5.1.2 High Risk Hazardous Chemicals/Select Agents
5.1.3 Controlled Substances, Precursor Chemicals & Controlled Lab Apparatus
· Always order the smallest amounts of the needed chemicals. Be familiar with disposal requirements before ordering chemicals.
· Check your inventory regularly and dispose of outdated or unnecessary chemicals. Avoid a stockpile of unused chemicals.
· Consider ordering solvents in safety tins rather than glass bottles. The metal containers are more expensive, but do provide protection against breakage and spillage. Such purchase orders should state that the more expensive containers are requested for safety purposes.
· If the compound is a High Risk Hazardous Chemical/Select Agent or DPS Controlled Item, special procedures are required (see sections 5.1.2 or 5.1.3, respectively).
· If the chemical compound is labeled/tagged with radioactive material, refer to the Radiation Safety Manual for additional ordering information.
5.1.2 High Risk Hazardous Chemicals/Select Agents
· The maximum quantity of the agent to be possessed by the Principal Investigator at any time shall not exceed the minimum amount needed to complete the project.
· The package containing the hazardous agent shall be inspected for leakage or damage upon receipt. EHS B&C shall be notified if leakage or damage is noted.
The following agents fall under the Health and Human Services (HHS)/Center for Disease Control and Prevention (CDC) Select Agent regulations and are strictly controlled.
Abrin Botulinum neurotoxin
Conotoxins Diacetoxyscirpenol
Ricin Saxitoxin
Shigatoxin Staphylococcal enterotoxins
Tetrodotoxin T-2 toxin
Soman Shiga-like ribosome inactivating proteins
If you are ordering or transferring on/off campus any of these agents, please contact EHS at ext. 21781 for further information.
5.1.3 Controlled Substances, Precursor Chemicals & Controlled Lab Apparatus
A Memorandum Of Understanding (MOU) was issued jointly by the Texas Higher Education Coordinating Board and the Texas Department of Public Safety (MOU on Controlled Substances, 1995 Health and Safety Code, 481.0621 (b), Texas Controlled Substance Act) to comply with a statutory requirement to implement and maintain a program for reporting information concerning controlled substances, controlled substance analogues, chemical precursors and chemical laboratory apparatus used in educational or research activities of institutions of higher education.
Records of purchase and external transfer are required. The sale, furnishing or transfer of controlled items off campus is strictly prohibited unless the recipient holds a DPS permit, waiver or is exempt. Off campus transfers require the completion of DPS Form Nar-22. Contact EHS B&C at extension 21781 for more information.
To implement this policy, individual faculty members (research and clinical laboratories) are required to maintain records of purchase of the items from a list of precursor chemicals and laboratory apparatus (see list below). A suggested way to accomplish this is to perform a screen print of the purchase requisition. Highlight any controlled items on the requisition and maintain in a file for future DPS audit. In addition, the Purchasing Department has assigned an attribute code of “Q” to be placed (or selected from the menu) in the field called “PURCHASE TYPE” on purchase requisitions for ease of identifying the controlled items. The use of this identifying code is required (not optional).
Precursor Chemicals
Laboratory Apparatus
Methylamine
Condensers
Ethylamine
Distilling apparatus
D-Lysergic Acid
Vacuum dryers
Ergotamine tartrate
Three-necked flasks
Diethyl malonate
Distilling flasks
Malonic acid
Tableting machines
Ethyl malonate
Encapsulating machines
Barbituric acid
Filter, buchner, separatory funnels
Piperidine
Erlenmeyer, two-necked, single, round bottom, thermometer, filtering flasks
N-acetylanthranilic acid
Soxhlet extractors
Pyrrolidine
Transformers
Phenylacetic acid
Flask heaters
Anthranilic acid
Heating mantles
Ephedrine
Adapter tubes
Pseudoephedrine
Norpseudoephedrine
Phenylpropanolamine
Sale, furnishing or transfer of controlled items off campus is strictly prohibited unless the recipient holds a DPS permit, waiver or is exempt (contact EHS-B&C prior to off campus transactions). In addition, off campus transactions require the completion of DPS Form Nar-22. Although transfer of any of the controlled items can be performed internally without documentation, it is recommended should any future questions arise.
