Chemical Safety

University personnel using hazardous materials in their research and/or teaching laboratories, including spaces where chemicals are used/stored, must generate an inventory listing and update it annually. This policy resulted both from negotiations with the State Fire Marshal related to chemical use and storage and concerns raised by accidents at other universities, as well as the Federal Bureau of Investigation. The registration process has been vetted through the University Environmental Health and Safety Committee, the Chemical Safety and Hazardous Materials Management Committee, and the Occupational Health and Safety Committee. Registration is completed through the Safety Management System. For additional information, please contact 540-231-3600. This requirement is relevant to all departments, colleges, laboratories, centers, and institutes where work is performed using hazardous materials or where conditions exist that could result in immediate or serious harm. The registration is required to be updated annually.

You can begin the registration of your chemicals and/or the creation of your lab or workgroup in the SMS by click here.

To download instructions on using the SMS, click here.

Three types of chemical containers used in the lab or work areas are subject to container labeling requirements:

1. Primary or original manufacturer containers have labels that are prepared by the manufacturer. 
2. Secondary containers have labels referred to as alternative workplace labels that are prepared by the user of the chemical container. Secondary containers are defined as containers into which chemicals are transferred from the original manufacturer container for use in a lab or work area.
3. Transfer containers are used solely to transfer chemicals from a labeled container to a secondary container or for immediate use. Such containers may not require a label when immediately emptied.

The labeling requirements for each of these container types is described below and summarized in this Table. Lab personnel or other users must understand the information conveyed by the manufacturer on the primary container labels and must understand how to prepare and understand any alternate workplace container labels.

Work activities are often performed in areas where chemicals are transferred through pipes. These pipes are not required to be labeled; however, the employee needs to be aware of potential hazards. Prior to starting work in areas having unlabeled pipes, the employee should contact their supervisor to determine:

• The identity of the chemical in the pipes;
• The potential hazards of the chemical; and 
• Necessary safety precautions to be taken to protect the employee.

If engineering controls are being used, such as working within a properly functioning fume hood or glove box, exposure is not expected. However, if engineering controls are not functioning properly or have not been employed, air monitoring may be warranted. Examples include fume hood failure, glove box failure, chemical spill, gas leak, explosion, or fire. Contact 540-231-3600 to arrange employee exposure monitoring.

For more information regarding Environmental Health & Safety services and requirements for substances with a Permissible Exposure Limit (PEL), click here.

Employers must review safety data sheets for chemicals/products used in the workplace to determine if they may be hazardous to personnel during work applications. Contact Environmental Health & Safety for assistance if the information provided is confusing or unclear. 

If a chemical/product presents either a physical or a health hazard, it is considered a hazardous product, and should therefore be included in the plan. 

In addition to hazardous products, the following are examples of items that should be evaluated by the designated responsible person to determine whether they should be included in the department's Hazard Communication Plan. 

• Wood or wood products that have been treated with a hazardous chemical and wood that may be subsequently sawed or cut generating dust must be included. (Wood products not treated and not sawed/cut are exempt and do not need to be included.) For example, carpenters who cut/saw/sand wood should include wood in the plan because exposure to some wood dust may result in potentially adverse health effects. 
• Articles, that under normal use conditions, have a potential for chemical release must be included (drill bits, for example). Articles that have no potential for chemical release are exempt and do not need to be included.
• Consumer products (that pose a physical or health hazard) used for a duration and frequency greater than what regular consumers would experience must be included. Consumer "over-the-counter" products used for the same/less duration and frequency than a normal consumer would use are exempt and do not need to be included. For example, cleaning products used by a custodian or housekeeper should be included in the plan because exposure will be greater than what a regular consumer would experience. 
• Nuisance particles that pose a physical or health hazard must be included. Nuisance dust and particles that do not pose a physical or health hazard do not need to be included. For example, grain dust. 

Because all substances are potentially hazardous - given the right dose and exposure - general precautions for handling chemicals should be adopted. Even for substances with no known significant hazard, exposure should be minimized. In general:

• Avoid skin contact (absorption hazard). 
  • Use appropriate personal protective equipment and apparel. Refer to the Personal Protective Equipment Program for more information.
  • Inspect gloves, confinement boxes, hoods, aprons, etc. for contamination or holes which might compromise their protective qualities.
• Avoid inhalation.
  • Do not purposely sniff chemicals.
  • When possible, work with hazardous chemicals/products inside a properly functioning fume hood (for laboratory applications) or in a well-ventilated area. 
  • Where engineering controls, such as the use of fume hoods, glove boxes, non-hazardous chemical substitution, or local exhaust ventilation systems are not possible, appropriate respiratory protection should be used. Refer to the Respiratory Protection Program for more information.
• Avoid ingestion.
  • Never taste chemicals.
  • Never pipette laboratory chemicals by mouth suction.
  • Do not eat/drink in areas where chemicals are in use. Contamination of food/drink is possible.
  • Do not store food/drink near chemicals. Chemical vapors may be absorbed by food.
  • Chemicals and chemical equipment must not be allowed in areas designated for the consumption, storage, and handling of foodstuffs.
  • Never use laboratory glassware or other containers to store or serve food/beverages.
  • Food must never be stored in the same refrigerator or freezer as chemicals or biological samples. Refrigerators, freezers, microwaves, ovens, etc. designated for food storage and use must be labeled "FOOD ONLY." Refrigerators, freezers, microwaves, ovens, etc. designated for laboratory use must be labeled "FOOD OR BEVERAGE MUST NOT BE STORED IN THIS UNIT."
  • Thoroughly wash hands after handling or using chemicals.
  • Do not smoke in areas where chemicals are in use. Per university policy No. 1010, smoking is not permitted inside any Virginia Tech building.

In order to avoid accidental spills and/or contamination, proper storage, use, and handling procedures must be established and followed.

