3-50 Laboratory Safety Policy

• Effective date of this revision: May 1, 2025
• Contact for more information: Office of Laboratory and Field Safety (OLFS)
  

BACKGROUND 

This policy establishes the minimum requirements for all University laboratories and lab workers. Individual departments or units may exceed requirements, as they deem necessary. It applies to workers regardless of their title and employment status.

PURPOSE 

CMU is committed to providing safe and healthy lab environments. The purpose of this policy is to prevent laboratory injuries and illnesses and to endure compliance with MIOSHA Part 431 – Hazardous Work in Laboratories. 

DEFINITIONS 

Chemical Hygiene Plan: The written program for CMU which sets forth procedures, equipment, personal protective equipment, and work practices that protect lab workers from the hazardous chemicals used in laboratories. 

Lab Worker: For purposes of this policy, a worker is an individual who works with hazardous materials in a laboratory. A lab worker may be faculty, staff, graduate student, postdoctoral scholar, undergraduate student researcher, volunteer, or visitor/visiting scholar.

NOTE: Lab workers exclude enrolled students in a teaching laboratory and individuals who are passively participating in tours, lectures, conferences, etc.

Laboratory (Lab): For the purpose of this policy, a laboratory is an area where hazardous materials are used or stored and where ALL the following criteria are met:

1. Chemical operations are carried out on a laboratory scale, i.e. the containers used in the operation are of a size that can be easily and safely manipulated by one person;
2. Multiple chemical procedures or chemicals are used; 
3.  The procedures involved are not part of a production process or simulate a production process; and
4. Protective laboratory practices and equipment are available and in common use to minimize to potential for lab worker exposure to hazardous chemicals. 

 NOTE: CMU still considers academic spaces without chemical inventories to be laboratories if they have biohazards, radiation hazards, or laser hazards, and the safety training, lab restrictions, and correction of lab deficiencies requirements still apply.

Safety Training Form: The form to be completed by the supervisor or their designee to document the training requirements for each lab worker.

Lab-Specific Safety Training Form: The form to be completed by the supervisor or their designee to document the on-site safety orientation specific to the lab and operation for new lab workers before the worker is granted unescorted access or assigned work activities in the lab. 

Student: An individual enrolled in an academic class.

Lab Supervisor: An employee with authority to hire personnel, evaluate performance, direct work assignments, apply progressive discipline, and direct resources to correct identified safety issues. The supervisor in a laboratory may be a principal investigator, faculty member, or staff member, For the purpose of this policy, the following are ineligible to be supervisors in a laboratory: graduate students, postdoctoral scholars, undergraduate student researchers, volunteers, or visitors/visiting scholars.

Laboratory Registration Manager: The database maintained by the Office of Laboratory and Field Safety (OLFS) and accessed by CMU Police, Facilities Management, and Environmental Health & Safety to assist with emergency response work order completion, regulatory compliance, and lab door sign postings.

POLICY

Vice President for Research and Innovation oversees compliance with this policy.

The Lab Safety Committee is responsible for promoting a safe working environment in all research and teaching laboratories on campus.

Directors/Deans/Department Chairs are responsible for communicating, promoting, and enforcing the policy in areas under their control.

Lab Supervisors are responsible for complying with the policy and ensuring their staff comply with this policy. Supervisors are responsible for completing the safety training forms or reviewing and approving the form if completed by others. They are also responsible for ensuring their staff complete the required training.

Supervisors are responsible for complying with the policy and ensuring their staff comply with this policy. Supervisors are responsible for completing the safety training forms or reviewing and approving the form if completed by others. They are also responsible for ensuring their staff complete the required training. 

Lab Workers must comply with CMU policy, the CMU Chemical Hygiene Plan, and MIOSHA Part 431 – Hazardous Work in Laboratories Standard. 

Lab Workers are responsible for completing the required training for areas in which they work or enter. They are responsible for informing others in the area of these requirements and reporting unsafe conditions to the Lab Supervisor.

Office of Laboratory and Field Safety (OLFS) is responsible for providing interpretation and clarification regarding this policy. OLFS will also provide consultation and tools to assist supervisors in completing the safety training form and meeting other requirements.

PROCEDURE 

Safety Training

Before lab workers are granted unescorted access to laboratory areas, they shall successfully complete all required safety training as offered/managed by the OLFS. The safety training requirement does not apply to students enrolled in laboratory courses, unless the student is considered a lab worker as defined above. However, the teaching laboratory instructor, teaching assistant, and/or classroom manager is still responsible for conveying the necessary information for students to work safely.

Safety Training Form and Lab-Specific Safety Training Form

Lab supervisors shall complete the safety training form for new lab workers or lab workers moving to a different lab. The form indicates the safety training requirements to work in the lab and is used by the OLFS to assign required training to the worker in the online training platform.

Lab supervisors shall complete the lab-specific training form for new lab workers or lab workers moving to a different lab. The form documents the safety orientation specific to the lab and operation for new lab workers. Lab supervisors shall keep a copy of this form for each active worker, and the form must be available upon request.

Both the Safety training form and the lab-specific training form are located in the CMU Chemical Hygiene Plan and shall be completed before the worker is granted access to or assigned work activities in the lab.

Chemical Hygiene Plan

Lab workers shall review the CMU chemical hygiene plan within 30 days of beginning work in a lab.

Lab Registration

Lab supervisors shall register labs by contacting the OLFS. Registration information includes primary and secondary emergency contacts, phone numbers, entry permissions, hazard warnings, and chemical inventories. The registration information is available to the contacts through Laboratory Registration Manager and shall be reviewed and updated biannually per to OLFS prompt or more frequently when conditions change. The registration information is required for emergency response, routine work order completion, and lab door signs to reflect the registration information. 

Each space MUST have a primary and secondary contact, and each contact must provide a cell phone number of indicate that the office phone number listed is forwarded to their cell phone. Phone numbers are not available to the public, only first responders and those individual with access to the information in Laboratory Registration Manager. Primary and secondary contracts must be lab supervisors.

Chemical Inventory

Lab supervisors shall maintain a real-time chemical inventory for each lab. They must update the inventory biannually in Laboratory Registration Manager for regulatory reporting and emergency response purposes. The chemical inventory template is in the CMU chemical hygiene plan.

Lab Deficiencies

Lab supervisors shall correct safety deficiencies identified during inspections or incident outcomes within 30 days. Time extensions may be given for corrective actions that cannot reasonably be completed in 30 days.

Enforcement

Faculty and staff are subject to discipline up to and including loss of access to registered lab spaces on campus if the policy is not followed.

Central Michigan University reserves the right to make exceptions to modify or eliminate this policy and or its content. This document supersedes all previous policies, procedures or guidelines related to this subject.