TEMPLE UNIVERSITY ENVIRONMENTAL HEALTH AND RADIATION SAFETY

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1 Page 1 of 5 ISSUED: 5/00 REVISED: 08/06 Introduction Purpose This chapter provides guidelines for minimizing exposure to mercury and compliance with applicable mercury regulations. Applicability This chapter is applicable to all Temple University employees, to all work conducted under the authority of Temple University, and to all equipment and property managed by Temple University. Non-Temple and contractor personnel will follow the provisions of this chapter while at Temple University facilities. This chapter may apply to facilities, branches, or divisions with any of the following: 1. An employee who may be exposed to mercury at levels greater than or equal to 0.05-mg/m Employees who show symptoms of mercury exposure. 3. Facilities that generate mercury-containing hazardous waste. Health Effects Mercury is a poison by inhalation. It is corrosive to the skin, eyes and mucous membranes. Systemic effects by inhalation include wakefulness, muscle weakness, anorexia, headache, tinnitus, hypermotility, diarrhea, liver changes, dermatitis, and fever. There is evidence of possible reproductive effects. Responsibilities for Mercury Safety Environmental Health and Safety Department (EHRS) The EHRS department has the following responsibilities related to mercury activities: 1. Policy implementation.. 2. Surveillance as requested by responsible supervisor. 3. Training as requested by responsible supervisor. 4. Exposure monitoring. Supervisors and Managers Supervisors and Managers must follow these responsibilities related to mercury activities: 1. Assess their site and operations to determine whether mercury is present or used. 2. All persons designated as mercury users shall have access to a copy of this section. The copy should be kept in the user's laboratory for reference. Additional copies are available through the EHS department.

2 Page 2 of 5 ISSUED: 5/00 REVISED: 08/06 3. Review and approve proposed uses of mercury containing products in areas within their jurisdiction. Such approval signifies that management will provide the resources necessary to control hazards and will establish, as organization policy, the procedures necessary to comply with OSHA, EPA, and other government regulations. Such compliance may include the following actions: Provide employee training regarding the safe use, storage, and disposal of mercury. Maintain an adequate stock of required personal protective equipment (PPE). Provide equipment such as eyewash stations, showers, and ventilation devices when required. Make requests to the EHS department for required exposure monitoring and surveillance of work activities. Maintain relevant Material Safety Data Sheets (MSDSs) for mercury products used. Arrange for transportation and disposal of mercury-related waste. Make regular visual inspections for leaks and spills for facilities with liquid mercury. Mercury Users Mercury users are those workers who work with or handle mercury-containing products in their job. These workers have the following responsibilities related to mercury activities: 1. Attend required training classes. 2. Properly use and maintenance of PPE. 3. Comply with Temple University, OSHA, and EPA and other government regulations as they pertain to mercury use. Exposure Monitoring For personal exposure monitoring, area air monitoring should also be performed to document levels within the work area. Area air monitoring data can be a worst-case exposure indicator for casually exposed workers. Exposure and area monitoring can be performed by EHRS, if required or needed. Please contact EHRS for more information. Personal Protective Equipment (PPE) Certain types of PPE are effective in controlling mercury exposure. In normal work situations, PPE should be used only as a supplement to engineering controls. Any mercury-contaminated PPE or clothing must be disposed of as mercury-contaminated waste. Employees must not take mercury-contaminated materials, clothing, or equipment home. Impermeable Gloves: N-Dex gloves are among the appropriate glove choices for protection against skin contact with mercury. Contact EHRS for additional information. Body Covering: Contact EHRS for assistance and additional information. Eye and Face Protection: Eye and face protection in the form of goggles will reduce exposure in cases of splash hazards.