• Only a quantity of hazardous chemicals that will be used during that shift are permitted out of approved storage locations.
• Work areas must be kept clean and orderly.
• Containers should be kept tightly sealed. Stoppers and other loosely fitting lids are not acceptable for permanent chemical storage.
• Chemicals or products that are no longer needed should be disposed of properly. Do not simply pour liquids down the drain. If the container label does not specify the proper disposal method, contact Environmental Health & Safety at 540-231-2982 for guidance. Chemicals no longer needed or used are considered waste and should be disposed of through Environmental Health & Safety. Refer to the online program on waste removal. 
• Chemical containers should be inspected regularly for signs of leaking, rust, or deterioration which may make them inherently dangerous (example: crystal formations).
• When it is necessary to move chemical containers "in-house", additional precautions may be necessary. Flammable liquids or corrosives should be transported in an appropriate safety-carrying container. Compressed gas cylinders must be in an upright position, regulators removed, cylinder caps in place, and secured in a cart manufactured for such purposes.

Proper storage of hazardous products is an important part of a department's program. It minimizes the risk of fires, explosions, accidental spills or releases, and helps to maintain a safe path of egress for building occupants in the event of an emergency. 

Specific information regarding storage may be found on the product container label or the safety data sheet. Unless otherwise specified by the manufacturer, store chemicals in a cool, dry, well-ventilated location that is out of direct sunlight. General guidelines for each type of hazardous chemical are provided below.

All hazardous waste must be properly disposed of through Environmental Health & Safety. Waste that requires handling and disposal includes chemicals, radioactive materials, infectious materials, lead dust, and asbestos waste. For more information, refer to waste disposal.

The Virginia Tech chemical hygiene plan (CHP) is included as part of Environmental Health & Safety's Chemical Safety Program. The chemical hygiene plan is designed to be reviewed online, but a paper copy can be obtained using the printer-friendly link provided.

All faculty, staff, and students (both paid and work-study) who work in a lab are required to have access to a chemical hygiene plan. A laboratory is defined (by OSHA) as a facility where:

• Chemical manipulations are carried out on a "laboratory scale;"
• Multiple chemical procedures are used;
• Procedures are not part of a production process; and
• Practices and equipment exist to protect employees from exposure to hazardous chemicals.

Laboratory scale means that work is conducted in containers that are designed to be manipulated by a single person. The majority of Virginia Tech's laboratories fit this OSHA definition, and must therefore maintain a chemical hygiene plan.

If you are unsure whether or not your facility meets this definition, please contact the University Chemical Hygiene Officer Autumn Timpano at actimpano@vt.edu or 540-231-3427.

The Laboratory Requirements section includes reference information and a link to the Laboratory-Specific document. Formerly known as Part B of the chemical hygiene plan this laboratory-specific documentation must be completed and maintained on file for all chemical/biological laboratories.

Storage of chemical hygiene plan

The chemical hygiene plan must be stored in a central location so all laboratory workers will have easy access to the information. Designating a shelf or filing cabinet drawer for safety manuals and training documentation is one way to accomplish this. During lab evaluations, Environmental Health & Safety personnel will often ask a lab worker where the chemical hygiene plan is located. If the employee doesn't know, this is noted and feedback is provided to the principal investigator.

The chemical hygiene plan summarizes policies and procedures to protect laboratory workers from, and inform them of, hazards inherent to their work with chemicals. 

The chemical hygiene plan applies to faculty, staff, graduate students, undergraduate students, work-study students, and volunteers who work in university chemical laboratories. There are two basic components of the chemical hygiene plan: 

• General laboratory procedures are provided below, and 
• Laboratory-specific documentation (doc) that must be completed by the Principal Investigator and maintained onsite.

Personnel who work with chemicals in a non-laboratory setting are covered by a hazard communication plan.

Responsibility for laboratory safety is assigned to several parties at Virginia Tech. 

• Chief executive officer (CEO) (i.e. the university president): This individual has ultimate legal responsibility for the university's compliance with this program.
• Chemical hygiene officers (CHO): These individuals are designated by the department and are responsible for completing the Laboratory-Specific Documentation, overseeing the implementation of the plan, and reviewing/revising the plan at least annually. 
• University chemical hygiene officer (UCHO): This individual works for Environmental Health & Safety. 
• Laboratory chemical hygiene officers (LCHO): Each "laboratory unit" shall designate an individual to serve in this capacity. These individuals are responsible for developing and documenting the Laboratory-Specific Documentation for the unit and will ensure implementation, such as training and inspection coordination. A "summary of duties" for these individuals can be found in Laboratory-Specific Documentation. 
• University Chemical Safety and Hazardous Materials Management Committee: This committee oversees compliance with the chemical hygiene plan and any additional relative information contained within this program. Responsibilities include an annual review of the plan and assignment of disciplinary actions necessary to deal with non-compliance. Membership will consist of research faculty and safety professionals. Appointments will be made by the Office of the Provost.
• Department heads have the responsibility for safety compliance within the department, including but not limited to: ensuring that principal investigators are aware of the chemical hygiene plan requirements and mandating laboratory unit participation in the program. Departmental safety officers or committees may serve in the delegation of this responsibility.
• Principal investigators: Research group leaders and instructional laboratory supervisors have the responsibility for appointing a laboratory chemical hygiene officers.
• Laboratory workers: Responsible for planning and conducting each laboratory operation in accordance with the chemical hygiene plan's Laboratory-Specific Documentation, and for developing good personal chemical hygiene habits. Additional information is provided in the Summary of Duties.

The university chemical hygiene officer conducts or facilitates safety training seminars on a regular basis, and acts as a consultant to laboratory personnel for related issues.

The laboratory chemical hygiene officer is responsible for informing employees of the following:

• The chemical hygiene plan location within the unit and general contents; 
• The laboratory-specific documentation location within the unit and general contents;
• The OSHA Lab Standard, available from osha.gov;
• The required reading list for the specific laboratory, including standard operating procedures (SOPs), and the Training Documentation Form, which must be signed and filed with the plan; and
• The location of safety data sheets and how to obtain them.

Responsible persons for establishing new research protocols in a lab should carefully review all operations for potential risks or hazards. The materials and chemical by-products should be understood before starting the experimental process. Once information and advice about the hazards have been obtained, appropriate protective procedures should be developed and the positioning of equipment should be planned.

