Personal Protective Equipment within Wet Laboratories Standard

This Standard applies to Personal Protective Equipment worn within Wet Labs by UCL employees, students and visitors.

Scope

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This document sets the minimum standard for Personal Protective Equipment ("PPE") to be worn in any laboratory on UCL owned or UCL run sites where the area is being used as a wet laboratory ("web lab"). 

Due to the risks associated with chemical and biological splashes, spills etc UCL has stated that in the teaching and research environment, the default for reasonable control measures is the wearing of PPE as stated in this Standard; it consists of eye protection and lab coats.

Any activity taking place in a wet lab/area where there is the use of chemical or biological substances must consider the risk of splashes and spills as a significant risk and implement this Standard.

Only when an additional specific risk assessment and the written procedures state that PPE is either not a suitable or necessary control measure can its use be modified. This could be due to the risk of the specific activity either not being present or that the PPE will not provide any additional control. 

This Standard covers:

• Staff, students, graduates, postgraduates and visitors who work in or visit wet labs.
• All wet labs used for teaching and research, including chemical and biological labs (including CL2 and CL3 labs and suites).
• Engineering spaces or other practical workspaces must follow this Standard if they carry the same or similar risk as wet labs in that the area risk assessment demonstrates there is a risk of splashes and spills of hazardous substances. 

Note that engineering spaces and other experiments may require PPE for other reasons, such as eye protection for the risk of projectiles or sharps. This must be considered when setting the minimum standard for the PPE for that area and specific activities in that area.

Where the use of this Standard does not apply

Cleaning or chemicals stores that are managed by contractors with no access to UCL staff or students (PPE requirements should be part of the risk assessment/method statement for the contracted activity).

Contractors and other individuals carrying out maintenance work within wet labs are not covered by this Standard. However, before they are allowed to enter the space, they must have a risk assessment and method statement that includes the hazards present in the wet lab and shows that these are controlled, which may include specific PPE requirements.

Legal requirements

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• Health and Safety at work etc Act 1974
• Control of Substances Hazardous to Health Regulations (COSHH) 2005
• Personal Protective Equipment (PPE) at Work Regulations 2022

Employers have a duty to ensure, as far as is reasonably practicable, the health, safety and welfare of their employees at work. Employers must complete a risk assessment, which should consider controls to manage the risks and provide adequate control to exposure.

Some risks may remain after engineering controls and safe systems of work have been applied, so adequate control of exposure cannot be achieved by other means and the employer must provide suitable personal protective equipment, in combination with other control measures.

Employees have a duty to wear any PPE that their employer requires, correctly.

Definitions

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• Biological substances – These include naturally formed or genetically modified bacteria, fungi, viruses, prions, as well as human or animal tissues and bodily fluids that may contain pathogenic organisms and present a risk to human and animal health.
• Chemical substances – Chemical substances exist as solids, liquids, vapours, mists, gases or fumes, and may change between phases of matter with changes in temperature or pressure. Note that chemical substances include water, acids and bases.
• Dry lab – A dry lab is a laboratory where the nature of the experiments does not involve significant risk from spills, splashes or exposure to hazardous chemical or biological agents.
• Eye protection – PPE that protects the wearer against exposure to hazards including chemical and biological hazards, dust, projectiles, gas and vapour or radiation. PPE options include safety spectacles, safety goggles, face screens, face shields and visors. Safety glasses are different to safety goggles as safety goggles provide the user with a higher level of coverage. Eye protection must comply with appropriate standards. Standard prescription glasses that do not comply are not protective and may increase the risks of personal injury if worn as a replacement for eye protection.
• Hazardous chemicals – A hazardous chemical is a pure substance or a mixture that may pose harm to human health, facilities, property or the environment.
• Lab coats – Worn to protect the user from contamination of general clothing. Lab coats are worn over the top of general clothing to provide splash protection from liquids, vapours, aerosols, fumes and mists preventing direct contact with the skin and clothes. UCL-approved lab coats must be made from fabric suitable for chemical use. Considerations should be made of chemical interactions with the fabric and reaction to fire. Many synthetic materials may be melted or degraded by lab chemicals. In addition, synthetic fabrics will ignite, burn or melt when exposed to a naked flame.
• Personal Protective Equipment ("PPE") – Equipment that can be worn or held by a person which protects against exposure to hazards that can impact a person’s health and safety. 
• Skin exposure – Exposure of the skin surface to hazardous substances can lead to chemical burns, damage or sensitisation through a single exposure or repeated exposures. Becoming sensitised to one substance can increase the risk of developing sensitisation to other substances. 
• Visitors – People external to UCL or from different UCL departments and buildings.
• Wet lab – A wet laboratory is an area used to handle various types of chemical or biological substances where there is a potential risk of spill, splash or exposure that could potentially cause harm to people. 

