Chemical
Chemical safety begins with lab directors (faculty/lab managers/supervisors) identifying and reducing the risks involved when working with chemicals. As a lab director, you are required to adopt and implement the University of Michigan (U-M) Standard Chemical Hygiene Plan (CHP), and where necessary, write Standard Operating Procedures (SOPs) for safety specific to the hazardous materials and methods used in your lab.
Chemical Hygiene Plan
Proper use of the CHP helps to ensure that research faculty, staff, and students who handle hazardous chemicals have the proper training and safety protections required under the law. The CHP provides the basic rules and guidelines generic to U-M research operations and every member of the laboratory is expected to read and understand it.
- Chemical Hygiene Plan (Updated June 2024)
- EHS Document Binder
- PPE Hazard Assessment & PPE Recommendations
Standard Operating Procedures
Templates
NOTE: This list will be updated as new SOPs are developed either by Environment, Health & Safety (EHS) or members of the U-M research community – please share your SOPs with others by sending a copy to EHSLabSafety@umich.edu.
Chemical Labeling
Labels are a highly effective and efficient method to communicate hazard information and prevent accidents and injuries. Clear and consistent labeling that follows the MIOSHA Hazard Communication Standard (HCS) is required in all University of Michigan laboratories, shops, studios, and other locations where employees use, store, or transport chemicals.
The HCS as it applies to laboratories requires that labels on incoming containers of hazardous chemicals must not be removed or defaced until the container is empty and rinsed. No chemical shall be accepted without an adequate identifying label. Original containers should be labeled with the date received and the date opened. This is particularly important for peroxide-forming compounds and other chemicals that become unstable over time, and it is good laboratory practice for ALL chemicals.
Many University workplaces, including laboratories, shops, and other facilities, purchase hazardous chemicals or products in large quantities, concentrates, or for mixing with other chemicals. To use the chemical/product it may need to be transferred to a smaller or different “secondary” container (e.g., vials, flasks or bottles) for dilution, mixing, or general use. The HCS requires secondary chemical container labels contain at least the following information:
- Full chemical name (no abbreviations)
- Concentration (e.g., percent, molarity, etc.)
- Hazards, if known or suspected (e.g., “flammable”, “corrosive”, “irritant”)
If you transfer a hazardous chemical into a secondary container, the secondary container must be correctly labeled to ensure workers are readily aware of the contents and understand the hazards. Labels can be handwritten or printed.
Secondary container labels are not required if both of the following apply:
- The reagent, stock solution and chemicals mixed for use are under the direct control of the person who transferred or prepared it, and
- The container will be emptied during that person’s work shift.
EHS has a limited selection of secondary chemical container labels that labs can request. Click the link above for more details and to place an order. Availability is not guaranteed. Labels will be delivered via campus mail. Labels are available in the two sizes shown below, with or without a protective cover sheet.
Downloadable label templates
EHS has developed templates for labs to make their own customized labels for use on secondary chemical containers. All templates are sized for printing on Avery 5263 or other compatible 2” x 4” label sheets.
In addition, the GoldFFX Safety Data Sheet program has the capability of creating and printing various size labels for use in the lab.
Peroxide-forming Chemical Labels
Containers with peroxide-forming chemicals listed in the Peroxide Forming Chemicals SOP, must be dated upon receipt and again when the container is opened so that the user can dispose of the material according to the recommendations on the SDS. Peroxide formers must be tested regularly as outlined in the SOP. For more information about labeling, storage, and handling of peroxide-forming chemicals, refer to the Peroxide Forming Chemicals SOP.
EHS has developed templates for labs to make their own labels for use with peroxide-forming chemicals. There are two size options available depending on the size of the container.
EHS has developed templates for labs to make their own labels for use with peroxide-forming chemicals. There are two size options available depending on the size of the container.
Chemical Waste Labels
All chemical waste containers must be labeled with the appropriate hazardous waste label. Containers need to be labeled as soon as waste begins to be accumulated in them. Hazardous waste labels are available by request on the EHS website.
Regulation of Methylene Chloride (Dichloromethane) under TSCA
In May 2024, the US Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (also known as DCM or Dichloromethane) under the Toxic Substances Control Act (TSCA). The regulation prohibits most industrial and commercial uses of methylene chloride and creates strict workplace protections for 13 conditions of use that are permitted under the new rule.
Detailed information about the EPA ruling, including the full text of the regulation, is available on the EPA website.
Methylene Chloride Workplace Chemical Protection Program (WCPP)
Laboratories and other research areas that use methylene chloride must do so in compliance with the U-M Workplace Chemical Protection Plan (WCPP).
Laboratories and other research units are required to evaluate options for eliminating methylene chloride from their operations or substitute it with a less hazardous alternative. Units that continue use of methylene chloride must be granted approval by EHS, implement all components of the U-M WCPP, and maintain personal exposures below the EPA exposure limits.
Appendix A: Operation Specific Exposure Control Plan (ECP)
Appendix A: Operation Specific Exposure Control Plan documents actions taken to mitigate occupational exposures and comply with the WCPP. This includes information regarding the operation involving methylene chloride, the control methods in place, and for control measures not selected, the rationale for why they cannot be implemented.
Supervisors, or a competent representative must complete Appendix A for any operation involving methylene chloride. Multiple operations by one user group may be listed under a single ECP, only if the controls implemented for the operations are the same. Multiple ECP forms may be required if the operations involve substantially different control measures.
Completed ECP forms must be submitted to EHS and a local copy should be stored with the group’s Chemical Hygiene Plan Documentation.
Implementation Timeline
December 2024: Initial publication of the WCPP and ECP
January 2025 – April 2025: Initial exposure assessment and personal exposure monitoring
Action items: All laboratories, shops, and studios should review their chemical storage areas to ensure an accurate inventory record of all methylene chloride and methylene chloride containing (≥0.1%) mixtures. Old, surplus, and unneeded inventory of methylene chloride should be sent for disposal via EHS and removed from the MISP inventory.
Units that plan to continue to use of methylene chloride:
- Evaluate options to eliminate or substitute for a safer alternative.
- Review current procedures and identify potential sources of high exposure. Implement controls to minimize exposures wherever possible.
- Complete the initial survey to briefly describe your intended operations
EHS representatives will contact units that have reported they intend to continue to use methylene chloride or have methylene chloride listed in their chemical inventory. The initial exposure assessment and personal exposure monitoring will consist of a review of procedures conducted, exposure controls utilized, and monitoring of airborne methylene chloride concentrations within the breathing zone of exposed persons.
Following exposure monitoring that shows exposures are below the EPA exposure limits, the Exposure Control Plan will be finalized to document the control measures.
If the results of the initial monitoring are not below the EPA exposure limits, additional controls must be implemented. Subsequent monitoring will be required to verify the effectiveness of the new controls.
August 1, 2025: Compliance deadline
By this date, all activities involving methylene chloride must be in compliance with the WCPP and be approved for use by EHS. Activities that cannot meet these requirements will not be permitted to continue. EHS must be notified prior to commencing any new operation involving methylene chloride.