Training	Annually	ROEHS	All users
JSNN X-ray Radiation Safety Training	Annually	ROEHS	All users
Equipment -specific training	Annual	Equipment Manager	All users
Completion of the “Radiation Worker Registration Form”	Initial	ROEHS	All users
Receiving and wearing a dosimeter badge	Used daily and renewed quarterly	ROEHS	All users
Using the equipment log sheet	Daily	Equipment Manager	All users

Note: Individuals who work with or around X-ray generating devices but are not authorized users of the device must complete the initial X-ray Safety Awareness Training. Upon completion of this training, users will be given an option to decide if wearing  a dosimeter badge is warranted.

The following chart illustrates the required steps for becoming an X-ray generating device authorized user.

Requirements and steps for Becoming an Authorized X-ray Generating Device User at JSNN

Exposure prevention and assessment

JSNN is committed to minimizing the X-ray exposure and maintaining the exposure to As Low As Reasonably Achievable (ALARA) levels. This is achieved through training, inspections, monitoring, safeguards, shielding, and other exposure prevention and control mechanisms. The ALARA action levels at JSNN are defined as 2% per quarterly-monitoring period or 10% annually of the latest applicable occupational exposure limits. Exposure above ALARA levels will be investigated by RSO.

NC DHHS rule .0104 (a), Annual occupational dose limits for adults and JSNN ALARA action levels

	Dose limit	Quarterly ALARA Action Level (2%)	Annual ALARA Action Level (10%)
Total Effective Dose Equivalent (TEDE)	5,000 mrem*	100 mrem	500 mrem
Total Organ Dose Equivalent (TODE)	50,000 mrem	1,000 mrem	5,000 mrem
Eye Dose Equivalent (EDE)	15,000 mrem	300 mrem	1,500 mrem
Shallow Dose Equivalent (SDE)	50,000 mrem	1,000 mrem	5,000 mrem

Other compliance requirements

A.  Posting requirements

For hazard communication and NC DHHS compliance purposes, the following documents, signs, and labels must be posted inside each room where X-ray generating equipment is present:

1. A copy of the JSNN Ionizing Radiation Safety Manual, containing program, dosimetry, training, inspection, and all other required records.
2. NC DHHS, Division of Health Service Regulation Notice to Employees (see appendix 1).
3. An X-ray caution sign at the room entrance along with emergency contact information.
4. An X-ray caution sign on the cabinet/enclosure and X-ray tubes.

B. Dosimeter badges

All users of the X-ray generating devices must wear their assigned personal chest dosimeter badge upon entering the room. Badges must be placed on the badge board inside the room before leaving the room. Badges are collected quarterly and submitted to LANDAUER for exposure analysis and report. ROEHS-Radiation Safety Officer (RSO) will review, approve, and provide the analysis report to the equipment manager for documentation and sharing with users. Individuals who work in rooms where X-ray producing devices are located but do not use the X-ray equipment will have an option to be enrolled into the program and receive a dosimeter badge.

C. Annual interlock check and survey

JSNN RSO will perform and document annual interlock checks as well as the annual survey, using a calibrated Geiger counter. Survey measures the radiation levels around the X-ray enclosure. Any survey readout above the background will be investigated and addressed by the manufacturer or a qualified third-party. Survey results need to be documented.

D. Program Assessment

Using the NC DHHS Radiology Compliance Branch Analytical Radiation Protection Program Assessment Form, the JSNN RSO must complete and sign the annual program review. Corrective actions are documented on this form.

E. Declared Pregnancy

Women who declare pregnancy will be registered into the protection program and will also be assigned a monthly fetal badge. Declared pregnancy shall be kept confidential unless the pregnant woman decides otherwise. Declared pregnant women who work around the X-ray producing devices (but not with the equipment) will also be required to comply with these requirements.

F. Training

Users of the X-ray generating devices must complete the initial JSNN X-ray Safety Training. An annual refresher training is required. Those working in the areas where X-ray generating equipment are installed, but do not operate/use the equipment, must complete the initial “X-ray Awareness Safety Training”. No refresher is required for this group. Although JSNN partners receive the same training and are assigned dosimeter badges, it is the responsibility of the partner’s safety representative to request and maintain the historic training and dosimetry records.

Registration of the X-ray Generating Devices

ROEHS registers all new devices with NC DHHS, Radiology Compliance Branch, within 30-days of the initial use of each X-ray unit. The device must be registered using the equipment form. The JSNN, as the facility providing the service, is also registered using the business application form. Any changes in equipment location, ownership, RSO, or application must be reported to NC DHHS. All radiation-producing devices to be surplused, donated or transferred to another North Carolina facility or other business, should be inspected by ROEHS before leaving the building. Under some circumstances, a device may be tagged or disabled by ROEHS to prevent its use. No attempt to energize or otherwise use the device should be made without prior notification of and approval from Radiation Safety.

Personal Protective Equipment (PPE) is used for protection against exposure to hazardous materials and is required in conjunction with other control methods to mitigate the impact should an incident occur. A lab coat, protective eyewear, long pants/dress, and closed-toe shoes are the minimum PPE requirements for entering the JSNN research labs.

In the hierarchy of exposure prevention and control, the primary methods for protecting researchers in a laboratory against chemical, biological, radiological, physical, and mechanical hazards are elimination, engineering, and administrative controls. Where these control methods are not appropriate or sufficient to control the hazard, personal protective equipment (PPE) is required. PPE is also required in conjunction with other controls to mitigate the impact should an incident occur.  

1. Minimum PPE requirements for entering research labs at JSNN
   1. Visitors For a “no touch visit” to the areas where chemical, biological, radiological, or mechanical hazards are present, eye protection and lab coat shall be provided.
   2. Researchers, volunteers, and partners Researchers (faculty, staff, and students), interns, volunteers, and partners entering the areas where chemical, biological, radiological, or mechanical hazards are present must wear a lab coat, protective eyewear, long pants and closed-toe shoes as the minimum PPE for entering the lab. This clothing shall be supplemented, as necessary, with the appropriate gloves and other personal protective equipment (PPE) necessary for the tasks to be performed.
2. PPE selection based on the hazard assessment OSHA 1910.132 PPE standard requires a documented hazard assessment for identifying required PPE for each task performed in the work environment. This includes any experiments using chemical or biological materials or equipment such as an autoclave. This assessment needs to be documented under the lab Safety Plan (Chemical Hygiene Plan).
3. Training Through completion of the annual lab safety training modules, review of the Safety Plan, and lab-specific PPE training provided by PI, all researchers must be trained on proper selection, use, maintenance, and limitations of their PPE.
4. Major Types of PPE
   1. Body protection
      1. Lab coat A lab coat is the minimum requirement for body protection in research labs. While polycotton blend lab coats are acceptable for basic chemical and biological research, fire-rated lab coats such as Nomex or other rated flame resistant fabrics will be necessary when working with open flames, pyrophorics, or using large volumes of highly flammable chemicals.  Please follow this link for more information JSNN Lab Coat Program
      2. Chemical resistant aprons and sleeves When transferring large volumes of chemicals, such as making an acid bath, or when using highly hazardous chemicals such as hydrofluoric acid, chemical protective aprons and sleeves will be required.  JSNN provides lab coats to all researchers through a third-party contractor.
   2. Eye and face protection
      1. Safety glasses Safety glasses are used for basic daily research activities. However, they do not provide protection against splashes. Safety goggles must be used when there is a risk of injurious chemical splash into the eyes. ROEHS offers a variety of safety glasses and goggles for researchers to select from. Safety glasses must meet the ANSI Z87.1 requirements. Contact ROEHS for laser, UV, and IR radiation protective safety glass selection.
      2. Safety goggles Safety googles must be used for protecting eyes against chemical splashes.
      3. Face Shields Face shields must be used in conjunction with safety glasses or safety goggles for face and eye protection.  Examples include dispensing cryogenic liquids,  preparing corrosive baths, or pouring large volumes of hazardous chemicals.  Face shields alone do not provide adequate splash protection for eyes.
   3. Hand protection
      1. Disposable nitrile gloves Disposable nitrile gloves provide limited protection against chemicals and are the minimum hand protection requirement in research laboratories. Disposable gloves shall be removed immediately after contact with chemicals. Users then need to wash hands before replacing disposable gloves. Using double (a second pair of gloves atop the first) nitrile gloves or wearing Silver Shield gloves under disposable nitrile gloves may be necessary where hazard/risk assessment indicates the need for additional hand protection.
      2. Heavy duty or chemical protective gloves Heavy duty or chemical protective gloves provide longer protection and can be reused as long as they are washed and air dried after each use. Inspect reusable chemical protective gloves before each use. Certain chemicals pose a skin absorption risk and require additional attention for glove selection Protective gloves provide limited protection based on the exposure duration and chemical concentration. Users must consult the glove manufacturer’s compatibility/selection chart to ensure that the selected glove provides the intended protection. Examples include:
         • Ansell Glove Selection Database
         • North Chemical Resistance Guide
      3. Avoid using latex gloves. Latex gloves provide poor protection against chemicals and can cause severe allergic reactions in some individuals. For more information, see Latex Allergies | NIOSH
      4. Heat and cold protection need to be properly selected for non-chemical lab hazards Examples include:                    
         • Excess heat.  Use properly selected, insulated gloves
         • Cold: specially rated gloves for activities such as working with cryogenics, dry ice, and working with minus 80°C freezers
         • cut and abrasions: cut-resistance gloves
   4. Hearing protection Before selecting and using a hearing protection device, a noise survey must be performed to assess the sound pressure levels and personal exposure. Contact ROEHS if you use a device or work in an environment with high noise levels.
   5. Respiratory protection Similar to hearing protection, using respiratory protection requires ROEHS pre-assessment and approval. This includes using disposable N95 respirators. Please refer to the JSNN Respiratory Protection Program for more information.
5. Other PPE requirements Activities outside the standard lab work such as working with lasers, farm work, or maintenance activities will require additional or different PPE assessments. The table below shows examples of the minimum PPE requirement for basic lab activities.