3 Page 3 of 5 ISSUED: 5/00 REVISED: 08/06 Respiratory Protection: Respiratory protection, in the form of supplied air or air purifying type, is not allowed as a substitute for engineering controls, but may be required in cases where engineering controls alone will not adequately reduce exposures. For air purifying respirators, specific mercury cartridges are available. When employees are required to wear respirators to reduce exposure, they must be enrolled in a Respiratory Protection Program, as required by OSHA. The Temple University requires respirator use in the following situations: 1. During emergencies, and entry into areas of unknown mercury concentration. 2. During the period to evaluate, purchase, and install engineering control equipment and/or modify work practices to achieve compliance with the PELs. 3. In work situations where engineering and work practice controls are not yet capable of reducing employee mercury exposure to or below the PEL. 4. During cleaning, maintenance, repair, and other work where engineering and work practice controls are not feasible. Work Practices Each facility shall review each employee s work practices with mercury and implement alternative work practices that will minimize exposure. Please contact EHRS to evaluate the effictiveness of any change. Leak and Spill Detection Facilities with liquid mercury shall create and maintain a program to detect leaks and spills. The equipment leak and spill detection program shall include: 1. Regular visual inspections for leaks and spills; 2. Preventative maintenance of equipment, including surveys for leaks, at regular intervals; 3. Provisions for mercury spill containment, surface decontamination, and waste disposal in work areas where spillage may occur; 4. Prompt cleanup of spills and repair of leaks using persons who wear appropriate protective clothing and equipment and are trained in the proper methods for mercury cleanup and decontamination; 5. Placement of mercury-contaminated waste and debris resulting from leaks and spills into sealed containers that bear a mercury hazard-warning label. The EHS personnel will bare this responsibility. Emergency Showers and Eyewash Stations Eyewash unit shall be located in the same area and must be accessible within ten seconds. Path to eyewash station shall be free of all obstructions. Emergency showers may be required in some cases. Please contact EHRS for additional information.

4 Page 4 of 5 ISSUED: 5/00 REVISED: 08/06 Emergency Situations For any emergencies, please follow instructions in EHRS policy 5.7. Laboratory workers can clean up a small spill that does not present an immediate health risk, such as a spill within a fume hood. Any resulting waste must then be packaged, and then disposed of as a hazardous waste. Consult with the EHRS for specific disposal requirements. For larger spills, the EHRS provides cleanup assistance. If a worker is unsure of his/her ability to clean up a mercury spill outside the control of a local exhaust ventilation device, he/she should call EHRS. Any time respiratory irritation occurs, leave the area and get to fresh air. In case of skin/eye contact with liquid, immediately remove contaminated clothing and flush affected areas with water. Any exposure (inhalation, absorption, ingestion) to mercury shall require a visit to the Employee Occupational Health Office for evaluation. Spill control supplies (adsorbent, gloves, goggles, and disposal bags) shall be made accessible to chemical laboratories and storage sites. Contact EHRS for more information and details. Mercury-Contaminated Waste Any mercury waste created must be characterized in accordance with EPA regulations. Waste determined to be hazardous will be affixed with a hazardous waste label, and handled on site for proper disposal by a hazardous waste contractor, as arranged by the EHRS Chemical Hygiene Officer. Personnel from the EHRS department must sign all manifests for hazardous waste disposal. Medical Surveillance Program The medical surveillance program is provided to monitor the health of mercury-exposed employees, and determine whether continued exposure will adversely affect their health. 1. The medical surveillance program is mandatory for employees who are exposed at or above the AL. 2. The medical surveillance program is optional for the following groups of employees; employees who show symptoms of mercury exposure, or employees who are exposed during an emergency. Hazard Communication Program Implementation of a written hazard communication program is required of each branch or division that uses mercury gas. The hazard communication program must address the following items: 1. Health risks of mercury: 2. Material Safety Data Sheets (MSDSs) 3. Container labeling of mercury 4. Medical surveillance program.

5 Page 5 of 5 ISSUED: 5/00 REVISED: 08/06 5. Instructions to immediately report signs of mercury exposure to the supervisor. 6. Uses and limitations of PPE. 7. Instructions for handling spills and emergency situations. 8. Proper work practices and the use of engineering controls. Employee Training Requirements Information regarding hazard communication training can be obtained from the EHS department. Training must be provided at the time of the initial job assignment and whenever there is a change to the work process. At a minimum, the topics addressed in the hazard communication training shall include: 1. The contents of the OSHA mercury standard (29 CFR ), as well as the location and availability of these regulations. 2. The contents of MSDSs. 3. Health risks 4. The medical surveillance program. 5. The mercury work activities that take place at the facility, and the appropriate work practices that will minimize exposure. 6. PPE use and limitations. 7. Instructions for the use of engineering controls in minimizing exposure. 8. Instructions for handling spills and emergency situations. 9. Access and location of training materials for the affected employees. 10. Container labeling Record-keeping Requirements EHRS will keep accurate and complete records for all mercury-related work areas. When it is felt that objective data will relieve exposure-monitoring requirements, records shall consist of the objective data and calculations that demonstrate that no employee is exposed to mercury at or above the Action Level. Exposure monitoring records shall be kept for at least 30 years. Medical evaluation records shall be kept for the duration of the employee's employment plus at least 30 years. Respirator fit test records shall be kept until replaced by a more recent record. Contractors are responsible for complying with these record-keeping requirements for their own employees.