A Chemical Hygiene Plan is a written laboratory safety program designed to protect employees from the health hazards associated with hazardous chemicals used in the laboratory. For workplaces covered by OSHA’s Laboratory Standard, 29 CFR 1910.1450 – Occupational Exposure to Hazardous Chemicals in Laboratories, the employer must develop and implement a written Chemical Hygiene Plan, commonly referred to as a CHP.
An effective Chemical Hygiene Plan does more than satisfy an OSHA requirement. It establishes how hazardous chemicals will be handled and used, identifies appropriate engineering controls and personal protective equipment, establishes employee information and training requirements, addresses emergency and medical procedures, and assigns responsibility for maintaining an effective laboratory chemical safety program.
The Chemical Hygiene Plan should be specific to the laboratory and the hazardous chemicals, procedures, equipment, and potential exposures present in that workplace. OSHA’s nonmandatory Appendix A specifically recommends a facility-specific CHP as the foundation of the laboratory’s chemical hygiene program.
What Is a Chemical Hygiene Plan?
OSHA defines a Chemical Hygiene Plan as a written program developed and implemented by an employer that establishes procedures, equipment, personal protective equipment, and work practices capable of protecting employees from the health hazards presented by hazardous chemicals used in the workplace.
For laboratories covered by 29 CFR 1910.1450, the plan must be capable of protecting employees from health hazards associated with hazardous chemicals and keeping employee exposures below applicable OSHA exposure limits. The plan must also be readily available to employees and their representatives.
In practical terms, the Chemical Hygiene Plan provides the framework for laboratory chemical safety, from the time chemicals enter the facility through their storage, handling, use, and eventual disposal.
Who Needs a Chemical Hygiene Plan?
OSHA’s Laboratory Standard generally applies to employers engaged in the laboratory use of hazardous chemicals as those terms are defined in 29 CFR 1910.1450. The standard is intended for laboratory-scale operations in which multiple chemical procedures or chemicals are used and the procedures are not part of a production process.
This can include many research, analytical, testing, educational, quality-control, development, and similar laboratories.
Not every workplace that uses chemicals is covered by OSHA’s Laboratory Standard. Production operations and activities that do not meet OSHA’s definitions of laboratory use and laboratory scale may instead be subject to other OSHA requirements.
For this reason, employers should first determine whether 29 CFR 1910.1450 applies to their laboratory operations before developing the Chemical Hygiene Plan around the standard.
OSHA Chemical Hygiene Plan Requirements
OSHA identifies specific elements that must be addressed in a compliant Chemical Hygiene Plan. The plan must describe the measures the employer will use to protect laboratory employees from hazardous chemicals.
At a minimum, the Chemical Hygiene Plan must address:
- Standard Operating Procedures (SOPs) relevant to safety and health when laboratory work involves hazardous chemicals.
- Criteria for selecting and implementing control measures, including engineering controls, PPE, and hygiene practices.
- Measures to ensure chemical fume hoods and other protective equipment are functioning properly.
- Employee information and training.
- Circumstances requiring prior approval before certain laboratory operations, procedures, or activities are performed.
- Medical consultations and medical examinations.
- Designation of personnel responsible for implementing the plan, including a Chemical Hygiene Officer.
- Additional protections for employees working with particularly hazardous substances.
A well-developed CHP normally expands upon these minimum requirements to address the laboratory’s actual operations.
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Laboratory Equipment Safety
Laboratory Hazard Assessment & Risk Assessment
Laboratory PPE
Laboratory Safety Inspections
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Laboratory Standard Operating Procedures (SOPs)
Medical Consultation & Chemical Exposure Response
Particularly Hazardous Substances
Respiratory Protection
Spill Prevention & Response
Chemical Hygiene Officer
OSHA requires the employer to designate personnel responsible for implementing the Chemical Hygiene Plan, including assignment of a Chemical Hygiene Officer (CHO).
The Chemical Hygiene Officer must be an employee who is qualified by training or experience to provide technical guidance in developing and implementing the Chemical Hygiene Plan. OSHA does not require the CHO to hold a particular organizational title.