Lab coat

Safety glasses

Goggles

Disposable nitrile gloves

Chemical protective gloves

Face Shield

Cryogenic gloves

Respirator

Chemical protective Apron

Chemical protective sleeves

Cut resistant gloves

Heat resistant gloves

Routine lab activities

√

√

√

Working with Cryogenics

√

√

√

√

√

Working with biologicals

√

√

√

High volume chemical transfer/mix

√

√

√

√

√

√

Working with sharp objects

√

√

√

Working with hot surfaces

√

√

√

Opening MBE system

√

√

√

√

Research operations generate hazardous biological, radiological, and chemical wastes. Unused and expired chemicals also are considered hazardous waste and are treated as such. State and federal regulatory agencies drive proper labeling, storage, and disposal requirements to which JSNN must adhere for both safety and compliance purposes. JSNN does not allow any drain disposal of the hazardous material.

GENERAL

The JSNN Hazardous Waste Management Plan (HWMP) is intended to assist PIs and researchers to comply with the provisions of the “Resource Conservation and Recovery Act (RCRA)” and the “Hazardous Waste Generator Improvement Rule (40 CFR 260 – 265)” requirement. State and federal regulatory agencies require specific labeling, storage, and disposal requirements for the hazardous waste, unused/abandoned, and expired chemicals to which JSNN must adhere for both safety and compliance purposes. JSNN does not allow any drain disposal of hazardous materials.

Definition

• ACUTE HAZARDOUS WASTE means Hazardous Waste that is one of the acutely hazardous commercial chemical products listed in § 261.33(e) for reactivity and toxicity.
• HAZARDOUS WASTE means any chemical, mixtures of chemicals, products of experiments or other materials from a laboratory that is expired or otherwise no longer needed, wanted, or usable and that is destined for hazardous waste determination by a trained professional. Hazardous Wastes include reactive, acutely hazardous wastes, and materials that may eventually be determined not to be solid waste pursuant to 40 CFR 261.2, or a hazardous waste pursuant to 40 CFR 261.3.

Roles and responsibilities

1.      PIs
   • Must assume the primary responsibility for ensuring that all JSNN hazardous waste program requirements are met
   • Need to ensure that all researchers complete their annual hazardous waste training and follow the waste storage and disposal requirements
   • Must report any concerns or deficiencies to JSNN Research Operations and Environmental Health and Safety (ROEHS)
   • Need to educate researchers and students on proper waste disposal and prevent any drain disposal
   • Need to develop and follow procedures for reducing hazardous waste generation during their research activities
2. Researchers
   • Understand and follow proper hazardous waste labeling and storage requirements
   • Avoid any drain disposal
   • Comply with JSNN hazardous waste labeling and disposal form requirements and prepare waste for monthly pick up schedules
   • Report spill and any other safety concerns to ROEHS
   • Follow waste minimization practices
3. ROEHS
   • Provides annual hazardous waste training
   • Performs routine lab and waste storage facility inspections
   • Develops and maintains JSNN hazardous waste management plan
   • Manages hazardous waste pickup, waste storage facility, and third-party disposal
   • Develops and maintains the emergency response and compliance plan for the waste storage facility
   • Ensures EPA compliance and reporting requirements
4. Gateway
   • Maintains the EPA small waste generator license
   • Communicates with third-party for bi-annual waste shipment
   • Ensures proper waste management for non-JSNN waste generators
   • Maintains JSNN-generated waste records, manifest and other regulatory documents
5. Third-party waste disposal contractor
   • Removes all hazardous waste on a scheduled semi-annual schedule
   • Ensures compliant bulking, packaging, labeling, documenting, and offsite shipping of the hazardous waste
   • Reports any discrepancies to JSNN ROEHS