The storage, handling, and consumption of food and drink are prohibited in certain high-risk laboratories, such as carcinogenic research labs, biological labs, pesticide labs, and labs containing highly toxic compounds. Additionally, some departments have rules prohibiting food in any laboratory.

Work with chemical or physical hazards (e.g. high voltage, mechanical hazards not known to be intrinsically safe) or any other work that might prove immediately dangerous to life and health (IDLH) shall not be conducted alone in any Virginia Tech laboratory. It is recommended that all laboratory work be conducted with a partner or co-worker, or in proximity to others, in case of emergency.

Work with chemical or physical hazards (e.g. high voltage, mechanical hazards not known to be intrinsically safe) or any other work that might prove immediately dangerous to life and health (IDLH) shall not be conducted alone in any Virginia Tech laboratory. It is recommended that all laboratory work be conducted with a partner or co-worker, or in proximity to others, in case of emergency.

These materials are covered by Federal and State policies set forth by the Drug Enforcement Agency (DEA) and Virginia Board of Pharmacy (VBP).

• Controlled substances: Anyone who engages in activities with controlled substances (e.g drugs) included on the Drug Enforcement Agency (DEA) Schedules I - V must obtain DEA registration. Refer to the DEA website for a listing of substances in Schedules I-V. Use of these materials also requires registration with the State of Virginia. Virginia Tech also provides guidance on the use of controlled substances.
  • Schedule VI substances are regulated by the Virginia Board of Pharmacy (VBP) and may include prescription medications used in research, inhalation anesthetics (i.e. isoflurane), some analgesics, and other substances.

• Listed chemicals: DEA requires vendors to identify each purchasing agent according to CFR 21, Part 1310.07, "Proof of Identity" before selling any of their designated Listed Chemicals. The actual procedure and required paperwork may vary between vendors. Please contact your department head or director for assistance in completing the proof of identity paperwork.

• Ethanol: Purchase and shipment are also regulated by Federal and State agencies. In order to simplify this process, Virginia Tech's Chemistry Department is currently the authorized point of contact for the University (College of Veterinary Medicine excluded). If you wish to order ethanol, please contact the chemistry stockroom manager. 
• Please refer to the guidelines on Controlled Substances in Research for more information.

Any material not used or no longer needed must be handled according to regulatory requirements. Individuals holding licenses to use Controlled Substances and/or Listed Chemicals in their research must meet the requirements set forth by DEA, VBP, and Virginia. To dispose of Controlled Substances/Listed Chemicals, please contact Environmental Health & Safety at 540-231-3427 in order to arrange a schedule. If you have any questions, contact your department head, director, or the university chemical hygiene officer.

Failure to follow proper waste storage requirements listed below may result in citations and/or fines by the EPA.

• A laboratory may accumulate up to 55 gallons of hazardous waste or one quart of "P-listed waste". If a lab accumulates more than these limits, it has three days to have the excess removed from the lab to the Environmental Health & Safety Hazardous Waste Accumulation Area. Refer to the EPA P-list, to identify which materials are included. 
• Hazardous waste may be accumulated in labs as long as they are collected in containers near the point of generation. This area must be under the control of the lab workers and laboratory chemical hygiene officer. Waste containers must then remain in the lab where they were filled until collected by Environmental Health & Safety authorized personnel.
• Hazardous waste containers must be in good condition and must be made of a material that is compatible with the waste it contains. 
• Containers must be closed except when adding waste. Failure to close the waste containers may constitute an effort to treat waste on-site - illegally. 
• The list of contents on the label must be updated whenever waste is added.

Certain chemicals require special handling and disposal. The following are some examples of these chemicals, and special handling instructions for them.

