Examples
Worked examples
- Is an instance
A university chemistry department's written Chemical Hygiene Plan designates a Chemical Hygiene Officer, requires annual fume-hood airflow certification, and specifies prior-approval procedures for reactions involving particularly hazardous substances such as select carcinogens.
- Is an instance
During an EHS internal audit, a biomedical research lab's Chemical Hygiene Plan is flagged as overdue for its required annual review; the principal investigator must update it before the lab can procure additional hazardous chemicals.
Counter-examples
Looks similar, but isn't
- Not an instance
A general campus office's binder of Safety Data Sheets for cleaning products falls under the general Hazard Communication Standard (29 CFR 1910.1200), not the laboratory-specific Chemical Hygiene Plan requirement, because the office is not conducting laboratory use of hazardous chemicals.
- Not an instance
A BSL-2 laboratory's biosafety manual and IBC-approved protocol for handling a risk-group-2 pathogen is a biosafety compliance instrument, not a Chemical Hygiene Plan — the regulatory basis (NIH Guidelines/biosafety) and administering committee (an Institutional Biosafety Committee, not EHS chemical safety) are different, even though the same physical lab may need both.
Editorial commentary
The OSHA Chemical Hygiene Plan (CHP) is the compliance instrument at the center of laboratory chemical safety in the United States: a written, facility-specific program required under OSHA’s Laboratory Standard, 29 CFR 1910.1450 (“Occupational exposure to hazardous chemicals in laboratories”), for every workplace where hazardous chemicals are used on a laboratory (non-production) basis. It is distinct from a general OSHA Hazard Communication program (29 CFR 1910.1200) and, in a research-institution setting, distinct from biosafety programs governing biological agents (see Biosafety Level (BSL)) — the Laboratory Standard governs chemical exposure, not biological containment.
What the standard requires
Where hazardous chemicals are used, the employer must develop and carry out a written CHP that specifies:
- Standard operating procedures (SOPs) for the safe handling of hazardous chemicals
- Criteria for selecting engineering controls (e.g., fume hoods), administrative controls, and personal protective equipment (PPE)
- A designated Chemical Hygiene Officer responsible for technical guidance and implementation of the plan
- Employee information and training on chemical hazards, detection methods, and emergency procedures, which often overlaps operationally with broader Responsible Conduct of Research (RCR) training programs
- Circumstances requiring prior approval from a supervisor or the Chemical Hygiene Officer before work proceeds
- Additional protective provisions for work with “particularly hazardous substances” — select carcinogens, reproductive toxins, and substances with high acute toxicity
- Exposure monitoring and medical-consultation procedures, including comparison of measured exposures against OSHA Permissible Exposure Limits (PELs) and defined action levels
The CHP must be reviewed and updated at least annually and kept accessible to laboratory employees at all times.
Why it matters for research administration
The CHP sits alongside, and is frequently reviewed alongside, other institutional compliance instruments that research administrators track: IACUC protocols for animal research, IRB approval for human-subjects research, and institutional biosafety committee (IBC) review for work with biological agents. A CHP is typically maintained by an institution’s Environmental Health and Safety (EHS) office, but its existence, currency, and enforcement are increasingly checked as part of sponsored-program compliance reviews, facilities-and-administrative (F&A) rate audits, and federal agency site visits — a lapsed or missing CHP is a citable OSHA violation with institutional-risk consequences that can extend into a principal investigator’s ability to keep operating a laboratory under an active award. See the Research Integrity & Compliance hub for the wider landscape of institutional compliance instruments.
How it differs from biosafety programs
A laboratory that works with both hazardous chemicals and biological agents — for example, a molecular biology lab using organic solvents alongside recombinant-DNA techniques — needs both a CHP and a biosafety program. The two are governed by different regulatory frameworks, administered through different institutional committees, and audited separately. The CHP addresses chemical exposure under OSHA jurisdiction; biosafety and biosafety-level (BSL) requirements address biological agents under NIH Guidelines and CDC/NIH biosafety guidance, and are typically overseen by an Institutional Biosafety Committee rather than an EHS chemical-safety function. Treating the two as a single “lab safety” compliance obligation in institutional policy documentation is a common and citable gap.
References
- OSHA, 29 CFR 1910.1450, “Occupational exposure to hazardous chemicals in laboratories” (the Laboratory Standard)
- OSHA Fact Sheet, “Laboratory Safety — Chemical Hygiene Plan (CHP)”
- 29 CFR 1910.1200, Hazard Communication Standard (general industry — distinguished from the Laboratory Standard’s lab-specific coverage)
- National Research Council, “Prudent Practices in the Laboratory,” referenced as non-mandatory guidance in 1910.1450 Appendix A
Also known as
Chemical Hygiene Plan · CHP · OSHA Laboratory Standard · 29 CFR 1910.1450 · laboratory safety and rules
Machine-readable encodings
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