Hazardous waste collection, storage, labeling, and disposal requirements

1.  Chemical waste Chemical waste includes any chemical, mixtures of chemicals, products of experiments or other material from a laboratory that is no longer needed, wanted, usable, or expired. The JSNN hazardous waste program requires specific labeling, storage, and disposal procedures that need to be followed.  To avoid any unintended exothermic chemical reactions, waste bottle overpressurization, and toxic chemical by-product generation, chemical waste shall not be mixed together. Drain disposal is against EPA regulations and shall be avoided.
   1. Collection To avoid any unintended exothermic chemical reactions, waste bottle over pressurization, and toxic chemical by-product generation, chemical waste of different nature shall not be mixed together. Drain disposal is against EPA regulations and shall be avoided. All chemical waste containers must be
      • Collected in compatible containers
      • Kept closed with a proper sealed cap
      • Placed in a secondary containment
      • Processes generating waste on a continuous basis (e.g. gas chromatography) must be collected via tubes that are fed through the cap without allowing chemical evaporation
   2. Labeling All chemical waste containers must be posted with ROEHS-provided waste labels at the beginning of the waste accumulation. Waste labels must indicate:
      • The word “hazardous Waste”
      • Bottle #
      • Chemical name(s) (no acronyms or formula)
      • Hazard category (e.g. flammable)
      • Accumulation start date
      • PI name
      • Room number.
   3. Storage Chemical waste storage requirements include:
      • Waste must be stored inside the room where it is generated
      • Containers must be kept closed (except when adding material). Use vented caps if there is a potential for waste bottle pressurization
      • Waste bottles must be stored in proper storage cabinets until ready for disposal
      • Chemical waste bottles can be kept inside the fume hoods while waste is being accumulated. Do not overload or use the fume hood as a waste storage
      • All chemical waste containers must be placed in a secondary containment
      • Funnel must be removed and bottle closed when not in use, or use a sealed attached funnel with a locked latch. Parafilm, rubber stoppers, or corks are not acceptable
      • Over accumulation of the waste must be avoided and waste shall not be stored for more than 6-months
      • Waste must be stored in a clean container with no visible residue outside. To avoid chemical reactions, keep the original containers for collecting and discarding the same material, once it becomes waste
      • See the “Hazardous Waste Satellite accumulation Poster”
      • If more than 1 Kg (2.2 lbs) of acute hazardous waste chemicals (EPA p list), it must be removed within 3 calendar days of the date that the 1 Kg was exceeded
   4. Disposal For proper waste disposal:
      • Do not overfill. Keep at least 10% space for expansion
      • List all chemical containers on the waste disposal form. Make sure the bottle number on the container matches the number on the form
      • Once ready for disposal, place form and waste bottle inside the satellite accumulation containers
      • Drain disposal of any chemicals, including media, is not allowed
      • No more than 55-gallons of waste is allowed in a satellite accumulation area
      • If more than 1 Kg (2.2 lbs) of acute hazardous waste chemicals (EPA p list), it must be removed within 3 calendar days of the date that the 1 quart/1 Kg was exceeded
      • Waste will be picked up on the first Wednesday of each month from 10:00 – 11:30 a.m.
   5. Empty chemical container disposal To discard empty chemical containers, researchers must:
      • Collect all contents/residue in a compatible container and discard it as hazardous waste
      • Remove or deface the label (chemical name and hazard pictograms)
      • Remove the cap
      • Store in a lined cardboard box
      • Avoid overfilling and making boxes too heavy to lift
      • Carry on a cart and discard in regular outdoor dumpster
      • For highly toxic chemical containers (EPA P-list), the empty container needs to be discarded as hazardous waste. Otherwise, the container needs to be first triple rinsed before disposal. Rinsate must be collected and discarded as hazardous waste.
2. Biological waste
   1. General Biological waste includes any biological material generated from research activities during manipulation or clean- up, regardless of its potential to infect humans, plants or animals that is/are no longer useful. Biological waste must be collected and disposed of properly. Avoid any drain disposal (liquid) or mixing with regular trash (solid). Examples of the biological waste include:
      • Materials contaminated or potentially contaminated during the manipulation or clean-up with Biosafety Level 1, 2, 3, or 4 material, animal or plant Biosafety Level 1, 2, or 3, or liquid human blood and body fluids
      • Materials contaminated with human/primate tissue or human/primate tissue cultures (primary and established) because these are handled at BSL-2
      • Animal blood, fluids and bedding from animals infected with agents requiring BSL-2 and BSL-3 container
      • Transgenic materials or animals
      • Biological sharps (e.g., needles, scalpels)
   2. Proper collection and labeling Biological waste shall be collected in red, hard-walled biohazard waste collection containers with maximum 15-gallon capacity. Waste containers must be lined with a clear autoclavable bag.
      • Use only clear biohazard bags for autoclaving. The red/orange biohazard bags are not allowed.
      • Biological waste containers must have a lid which remains closed when not in use. Both lid (if removable) and container must bear the biohazard symbol with the word “Biohazard.”
      • All biological waste containers including biohazard sharps shall only be filled 2/3.
      • Liquid biological waste such as spent culture media should never be allowed to sit for longer than 24 hours.
   3. Biological Waste Disposal Biological solid waste, liquid waste, and sharps each have specific requirements for collecting, labeling, storage, autoclaving, and disposal. See the Biological waste Disposal Chart for biological solids, liquids, sharps, and animal/plant disposal requirements.

Inspections

JSNN ROEHS will perform at least one scheduled and one unannounced follow-up waste inspection annually. Labs are encouraged to perform self annual inspections as well. See the JSNN waste inspection form for items reviewed during the ROEHS visit. Highlights of the waste inspection include:

1. Waste is accumulated in the room where generated
2. Waste containers are suitable for the contents (compatibility)
3. There is no visible residue on waste containers
4. All containers are affixed with the JSNN-ROEHS provided hazardous waste labels, displaying all required information
5. Waste containers are properly closed
6. 10% head space allowed for expansion
7. Waste containers are stored properly in designated storage cabinets, or in satellite accumulation areas, once ready for disposal.
8. Waste form and labels are properly utilized with accurate information

Hazardous waste reduction and best management practices

JSNN is committed to a policy for hazardous waste management that places a high priority on waste minimization and environment pollution prevention In accord with the EPA guidelines through:

1. Guiding researchers in substitution of the hazardous chemicals with more environmentally friendly alternatives
2. Reducing purchase and storage volumes
3. Utilizing good practices in maintaining chemical containers closed and using secondary containment for potential spill
4. Reuse and recycling material
5. Utilizing processes and practices requiring lower chemical volume/ concentration and generating less hazardous waste
6. Training and audit to ensure effectiveness of the waste management program
7. Using satellite accumulation area for proper collection, labeling, and disposal
8. Routine waste pickup schedules to prevent waste accumulation in research labs
9. Distributing hazardous waste labels and waste disposal forms for a unified hazard identification method

Training

All JSNN research faculty, staff, interns, and partners are required to fulfill the annual hazardous waste training, presented by ROEHS. Lab/equipment access will not be granted until training requirements are satisfied. 

Waste Storage Facility

Collected waste from the laboratories is stored at the JSNN waste storage room until it is processed and transported off-site by a licensed third-party for final disposal. The third-party waste pickup is scheduled twice a year. GATEWAY is the EPA small waste generator permit holder and arranges for the bi-annual waste pick up and other regulatory compliance requirements for waste removal. JSNN-ROEHS will inspect the waste storage room on a monthly basis, making sure that hazardous waste is safely stored with no sign of spills, pressurization, or reactions.  The monthly inspection checklist will be kept inside the waste storage room.

Unknown Materials

Researchers are required to ensure proper identification of all chemicals throughout their storage and use cycle. PIs must follow the student off-boarding process and make sure that all chemicals/samples are identified, labeled, and discarded before the researcher’s departure. Disposal cost for unknown material is substantially higher than identified material. Unknown materials must be labeled “Hazardous Waste-Unknown”

Spill Minimization and Cleanup

Use secondary containments to contain any spill from hazardous waste.  Maintaining certifications may range from annual to up to three years. For each process in the lab safety plan, PIs must  include a section for emergency and spill clean up procedures and address spill prevention, containment, and control plans specific to their labs and communicate this information to all employees, students, and interns. Laboratory chemical inventory must be maintained and updated, as chemicals are removed and discarded.

For any life threatening chemical spill emergency, call 911.  For all other contained spills, call ROEHS at 336-285-2878 (during normal working hours) or 919-357-1134 (after hours). Do not attempt any spill clean up before consulting ROEHS. Report any spill to your supervisor, leave the area, and make sure that area is posted with a visible “Do Not Enter, Hazardous Chemical Spill” sign until the area is cleared by ROEHS.

In case of chemical exposure to eye or skin, use emergency eyewash (eye exposure) and safety shower (skin exposure) and seek medical assistance by calling 911.

Clean room is a critical environment from both safety and quality control stand points. Due to the types of the experiments, equipment, and materials used in clean rooms, it requires its own safety management program, including spill response, safety training, SOPs, and equipment-specific training. Demonstrated safety competence is a requirement for clean room access.

Safety training requirement

JSNN cleanroom uses several hazardous chemicals, including gases, processes, and equipment that require their own specific hazard review and safety training. To gain access to cleanroom, users must:

1. Complete the minimum required safety training modules
   • Lab safety training
   • Hazardous waste training
   • Nanomaterials safety training
2. Complete cleanroom safety training
3. Fulfill training requirements for the equipment they use. This training is provided by cleanroom manager
4. Document the entry and reserve equipment on the FOM (Facility Online Manager) system

Molecular-beam epitaxy (MBE) system

In addition to the required training modules listed above, all MBE users must enroll in the JSNN Respiratory Protection  Program and fulfill the program requirements.

spill response

 Unlike other research labs, cleanrooms are designed and balanced to maintain positive pressurization. Cleanroom emergency preparedness and response plan must consider this for proper response and evacuation during major spill scenarios.