• Reactives: While all chemicals are reactive to some degree, special attention must be given to some inherently unstable and potentially reactive/explosive chemicals which are susceptible to rapid decomposition or reaction. These chemicals can react alone, or with other substances in a violent manner, giving off heat and toxic gases or leading to an explosion. Reactions of these chemicals often accelerate out of control and may result in injuries or costly accidents. 
• Mercury: Elemental mercury should never be added to another chemical for disposal. Many of our waste disposal firms will not accept waste contaminated with mercury. Place mercury waste and debris (ex. broken thermometers or manometers) separately in a sealed container for collection by Environmental Health & Safety authorized personnel. Mercury spill clean-up may require special assistance. Contact Environmental Health & Safety.
• Peroxide-formers: Some chemicals form explosive concentrations of peroxides with age (see list). When peroxides become concentrated by evaporation or distillation and are disturbed by heat, shock, or friction, they may explode with extreme violence. These substances must not be housed in labs for long periods of time. To minimize the hazard of peroxide formation, strictly observe the following safety guidelines.
• Picric acid: When picric acid becomes desiccated (color changes, visible crystals, or crystalline matrix formation in the cap), it forms picrate salts, which are an explosion hazard. Dry picric acid is classified as a class "A" explosive! It is shock-sensitive and can explode when disturbed. If you suspect that you have desiccated picric acid:
  • Do not touch the container! The act of moving the container may be enough to detonate the material.
  • Prevent all personnel from entering the area, or disturbing the container.
  • Contact Environmental Health & Safety at 540-231-2509 or call 540-231-6411 and ask dispatch to notify Environmental Health & Safety immediately. 
• Perchloric acid: To minimize hazards related to perchloric acid, follow these recommendations:
  • The building should be of masonry construction.
  • Floors should be concrete or tile. Handling acid on wooden floors is dangerous, especially after the acid has dried. The wooden floor will then become sensitive to ignition by friction.
  • Benches should be constructed or resistant materials (not wood) to prevent acid absorption, especially at the bottom surface, which rests on the floor and would be subject to the greatest exposure from acid spills. Benchtops of resistant and nonabsorbent materials, such as chemical stoneware, tile, epoxy composites, and polyethylene are recommended.
  • Shelves and cabinets made of epoxy-painted steel are highly recommended over wood.
  • Heating sources, such as electric hot plates, electrical or steam-heated sand baths, or a steam bath are recommended for heating perchloric acid. Direct flame heating or oil baths should not be used.
  • Glassware can crack or break due to thermal or mechanical shock. Quartz apparatus should be considered, especially since it is necessary for many experiments to chill rapidly from the boiling point. Rubber stoppers, tubes, or stopcocks should not be used with perchloric acid due to incompatibility.
• Piranha solution: This solution is commonly used to remove organic residues from substrates; however, it can be dangerous.  
  • Typically, there are two different piranha solutions used in the laboratory.
  • Acid piranha is a 3:1 mixture of concentrated sulfuric acid (H₂SO₄) with hydrogen peroxide (H₂O₂). It produces heat upon mixing and is self-starting, meaning it will react with organics without being heated.
  • Base piranha is a 3:1 mixture of ammonium hydroxide (NH₄OH) with hydrogen peroxide (H₂O₂). It is equally dangerous as acid piranha when hot, although the base piranha must be heated to 60°C before the reaction takes off.
  • It is possible for the piranha reaction to accelerate out of control. The results could be as small as an overflowing container and a benchtop to clean up, or as large as a major laboratory explosion. Most often, these out-of-control reactions are caused by the addition of organic compounds to piranha solutions. The rapid oxidation of these organic materials produces enormous quantities of heat and gas. In a closed container, this will lead to an explosion.
  • The handling of piranha solutions requires the use of personal protective equipment, such as safety goggles AND a full face shield, heavy-duty rubber gloves (or equivalent), and a protective apron over a lab coat.
  • It is imperative that safety equipment contaminated with organic material not come into contact with piranha solution. Remember, the addition of organics to a fresh hot piranha solution produces an immediate and violent reaction.
  • It is imperative that the worker remembers that he or she IS organic. Piranha solution on a person will produce an immediate and violent reaction. Avoid all skin exposures in the presence of piranha solutions.
  • Piranha can melt or otherwise attack plastic containers. Use only glass containers for the piranha solution. All containers having piranha solution, including hazardous waste containers, must be clearly labeled as containing piranha solution. The label must also detail the hazards (corrosive, reactive) and be clearly visible to anyone working with or coming into contact with the material.
  • When preparing the piranha solution, always add the peroxide to the acid very slowly.  The peroxide is added immediately before the process because it immediately produces an energetic exothermic reaction with the gas release.  Remember, piranha solutions will heat up during the mixing process.  The solution is likely to become very hot, over 100°C – handle with care.
  • Substrates and glassware that is being cleaned should be rinsed and dried before placing them in a piranha bath.  Piranha solution is used to remove organic residues, not the organic compounds themselves.
  • Leave the hot piranha solution in an open container until cool. Don’t store hot piranha solutions because closed containers will likely explode.
  • Adding any acids or bases to piranha, or even adding water, will accelerate the reaction, producing more heat, gas, and potential for accidents.
  • Mixing piranha with organic compounds may cause an explosion.  This includes acetone, photoresist, isopropyl alcohol, and nylon.  It is imperative that organics are not stored or staged near the piranha solution mixing area or the bath.
  • Do not attempt to store hot piranha solution in an air-tight container – it will explode.  Leave the solution in an open container and allow it to cool down for several hours.  Make sure that the open container is clearly labeled and left in a safe area during this process.
  • Once cooled down, the solution can be transferred to a closed, glass container for waste storage. Clearly label the container with “Hazardous Waste – Piranha Solution.” No other materials must be mixed with this waste.
  • In case of exposure to piranha solution, such as skin or eyes, rinse the affected area thoroughly with large amounts of water (safety shower or eyewash station) for 15 minutes or more to reduce the likelihood of burns. Remove all contaminated clothing immediately with appropriate gloves and safely discard.
  • In case of exposure to piranha solution from inhalation, the person should be assisted to an area with fresh, uncontaminated air.  Seek medical attention in the event of respiratory irritation, cough, or tightness in the chest. Symptoms may be delayed.
• Hydrofluoric acid: Hydrofluoric acid (HF) is an extremely corrosive acid used for many purposes, including mineral digestion, surface cleaning, etching, and biological staining. Its unique properties make it significantly more hazardous than many of the other acids used on campus. The following safety guidelines must be used when working with hydrofluoric acid. 
• Acrylamide (gels, liquids, solids): Commonly used in industry and research, particularly in the electrophoresis of DNA in polyacrylamide gels at Virginia Tech. Acrylamide in nearly all of its forms is toxic and considered to be a potential human carcinogen.  It is also listed as a potential teratogen. Because of its toxic nature, every precaution must be taken to properly and safely handle it. 
  • Acrylamide is harmful if swallowed, inhaled, or absorbed through the skin. It affects the central and peripheral nervous systems, reproductive system, as well as being an irritant to the eyes, skin, and respiratory tract. 
  • The following personal protective equipment is required: safety glasses or goggles, rubber gloves (or other gloves recommended for this chemical), and lab coats.
  • All work done with liquid and solid acrylamide should be performed in a properly functioning fume hood. This will eliminate nearly 100 percent of the hazards presented by airborne particles and vapors.
  • Do not store acrylamide in the presence of oxidizers, peroxides, acids, or bases to avoid potential violent polymerization.
  • Acrylamide may also polymerize violently in the presence of heat above the melting point of 85°C.
  • Acrylamide must be stored in appropriate containers for disposal, away from heat sources, out of direct sunlight, and away from the incompatible chemicals listed above.
  • All acrylamide is to be considered hazardous waste for disposal purposes.  Even when polymerized, there is a significant portion (greater than 1% of the total solution) that is in monomer formation.  This amount of monomer means that the entire solution is toxic hazardous waste.
  • Acrylamide gels should be place in the bags supplied by Environmental Health & Safety (not red or yellow bags, please). Pour off any liquid before placing the gels in the bags.
  • Acrylamide liquid waste should be poured into appropriate containers (i.e. carboys) for disposal through Environmental Health & Safety. Please do not put solids in with the liquid waste, including paper towels, fish heads, sheep eyes, or other solid materials.
  • In the event of a large spill of acrylamide, back away,  call 911, and secure the lab area. The irritant and toxic nature of the chemical warrants help from experts.
• Radioactive material/waste: Radioactive material must be registered with the university radiation safety officer. Registration ensures that all individuals involved with radioactive material receive appropriate safety training and radiation monitoring badges if required.