UCL requirements for PPE worn in Wet Labs

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This is the expected minimum standard for PPE in all UCL’s wet labs. Risk assessments can be used to identify additional PPE requirements but cannot lower the standard of PPE used.

Lab Coat

A lab coat must be worn by all staff, students and visitors, when going beyond the entrance to any wet lab. 

The minimum standard for a reusable wet lab coat is:

• Standard ‘V’ neck coats are suitable for general laboratory procedures.
• Either cotton or polyester-cotton (65%:35%) for biological use which can be autoclaved, or cotton-polyester (75%:25%) which can be treated with Proban to be flame retardant.
• Press stud fastening to allow for quick removal if contaminated.

The standard required for a reusable CL2 and CL3 wet lab coat is:

• Double-fronted, high-neck coats with kitted cuffs (Howie style).
• Not cotton as these cannot be autoclaved.
• Press stud fastening.

The requirement for flame retardant treatments for lab coats must be set on a lab-wide basis based on all the hazards within the lab. If fire or exposure to flames is a significant hazard, polyester-cotton (65%; 35%) lab coats are not allowed as they burn readily and will melt and stick to the body causing burns. 

All staff should have at least one lab coat issued to them. Clean, reusable, or disposable lab coats should always be available for visitors in a range of sizes.

• The lab coat must be fully fastened when in the lab and all jewellery, scarves, ties and accessories that might become contaminated or cause entanglement, should be contained within the lab coat.
• The lab coat should be maintained in good condition, laundered at routine intervals and laundered as soon as possible after hazardous substances have been spilled or splashed onto the lab coat. 
• Failure to wear or correctly wear a lab coat will result in the individual being asked to leave the wet lab and may result in further disciplinary action if the behaviour is repeated.

Eye Protection

Eye Protection must be worn by all staff, students and visitors when going beyond the entrance to any web lab. Where this is not practicable, eye protection must be put on as soon as possible upon entering the laboratory and always prior to any work starting. Note that local arrangements must ensure the risk of eye injury from spills and splashes is reduced as far as is reasonably practicable at all times.

The minimum standard is BS EN 166:

• Class 1 (permanent wear).
• F (strength).
• 3 (chemical risk).

Arrangements must be in place to accommodate those individuals who need to wear corrective glasses. Over-glasses or prescription safety glasses must meet the standard.

• Eye protection must undergo user checks routinely.
• All users must undertake a visual check of their eye protection before use.
• If damaged, contaminated or having received an impact, they should be removed from use and replaced if necessary. 
• Failure to wear eye protection or failure to wear eye protection correctly will result in the individual being asked to leave the wet lab and may result in further disciplinary action if the behaviour is repeated. 

Suitable clothing

Although footwear and appropriate clothing is not considered PPE it must provide minimum protection to the skin and the foot.

Cotton or canvas shoes are not suitable as chemicals may soak through to the foot too quickly.

• Footwear must fully enclosed and cover feet.
• Footwear must be able to resist hazardous substances to slow exposure to the foot.
• Clothing must be sufficient to cover the legs and resist exposure to hazardous substance splashes and spills.

Risk assessment

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The risk from spills and splashes of substances harmful to health must be included in all activity risk assessments for wet labs. Although the baseline protection may not change, it may be necessary to increase the standard of control measures depending on the risk. This may include the need for PPE to be provided for covering areas not covered by a lab coat, further head protection or footwear, more face and eye protection, or RPE.

Storage of PPE for Wet Labs

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• Storage must be available for staff and visitors’ lab coats and eye protection on site.
• The storage area must be situated as close as possible to the wet lab.
• Storage can be inside the wet lab, provided there is a suitable distance between the storage area and the activity – to lower the risk of spills and splashes before the eye protection and lab coats are put on.
• The storage area must maintain both eye protection and the lab coat in a suitable condition.

Lab Coats

• Lab coats must be hung or stored in such a manner as to minimise the risk of contamination on the outside being transferred to the inside of the coat or to any other object. 

Eye Protection

• Eye protection must be stored in such a manner as to minimise the risk of the lenses being scratched or the frames being bent out of shape.
• Eye protection must be stored so they are free from dust or other contamination on the inside of the lens which is closest to the eye.

Gloves

• Gloves must be stored away from areas where they can be easily contaminated.
• Nitrile gloves must be stored away from direct sunlight as sunlight will deteriorate the gloves.