Depending on the size and complexity of the laboratory operation, responsibilities of the Chemical Hygiene Officer may include:
- Developing and maintaining the Chemical Hygiene Plan.
- Assisting with laboratory chemical hazard assessments.
- Reviewing laboratory safety procedures and SOPs.
- Monitoring chemical procurement, storage, use, and disposal practices.
- Coordinating laboratory safety inspections.
- Evaluating chemical fume hoods and other exposure controls.
- Assisting with employee training.
- Reviewing chemical incidents and exposures.
- Tracking corrective actions.
- Reviewing the effectiveness of the laboratory’s chemical hygiene program.
OSHA also allows for establishment of a Chemical Hygiene Committee when appropriate.
Laboratory Chemical Safety Procedures
The Chemical Hygiene Plan should establish fundamental rules for the safe handling of hazardous chemicals.
Employees should understand the hazards of the chemicals they use before beginning work. This includes reviewing available Safety Data Sheets (SDSs), container labels, applicable SOPs, and other hazard information.
Laboratory chemical safety practices should address topics such as:
- Chemical purchasing and receiving.
- Chemical inventories.
- Container labeling.
- Safety Data Sheets.
- Chemical storage.
- Chemical compatibility.
- Chemical transfers.
- Handling highly hazardous chemicals.
- Laboratory housekeeping.
- Personal hygiene.
- Chemical fume hood use.
- Personal protective equipment.
- Spill prevention and response.
- Chemical waste management.
- Emergency procedures.
Laboratory employees should never perform unfamiliar hazardous chemical procedures without first understanding the hazards and required controls.
Standard Operating Procedures
The Chemical Hygiene Plan must include or incorporate standard operating procedures relevant to safety and health considerations when laboratory work involves hazardous chemicals.
The amount of detail necessary in an SOP depends on the operation and its hazards. A routine low-hazard procedure may require relatively simple instructions, while work involving highly toxic, reactive, pyrophoric, explosive, corrosive, or otherwise hazardous substances may require a detailed written procedure.
A laboratory SOP may address:
- Chemicals and hazards involved.
- Required equipment.
- Engineering controls.
- PPE.
- Safe handling procedures.
- Operating limits or restrictions.
- Chemical incompatibilities.
- Storage requirements.
- Spill and emergency procedures.
- Waste disposal.
- Decontamination.
- Required approvals.
- Procedures for equipment or control failure.
SOPs should reflect how the work is actually performed rather than serving only as generic safety statements.
Chemical Storage and Compatibility
Proper chemical storage and compatibility are essential parts of laboratory chemical safety.
Chemicals should be stored according to their hazards and compatibility rather than simply alphabetically. Incompatible chemicals must be separated when contact between them could cause a fire, explosion, release of toxic gas, violent reaction, or other hazardous condition.
Examples of chemical groups that may require separation include:
- Acids and bases.
- Oxidizers and organic or combustible materials.
- Water-reactive chemicals and aqueous materials.
- Flammable liquids and ignition sources.
- Cyanides or sulfides and acids.
- Strong oxidizing acids and incompatible organic acids.
- Highly reactive or pyrophoric chemicals.
Chemical storage should also consider container integrity, shelf loading, secondary containment, temperature, ventilation, security, and accessibility.
For additional information, see Chemical Storage and Compatibility.
Chemical Fume Hood Safety
A chemical fume hood is one of the most important engineering controls available for reducing employee exposure to hazardous chemical vapors, gases, fumes, and aerosols.
OSHA requires a Chemical Hygiene Plan to include a requirement that fume hoods and other protective equipment function properly and to specify measures for ensuring their proper and adequate performance.
Laboratories should establish procedures for inspection, testing, maintenance, and proper use of chemical fume hoods.
Employees should understand:
- When a chemical fume hood is required.
- How to determine whether the hood is operating.
- Proper sash position.
- How equipment placement affects airflow.
- Why the hood should not be unnecessarily cluttered.
- What to do if airflow is lost or an alarm activates.