The MOU requires that any laboratory that discovers an unacceptable discrepancy, loss, pilferage, or theft of a controlled item is responsible for submitting a written report of the incident to the University Police no later than 5 business days after the day of discovery.
Department chairmen are responsible for instituting departmental procedures for ensuring the security of controlled items. University Police may be contacted for assistance regarding this matter.
Researchers are also reminded that they are not exempt from annual registration with the Federal Drug Enforcement Agency under the Federal Controlled Substances Act for the purchase and possession of controlled substances and controlled substance analogues. Registration applications may be obtained from the regional DEA office and must be submitted to Washington, D.C. Processing takes about 8 weeks. The address of the closest regional office is:
DEA Diversion Group (Registrations)
333 West Loop North, Suite 300
Houston, TX 77024-7707
(713) 613-7661
Do not store hazardous chemicals in alphabetical order. This may place incompatible chemicals next to one another, (i.e., acetic acid and ammonium hydroxide, an acid and a base) or may cause large sized, glass bottles to be stored on a top shelf. Chemicals should be segregated according to compatibilities and hazards.
The following guidelines should be used when storing any chemical:
· Every chemical should have a specific storage location and should be returned immediately after use.
· Be sure to read the label on every container for storage instructions and follow those instructions carefully.
· Except for those chemicals in use, do not use a chemical fume hood as a storage area for chemicals or solvents. The cabinet below the chemical fume hood is suitable for storage if it is vented and labeled.
· Chemicals cannot be stored under sinks.
· Volatile and odoriferous chemicals need to be stored in a ventilated cabinet.
5.2.1 Related and Compatible Storage Groups
Inorganic Family
Organic Family
Metals, hydrides
Acids, anhydrides, peracids
Halides, sulfates, sulfites, thiosulfates, halogens, phosphates
Alcohols, glycols, amines, amides, imines, imides
Amides, nitrates (except ammonium nitrate), nitrites, azides
Hydrocarbons, esters, aldehydes
Hydroxides, oxides, silicates, carbonates, carbon
Ethers, ketones, ketenes, halogenated hydrocarbons, ethylene oxide
Sulfides, selenides, phosphides, carbides, nitrides
Epoxy compounds, isocyanates
Chlorates, perchlorates, perchloric acid chlorites, hypochlorites, peroxides, hydrogen peroxide
Peroxides, hydroperoxides,
azides
Arsenates, cyanides, cyanates
Sulfides, polysulfides, sulfoxides, nitrites
Borates, chromates, manganates, permanganates
Phenols, cresols
Nitric acid, other inorganic acids
Sulfur, phosphorus, arsenic, phosphorus pentoxide
5.2.2 Incompatible Storage Groups
Chemical
Avoid . . . .
Acetic acid
Chromic acid, nitric acid, hydroxyl-containing
compounds, ethylene glycol, perchloric acid, peroxides and permanganates
Acetic anhydride
Ethylene glycol, perchloric acid
Acetone
Concentrated nitric acid sulfuric acid
Acetylene
Chlorine, bromine, copper, silver, fluorine, mercury
Alkali and alkaline earth metals, such as potassium, lithium, magnesium, calcium (powdered)
Carbon dioxide, carbon tetrachloride, other chlorinated hydrocarbons (do not use water, foam, or dry chemical on fires involving these metals). Dry sand should be available.
Ammonia (anhydrous)
Mercury, chlorine, calcium, hypochlorite, iodine, bromine and hydrogen fluoride
Ammonium nitrate
Acids, metal powders, flammable liquids, chlorates, nitrate, sulfur, finely divided organics or combustibles
Aniline
Nitric acid, hydrogen peroxide
Bromine
Ammonia, acetylene, butadiene, butane and other petroleum gases, sodium carbide.