Equipment used in cleanroom

 Visit JSNN web page for list of equipment used in the cleanroom. Standard operating procedures (SOPs) are developed for each equipment, including risks and hazards associated with equipment and required protection. 

Equipment using hazardous material, high voltage, high pressure, high temperatures, or any other sources of chemical or physical hazards require user specific training. A hazard review with ROEHS is required before purchasing such equipment.

Before purchasing new equipment

• Verify that the lab has the required utility capacity (e.g. exhaust, electricity, waster, etc.)
• Equipment is inherently safe and in compliance with US Federal and State regulatory compliance requirements.
• Contact ROEHS for review and approval of equipment including:
  1. CT scanners
  2. 3D printers
  3. Electron microscopes
  4. Emergency eyewash / safety shower
  5. Fume hoods and ventilated enclosures
  6. Gas chromatographs with electron capture detectors
  7. Gas monitoring equipment
  8. Gas scrubbers
  9. Gas storage cabinets
  10. Respirators (including SCBA)
  11. Static eliminator devices
  12. X-ray producing equipment
  13. Laser cutters
  14. Class 3d or 4 lasers

Before operating new equipment

• Perform a hazard review
• Develop a Standard Operating Procedure (SOP)
• Maintain user manual and all other technical documents in a safe place
• Train all users
  • Refresher training
  • Document training records

After operation of new equipment

• Make sure manufacturer’s required test, calibration, and maintenance is followed
• Re-evaluate the safety program and make adjustments as needed

Respiratory protection may be used only when engineering controls and safe work practices are not sufficient enough to prevent inhalation exposure to hazardous material. Using any respirator at work, including disposable N95, will require ROEHS review and pre-approval.

Program Elements

When working with hazardous materials, elimination, substitution, engineering controls, and safe work practices are the primary means to prevent employee overexposure to hazardous airborne materials. However, when these control methods are not sufficient, feasible, available, or when potential high exposure to hazards/risks prompts additional protection/mitigation, then wearing a respirator may be necessary. Major types of respirators include:

• Air Purifying Respirators (APRs, used for protection against particulates only)
  • Filtering Facepiece Respirators such as disposable N95
  • Elastomeric half-face respirators with replaceable filter/cartridges
  • Elastomeric full-face respirators with replaceable filters/cartridges
  • Powered air purifying respirators (PAPR) 
• Supplied Air Line Respirators (SALR)
• Self Contained Breathing Apparatus (SCBA)

Users who are required to wear respiratory protection must follow OSHA’s Respiratory Protection Standard (RPS) (29 CFR 1910.134). Selecting and using a respirator at JSNN will require the supervisor and Research Operations and Environmental Health and Safety (ROEHS) review and pre-approval. The following are the core elements of OSHA’s respiratory protection program:

1. Written respiratory protection program (RPP) with lab-specific procedures for respirator use
2. Medical evaluations
3. Fit testing
4. Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations
5. Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators
6. Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
7. Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations
8. Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance
9. Procedures for regularly evaluating the effectiveness of the program

JSNN-ROEHS will oversee the site specific aspects of the respirator protection program.The JSNN Respiratory Protection Program can be used as the site-specific written program if the forms and documents included in the appendices I-VI are completed and maintained up to date.  ROEHS will provide first testing and training and will assist PIs/labs with the development of the site specific program.

Roles and responsibilities

• Principal Investigators (PIs)
  1. Perform PPE assessment and identify students/employees who need respiratory protection and refer them to ROEHS
  2. Make sure that all individuals who are required to wear a respirator have completed and stay current with their medical, fit test, and training requirements
  3. Develop written SOPs/procedures for activities requiring a respirator
  4. Makes sure that all students/employees have access and use the respirators for the intended tasks, as identified by PI and approved by ROEHS
  5. Report any concerns or deficiencies to ROEHS for proper action
• Respirator users
  • Follow the respirator use requirements provided by ROEHS respiratory protection training
  • Wear the respirator as instructed by the PI and ROEHS
  • Inspects the respirators on a monthly basis and before and after each use
  • Understand the limitations and report any malfunction or concerns to the PI for proper action
  • Stay updated with the annual fit testing and training requirements
• JSNN ROEHS
  1. Develops and implements the JSNN Respiratory Protection Program
  2. Provides guidelines for respiratory protection compliance
  3. Provides required training and fit testing for the respiratory users
  4. Supports PIs and users with their regulatory compliance requirements
  5. Maintains training and fit testing records

Respiratory Exposure Hazard Assessment and Selection

The mandatory use of respirators can be based on exposure to hazardous substances above the occupational exposure limit (PEL, TLV, etc.). The initial step in the process is to perform a respiratory exposure hazard assessment. If there is any reason to believe that respiratory protection may be necessary,  a respiratory exposure hazard evaluation for each operation, process, or work area will need to be conducted.  This can be done by completing the JSNN  Respiratory Exposure Hazard Questionnaire (REHQ) . This form needs to be completed and forwarded to JSNN ROEHS (mhfahim@uncg.edu). If it is determined that respiratory protection is warranted, ROEHS will stipulate what type of respirator is appropriate for the specific exposure hazard.  The supervisor will keep a copy of the completed form.

Respirator selection requires correctly matching the respirator with the hazard, the degree of hazard/risk, and the user.  The following guidance and selection factors are used in this process:

• OSHA Technical Manual Section VII, Chapter 2.V. Respirator Selection
• OSHA’s Etools Respirator Selection
• NIOSH Respirator Selection Logic

All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification.

Medical Evaluation

Students/employees who need to use respirators must be able to tolerate the physical and psychological stress imposed by respirator use. Individuals will not be allowed to wear respirators until a physician or other licensed health care professional (PLHCP) has determined that they are medically able to do so. Individuals who forgo the medical evaluation cannot work in an area or process requiring respirator use.  The only exception to this medical evaluation is voluntary or comfort-use of filtering facepiece (N-95) respirators.

The following table provides a summary on the types of respirator, application, medical evaluation, and frequency of medical evaluations for JSNN respirator users:

Respirator type	Application	Medical requirements	Medical Frequency	Training Frequency	Fit Testing Frequency
Filtering facepiece (N-95) (voluntary use)	Non-hazardous particulate exposure	Initial ROEHS approval and signing  the Voluntary Use Form	N/A	N/A	N/A
Filtering- facepiece (N-95) (required use)	Infectious gents, metal/toxic particles	Medical exam	Initial onlyand when change in health status or deemed needed by healthcare provider	Annual	Annual
Half/Full-Face negative pressure air purifying orPowered Air Purifying Respirator (PAPR)	Chemical gases, vapors, metal fumes, etc.	Medical exam. Additional medical exams if deemed needed by healthcare provider	Annual	Annual	Annual
Self-Contained Breathing Apparatus (SCBA) or  Supplied Air Respirators	High risk chemical gases, vapors, metal fumes, emergency response, etc.	Medical exam. Additional medical exams if deemed needed by healthcare provider	Annual	Annual	Annual

Note: This medical requirement and frequency is for compliance with OSHA’s Respiratory Protection Standard only. There are different medical surveillance requirements and frequencies for employees who would come under other OSHA standards (silica, asbestos, lead, etc….).