- The limitations of a chemical fume hood.
A fume hood should not be treated simply as a convenient location for chemical storage.
For additional information, see Chemical Fume Hood Safety.
Laboratory PPE
Personal protective equipment is an important component of laboratory chemical safety, although PPE should not replace feasible engineering and work-practice controls.
Appropriate laboratory PPE is determined by the chemicals being used, routes of potential exposure, quantities, procedures, and foreseeable incidents.
Depending on the hazard, PPE may include:
- Safety glasses.
- Chemical splash goggles.
- Face shields.
- Chemical-resistant gloves.
- Laboratory coats.
- Chemical-resistant aprons.
- Protective sleeves.
- Appropriate footwear.
- Respiratory protection when required.
Glove selection is particularly important because no single glove material provides adequate protection against every chemical.
Where respiratory protection is necessary, OSHA requires respirators to be selected and used in accordance with the Respiratory Protection Standard, 29 CFR 1910.134.
For additional information, see Laboratory PPE.
Particularly Hazardous Substances
OSHA requires additional employee protection for work involving particularly hazardous substances.
For purposes of the Laboratory Standard, these include:
- Select carcinogens
- Reproductive toxins
- Substances with a high degree of acute toxicity
The Chemical Hygiene Plan must give specific consideration to additional protections for these substances, including, where appropriate:
- Establishment of a designated area.
- Use of containment devices such as chemical fume hoods or glove boxes.
- Procedures for safe removal of contaminated waste.
- Decontamination procedures.
The appropriate controls should reflect the particular substance, quantity, procedure, exposure potential, and consequences of an uncontrolled release.
Prior Approval of High-Hazard Operations
Not every laboratory procedure should be allowed to begin solely at the discretion of the individual performing the work.
OSHA requires the CHP to identify circumstances under which a laboratory operation, procedure, or activity requires prior approval from the employer or the employer’s designee before implementation.
A laboratory might require prior approval for activities involving:
- Particularly hazardous substances.
- Highly reactive or unstable chemicals.
- Pyrophoric materials.
- Explosive or potentially explosive reactions.
- Significant scale-up of an existing procedure.
- New or unfamiliar hazardous chemistry.
- Operations involving unusual temperatures or pressures.
- Unattended high-hazard operations.
- Procedures where failure of a control could create a serious exposure.
Prior approval provides an opportunity to evaluate the hazards and controls before the work begins.
Safety Data Sheets and Chemical Labeling
Employees must have access to reliable information about the chemicals used in the laboratory.
Under OSHA’s Laboratory Standard, employers must ensure that labels on incoming containers of hazardous chemicals are not removed or defaced. Employers must also maintain Safety Data Sheets received with incoming hazardous chemicals and ensure that they are readily accessible to laboratory employees.
Laboratory procedures should establish requirements for labeling secondary containers and identifying solutions, mixtures, samples, reaction vessels, and other containers so employees can understand their contents and hazards.
Unknown or inadequately identified chemicals can create serious problems during normal operations, spill response, emergency response, and waste disposal.
Exposure Controls
The Chemical Hygiene Plan must establish criteria for determining and implementing measures to reduce employee exposure to hazardous chemicals.
Controls should generally emphasize preventing exposure rather than relying exclusively on PPE. Depending on the operation, controls may include:
- Substitution with a less hazardous chemical or process.
- Enclosed processes.
- Chemical fume hoods.
- Local exhaust ventilation.
- Glove boxes.
- Splash guards or barriers.
- Process isolation.
- Administrative controls.
- Safe work practices.
- PPE.
OSHA’s nonmandatory Appendix A recommends applying the hierarchy of controls and emphasizes engineering controls before administrative measures, work practices, and PPE where feasible.
Exposure Monitoring
Employee exposure monitoring may be required when there is reason to believe exposure to an OSHA-regulated substance routinely exceeds the applicable action level or, when no action level exists, the permissible exposure limit.
When monitoring is required, it must be performed in accordance with the relevant OSHA requirements. OSHA also requires employees to be notified of monitoring results within 15 working days after the employer receives the results, either individually in writing or by posting the results in an appropriate location accessible to employees.
