A. What Are Select Carcinogens?
These guidelines for the laboratory use of chemical carcinogens establish procedures and safeguards for minimizing exposure of laboratory personnel to chemical substances that pose a carcinogenic risk. They apply to all substances defined as "select carcinogens" by the OSHA Laboratory Standard and include:
- all OSHA regulated carcinogens (29 CFR Subpart Z),
- all substances the National Toxicology Program (NTP) lists as "known to be carcinogens",
- all substances the International Agency for Research on Cancer (IARC) defines as Group 1, "carcinogenic to humans",
- all substances NTP lists as "reasonably anticipated to be carcinogens", and
- all substances IARC lists as Group 2A, "probably carcinogenic to humans" or 2B, "possibly carcinogenic to humans".
Appendix V(i)-A is a compilation of the lists from the sources listed above. With the exception of approved exemption petitions all substances listed must be handled in accordance with the following guidelines. These guidelines are adapted from the National Institute of Health: "NIH Guidelines for the Laboratory Use of Chemical Carcinogens".
B. Employee/Student Notification
The supervising faculty member is responsible for informing all employees and students that the chemical they are working with is a select carcinogen.
C. Personal Protective Equipment
Protective Clothing. Laboratory coats must be worn when handling greater than one liter of a select carcinogen which is readily absorbed through the skin, as indicated by an "s" on the list (see Chapter V(b)). Laboratory coats used for this purpose should not be worn outside of the laboratory. Contaminated clothing must be removed immediately and disposed of or laundered separately from street clothes.
If hand contact is possible, gloves appropriate for the task and with resistance to the chemical involved must be worn. Disposable gloves must be discarded after every use and immediately after overt contact with a select carcinogen. Non-disposable gloves must be designated for use only with select carcinogens and must be decontaminated after every use.
Eye Protection. Appropriate eye protection must be worn as described in Chapter V(b).
D. Personal Hygiene
Hands must be washed with soap and water immediately after overt contact, at the completion of any procedure, and prior to leaving the laboratory. If eyes or other parts of the body are contaminated they must be immediately washed or flushed as described in Chapter III.
E. Work Area Identification And Access
Each work area or laboratory where select carcinogens are being used on a regular basis must be labeled with a sign with the following or similar warning:
CAUTION -- POTENTIAL CANCER HAZARD
When work areas have not been decontaminated or experiments involving select carcinogens are left in progress, a DO NOT ENTER sign listing the name and phone number of the person to be contacted in case of emergency must be posted on the exterior door.
F. Handling And Storage Procedures
Work Surfaces. All work surfaces on which non-volatile select carcinogens are used should be smooth and nonporous or covered with stainless steel or plastic trays. The work surface or trays should be decontaminated after the procedure is complete.
Containment Equipment. Procedures using volatile select carcinogens and those involving solid or liquid select carcinogens that may result in the generation of aerosols or airborne particles should be conducted in a fume hood, glove box or other containment device. Examples of aerosol generation procedures include: transfer operations, blending, open vessel centrifugation, and injection.
Vacuum Lines. Vacuum lines, other than water aspirators, should be protected (e.g., with an absorbent or liquid trap and a HEPA filter) to prevent entry of any select carcinogen into the system.
Decontamination. Equipment and contaminated materials should be decontaminated by procedures that deactivate (see Section H) the select carcinogen, if such procedures are available. If deactivation procedures are not available, the equipment should be rinsed with an appropriate solvent and the solvent collected as hazardous waste. Decontamination of the work area must be done whenever there has been overt contamination and at the end of each experiment. Ideally, the work area should be decontaminated daily. If a work area is not decontaminated prior to leaving for the day, a DO NOT ENTER sign must be posted, as described in Section F above.
Container Labeling. Containers in which select carcinogens are stored must be labeled with, at a minimum, the chemical name and a warning indicating it is a select carcinogen or, alternately, a particularly hazardous substance. In lieu of labeling containers, storage areas may be labeled.
G. Waste Disposal
Waste Minimization. One goal of experimental design should be the minimization of waste produced. Using the least amount of chemical required and limiting the use of disposable equipment are effective methods.
Deactivation. When possible, wastes should be deactivated to form non-carcinogenic and/or non-toxic degradation products. Deactivation procedures for some carcinogens are described in the following publications and may also be available from the manufacturer.
Castegnaro, M., Sansone, E,B., 1986. Chemical Carcinogens, Some Guidelines for Handling and Disposal in the Laboratory. Springer-Verlag, New York.
Armour, M., et al., 1986. Potentially Carcinogenic Chemicals, Information and Disposal Guide. University of Alberta, Edmonton, Alberta, Canada
Collection for Off-Site Disposal. If deactivation methods are not available or the deactivation product remains hazardous (e.g. flammable) all contaminated materials must be collected for off-site incineration. The procedures outlined in Chapter XI(a) for hazardous waste disposal should be followed.
H. Special Requirements For Formaldehyde
OSHA has established a separate Standard for formaldehyde, 29 CFR 1910.1048 that applies to laboratories as well as other users of formaldehyde. Under that Standard employee exposure monitoring is required to determine if a particular experiment results in overexposure to formaldehyde. As with the requirements of the OSHA Laboratory Standard, the same standards of protection with regard to formaldehyde exposure will be applied to students and other members of the Mount Holyoke College Community.
To accomplish the required monitoring, faculty members should notify the Chemical Hygiene Officer at least 2 weeks before any experiment where formaldehyde is used in concentrations greater than 0.1 percent. If monitoring has been conducted in previous semesters for that experiment, notification is not required unless the Chemical Hygiene Officer has informed the faculty that additional monitoring is necessary. Additional requirements of the Standard may apply based on the results of monitoring, these requirements will be discussed with individual faculty members as needed.
The Formaldehyde Standard also establishes hazard communication requirements, labeling, MSDS, and training, for the use of all solutions greater than 0.1 percent or materials capable of releasing formaldehyde in excess of 0.1 ppm.
Labeling. For products capable of releasing 0.1 to 0.5 ppm, labels must include a warning that the product contains formaldehyde and that more information is available on the MSDS. For products capable of releasing greater that 0.5 ppm, the label must also address health hazards and include the words "Potential Cancer Hazard". Products purchased after December 1992 should be properly labeled by the vendor. Products purchased before that date or that are not in their original labeled container must be labeled with the appropriate warning. Both types of labels are available from the Chemical Hygiene Officer.
MSDS. Material Safety Data Sheets must be readily accessible for all formaldehyde containing products. MSDS are available in each Department as described in Chapter V(a).
Information and Training. Annual training is required for all formaldehyde product users. That training is the responsibility of the faculty member supervising the use of the formaldehyde product. Specific requirements are described in Appendix V(m)-B.