Hazardous Materials in Animal Care Spaces
Animal care spaces at UC Davis are unique since they have both research and daily animal care aspects. It is important for all users of the space, including researchers and animal care staff, to work together to ensure a safe working environment for everyone.
Policy 49 describes the policies, responsibilities, and procedures associated with the use of hazardous materials in animal care spaces at UC Davis. Additional guidance regarding how Policy 49 should be implemented can be found by accessing the various sections below.
Facility Managers/Technicians-In-Charge and Animal Care Staff
All animal care spaces at UC Davis, and the employees that work in those spaces, fall under the Hazard Communication Program. This program is designed to increase employee awareness of any chemicals and/or medications used in the workplace by providing information about these materials, identifying the associated hazards and potential harmful effects, and how to protect from the risks of those hazards.
PIs and Researchers
All research laboratories at UC Davis, and the researchers that work in those spaces, fall under the Chemical Hygiene Plan. When a researcher enters an animal care space they must also comply with the policies and procedures set forth by the Facility Manager or Technician-in-Charge to ensure the safety of animal care staff, in addition to themselves.
- Biohazardous Material
- Microorganisms or other biological materials (e.g. human cells or body fluids, non-human primate cells or bodily fluids) that present a risk or potential risk to the health of humans, animals, or the environment. They must be listed in Section 8 and Sections 14a and 14b of the Animal Care and Use Protocol to alert animal care staff to reference the VHSS for proper disposal procedures.
- Biological Use Authorization (BUA)
- Document that outlines research involving recombinant DNA technology (including viral vectors), and/or materials that are infectious (or potentially infectious) to plants, animals, or humans. The BUA must be approved by the UC Davis Institutional Biosafety Committee (IBC) prior to EH&S signing off on the Animal Care and Use Protocol.
- Environmental Hazard
- Environmental hazards are indicated by Globally Harmonized System (GHS) hazard codes H400 (Very toxic to aquatic life) and H410 (Very toxic to aquatic life with long lasting effects). Many materials that are environmental hazards are also health hazards; however, there are instances where a material does not pose a health hazard to animal care staff but may still be an environmental hazard. Materials that are only classified as environmental hazards require a Vivarium Hazard Safety Sheet (VHSS) to ensure proper disposal. They must be listed in Sections 14a and 14b of the Animal Care and Use Protocol and in Section 8 to alert animal care staff to reference the VHSS for proper disposal procedures.
- Hazard Communication Program
- All animal care spaces at UC Davis fall under the Hazard Communication Program. This program is designed to increase employee awareness of any chemicals and/or medications used in the workplace by providing information about these materials, identifying the associated hazards and potential harmful effects, and how to protect from the risks of those hazards. The Hazard Communication Program must clarify standard PPE practices and animal handling requirements to protect workers from Standard of Care medications, procedures to protect workers from exposure to hazardous materials, as well as the facility-determined method for PIs/researchers to alert vivarium staff that a hazardous material or Standard of Care medication is present (e.g., hazard cards, door signs). Refer to EH&S webpage regarding the Hazard Communication Program in Animal Care Spaces (coming soon) for more details.
- Hazardous Chemical
- Hazardous chemicals cover a broad range of chemicals as described in 8 CCR §5194. A hazardous chemical is any chemical which is classified as a physical hazard, or a health hazard, an asphyxiant, combustible dust, pyrophoric gas, a hazard not otherwise classified, or is included in the List of Hazardous Substances (8 CCR §339). As it pertains to this policy, hazardous chemicals are carcinogens (GHS hazard codes H350, H351), reproductive hazards (GHS hazard codes H340, H341, H360, H361), antineoplastics, chemicals with unknown hazards, Schedule I or 2 Controlled Substances, hallucinogenic material, or any material whose hazards cannot be sufficiently addressed via the hazard communication program. These chemicals will receive a VHSS detailing the proper handling and disposal requirements of that material.
- Hazardous Material
- Hazardous materials in this policy covers all categories of hazardous chemicals, recombinant/biohazardous material, and radioactive material. All hazardous materials must be listed Sections 14a and 14b of, the Animal Care and Use Protocol (ACUP). Hazardous materials that have hazards that cannot be sufficiently addressed via the hazard communication program will receive a VHSS detailing the proper handling and disposal requirements of that material and be included in Section 8 of the Animal Care and Use Protocol.
- Injury and Illness Prevention Program (IIPP)
- The purpose of an Injury & Illness Prevention Program is to establish a management framework for reducing the risks associated with workplace injuries and illnesses, and identifying what is required to promote the safety and health, and create an outline of policies and procedures to achieve safety and health goals. All areas on campus, including but not limited to, research areas and animal care spaces, are required by Cal/OSHA to have an IIPP.
- Radiation Use Authorization (RUA)
- Work with ionizing radiation requires a Radiation Use Authorization from the Radiation Safety Committee (if necessary), the Radiation Safety Officer, Alternate Radiation Safety Officer, or designee to conduct specific research using radionuclides. Research involving ionizing radiation in animal research requires an RUA prior to EH&S signing off on the Animal Care and Use Protocol.