Exposure monitoring may also be useful when evaluating new procedures, investigating control failures, or determining the effectiveness of engineering controls.
Medical Consultation and Medical Examinations
Employees working with hazardous chemicals must be provided an opportunity for medical attention under specified circumstances.
These include when:
- An employee develops signs or symptoms associated with possible hazardous chemical exposure.
- Required exposure monitoring shows routine exposure above an applicable action level or PEL under circumstances triggering medical surveillance.
- A spill, leak, explosion, or other event creates the likelihood of hazardous exposure.
Medical consultations and examinations required by the Laboratory Standard must be performed by or under the direct supervision of a licensed physician and provided without cost to the employee, without loss of pay, and at a reasonable time and place.
Chemical Spills and Laboratory Emergency Procedures
The Chemical Hygiene Plan should coordinate with the laboratory’s emergency procedures so employees know what to do when normal controls fail.
Employees should know how to respond to:
- Chemical spills.
- Chemical splashes and exposures.
- Fires.
- Uncontrolled chemical reactions.
- Fume hood or ventilation failures.
- Gas releases.
- Damaged chemical containers.
- Equipment failures.
- Evacuations.
A critical part of emergency planning is distinguishing between a small incidental spill that trained laboratory personnel can safely manage and an emergency release requiring evacuation and specialized response.
Emergency eyewashes, safety showers, spill-control materials, alarms, emergency contacts, and other required equipment should be accessible and maintained for the hazards present.
For additional information, see Laboratory Emergency Procedures.
Laboratory Safety Training
Employees must receive information and training sufficient to understand the hazardous chemicals in their work areas and the measures necessary to protect themselves.
OSHA requires this information at the time of an employee’s initial assignment to an area where hazardous chemicals are present and before assignments involving new exposure situations. The employer determines the frequency of refresher information and training under the Laboratory Standard.
Training must address, as applicable:
- Methods used to detect the presence or release of hazardous chemicals.
- Physical and health hazards of chemicals in the work area.
- Measures employees can use to protect themselves.
- Appropriate work practices.
- Emergency procedures.
- Required PPE.
- Applicable details of the employer’s Chemical Hygiene Plan.
Employees must also be informed of the location and availability of the Chemical Hygiene Plan, applicable exposure limits, signs and symptoms of chemical exposure, and reference materials such as Safety Data Sheets.
For additional information, see Laboratory Safety Training.
Laboratory Safety Inspections
Routine laboratory inspections help determine whether the Chemical Hygiene Plan is actually being implemented.
A laboratory safety inspection may evaluate:
- Chemical storage and compatibility.
- Chemical labeling.
- SDS availability.
- Chemical fume hood condition and use.
- PPE availability and use.
- Emergency eyewashes and safety showers.
- Spill-control materials.
- Waste containers.
- Housekeeping.
- Compressed gas cylinders.
- Electrical and equipment hazards.
- Emergency exits.
- Training and documentation.
OSHA’s nonmandatory Appendix A recommends regular inspections and follow-up to ensure identified deficiencies are corrected.
For additional information, see Laboratory Safety Inspection and Laboratory Safety Checklist.
Chemical Waste Management
Laboratory chemical waste must be identified, segregated, accumulated, stored, and disposed of according to its hazards and applicable environmental requirements.
Employees should not dispose of laboratory chemicals into sinks, ordinary trash, outdoors, or through evaporation unless the particular disposal method has been evaluated and specifically authorized.
Waste procedures should address:
- Waste identification.
- Chemical compatibility.
- Waste segregation.
- Container selection.
- Container closure.
- Labeling.
- Accumulation areas.
- Spill prevention.
- Waste pickup and disposal.
- Unknown chemicals.
- Reactive or unstable waste.
Waste management should be considered when planning an experiment rather than only after the waste has already been generated.
Chemical Hygiene Plan Review
A Chemical Hygiene Plan is not intended to remain unchanged indefinitely.
OSHA requires employers to review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary.
