Question: “What is the simplest way to have one chemical management plan to address both HazComm and Lab Standard (29CFR 1200 & 1450)?”
Answer: An addendum which addresses necessary elements of HAZCOM would be the preference, since CHPs are both critical to compliance with 1910.1450 and lab-specific.
Are you familiar with the National Research Council Recommendations Concerning Chemical Hygiene in Laboratories (Non-Mandatory)?
It references a current laboratory safety customer, Texas Tech University, and while it is somewhat dated (2011), it is instructive here because it outlines exactly where you would want to amend your CHP to align with HAZCOM/GHS...
2. Chemical Procurement, Distribution, and Storage
Prudent chemical management includes the following processes:
(a) Information on proper handling, storage, and disposal should be known to those who will be involved before a substance is received.
(b) Only containers with adequate identifying labels should be accepted.
(c) Ideally, a central location should be used for receiving all chemical shipments.
(d) Shipments with breakage or leakage should be refused or opened in a chemical hood.
(e) Only the minimum amount of the chemical needed to perform the planned work should be ordered.
(f) Purchases of high risk chemicals should be reviewed and approved by the CHO.
(g) Proper protective equipment and handling and storage procedures should be in place before receiving a shipment.
(a) Chemicals should be separated and stored according to hazard category and compatibility.
(b) SDS and label information should be followed for storage requirements.
(c) Maintain existing labels on incoming containers of chemicals and other materials.
(d) Labels on containers used for storing hazardous chemicals must include the chemical identification and appropriate hazard warnings.
(e) The contents of all other chemical containers and transfer vessels, including, but not limited to, beakers, flasks, reaction vessels, and process equipment, should be properly identified.
(f) Chemical shipments should be dated upon receipt and stock rotated.
(g) Peroxide formers should be dated upon receipt, again dated upon opening, and stored away from heat and light with tightfitting, nonmetal lids.
(h) Open shelves used for chemical storage should be secured to the wall and contain 3/4-inch lips. Secondary containment devices should be used as necessary.
(i) Consult the SDS and keep incompatibles separate during transport, storage, use, and disposal.
(j) Oxidizers, reducing agents, and fuels should be stored separately to prevent contact in the event of an accident.
(k) Chemicals should not be stored in the chemical hood, on the floor, in areas of egress, on the benchtop, or in areas near heat or in direct sunlight.
(l) Laboratory-grade, flammable-rated refrigerators and freezers should be used to store sealed chemical containers of flammable liquids that require cool storage. Do not store food or beverages in the laboratory refrigerator.
(m) Highly hazardous chemicals should be stored in a well-ventilated and secure area designated for that purpose.
(n) Flammable chemicals should be stored in a spark-free environment and in approved flammable-liquid containers and storage cabinets. Grounding and bonding should be used to prevent static charge buildups when dispensing solvents.
(o) Chemical storage and handling rooms should be controlled-access areas. They should have proper ventilation, appropriate signage, diked floors, and fire suppression systems.
(a) As described above, a risk assessment should be conducted prior to beginning work with any hazardous chemical for the first time.
(b) All SDS and label information should be read before using a chemical for the first time.
(c) Trained laboratory workers should ensure that proper engineering controls (ventilation) and PPE are in place.