Suitable eyewash facilities and deluge showers must be available to all chemical laboratories where there is a potential for human contact with hazardous/caustic materials and all pesticide mixing areas. Access must be within ten unobstructed seconds from the work area. These safety devices are necessary for halting the damage incurred from a chemical splash to the eyes, or spill on the body.

Laboratory fume hoods are ventilated enclosures designed to protect laboratory personnel from inhalation exposure to chemical vapors and dust. Prior to purchasing, installing, or moving a fume hood, the laboratory chemical hygiene officer must consult with Environmental Health & Safety for guidance. Fume hoods must be certified by Environmental Health & Safety. 

In order for a hood to be effective, it must be properly selected, installed, and utilized. Some variables that can impact the effectiveness of a hood are:

• Sash opening height, ease of movement, and condition of glass;
• The integrity of the cabinet (side panels in place, no modified openings added to walls, etc);
• Amount of items (e.g., chemicals and equipment) stored within the hood;
• Air velocity (i.e. "face velocity"); and
• Hood location within the laboratory.

Environmental Health & Safety conducts fume hood certifications, which include a general inspection, measurement of air/face velocity, and determination of proper sash positioning. These certifications occur on a routine annual basis and following maintenance involving the fan motor or other corrections after a previous failure or extended non-use period. Certification will be expressed as "pass" or "fail." A hood that has passed certification will be indicated by a "hood certification" sticker, which will note the testing date, person's initials, and average face velocity or smoke test results. The hood may be marked with adhesive arrows to indicate sash position, or testing height may be noted on the label. Many manufacturers have sash stops in place which also indicate recommended operating position.

A hood that has failed certification will be indicated by a bright orange (or another bright color) tag that states "CAUTION! - THIS HOOD IS OUT OF ORDER." It is very important that a hood bearing this tag not be used. The laboratory chemical hygiene officer, principal user, or other designated representative is responsible for contactingthe Division of Campus Planning, Infrastructure, and Facilities for necessary repairs.

If a hood has been tagged by Environmental Health & Safety as having failed certification, or if it is apparently malfunctioning, the following steps should be taken:

• Tightly cap or remove chemical containers.
• Tightly cap containers when the problem is with the roof exhaust fan.
• Remove containers when the problem is within the hood, or when the source of the problem is unknown.
• Call the Division of Campus Planning, Infrastructure, and Facilities at 540-231-4300 to report the problem/submit a work order.
• Ensure that work is not conducted in the broken hood until repair and recertification have been successfully performed.

Please contact Environmental Health & Safety for further guidance and information as needed.

Each laboratory must have an appropriate, functional, unobstructed portable fire extinguisher mounted on the wall three to four feet from the floor. Portable fire extinguishers must be inspected by laboratory personnel monthly, with the inspection documented on the tag attached to the extinguisher. For more information, click here.

All departments are required to have an Emergency Action Plan specific to the building where employees are located. This plan provides detailed information regarding actions to be taken by personnel in the event of an emergency, such as fire, explosion, injury, medical emergencies, chemical exposures, chemical spills, acts of terrorism, acts of nature (severe weather), etc. For more information on emergency planning, click here. 

Minor spills of hazardous chemicals that pose little or no threat to the safety and health of personnel can be cleaned by competent departmental personnel by following the warning and cautions signs on the container's label or manufacturer's material safety data sheet or safety data sheet. A hazardous material emergency exists when cleanup of a spill of hazardous material is beyond the level of knowledge, training, or the ability of the staff in the immediate spill area or the spill creates a situation that is immediately dangerous to the life and health of persons in the spill area or facility. 

• Alert personnel in the immediate area of the spill and evacuate the room.
• Confine the hazard by closing doors as you leave the room.
• Use eyewash or safety showers as needed to rinse spilled chemicals off of personnel.
• Evacuate any nearby rooms that may be affected. If the hazard may affect the entire building, evacuate the entire building.
• Notify university police by calling 911 and provide the chemical name, location of the spill, size of the spill, number of injured persons (if any), and any environmental concerns, such as the location of storm drains or streams. You will also need to provide your name and a telephone number. Always call from a safe location. Be prepared to spell chemical names. 

Procedures for laboratory personnel to handle chemical, biological, or radiological spills are provided in the laboratory-specific documentation. Trained laboratory personnel are authorized to determine appropriate emergency response measures for their areas.

Environmental Health & Safety is responsible for conducting safety inspections of all university chemical laboratories, research stations, and chemical storage areas. These inspections allow Environmental Health & Safety to monitor compliance with the program and identify any problems inherent to the plan itself. The inspection form used by Environmental Health & Safety is provided for your convenience. It may be used as a guideline for establishing unit chemical safety programs.

Refer to the Inspection Checklist (doc).

The Commonwealth of Virginia has developed and implemented a detailed program for applicator training, certification, and pesticide use in compliance with applicable state and federal regulations. Virginia Tech faculty and other personnel work closely with state representatives to ensure the programs are current, functional, and implemented properly. Protocols used on campus will not replace or supersede any requirements mandated by the Virginia Department of Agriculture and Consumer Services, Office of Pesticide Services (VDACS, OPS).

Pesticide use on university property and/or by Virginia Tech personnel is designated as commercial use by definition and scope of work. State law requires that individuals be trained and certified within 90 days of employment.

Departments with individuals (faculty, staff, and students) using pesticides, either in research or as part of their position responsibilities must follow requirements defined by the Virginia Tech Pesticide Programs (VTPP) for training, certification, supervision, etc. 