- Radioactive Material
- Any material, solid, liquid, or gas that emits ionizing radiation spontaneously.
- Recombinant Material
- Nucleic acids, cells, or organisms that are made by combining genetic material from two different sources.
- Standard of Care
- Standard of care medications are those that are FDA approved for use in humans and/or animals, AND that do NOT appear on the NIOSH “List of Hazardous Drugs in Healthcare Settings.” These medications do not require a VHSS whether being used clinically or as part of an approved IACUC protocol. This condition holds true only if the medications are administered in a veterinary formulary approved route and appropriate dose for the application: any medications administered outside of an approved route will be subject to chemical safety office review and may require a VHSS.
- Viral Vectors
- A modified form of a virus used to deliver genetic material or "payload" into a cell. Viral vectors can have specific hosts and the gene products encoded by the genetic material can influence safe handling and disposal practices, so be sure to refer to the relevant VHSS for safety information.
- Vivarium Hazard Safety Sheet (VHSS)
- The VHSS is a tool to inform animal care staff of a specific hazard that exists in the vivarium and to inform of proper administrative and engineering controls, PPE, and waste disposal requirements. A VHSS is created for protocols where animals will be administered hazardous chemicals, recombinant/biohazardous material, and radioactive material, as well as for environmental hazards or materials with non-routine disposal requirements to ensure proper handling.
Frequently Asked Questions
- What is the expected review time if my animal protocol includes biological, radiological, or chemical components?
- The review time for each of these components varies.
Biological or Radiological component: Before an animal protocol and/or amendment is submitted to IACUC researchers should have a Biological Use Authorization (BUA) or Radiological Use Authorization (RUA) in place if they plan to include biological or radiological materials in the animal protocol/amendment. At the time of protocol/amendment review, EH&S representatives will review the animal protocol/amendment to ensure materials listed in the protocol/amendment are already covered in the BUA and/or RUA. If a BUA or RUA is needed for proposed work, the PI will need to obtain a BUA or RUA before the animal protocol/amendment is approved.
Chemical components: EH&S reviews chemical components at the time of protocol/amendment submission. Since there is no prior approval process in place (like in the case of a BUA or RUA) the PI/researcher may be required to answer additional questions regarding the chemical component of the protocol/amendment. This could include additional information regarding the chemical to be used, proposed route of administration, and/or handling considerations to list a few.
- What is a VHSS?
- Viviarum Hazard Safety Sheets (VHSSs) serve as a tool to inform animal care staff of specific hazards and to inform of proper administrative and engineering controls, PPE, and waste disposal requirements. A VHSS is created for protocols where animals will be administered hazardous chemicals, recombinant/biohazardous material, and radioactive material, as well as for environmental hazards or materials with non-routine disposal requirements to ensure proper handling.
Note: the investigator is ultimately responsible for ALL the hazards they introduce into the vivarium. Standard of Care medications such as analgesics and antibiotics are hazards that do not receive a VHSS, however, the PI is still responsible to ensure proper hazard communication to animal care staff using the method outlined by the facility.
- How do VHSSs get attached to the animal protocol?
- VHSSs for hazardous materials covered by a BUA or RUA can be attached to the protocol by the PI/researchers when the protocol is being filled out. Look for the appropriate VHSS in the IACUC VHSS library and select the appropriate VHSS to attach.
VHSSs for hazardous chemicals go through a separate process. At the time of submission, no VHSSs need to be attached, but all hazardous materials must be listed in Section 8, and all materials administered to animals in the study must be listed in Sections 14a and b. The Chemical Hygiene team reviews the use of the hazardous chemicals, develops a VHSS, and attaches the VHSS to the protocol.
- What should be included in an animal protocol to help speed up the approval process by EH&S?
- Providing the full name of the chemicals and drugs being used (e.g., 'azoxymethane' as opposed to 'AOM', 'clenoliximab' rather than 'anti-CD47'), as well as the Chemical Abstracts Service (CAS) number of the chemicals and drugs being used can help to speed up the review process. Alternatively, providing a copy or a link to the manufacturers’ Safety Data Sheet(s) can also help speed up the process.
- My material didn't get a VHSS, that means it has no hazards, right?
- Not quite. VHSSs are intended to provide animal care staff with additional information on how to handle contaminated animals and bedding safely. Hazardous materials that can be safely handled under the Facility's established Hazard Communication Program, such as Standard of Care medications, or those materials that do not pose any health hazard to animal care staff when handling contaminated animals or bedding, do not receive a VHSS. These materials may still be corrosive, flammable, acutely toxic, etc. Be prepared to share the hazards of any materials you may use in an animal care facility with animal care staff, Facility Managers/Technicians-In-Charge.
- I have a question about biological/radiological/chemical safety. Who can I ask for help?
For Biological Safety/help with a BUA:
For Radiological Safety/help with an RUA: