Chemical Exposure Program

WCPP is a program to protect potentially exposed persons in the work place and/or who are engaged in conditions of use that are not prohibited. The WCPP requirements include inhalation exposure limits, called EPA existing chemical exposure limit (ECEL) and EPA short term exposure limit (EPA STEL) to protect potentially exposed persons.

What is an Existing Chemical Exposure Limit (ECEL)?

An Existing Chemical Exposure Limit (ECEL) is a regulatory occupational exposure limit (OEL) set by EPA to limit inhalation risks to workers exposed to certain chemicals in a workplace. The ECEL is a maximum average airborne concentration of the chemical that someone can be exposed to in the workplace without experiencing unreasonable risk from inhalation exposure to the chemical. ECEL is expressed as an 8-hour time-weighted average (TWA). EPA may also propose or set an EPA Short-Term Exposure Limit (EPA STEL), written as a 15-minute TWA.

WCPP is a program to protect potentially exposed persons in the work place and/or who are engaged in conditions of use that are not prohibited. It consists of:

• Establishment of an EPA Occupation Exposure Limit or EPA Short-Term Exposure Limit under TSCA
• An ECEL action level
• Occupational exposure monitoring
• Regulated area(s)
• Exposure Control Plan
• Direct Dermal Contact Control (DDCC)
• PPE Program
• Training requirements
• Recordkeeping requirements
• Downstream notification

UTD’s Chemical Protection Program begins when Risk & Safety identifies chemical(s) on campus that pose a potential risk to the user, the responsible party must register the chemical(s) with UTD using the Chemical Registration Form in BioRAFT and participate in exposure testing.

When completing the form, please make sure each of these topics can be identified:

Basic Information

• Lab/Space Name
• Principle Investigator/Responsible Party
• Form completed by
• Chemical(s) used
• Lab members using the chemical
• Special considerations of the users
• Frequency of use
• Associated space(s)

Hazards

• List all hazards associated with the chemical(s)
• Waste management methods (Please include Laboratory Waste Stream #, if possible.)

Hazard Analysis

• Hazard Analysis Form
• Standard Operating Procedure
• Manufacturer’s SDS

PPE and Equipment

• List all PPE required to use the chemical.
• List engineering controls
• List decontamination procedures, if possible.
• List any special emergency equipment beyond the standard eyewash, safety shower and ABC fire extinguisher.

Starts with Chemical Identification: chemical inventory or chemical purchase.

Form Notification: Chemical Registration Form will be assigned in BioRAFT to the Responsible Party.

Form Completion: The Responsible Party must complete/submit the form with the information mentioned above​.

Form Review: The Safety Team reviews the form.

• Form Resubmission​: The Safety Team notifies the user(s) of missing information and requires the form to edited/resubmitted​. Return to Form Completion stage above.
• Form Accepted: The Safety Team notifies user(s) through BioRAFT the form is accepted​

Once the form is accepted, the Chemical Registration Form process is completed. If the chemical(s) registered in the form are regulated for exposure limit assessments, the user(s) will be notified on being placed in the Chemical Exposure Program.

As a part of the Chemical Exposure Program, the Chemical Safety team will notify the UTD Community of regulated chemicals and their exposure limits using the campus wide messaging system, BioRAFT and the University wide mass communication system.

As a part of this notification, the Chemical Safety team will communicate potential sources of where the regulated chemical(s) reside such as in pure form for research purposes or within household hazardous materials.

From there, the community may reach out to Safety@utdallas.edu for removal of the material(s) or be placed in the exposure program.

In addition to the campus wide communication, the Chemical Safety team will notify individual users using the UTD Campus Inventory to schedule an exposure testing date for regulated chemicals that remain in their inventory for use.

Once the Chemical Registration Form is completed, the Chemical Safety team will review the form and schedule an in-person consultation with the user(s) to perform exposure testing as well as what they can expect from the program.

The process for exposure testing is:

• Notification of regulated chemical(s)
• Complete chemical registration form(s)
• Schedule exposure testing consultation & test date
• Communicate exposure testing results to user/responsible party
• Provide follow-up consultation with recommendations to lower exposure levels
• If necessary, provide additional exposure testing

If you or someone in your laboratory space is concerned about their exposure to chemicals, send an email to Safety@utdallas.edu to begin the Chemical Exposure Program. The Chemical Safety team will reach out to you for a consultation to determine an exposure test that best fits your needs. Results will be provided to your UTD Email and, if necessary, we will schedule a follow up consultation to go over the test results and provide recommendations to lower your exposure.