Supervisors of pesticide operations must be appropriately trained and certified according to VDACS OPS guidelines and must provide for the safe and appropriate use of all pesticides used in work applications. Please refer to the Pesticide Applicator Overview developed by VTPP. This includes:

• Training (within 90 days of employment) and certification of all individuals using pesticides;
• Availability and use of appropriate personal protective equipment (as documented on the Hazard Assessment Form);
• Proper storage, handling, and disposal of pesticides; and 
• Recordkeeping and postings. 

If a research project is involved, a responsible person must be designated before pesticides are used. Experimental products must be handled in such a manner as to minimize potential risks to university personnel and property. All experimental products must be obtained through appropriate procurement procedures, which include registering the products, reporting quantities, and coordinating the return of any materials not used during the trial period.

Employees working with pesticides are responsible for: 

• Attending and obtaining necessary training and certification; 
• Wearing assigned personal protective equipment; and 
• Handling the products in a safe manner and according to label requirements. 

Contractors using pesticides as part of a project with the university must follow requirements mandated by the Commonwealth of Virginia. Please refer to the VTPP site for Commercial Applicator Overview compliance details. 

Environmental Health & Safety works to ensure safe work practices, compliance, and serves as a liaison between regulatory officials and university administration. Personnel will use guidelines given through VTPP, and in other applicable parts of the Hazardous Chemical Management Program when conducting audits, evaluations, consultations, and when reviewing site assessments for proposed pesticide storage/mixing facilities. 

The University Chemical Hygiene Officer may assist employees in coordinating the requirements of this program, which include:

• Evaluation of pesticide storage and security practices;
• Ensuring proper site development and postings; 
• Reviewing training documentation and product application records; and 
• Consulting, as needed.

Proper storage of pesticides is just as critical and specific as with any other chemical product. Recommendations for storage and handling contained elsewhere within this document are also applicable to pesticides, including maintaining a Chemical Inventory; however, this inventory should be kept at a separate location in the event of an emergency at the storage facility that impacts access or presents loss risk.

Each pesticide container should be marked with the date of purchase before it is placed in storage. Since many pesticides have a "shelf-life", older products should be used first. Additionally, only purchase quantities that will be used up within one year or the duration of the project.

Empty waste containers and pesticide products for disposal should be kept in a separate part of the facility. Ensure that waste materials are easily identifiable as waste in order to minimize confusion.

Remember to always follow the product label for storage requirements.

An appropriate storage facility must be provided that is environmentally acceptable and secure. The area must be kept clean, dry, and at the appropriate temperature in order to maintain the integrity of the product. Product labels will help identify specific segregation criteria. Site postings must be included to protect users, the public, and emergency response personnel. Refer to VCE or VTPP for further details. 

Site assessments are recommended for all pesticide storage areas. Human and environmental safety issues must be considered before constructing new facilities and when evaluating current operations. First, determine the proximity of the proposed site to sensitive places, such as residential lots, ground and surface water sources, livestock areas, fertilizer storage facilities, etc. In addition, the location with regard to prevailing winds, traffic patterns, and security in the event of an emergency, must be evaluated. Before new site construction begins, baseline environmental information must be obtained for review as part of the assessment. This data is obtained from soil, surface, and groundwater sample analyses, available historical information, and visual observations. Copies of all assessment data collected must be forwarded to Environmental Health & Safety for environmental review. For assistance, contact Environmental Health & Safety at 540-231-2510. 

• Facility site plans are an essential part of the site assessment. This plan is critical for compliance with Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Resource Conservation and Recovery Act (RCRA), Superfund Amendments and Reauthorization Act (SARA), and other associated regulations. In addition to the previously mentioned observations, the site plan should include:
  • Soil type and topography; 
  • Water table, depth to groundwater, and flood plain delineations; 
  • Watershed and associated drainage information; and 
  • Location in relation to other material storage areas (e.g. fertilizer, fuels, feed, equipment).
• Design issues for setting up the storage facility should also be considered. Construction materials, security features, segregation requirements, size, and environmental controls must also be taken into account.
  • Interior floor and wall surfaces must be chemically impervious and easily cleaned. Examples include plastic, vinyl, and some coated/painted metals. Concrete is porous and must be treated with appropriate protective coatings in order to prevent absorption. Wood is permeable and difficult to seal, and should not be used for permanent flooring. Individual wood units (e.g. pallets) can be used in certain circumstances since they can be easily disposed of in the event of a spill.
  • Appropriate secondary containment systems must be used inside the facility. Such systems include raised floor sills and ramps, open grate trenches with sumps, and tubs for smaller containers. Outside, the use of constructed curbs, pads, and grate drains can help contain accidental spills and water run-off in the event of a fire.
  • Do not connect drains or sumps to a sewer or septic system or other open discharge.
  • Shelving, like floors, must also be chemically impervious. Shelves must be constructed with lips, sills, or secondary containers used in order to prevent spills and contamination from shelf to shelf. Do not exceed the load limits of the cabinets or shelves.
  • Pesticide storage buildings must meet all applicable fire and electrical code requirements. Related issues include storage criteria for flammable and combustible materials and explosive venting. Suppressant fire systems utilizing dry chemicals are the preferred fire control method due to water run-off and contamination issues.
  • Storage areas must be placarded or labeled to show pesticide storage and "No Smoking."
  • Ventilation is critical to minimizing the fire, explosion, and health risks. Warm weather ventilation reduces temperature extremes and vapor accumulation. In unheated storage spaces, natural ventilation may be the best alternative. Wall vents are most effective at floor level (within 12 inches) since most flammable vapors are heavier than air. In large storage facilities, mechanical ventilation is much more effective. Generally, systems should provide approximately six air changes per hour. Fans and ducts should be designed to move the entire air volume from the room involved to ensure heavier air vapors are removed. Systems must also be explosion-proof when Class I liquids are involved.
  • Do not store pesticides in basements or below grade level where vapors may accumulate. 

In summary, all pesticide storage areas must be designed to provide a secure, stable environment with adequate ventilation, and must meet all applicable fire and electrical code requirements. Storage guidelines put forth by VTPP are used by Environmental Health & Safety personnel for evaluation criteria.