All respirator users, including required use of a filtering facepiece (N-95) shall:

• Complete and submit the JSNN Respiratory Exposure Hazard Questionnaire (REHQ). JSNN-ROEHS needs to review and approve the form. 
• Complete the medical exam at a qualified center, using the
  • Medical Exam Request From . After the review of this form  by the healthcare provider (HCP),  the respirator users will either be cleared for respirator use, or scheduled for a follow-up medical examination
  • OSHA Respirator Medical Evaluation Questionnaire (This is confidential medical information and the employee must complete this questionnaire without help from their supervisor. Their supervisor must not look at or review the answers on this form)
• Obtain and bring a signed copy of the Respirator Use Medical Approval Form to JSNN-ROEHS. The employee and supervisor will receive a copy of the written recommendations, which will indicate whether or not they have been cleared to wear a respirator, and if there are limitations on such use.  Information concerning diagnosis, test results, or other confidential medical information will not be disclosed to their employer.
• Complete the JSNN respiratory protection training
• Complete the JSNN fit testing procedure (using their own respirator)
• Stay updated with the respiratory inspection, clean up, and annual training and fit testing

A powered air-purifying respirator (PAPR) must be provided to any employee if information from the HCP indicates that the employee can use a PAPR, but not a negative pressure respirator. If, subsequent to this evaluation, the HCP determines that the employee is able to wear a negative pressure respirator, the employer will no longer be required to provide a PAPR to that employee.

Additional medical evaluation or medical re-evaluation for any employee would be required when:

1. The employee reports medical signs or symptoms that are related to the employee’s ability to use a respirator
2. The PHCP, supervisor, or the respirator program administrator observes that the employee is having a medical problem during fit testing or workplace respirator use
3. Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee re-evaluation
4. A change occurs in workplace conditions (e.g., physical work effort, type of respirator used, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee

The flowchart below illustrates steps needed for the respiratory protection compliance:

Training and Fit Testing

Each employee required to wear a respirator must be trained prior to initial use.  For continued respirator use this training must be repeated at least every 12 months. The training must include at the least the following information:

1. Why the use of a respirator is needed;
2. What the respirator can and cannot do to protect the user;
3. How to properly inspect, put on, take off, and use the respirator;
4. How to check the seal of the respirator (also called a “user seal check”);
5. How to use the respirator effectively in emergency situations, including situations in which the respirator doesn’t work properly;
6. How to recognize medical signs and symptoms that may limit or prevent the safe use of a respirator;
7. How improper fit, usage, or maintenance can reduce the respirator’s ability to protect the user;
8. What the procedures are for maintenance and storage of the respirator; and
9. What are the requirements for  OSHA’s Respiratory Protection Standards and JSNN Respiratory Protection Program.

JSNN ROEHS will offer either classroom or on-line general training on proper respirator use.

In addition to the general training, site-specific training will need to be conducted by a supervisor. This training focuses on the specific practices and policies of the worksite and the employees’ responsibilities.

Fit-testing and fit-checks are important to ensure that there is a good seal between the face and respirator facepiece. For respirators which require a tight seal, beard growth is not permitted. Fit testing will be required for all employees who are required to wear a tight-fitting facepiece respirator and shall be performed:

1. After an employee has completed a medical evaluation and prior to being allowed to wear any respirator with a tight fitting facepiece in the work environment
2. Whenever a different respirator facepiece is used
3. At least annually thereafter
4. When there are changes in the employee’s physical condition that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.)

Employees will be provided with several models and sizes of respirators so that they may find the optimal fit.  JSNN ROEHS can provide fit testing as part of the hands-on training.

For details on fit testing and fit-checks see the OSHA Fit Testing Video and Procedures.

Chemical Cartridge and Filter Replacement Schedule

A Respirator Cartridge Change Schedule must be developed for cartridges or canisters used with air-purifying respirators that do not have an End of Service Life Indicator (ESLI).  The purpose of this is to prevent contaminants from breaking through the respirator’s sorbent cartridge(s), and thereby over-exposing employees. A cartridge replacement schedule is followed based on manufacturer breakthrough test data and/or OSHA guidance. The following links provide direction on this issue:

• Department of Labor Respirator Change Schedules
• 3M Respirator Cartridge and Filter Replacement Program

Chemical cartridges should not be used for more than 6 hours in dry conditions and no more than 4 hours in humid environments. Cartridges should not be left on respirators after use. For respirators worn exclusively for protection against particles, filters will be changed according to the manufacturer’s specification and whenever the wearer detects an increase in breathing resistance.  It is the responsibility of the supervisor to ensure that the change schedule is complete and updated as necessary.

Inspection, Cleaning, Storage, & Maintenance

Respirators should be inspected before and after each use, and during cleaning and sanitizing. During the inspection, the condition of the facepiece, straps, valves, filter and/or cartridge elements, air hose, and protective lens (full face or units with hoods) should be checked. If parts are worn or defective, make certain that the unit is repaired or replaced. Be alert that not all respirators have replaceable parts. Respirator parts for different brands, (i.e Scott or 3M), are not interchangeable. If in doubt, contact JSNN- ROEHS (mhfahim@uncg.edu).

Respirators, including Self Contained Breathing Apparatus (SCBA), maintained for emergency use, must be inspected monthly and after each use. Respirators that are maintained for use in emergencies will be certified by documenting the date that the inspection was performed, the name or signature of the inspector, the findings of the inspection, any required remedial action, and a serial number or other means of identifying the inspected respirator. This inspection shall follow the manufacturers’ instructions.

Respirators will be cleaned and disinfected using the manufacturer’s recommendations for each respirator. The frequency of cleaning and disinfecting as follows:

1. Respirators that are issued for the exclusive use of an employee will be cleaned and disinfected as often as necessary to be maintained in a sanitary condition. Employees will be responsible to clean and disinfect respirators issued for their exclusive use..
2. Respirators maintained for emergency use will be cleaned and disinfected after each use.

Store respirator to protect against dust, sunlight, extreme temperatures, physical damage, and moisture.  Use a separate bag to store filters and cartridges.  All respirators are to be maintained according to the manufacturer’s recommendations.

Breathing Air Quality

The supervisor will ensure that breathing air for atmosphere-supplying respirators will be of high purity, meets quality levels for content, and does not exceed certain contaminant levels and moisture requirements.

For supplied-air respirators (SARs), only Grade D breathing air shall be used in cylinders. Supervisor shall coordinate deliveries of compressed air with the approved vendor and require certification that the air in the cylinders meets the specifications of Grade D breathing air. Moisture content in the cylinders will not exceed a dew point of –50 °F (-45.6 °C) at 1 atmosphere pressure. Note: This requirement will prevent respirator valves from freezing, which can occur when excess moisture accumulates on the valves. All breathing gas containers must be marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.

Compressors used for supplying breathing air must be constructed and situated so contaminated air cannot enter the air-supply system. The location of the air intake will be in an uncontaminated area where exhaust gases from nearby vehicles, the internal combustion engine that is powering the compressor itself (if applicable), or other exhaust contaminants being ventilated will not be picked up by the compressor air intake.

Compressors will be equipped with suitable in-line, air-purifying sorbent beds and filters to further ensure breathing air quality and to minimize moisture content so that the dew point at 1 atmosphere pressure is 10 °F (5.56 °C) below the ambient temperature. Sorbent beds and filters will be maintained and replaced or refurbished periodically according to the manufacturer’s recommendations.  An inspection tag will be kept at the compressor indicating the most recent change date and the signature of the Program Administrator or designee authorized to perform the maintenance. Only non-oil-lubricated compressors will be used.

The supervisor will ensure that the compressor intake will not allow the introduction of carbon monoxide greater than 10 parts per million (ppm) into the system.

Note: This could be from sources other than the compressor such as forklifts/vehicles or other gas-powered equipment.

Breathing air couplings must be incompatible with outlets for non-respirable plant air or other gas systems to prevent accidental servicing of airline respirators with non-respirable gases or oxygen. No asphyxiating substance (e.g., nitrogen) will be allowed in the breathing airlines.

