Risk assessment – PPE as a control measure in wet laboratories

Risk assessments for activities using chemical or biological substances must include control measures for the risk of spills and splashes. This page has guidance on how to write this risk assessment.

Personal Protective Equipment (PPE) is provided when a risk assessment shows that risk still remains when all other control measures have been implemented.

UCL has assessed the normal working conditions for the use of hazardous substances and has decided that in these conditions there will be a residual risk and that the wearing of lab coats and eye protection is required, particularly due to the likelihood that the consequences of any injury to the eye may cause permanent sight loss.

• The Standard (“Personal Protective Equipment within Wet Laboratories”) is the generic risk assessment that may be added to for specific activities where either the hazard is used in such a way that the risk is lower or additional control measures have been put in place to lower the risk to as close to none as practicable.
• Only when an approved specific risk assessment and administrative controls are in place, and all staff, students and visitors are aware of this, can the use of lab coats, eye protection or gloves be considered not to be required PPE and therefore not compulsory to be worn.
• The specific risk assessment has to be suitable and sufficient in identifying the hazards, the risks that the hazards present and the specific nature of how the control measures will eliminate or lower that risk.

Safety Services has provided the following guidance to help ensure that when considering the need for PPE as a control measure. This does not cover any other hazard or control measure that also needs to be included in the specific risk assessment and it is still the department’s responsibility to author and approve the risk assessment before work begins.

Background

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Assessment outline

Summarise the specific task including the hazards of the chemical or biological substance (state whether wet or dry) that is being used. It must be clear from the beginning of the risk assessment what this covers because:

1. No task using any wet chemical or biological substance should be carried out without wearing a lab coat or eye protection. PPE must be used where wet chemical or biological substances are part of a task.
2. Where any chemical or biological dust has a risk of being blown into the eye area, eye protection must be worn.
3. If the task can be separated into activities, this may allow PPE requirements to change between the tasks as the chemical or biological substance may be contained and can no longer be spilled or splashed, but it must be clear where the hazards and risks are different and where different control meausres apply.

Further location information

Summarise the other tasks that will be undertaken in the area, the standard covers all wet labs and other practical spaces using chemical or biological substances for teaching and research. It must be clear that the person working on the specific task is not at risk from others in the area spilling or splashing the chemical or biological substance because: 

1. People make mistakes. For example, when moving or using chemical or biological substances they may trip and spill chemical or biological substances allowing the chemical or biological substance to reach other people in the area.
2. Administrative controls require greater supervision than engineering controls and if PPE requirements are not standardised in an area it must be clear what is required, where and how it is managed and be able to be inspected.
3. Ensure that the engineering controls are suitable for both the area as well as the specific activity.

Activities, hazards, controls

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Add an activity

Most tasks can be broken down into separate steps or tasks, such as storage, preparing the sample, analysing the sample, clearing up and waste management. Some tasks, for example, analysing the sample, may be able to be broken into smaller sub-tasks. 

When considering the PPE requirements there may be specific activities where the general PPE requirement either introduces additional hazards or the risk is not significant. By breaking up the activity into separate tasks it allows this to be shown easily. 

Hazards

When the UCL PPE Standard for Wet Labs is being followed, the hazard can be the risk of injury to a person through spills and splashes of chemical or biological substances.

When a specific risk assessment is considering that specific PPE is either not required or will introduce an additional hazard, the hazard title and summary should cover this by indicating the injury to the body part the PPE is there to protect. 

Example – injury to eye(s)

Summarise how the eye(s) could be damaged – this could include one or more of the following:

• Chemical burn – from splash of stated chemical entering the eye.
• Irritation caused by/from fumes or gases interacting with the eye(s) during the activity.
• Scratching or other physical damage to the eye from particles such as dust or powder from the stated chemical or other hazard entering the eye.
• Puncture injury from contaminated shrapnel injury from an expected or unexpected explosion of an object containing chemicals or near to chemicals.
• Temporary or permanent sight loss.

Existing control measures

All control measures that will be in place during the tasks have to be listed here. This should follow the hierarchy of control which ensures that the most effective controls are put in place first. For example, permanent engineering control measures that protect many people before less effective controls such as PPE which only protect the individual. 

This will allow the risk assessment to show that the risk from the injury and therefore the requirement for the PPE is no longer necessary. Areas that should be explicit in the risk assessment are:

Elimination or substitution

• Use of non-hazardous chemicals, including lowering the concentration so that the risk is as low as practicable.
• Use of small amounts that cannot be spilled or splashed far.

Engineering controls

• Separation of hazard and people.
  • Demarcation of zones where chemical or biological substances can be used or where they cannot enter – there must be a buffer zone based on people spilling the chemical or biological substances.
  • Secondary containment of the chemical or biological substances, carried out in a fume cupboard or booth, separating the risk from the rest of the area or an enclosed area for those not using the chemical or biological substances.
  • Secure containment of the chemical or biological substances – usually in storage areas.
• Removal of handling of the chemical or biological substances.
  • Use of dosimetry.
  • Automatic filling or other equipment.
• Procedural controls.
  • Separation of chemical or biological substances and people through control of work activities.
    • Time set for work with chemical or biological substances.
    • Booking of the lab so only one person/team at a time is the lab.
    • Standard operating procedures with a workflow indicating when eye protection has to be worn.
  • Signage.
    • Signage or warnings to ensure people entering the area that work with a substance that poses a risk to eyes is taking place and that they must wear eye protection upon entry. Signage by the chemical or biological substance reminding the need for eye protection before using chemicals or specific equipment.
• Information and instructions.
  • Departmental specific induction to indicate when the UCL standards are enhanced with specific risk assessments.
  • Lab specific induction to include/refer to PPE standards and lab specific risk assessments.
  • Procedures in place stating when eye protection has to be worn.
  • Procedures in place for when eye protection is not required.
• Training and supervision.
  • Staff and students are to be briefed and involved in all relevant risk assessments.
  • Competence checks to include knowledge and adherence to the PPE rules including those for eye protection.
  • All staff to be aware and understand that anyone can ask them to leave a lab if they do not follow eye protection rules.
  • All non-conformities are to be reported to the Head of Department.
  • Departmental procedures are in place for action to be taken if failure to follow the rules is found to be persistent behaviour.

Existing control measures

It must be clear to the approver of the risk assessment why PPE is not considered to be a reasonable control measure. Therefore in addition to being explicit on how the hazard is controlled, there must be information on why the PPE is not required by answering these points.

• Why the specific item of PPE is not suitable for the conditions of the activity.
• Do the other control measures lower the risk as far as reasonably practicable.
• Is there suitable information/instruction and training to ensure that the individual carrying out the task understands the risks.
• Is there suitable supervision to ensure that PPE is worn correctly?

When additional risk assessment layers are added to UCL standards it is recommended that either the department has a written procedure to ensure that there is an appropriate level of approval for the specific risk assessment or that it is approved by the Head of Department.