The review should consider changes such as:
- New hazardous chemicals.
- New laboratory procedures.
- New equipment or technology.
- Changes in personnel or responsibilities.
- New or revised exposure information.
- Laboratory inspection findings.
- Chemical spills or exposure incidents.
- Employee concerns.
- Changes in regulatory requirements.
- Identified weaknesses in existing controls.
The annual review should evaluate whether the plan is actually protecting employees—not merely whether the document exists.
Chemical Hygiene Plan Checklist
A basic Chemical Hygiene Plan checklist can help determine whether the written plan addresses OSHA’s core requirements:
- Written Chemical Hygiene Plan established and implemented.
- Chemical Hygiene Officer designated.
- Responsibilities clearly assigned.
- Laboratory-specific chemical hazards evaluated.
- Appropriate SOPs established.
- Chemical storage and compatibility procedures established.
- Engineering-control criteria established.
- Fume hood and protective-equipment performance addressed.
- Laboratory PPE requirements established.
- Employee information and training addressed.
- Prior-approval requirements identified.
- Medical consultation and examination provisions established.
- Particularly hazardous substances addressed.
- Designated areas established where appropriate.
- Chemical spill and emergency procedures established.
- Chemical waste and decontamination procedures addressed.
- Chemical labels and SDSs maintained.
- Exposure monitoring addressed where applicable.
- Plan readily available to employees.
- Chemical Hygiene Plan reviewed at least annually.
- Plan updated when necessary.
This checklist is a useful starting point, but the adequacy of a CHP ultimately depends on whether it addresses the actual chemicals, procedures, equipment, and exposure hazards of the particular laboratory.
Chemical Hygiene Plan vs. Laboratory Safety Manual
A Chemical Hygiene Plan and a Laboratory Safety Manual are closely related, but they are not necessarily the same document.
The Chemical Hygiene Plan specifically addresses employee protection from hazardous chemicals under OSHA’s Laboratory Standard. A broader Laboratory Safety Manual may also cover hazards such as:
- Biological safety.
- Compressed gases.
- Cryogenic liquids.
- Electrical safety.
- Centrifuges and autoclaves.
- Machine guarding and Lockout/Tagout.
- Radiation and lasers.
- Laboratory animals.
- Ergonomics.
- Security.
- Waste management.
- General laboratory practices.
The CHP can therefore be a standalone document or an identifiable component of a more comprehensive Laboratory Safety Manual, provided the applicable OSHA requirements are addressed and the plan is readily available to employees.
Developing a Chemical Hygiene Plan for Your Laboratory
A useful Chemical Hygiene Plan should be built around the laboratory—not simply copied from a generic template and filed away.
Start by identifying the hazardous chemicals and procedures used in the laboratory. Determine how employees could be exposed, what engineering controls are available, what PPE is necessary, which procedures require written SOPs or prior approval, and how emergencies and exposures will be handled.
Then assign responsibility for implementing the program, provide employees with the required information and training, inspect laboratory operations, correct identified deficiencies, and periodically evaluate whether the program is working as intended.
OSHA describes the CHP as the foundation of the laboratory chemical-safety program and requires covered employers to implement—not merely possess—the written plan.
Chemical Hygiene Plan Template
Employers developing a Chemical Hygiene Plan should customize the document to their laboratory operations, hazardous chemicals, equipment, personnel, and procedures.
A comprehensive plan may include:
Purpose and Scope → Responsibilities → Chemical Hygiene Officer → Hazard Identification → Chemical Procurement and Inventory → Standard Operating Procedures → Chemical Handling → Chemical Storage and Compatibility → Engineering Controls → Chemical Fume Hoods → Laboratory PPE → Particularly Hazardous Substances → Prior Approval → Exposure Monitoring → Medical Consultation → Spill and Emergency Procedures → Chemical Waste → Employee Training → Inspections → Recordkeeping → Annual Program Review
A properly developed plan gives employees a practical framework for working safely with hazardous chemicals while helping the employer meet the requirements of OSHA’s Laboratory Standard.