Voluntary use of N95

Voluntary or comfort users of respirators form must be submitted  before voluntary use is permitted while working at JSNN.

Record Keeping

The JSNN-ROEHS will retain a copy of the HCP’s written recommendation for each employee subject to medical evaluation. Each employee’s completed medical questionnaire, results of relevant medical tests, examinations, and diagnosis, etc., will be maintained by the HCP for a period of 30 years. Records of medical evaluations will be made available as specified in 29 CFR 1910.1020. The JSNN ROEHS will retain fit test records for respirator users until the next fit test is administered.  These records consist of:

1. Name or identification of the employee tested.
2. Make, model, and size of the respirator fitted.
3. Date of the fit test.
4. Fit factor and other records of the test.

The JSNN ROEHS will retain employee training records that include the names of employees trained and the dates when training was conducted.

 A current copy of the written respiratory protection program will be kept online.  All written materials are required to be maintained under the recordkeeping requirements, and will be made available, upon request, to the employee who is subject to the records.

Program Evaluation

The supervisor is responsible to conduct evaluations of the workplace, as necessary and inform ROEHS of any changes. Periodic program evaluation is required to ensure that the provisions of the respiratory protection program are being implemented for all employees using respirators. In addition, evaluations will be conducted to ensure the continued effectiveness of the program. Evaluations of the workplace will determine whether the correct respirators are being used and worn properly and will also serve to determine whether the training program is effective. The supervisor is responsible to periodically monitor employee use of respirators to ensure that they are being used and worn properly.

Supervisors, in conjunction with ROEHS will also regularly consult with employees wearing respirators to ascertain the student/employees’ views on program effectiveness and to identify any problems so that corrective action can be taken.

The following factors will be evaluated to determine program effectiveness:

1. Respirators are properly fitted and if employees are able to wear respirators without interfering with effective workplace performance.
2. Respirators and filters/cartridges are correctly selected for the hazards encountered.
3. Respirators are used properly depending on the workplace conditions encountered.
4. Respirators are being maintained and stored properly.

The Program Administrator will be responsible to correct any problems associated with wearing a respirator that are identified by employees or that are revealed during any other part of this evaluation.

Appendices

• Appendix I, Voluntary/Comfort Use of N95 Respirators Attestation
• Appendix II, Respiratory Exposure Hazard Questionnaire
• Appendix III, JSNN Occupational Medicine Exam Request Form
• Appendix IV, OSHA Respirator Medical Evaluation Questionnaire
• Appendix V, Respiratory Compliance Flow Chart

Emergencies include fire, flooding, medical, exposure, hazardous material release or spill, violence, utility failure, severe weather, or any other situation posing an immediate risk to health, life, property, research, or the environment and requires immediate intervention. Advanced planning, training, and drills and exercises are crucial in mitigating the impacts of such occurrences.

General

Emergencies include any natural or human-caused incidents, situations, or threats that can pose an immediate risk to human health and life, property, research, or the environment. Advanced planning and preparedness are the best methods for mitigation and minimizing the negative impacts of emergencies. View the emergency flip chart in your lab for more information on responses during and after emergency situations.

Report any non-emergency situations such as controlled/limited spills, chemical odors, or unsafe conditions that require immediate attention to your supervisor and ROEHS. Report any near miss incidents for further investigations. This will help us to perform a root cause analysis and make sure that a near miss will not turn into a real incident next time.

Life-threatening medical emergencies

1. Call 911
2. Inform your supervisor
3. Inform JSNN-ROEHS
4. Inform building security

Fire and explosion

1. Leave the area and close the door behind you. Assemble outside the building in the designated area.
2. If safe/possible, shutdown equipment and experiments that may become unstable while your lab is evacuated
3. Activate fire alarm pull station and call 911
4. Inform your supervisor and building security
5. Leave the area and close the door behind you
6. Do not use the elevators
7. Use fire extinguishers only if you are trained and the fire is small and under control. Otherwise, delayed 911 calls may result in a larger and out of control fire scenario

Major exposure (chemical, biological, ionizing radiation, etc.) requiring immediate medical attention

1. Call 911
2. Inform your supervisor
3. Inform ROEHS
4. In case of exposure to chemicals/biologicals, use eyewash station or safety shower for at least 15 minutes
5. If someone is assisting you, ask to obtain a copy of the chemical SDS
6. Inform building security

Spills (chemical/biological) that are not contained and pose an immediate risk to lab/building occupants

1. Leave the area and close the door behind you. Assemble outside the building in the designated area.
2. Call 911
3. Activate fire alarm pull station , if building/floor evacuation is needed
4. Inform your supervisor
5. Inform ROEHS
6. Inform building security
7. Do not return to incident area until cleared by ROEHS
8. Do not attempt cleaning up any spill without ROEHS approval

Spills (chemical/biological) that are contained and under control

1. Leave the area and close the door behind you
2. If safe, use absorbent pads and socks to prevent chemical from reaching into the drain
3. Call ROEHS at 919-357-1134

Toxic, pyrophoric, or flammable gas detection alarm

1. Leave the area and close the door behind you. Assemble outside the building in the designated area
2. Activate fire alarm pull station , if building/floor evacuation is needed
3. Call Gateway Facilities (336-217-5115)
4. Call 911 if you have observed uncontrolled gas release
5. Inform your supervisor
6. Inform ROEHS
7. Inform building security
8. Do not enter until cleared by ROEHS

Oxygen Deficiency Alarm

1. Leave the area and close the door behind you
2. Inform your supervisor
3. Inform ROEHS
4. Inform building security
5. Do not enter until cleared by ROEHS

Electricity and other utilities failure

1. Call Gateway Facilities (336-217-5115)
2. Inform your supervisor
3. Inform building security
4. Inform ROEHS for material/equipment safety concerns
5. Check equipment after utility is restored

Water leak/damage

1. Call Gateway Facilities (336-217-5115)
2. Inform building security
3. Inform your supervisor
4. Inform ROEHS
5. Protect hazardous material from coming in contact with water
6. Move/cover sensitive equipment
7. Do not enter flooded area due to electrical hazard

Violence, active shooter, or any threats

1. Call 911
2. Take shelter in place
3. Inform building security
4. Inform your supervisor

Severe weather

1. Follow the university emergency management updates
2. If trapped at work, shelter at a designated safe location
3. Call 911 for medical or other emergencies

Emergency Exits

To ensure proper evacuation during emergencies and to comply with building fire codes, all lab isles, exit doors, and exit routes outside the lab must stay free of obstruction at all times. Post an emergency exit map inside your research lab and mark the nearest exits. PIs must make sure that staff, students, and interns are aware of emergency exits and understand the emergency evacuation requirements. Routine fire drills will help researchers to better prepare for emergencies. ROEHS will conduct annual fire drills.  

Lab Emergency Preparedness Plan

Natural or human-made emergencies may interrupt building access, disrupt utilities, or require immediate evacuation. Advance preparation for unforeseeable incidents and emergency shutdowns will familiarize faculty, staff and students with actions required for mitigating the loss of research, property, or life. Please be aware that the unpredictable nature of emergency events sometimes prevents an orderly response. A Lab Emergency Preparedness Plan (LEPP) is developed by PIs with their research in mind. This plan will help researchers to:

• Plan in advance for protecting research materials, data, and information in case of a catastrophic event
• Minimize the impact of the incident on research and be able to continue their research with minimum interruption and/or damage
• Identify high risk activities and processes that need to be protected or disconnected before evacuation. Examples include reactions that may become unstable if not attended.
• Protect research materials during prolonged loss of utilities
• Protect researchers and manage a smooth and safe evacuation

PIs must use the JSNN-ROEHS template for their Lab Emergency Preparedness Plan 

View this page for a list of safety program compliance and application forms, safety training requests, and chemical and safety equipment quick fact sheets.