Calcium oxide
Water
Carbon (activated)
Calcium hypochlorite
Chlorates
Ammonium salts, acids, metal powders, sulfur, finely divided organics, combustibles
Chromic acid and chromium trioxide
Acetic acid, napthalene, glycerol, turpentine, alcohol and other flammable liquids
Chlorine
Ammonia, acetylene, butadiene, butane and other petroleum gases, hydrogen, sodium carbide, turpentine, benzene and finely divided metals
Chlorine dioxide
Ammonia, methane, phosphine, and hydrogen sulfide
Copper
Acetylene, hydrogen peroxide
Fluorine
Isolate
Hydrazine
Hydrogen peroxide, nitric acid, other oxidants
Hydrocarbons (benzene, propane, gasoline, turpentine)
Fluorine, chlorine, formine, butane, chromic acid, peroxides
Hydrocyanic acid
Nitric acid, alkalies
Hydrofluoric acid, anhydrous (hydrogen fluoride)
Ammonia (aqueous or anhydrous)
Hydrogen peroxide
Copper, chromium, iron, most metals or their salts, any flammable liquid, combustible materials, aniline, nitromethane
Hydrogen sulfide
Fuming nitric acid, oxidizing gases
Iodine
Acetylene, ammonia (anhydrous or aqueous)
Mercury
Acetylene, fulminic acid, ammonia
Nitric acid (concentrated)
Acetic acid, acetone, alcohol, aniline, chromic acid, hydrocyanic acid, hydrogen sulfide
Nitroparafins
Inorganic bases, amines
Oxalic acid
Silver, mercury
Oxygen
Oils, grease, hydrogen, flammable liquids, solids or gases
Perchloric acid
Acetic anhydride, bismuth and its alloys, alcohol, paper, wood, grease, oils
Peroxides (organic)
Acids (organic or mineral), avoid friction, store cold
Phosphorus (white)
Air, oxygen
Phosphorus pentoxide
Alcohols, strong bases, water
Picric acid (trinitrophenol)
Copper, lead, zinc concrete, ammonia, calcium, bases
Potassium chlorate
Acids (see also chlorates)
Potassium permanganate
Glycerol, ethylene glycol, benzaldehyde, sulfuric acid
Silver
Acetylene, oxalic acid, tartaric acid, fulminic acid, ammonium compounds
Sodium
See alkali metals
Sodium nitrite
Ammonium nitrate and other ammonium salts
Sodium peroxide
Any oxidizable substance, such as ethanol, methanol, glacial acetic acid, acetic anhydride, benzaldehyde, carbon disulfide, glycerol, ethylene glycol, ethyl acetate, methyl acetate, furfural
Sulfuric acid
Chlorates, perchlorates, permanganates
The transportation of hazardous materials is strictly regulated. Failure to adhere to applicable regulations can result in fines and/or punitive actions against the university and the transporter. In addition to violating state and federal transportation laws, personal liabilities can be associated with failure to follow the appropriate shipping and handling requirements.
The Department of Transportation (DOT) regulations regarding the shipment of hazardous materials state that “…no person may offer or accept a hazardous material for transportation in commerce unless…the hazardous material is properly classed, described, packaged, marked, labeled and in condition for shipment.” (HM-171.2)
In agreement with the Civil Aviation Security Field Office and the Federal Aviation Administration, UTMB has established a system to meet these requirements. No UTMB employee will be permitted to ship hazardous materials without having completed certified DOT/ IATA training. Retraining is required every two years. If hazardous chemical shipments are planned, notify EHS prior to shipment (including Select Agent toxins). Any such shipment must be reviewed by a representative from EHS prior to shipment. Select members of the EHS staff and Materials Management group have successfully completed the training course in order to oversee shipping of hazardous materials. Any UTMB employee shipping hazardous materials without the required current training is acting as their own agent and assumes all liability as such.
For detailed information on hazardous waste disposal, see Chapter 10 in the Safety Manual. For chemical (and radioactive) waste pick-up, complete the on-line request form at http://www.utmb.edu/ehs/EPM/EPM.html . After completing the on-line web-based form, submit it electronically to EHS and the request will be processed for pick-up the next pick-up day. Chemical pick-up days are Wednesdays and Fridays. Radioactive waste pick-up days are Tuesdays and Thursdays. Once submitted, you will receive electronic confirmation of your request.