Pesticide storage areas must be constructed to prevent unauthorized individuals from gaining access. If pesticides are kept in a general use area or laboratory, then precautions must be implemented to restrict access. Perimeter fencing, buildings, and/or cabinets with locks are all examples of secure storage areas.

Spill response supplies must be maintained at the storage facility. Extra sets of personal protective equipment (i.e. gloves, boots, Tyvek® suits, etc.) should be available, as well as a non-sparking shovel and some type of absorbent material (i.e. kitty litter). Other items that may be needed depending on the materials involved are respirators, coveralls, and chemical absorbent pads ("pigs"). A careful review of all pesticides in storage must be performed to identify risks involved and to determine the items required to contain and control small spills.

Pesticide containers should be routinely inspected to verify the integrity of containers and labels. Look for leaks, damaged bottles, faulty aerosols, tears/splits in bags, etc. If a material is found leaking or the container is damaged, there are several options:

• Try to use the pesticide immediately at a site and rate allowed by the label.
• Transfer the material into another container that originally held the same product.
• Transfer the contents to an appropriate container that can be closed. If possible, remove the label from the damaged container and place it on the new one. Otherwise, label the secondary container with the product name and registration number and request another copy of the label from the dealer or manufacturer.
• Place the entire damaged original container into a suitable larger secondary container. If the label is no longer legible, use the name and registration number to request another copy as noted above.
• Never put pesticides in unlabeled or unsuitable containers.

Pesticide use for the university primarily revolves around three types of applications:

• Research and development, specifically experimental products: Some may be registered and some may be going through further studies under the direction of university personnel. In these cases, application rates and the size of test areas may vary significantly. Production methods may be appropriate while at other times a smaller-scale approach may be required. 
• Grounds maintenance, including the use of herbicides, insecticides, rodenticides: These cases are almost entirely small scale and involve travel distance and time between applications.
• Production, including field crops, forest, pasture, and orchard management, marine anti-foulant painting, and livestock health: This application typically involves larger target areas and increased volume of product. In addition, the location of target areas may involve some travel distance between storage areas and sites of application. This can include moving pesticides on public highways, in proximity to private property, and/or near environmentally sensitive areas, such as private water sources, creeks, and ponds.

The scale of the operation and the expected or desired outcome are also factors to consider when planning an application. In general, the outcome or objective must be clearly defined and the least toxic product possible must be selected. Those applying pesticides on university property outside of research within laboratory spaces, must have training and be authorized through the Virginia Pesticide program as administered by the Virginia Department of Agriculture and Consumer Services.  In addition to following label directions and precautions, pay special attention to weather conditions, the proximity of non-target flora and fauna, and human activities within or near the area. The differences in the groups mentioned above further dictate options available to the applicator.

Pesticide use for the university primarily revolves around three types of applications:

• Research and development, specifically experimental products: Some may be registered and some may be going through further studies under the direction of university personnel. In these cases, application rates and the size of test areas may vary significantly. Production methods may be appropriate while at other times a smaller-scale approach may be required. 
• Grounds maintenance, including the use of herbicides, insecticides, rodenticides: These cases are almost entirely small-scale and involve travel distance and time between applications.
• Production, including field crops, forest, pasture, and orchard management, marine anti-foulant painting, and livestock health: This application typically involves larger target areas and increased volume of product. In addition, the location of target areas may involve some travel distance between storage areas and sites of application. This can include moving pesticides on public highways, in proximity to private property, and/or near environmentally sensitive areas, such as private water sources, creeks, and ponds.

The scale of the operation and the expected or desired outcome are also factors to consider when planning an application. In general, the outcome or objective must be clearly defined and the least toxic product possible must be selected. In addition to following label directions and precautions, pay special attention to weather conditions, the proximity of non-target flora and fauna, and human activities within or near the area. The differences in the groups mentioned above further dictate options available to the applicator.

Mixing

There are two primary methods of mixing pesticides for applications considered within the scope of this program. They are "in-house" (or other designated area) and "in-field." The operation or application process will dictate which process is most applicable.

In-house preparation

For smaller-scale operations involving experimental products, grounds, or veterinary applications, the ability to prepare materials inside a shop or lab is advantageous due to the availability of clean water, spill containment, and personal protective equipment. The water source must be protected from product contamination by work practices, such as keeping water hoses above levels of pesticides when mixing, and through the use of devices designed to prevent back siphoning. Special precautions must be taken to prevent spills or waste products from entering the wastewater system. Avoid using sinks directly connected to wastewater lines. 

• If floor drains are present, verify that they are not connected to a septic tank or wastewater discharge line before allowing any spill or clean-up water to enter. All affected drains and lines should be connected to a separate holding tank with a sump. After each mixing, any liquid collected into the reservoir can be removed and applied to the target area as rinsate.
• In the absence of a holding tank, secondary containment should be used to control spills. Use large tubs to hold small portable sprayers while mixing product and rinsing containers. Any material collected in the secondary container can then be placed into the sprayer for application as with rinsates.
• In rare cases, rinsates are not suitable for adding to tanks and applying on target areas. Special care must be taken to collect rinsates and dispose of them as waste pesticide products. Specific examples include:
  • The product labeling restricts rinsate use as a dilute, as in the case of strongly acidic or alkaline agents.
  • The rinsate contains strong cleaning agents that may harm the target organism.
  • The rinsate solution may not be compatible with or may make a mixture unstable.
  • The original product was used in an animal dose case (e.g. pour-ons for livestock).

In-field preparation

Large-scale applications usually involve production operations. The repeated draining of pesticide residuals (product and rinsates) onto a small area increases the risk of groundwater contamination. Providing a system to mix chemicals and rinse equipment in the field helps to reduce some of the risks associated with handling and wash-down facilities. Some advantages to on-site or in-field mixing include:

• Minimization of bio-accumulation from repeated spills or leaks in the same small mixing area.
• Prevention of buildup of waste mixtures of different pesticides by eliminating the use of a holding tank for spill cleanup.
• Reduced costs by eliminating the need for the above-mentioned holding tanks, sumps, and increased waste disposal costs.
• Reduced risk of spills while in transit; less impact on non-target plants, animals, and surrounding environment.
• Simplification of the preferred practice of applying tank tailings and rinsates on labeled crops.