• Training Confirmation Form.docx
• JSNN Student off boarding checklist.docx
• Contractor safety
• Hazardous Waste Inspection Form
• Minor Agreement in Connection with activities in Research labs
• Parent Guardian Agreement Release and Consent
• JSNN Eyewash log- 2022
• Emergency Eyewash Fact Sheet .docx
• Chemical Fact Sheets:
  • Osmium Tetroxide Fact Sheet .docx    
  • Piranha solution Fact Sheet .docx
  • HF Fact Sheet .docx

Availability and ready access to Safety Data Sheets (SDSs) is a requirement under OSHA Hazard Communication and lab safety standards. Safety Data Sheet contains detailed information including risk and hazards associated with a specific chemical and is unique to each manufacturer. While electronic access is acceptable, chemical users are required to maintain hard copies of the appropriate SDS for high hazard and frequently/large volume used chemicals. Researchers must review contents of the SDS before placing a new order, using chemicals in a new experiment, or modifying an existing experiment. Bookmark and use the link below to the “MSDSonline” program as your SDS search tool:
https://chemmanagement.ehs.com/9/598cf5b1-6aaa-4458-97d7-220665c04d52/msdsonline-search/

Due to their size and enhanced surface area, nanomaterials may manifest chemical and physical properties different from their parent or bulk material. This could result in higher exposure risk and health and physical hazards. The procurement, generation, use, distribution, and disposal of nanomaterials at JSNN research labs require ROEHS review and approval.

This program refers to the procurement, generation, use, distribution, shipment, and disposal of nanomaterials at JSNN research labs. Nanomaterials include any particles or fibers with at least one dimension less than 100 nanometers (0.1 micrometer). All new experiments using nanomaterials must be reviewed and receive written approval by the Research Operations and Environmental Health and Safety (ROEHS) office. Researchers using nanomaterials must also adhere to the following program requirements:

1. All users must review the Requirements for Working Safely With Nanomaterials at JSNN Research Labs
2. Users must complete the annual nanomaterials safety training.
3. Users must perform a written hazard review and develop required Standard Operating Procedures (SOPs), where health and physical hazards associated with the material, as well as safe handling procedures and protective measures, are described for all users.
4. PIs must document the processes under their Lab Safety Plan or Chemical Hygiene Plan (CHP).
5. Research labs must have access to a functional fume hood and perform all processes involving the use of nanomaterials inside the hood (or a ROEHS-approved exhaust enclosure).

Resources and study references

Please review the following documents for more in-depth information on the safe handling of nanomaterials:

1. CDC/NIOSH- Safe Nanotechnology in the Workplace
2. CDC/NIOSH – General Safe Practices for Working with Engineered Nanomaterials in Research Laboratories
3. OSHA Fact Sheet – Working Safely with Nanomaterials
4. CDC/NIOSH- Controlling Health Hazards When Working with Nanomaterials
5. AIHA- Personal Protective Equipment for Engineered Nanoparticles

PIs must fulfill the JSNN approval process before bringing minors under the age of 18 to their research labs as volunteers. Parental/legal guardian agreement form must also be completed and signed in advance. See JSNN Policy for Minors as Volunteers (non-paid) and Visitors in Research Laboratories.

JSNN Policy for Minors as Volunteers (non-paid) and Visitors in Research Laboratories Version 1-2022

This policy is intended to protect minors (defined as individuals under the age of 18), who may potentially be exposed to hazardous materials in research laboratories. Minors under the age of 15 are not permitted to volunteer or work at JSNN laboratories.  

Visiting or touring minors aged 12-17

Minors aged 12-17 touring or passing through the JSNN laboratories must be under the direct supervision of a JSNN faculty or staff familiar with the area’s risks and hazards. High risk research activities must be halted during the visit. Prior to the tour/site visit, minors must receive a basic safety orientation, including both general safety information and any hazards particular to the lab being visited, and must require strict adherence to personal protective equipment (PPE) and proper attire, including closed-toe shoes and long pants, eye protection, and lab coat policies. Site visits requiring entering research lab spaces must be reviewed and approved in advance by JSNN ROEHS.

Minors aged 15-17 working as volunteers

Minors are not allowed to work with hazardous materials/equipment, participate in operations where hazardous materials are present, or where hazardous activities take place except under the following circumstances:

• PI submits an approval request form (two weeks in advance) to the JSNN Research Operations and Environmental Health and Safety (ROEHS) and receives approval.
• Minor provides parent/guardian-signed “Parent Guardian Agreement Release for Lab. from
• Minor provides signed “Minor Agreement Release for Lab”
• Minor receives all necessary safety training modules required by ROEHS and complies with JSNN Personal Protective Equipment (PPE) requirements.
• Minor only participates in research activities during normal business hours and is always accompanied with an assigned adult supervisor while in the research lab.

Minors are not allowed to work with or around X-ray producing devices or work with hazardous material and equipment. The scope, nature, and details of the minor’s work must be documented and attached to the Lab Safety Plan/Chemical Hygiene Plan.

Both the “Parental Agreement” and “Minor Agreement” forms must be archived with PI/Department and a copy of each form submitted to ROEHS.

By initiating the approval request form, PI also acknowledges that:

• He/she has read and is familiar with the requirements of this policy.
• Minor will be supervised by an assigned adult supervisor while in the lab. Minors are not allowed to perform activities alone.
• Minor will fulfill all required and necessary training.
• Minor’s safety and the safety of others present in the laboratory is assured.
• Proposed activities for minors are documented and permitted under the JSNN policies for Minors in Laboratories.

Under no circumstances shall individuals unable to understand safety training be permitted in laboratories. Safety training is tailored toward minor’s safety and includes general awareness about chemical, biological, and physical hazards, radiation safety, and emergency procedures. PIs must provide and document additional lab-specific safety training, including the introduction of their Chemical Hygiene Plan/Lab Safety Plan and conveying the roles and limitations of the minor’s activities.

For further information, please visit:

1. UNCG Policy Manual, Minors in Research Labs
2. UNCG Policy manual, Youth Programs
3. NC A&T POLICY 1111, Protection of Minors on Campus  
4. NIH NIH POLICY MANUAL, 3015 – Admittance of Minors to Hazardous Areas

Fume hoods and other local exhaust devices are the most important engineering control methods for minimizing or eliminating the exposure to airborne hazardous materials in research laboratories. All hazardous chemicals, including nanomaterials, must be transferred and used only in a tested and fully functional exhausted fume hood or other ROEHS-approved exhaust enclosures.

General

This Program is intended to bring all stakeholders in a collaborative approach toward establishing a Local Exhaust Ventilation Management Program (LEVMP). Laboratory fume hoods are the most important engineering control devices in research lab environments for preventing or minimizing exposure to airborne hazardous materials that are generated during the course of experiments or as a result of an incident or spill. These include liquids, gases, vapors, and particulate matters, including nanomaterials. Hazardous materials shall only be used inside a tested and functional exhausted fume hood. Other exhaust devices, including recirculated air (ductless) fume hoods, snorkels, gas cabinets, and exhaust enclosures are also used for limited applications in controlling and exhausting heat, odorous, and low hazard chemicals in low volume applications. Using any exhaust device other than an exhausted fume hood requires ROEHS review and approval.

Users must receive proper training, understand different exhaust devices and their application and limitations, and make sure that devices are used properly and based on their intended design. This program can only become successful if all users and stakeholders recognize and fulfill their roles and responsibilities.