When gloves that are used to protect against the risk of sensitisation are themselves considered a hazard due to the activity undertaken, this must be made clear in the risk assessment for the activity. The risk assessment must include the alternative control measures that are to be implemented. This may include the requirement to undertake low level health surveillance for workplace dermatitis.

Movement between laboratories

Lab coats and gloves that are or could be contaminated are not to be worn outside wet labs. 

In most cases when transferring chemical or biological samples between labs, substances should be packed such that PPE is not required. Where this is not possible, a written risk assessment will be required, and the control measures should either include a clean lab coat and fresh nitrile gloves or local rules/written arrangements regarding how the local areas are managed that are agreed by all users of the areas, including all departments in shared spaces. All local rules/written arrangements must be supported by, or derived from, a suitable and sufficient risk assessment. This is to prevent contaminating areas outside of the wet lab e.g. corridors/door handles, or spills and splashes impacting staff not wearing PPE.

If the wet lab is part of a suite of rooms such as the CL3 lab, then a lab coat, eye protection and gloves can be worn when moving around the suite. However, they must be removed upon leaving the suite to prevent potential contamination outside the containment areas.

Responsibilities

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Department responsibilities

1. Ensuring they know which areas they have that are classified as wet labs and inform all staff, students and visitors about these areas and the requirement for PPE.
2. Ensuring there is a suitable risk assessment for all wet labs that either:
   1. Clearly states how they are following the UCL standard, specification for the PPE to be worn in that area; or
   2. Defines any areas, such as areas for microscope work, that are located in the wet labs and covers the other control measures that are in place showing why specific PPE may be either unnecessary or introduces a new hazard.
3. Ensuring that all staff, students and visitors are aware of the UCL standards for PPE in wet labs and that they follow the latest UCL Safety Standard that applies to these areas.
4. Ensuring that all risk assessments for specific activities with chemical or biological substances or in areas where chemical or biological substances are used include control measures for the risk of spills and splashes.
   • Acknowledgment of this standard and information on whether any additional standard for the PPE has to be used; or
   • A full assessment of all the controls in place that lower the risk of spills and splashes as far as reasonably possible showing why the PPE requirement differs from the standard. See Risk Assessment – PPE as a control measure in wet laboratories for guidance.
5. Ensuring PPE is available in a range of sizes to fit the users.
6. Ensuring that each wet lab has a specific risk assessment that covers:
   • Whether the minimum standard of lab coat is suitable or if additional requirements are needed, such as greater protection around the neck and wrist, specific fabric needs and whether flame retardant lab coats are required. 
   • If additional requirements for eye protection are needed including:
     • Additional strength.
     • Heat resistance.
     • Different designs such as safety goggles instead of safety glasses.
   • Information on what standard glove is required and if any activity requires an assessment for not wearing gloves.
   • To provide the descriptions and specifications when higher protection is required for the activity such as when working with liquid nitrogen which may require face shields, thermal gloves and aprons. 
   • Any additional PPE that is required for the area or task including but not limited to respiratory protection equipment such as FFP3 masks. 
7. Providing both a departmental and lab-based standard for footwear in wet labs.
8. Providing information on the following:
   • Storage.
   • Cleaning.
   • Maintenance.
   • Provision of PPE, including policy on prescription safety glasses for staff.
   • Training including wearing, donning and doffing of PPE, what to do with contaminated PPE.
   •  Replacement.
9. Carrying out checks, inspections and audits on the implementation of this standard and any additional requirements set by the department and included in the approved risk assessments.

Safety Services responsibilities

1. Providing UCL Safety Standards for research and teaching activities across the UCL campus.
2. Communicating this standard and any changes in legislation to all the departments.
3. Communicating any changes in legislation and to this standard to the Chemical Safety Sub-Committee and the Genetic Modification and Biological Safety Sub-Committee.

Chemical Safety Sub-Committee responsibilities

1. Reviewing this UCL Safety Standard annually.

Genetic Modification and Biological Safety Sub-Committee responsibilities

1. Reviewing this UCL Safety Standard annually.

Records

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• Risk assessments describing the PPE required, including suitability, compatibility, maintenance, storage, cleaning.
• PPE issue, inspections of usability and maintenance records where necessary.

Monitoring and review

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Regular inspections of PPE to check that it is not damaged or compromised reducing its protection to the user from hazardous agents.

References

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• The Personal Protective Equipment at Work (Amendment) Regulations 2022
• The Control of Substances Hazardous to Health (COSHH) Regulations 2002
• UCL Risk Assessment Standard
• Substances Hub
• Workplace Health