There are equipment requirements for successful in-field preparation:

• A nurse tank with hoses and a pump to provide a clean, adequate water supply is imperative. It can also be used for emergency showering, if properly plumbed and potable.
  • Permanently mark the nurse tank (i.e. clean water tank) so that it is used only for clean, potable water.
• An anti-siphoning device or hose supports to prevent contamination of the water supply.
• Secondary containment is useful for the transportation of concentrated products from storage to the field site for mixing. (This containment should be adequate to contain a leaking or damaged container and all contents.)
• Appropriate personal protective equipment.
• Emergency eyewash treatments, such as closed containers of clean water. 
  • Containers must be kept clean.
  • The water must be changed routinely to prevent the growth of bacteria.
  • Treatments must be stored separately from chemical products.
  • Containers must be clearly labeled.
  • Must be able to provide 15 minutes flushing capacity. 

Any system for field mixing and rinsing should be developed with ease and effectiveness in mind. The key to any design is an adequately sized portable source for clean water. 

Closed mixing systems

The use of closed systems requires that mixing operations be conducted in the area of the equipment. These systems are used to minimize the risk of exposure to product materials during mixing operations and are designed to prevent contact with the pesticide product. There are two major types of closed systems - mechanical and soluble packaging. While some pesticides require closed systems for handling, and some states may require their use through legislation, they are generally only used when working with products of high acute toxicity.

If a closed system is implemented, special care must be taken to ensure that spills and leaks are contained in an appropriate manner and held for disposal. Mixing of pesticide products in containment vessels can complicate disposal procedures and change the classifications of materials involved.

Sprayers and associated equipment are the key to the effective and safe application of pesticides. It is imperative that the equipment be cleaned and maintained in such a manner as to prevent damage to lines, nozzles, tanks, and pumps. Careful rinsing after each application (by job or field) will prevent buildup in lines and nozzles and make end-of-season cleaning much easier. Thorough cleaning, inspection, and maintenance prior to putting items in storage at the end of the season will increase the productive life of the equipment and help minimize the risk of future pesticide contamination problems.

Follow product labels and equipment operation manuals for specific guidelines on cleaning, equipment maintenance, and end-of-season storage.

Best practices are management strategies selected to address production problems in a manner that best utilizes available resources. These practices have been developed over time and are used extensively throughout the industry. The university encourages and expects applicators to use such practices whenever applicable.

• Integrated pest management: A system that combines several management policies to address pest problems. No single form of control provides optimal results. Basic principles include careful identification of all pest problems involved, using pest-resistant cultivars (if available), implementing good agronomic practices (quality seed, soil testing, etc.), use of biological controls (when available), and rotation of pesticides used.
• Soil and water conservation best practices focus on optimizing soil fertility, controlling water runoff, preventing the indiscriminate spread of chemicals, and preserving soil integrity. These include:
  • Nutrient management planning to utilize animal wastes as a source of organic material and nutrients;
  • Crop rotation;
  • Use of reduced tillage methods where macropores are not an issue;
  • Contour stripping; and
  • Use of vegetative filter strips.

Transportation of pesticides is a concern for application operations that involve highway use and/or movement across private properties. General precautions are to be implemented in order to protect the applicators, the public, and the environment.

Equipment used to move products from purchase to storage, and to the site of use, should be carefully maintained to ensure proper operation. In addition to vehicle operation, there must be adequate security for containers. This would include proper ventilation, secure holding areas, and spill prevention and control. Hazardous material placarding of vehicles operating on state highways is required. The EPA Worker Protection Standard requires that drivers of vehicles transporting containers that are not factory sealed be trained as Worker Protection Standard pesticide handlers, or be certified applicators.

All containers included for transfer by vehicle must be labeled. This includes the manufacturer's label for primary containers and appropriate information for secondary or transfer containers.

In the event of any spill or unexpected release, while transporting pesticides, specific strategies must be implemented.

• The spill must be contained.
• The area must be secured.
• Notify Environmental Health & Safety directly at 540-231-3600 for assistance and guidance with small spills/releases. After hours, call the Virginia Tech Police Department at 540-231-6411 and request Environmental Health & Safety assistance. If the incident poses a threat to any person, public health or safety, or to the environment, call 911 immediately. 
• Minor spills must be cleaned up as soon as possible.
• Spills involving ground contamination require absorbents, shovels, empty containers for contaminated soil and product.

Notification to the Virginia Department of Agriculture and Consumer Services (VDACS), Office of Pesticide Programs is required if any of the following products and quantities are stored:

• One or more pounds of:
  • Aldicarb (Temik)
  • Chlordane
  • Coumafuryl (Fumarin)
  • Methamidophos (Monitor)
  • Paraquat (Gromoxone Super)
  • Sulfur dioxide
• 10 or more pounds of:
  • Carbofuran (Furadan)
  • Carbon disulfide
  • Dichlorvos (DDVP, Vapona)
  • Dimethoate (Cygon, De-fend)
  • Strychnine
• 100 or more pounds of:
  • Methyl parathion (Penncap-M)
  • Nicotine
  • Trichlorfon (Dylox, Proxol)
  • Warfarin (Co-Rax, Rodex)
• 1000 or more pounds of:
  • Dinoseb (Premerge, Dinitro)
  • Methyl bromide
  • Sodium arsenate (Atlas "A", Penite)

When pesticide products have expired or are no longer needed, they must be disposed of as hazardous waste, if they cannot be disposed of safely as rinsate. Contact Environmental Health & Safety for hazardous waste removal at 540-231-2509.

Empty product containers require special processing and handling as well. Once empty, triple rinse and recycle or recondition metal and plastic containers. For larger volume containers, such as 30 and 55-gallon drums, check with the pesticide dealer or manufacturer for reconditioning options. Some products have special conditions regarding the disposal of containers.