Roles and Responsibilities

1. PIs
   • Make sure all users have received updated training on proper use of the fume hoods and other local exhaust devices.
   • Make sure that users understand the application and limitations and apply all required safety precautions and good work practices when utilizing the equipment.
   • Report all deficiencies, malfunction, and safety concerns to JSNN Research Operations and Environmental Health and Safety (ROEHS.
2. Users
   • Follow all guidelines provided in fume hood training.
   • Properly use the equipment based on their intended use as well as its limitations.
   • Receive proper safety and fume hood use training.
   • Avoid any misuse, alteration, or modification that may impact hood performance.
   • Report all deficiencies, malfunction, and safety concerns to the PI.
   • Avoid using fume hood or other exhaust devices that indicate insufficient flow through an alarm mechanism or a warning sign posted by ROEHS.
3. JSNN ROEHS
   • Performs bi-annual local exhaust inspections.
   • Provides training for users.
   • Issues work orders and follow ups on identified and reported deficiencies.
   • Develops and maintains local exhaust ventilation management program.
   • Communicates with Facilities Maintenance to ensure that proper preventive maintenance, calibration, and communication/tag-out procedures are in place during repair.
4. Facilities Maintenance
   • Responds to the issued work orders in a timely manner.
   • Communicates with ROEHS on any maintenance, shutdown, or system malfunction issues.
   • Maintains the mechanical, electrical, and electronic control systems fully functional and calibrated.
   • Develops a preventative maintenance program in compliance with JSNN local exhaust ventilation program requirements.

Equipment selection, installation and modification

Any new local exhaust ventilation system or the modification of an existing device or system requires JSNN ROEHS review and approval. This is critical for making sure that equipment meets applicable codes and standards, provides sufficient/intended protection, and is compatible with the building system and existing exhaust/supply capacity. 

Fume hood performance test

All fume hoods are inspected by JSNN ROEHS on a semi-annual schedule. All other exhaust devices are checked annually. Additional tests are performed for new installations, upon work order closure/post repair, after major modifications, or upon a user’s request.

Material and test equipment

• Materials
  • Fog generating liquid
  • Hood operating status labels
• Tools and equipment
  • TSI VelociCalc (hot-wire anemometer)
  • Small volume smoke generator
  • Tape measure

Local exhaust ventilation system test procedures

1. Constant Air Volume (CAV)
   • Fave velocity test
     • Set the VelociCalc at the 5-10 seconds interval set point.
     • Close the horizontal sash openings (if applicable).
     • Open the vertical hood sash to 18 inches (or lower for fixed sash height designs).
     • For manifold hoods, make sure all hoods inside the room are running with sash raised at 18” sash height (or lower for fixed sash height designs).
     • Make sure the lab door is kept closed during the test.
     • Divide the hood face opening into imaginary 1’ x 1’ grids. Using the hot-wire anemometer, measure the face velocity at the center of each grid. In the absence of a ring stand, use an articulated probe, rested on the sash (for upper row readings) or airfoil (for lower row readings). For satisfactory test results, the average of the readings (average face velocity) must fall between 90 fpm and 120 fpm.
     • Investigate the cause, if single readings are not within ± 20% of the average face velocity.
   • Cross drafts measurement
     • Measure the cross draft, as specified in the ASHRAE 110 test method. Investigate/correct cross drafts more than 50% of the average face velocity (ideally more than 30%).
   • Room pressurization test
     • Check the room pressurization with the hood sash at 18” (or lower for fixed sash height designs). Report if room pressurization is positive, too negative (10 fpm or more, measured at the room’s full door opening face, when all doors are fully open), or fluctuating compared to the hallway/adjacent non-lab areas.
   • Fume hood monitor/alarm check
     • Check monitor digital readout (if applicable) and audible/visible alarm functions.
     • Check mute button and any other monitor/ alarm functions
     • The low flow alarm should be set at 70 fpm (50 fpm for ductless hoods). High velocity alarms must be disabled.
   • Additional room and hood environment check
     • Supply diffuser location to the fume hood.
     • Fume hood location to the door, high traffic areas, or any other source of cross drafts.
     • Sash’s smooth movement check.
     • hood light switch
     • Electrical outlets
     • Airfoil integrity
     • Back baffle and side panels installation
     • Hood – work surface joints sealing
     • Any user’s modification or alteration, including air foil or back baffle blockage, obstacles, large equipment, or overloaded fume hoods.
2. Recirculating (ductless) hoods
   • Recirculating air hoods have several use/application limitations and must be approved by ROEHS before purchase.
   • Test procedure for the recirculating fume hoods is identical to the CAV hood test method. However, the average face velocity for ductless fume hoods must fall between 55-70 fpm.
   • In addition to test procedures for CAV hoods, recirculation hoods’ filter capacity, fan function, and chemical detection monitor function need to be verified.
3. Variable Air Volume (VAV) hoods
   • The following tests are required for the VAV hoods, in addition to the tests performed for the CAV hoods
     • Repeat the face velocity measurement at 13” sash height. Check if average face velocity stays rather constant, when compared to the measurement results at 18” (± 20%). Report drifts as “VAV valve/control modulation malfunction”
     • Whenever applicable, check the hood zone presence sensor, emergency purge button, and sash position alarm.
     • Check the room pressurization with all hood sashes at 18” and repeat with all sashes closed.

Fume hood test pass and fail criteria

• Green Sticker: Meets JSNN requirements
  • Fume hoods must have an average face velocity of 90 to 120 fpm (55-70 fpm for ductless hoods) with the sash at 18” from the hood work surface (or lower for fixed sash height designs). All hoods must pass a local visualization (smoke) test to meet the requirements. Capture of all smoke within 6 inches of the hood face (inside the hood) at 18” (or lower for fixed sash height designs) sash height is required to meet the standard.
  • All hoods and room environment elements/components impacting hood containment and performance, including sash movement, cross draft velocity, VAV control systems function, and hood loading and layout/obstruction meet the requirements.
• Red Sticker: Does Not Meet JSNN requirements (Do Not Use)
  • Any hood with an average face velocity of 89 fpm or less at 18” (or lower for fixed sash height designs) sash height.
  • Any recirculating hood/ductless hood with average face velocity of 54 fpm or less
  • Hoods defective for reasons other than face velocity such as failure of the local visualization smoke test, a non-operational sash, strong (50 fpm or more for exhausted hoods and 30 fpm or more for ductless hoods) cross draft, or a missing sash/baffle.
  • Hood is out of service and shall not be used until it’s fixed and verified by ROEHS
  • A “Do Not Use” sign will be posted to the sash. This sign stays posted until the hood is fixed and velocity is checked and verified by ROEHS. Only ROEHS is allowed to remove the sign after verification (tag-out procedure)
• Blue Sticker: Does Not Meet JSNN requirements
  • Hoods that have average face velocities above120 fpm@18” (or lower sash height for fixed-sash hoods. This number is 70 fpm for ductless hoods).
  • While some studies indicate loss of containment at 150 fpm or higher face velocities, blue stickers are mostly issued for energy conservation and room air optimization purposes.
  • Users can continue using the hoods posted with a blue sticker, while work order for face velocity adjustment is in progress.

Work order procedure

ROEHS issues a work order for deficiencies found/reported

• For fume hood performance /containment-related work orders, ROEHS will post the hood with a “Warning, Do Not Use Sign”.
• ROEHS will notify the PI when the hood is out of service.
• This sign will remain posted until the hood is fixed and revisited by ROEHS. Signs must only be removed by ROEHS once hood performance is found satisfactory (tag-out procedure).
• ROEHS will notify PI when the hood is back to normal operation.

Applicable Standards

1910. 29 CFR Part 1910.1450, “ Occupational Exposures to Hazardous Chemicals in Laboratories’”
1911. ASHRAE 110 (latest version) “Method of Testing Performance of Laboratory Fume Hoods”
1912. ANSI Z9.5 (latest version) “Laboratory Ventilation” standard
1913. NSF 49 1992 “Class II (Laminar Flow) Biohazard Cabinet”