Chemical Management

Scope of “Chemical” Safety

University and College chemical safety guidelines apply to lab/research grade chemicals; hazardous reagent kits such as those with corrosive, irritant, or flammable components; hazardous consumer products such as resin and spray paint; chemical stains such as crystal violet and phalloidin; biological samples stored in hazardous fixatives such as formalin or alcohols; environmental samples that are known or suspected to be hazardous; and lab-synthesized chemicals. Contact the College Safety Team if you have questions about specific materials. Common clarifications from the SJSU Chemical Hygiene Plan.

  • Non-hazardous, Neutral Chemicals: Chemical safety guidelines do not generally apply to non-hazardous, neutral chemicals because reporting to regulatory authorities is not usually required, harm to emergency first responders is unlikely, and impacts to hazardous chemical waste streams are rare. "Hazard" is identifiable through Globally Harmonized System (GHS) labeling such as flammable, corrosive, irritant, toxic, and oxidizer. Personnel are responsible for careful review of Safety Data Sheets to confirm whether the chemicals they procure are hazardous. Examples of products that are generally exempted from chemical safety rules are: 
    • non-hazardous, neutral salt buffers -- common examples are saline and tris buffer
    • non-hazardous, neutral media -- common examples are cell culture media, synthetic body fluids, and agarose 
  • Hazardous Household Consumer Products: Hazardous household consumer products must be managed safely because they are a common source of lab/shop injuries and spills at SJSU. In general, lab/shop supervisors have discretion to procure and manage hazardous household consumer products. These items need to be included in the chemical inventories for labs/shops that are authorized to work with hazardous materials to ensure that emergency first responders are aware of their presence. These items do NOT need to be inventoried if small amounts are present in other non-hazardous spaces (such as a single cleaning spray bottle, hand sanitizers, and pre-packaged surface disinfectant wipes in a break room). The campus has a robust Safety Data Sheet library which includes most common hazardous household consumer products. Environmental Health & Safety exempts these products from New Chemical Procurement Form requirements. The college exempts these products from the requirement to deliver directly to the safety office. Hazardous household consumer products must be disposed of through hazardous chemical waste streams.
    • 3D printer filament and solder must always be accounted for in the lab/shop chemical inventory to ensure that required safety data sheets for this specialized material is available to personnel and emergency first responders.
  • Biological Materials: See the Biosafety page for detailed guidance. Most biological materials are managed based on biohazard level without substantial chemical safety considerations. Chemical safety regulations apply to biological materials that are stored in hazardous chemicals such as toxic aldehyde fixatives or flammable alcohol fixatives. For example, an accurate estimate of the quantity of fixative and container sizes must be represented in the chemical inventory. Containers with flammable liquids over 1 L in size must be stored in a flammable storage cabinet.  
  • Environmental Samples: Chemical safety rules do not generally apply to non-hazardous and neutral environmental samples such as minerals, soils, rocks, or salts. These environmental samples are not considered chemical hazards as long as their composition is not hazardous and they are not contaminated with hazardous materials. The professional judgement of field researchers and lab/shop supervisors is critical to identify potentially hazardous field sites and environmental samples. If lab/shop supervisors pursue projects involving potentially hazardous environmental samples, they must work with the College Safety Team to set up safe operating procedures and must also maintain compliance with relevant SJSU safety and compliance programs/policies. Additionally, lab/shop supervisors must work with the College Safety Team to address processes involving environmental samples that could release hazardous chemicals – such as silica dust generation from grinding rocks or toxic organic vapor emission from heating contaminated materials. Examples of hazardous environmental samples include:
    • Samples with known hazardous composition such as substantial arsenic or mercury content (contact ehs@sjsu.edu for help)
    • Samples collected from a location with high likelihood of chemical contamination such as water collected from a Superfund site, from a volcanic area releasing sulfur dioxide, or near an industrial chemical facility (contact ehs@sjsu.edu for help)
    • Radioactive contamination or composition (contact ehs@sjsu.edu for help)
    • Regulated or quarantine soils that contain plant/agriculture threats (contact biosafety@sjsu.edu for help)
    • Samples collected from locations with high likelihood of biohazard contamination like at a sewage spill or by a concentrated animal feeding operation (contact biosafety@sjsu.edu for help)
  • Lab-Synthesized Chemicals: Lab-synthesized chemicals must be managed with extra precautions and are presumed to be toxic until their identity is confirmed and matched to an established Safety Data Sheet. Lab-synthesis is only acceptable in SJSU laboratories designed and equipped for this purpose. Lab/Shop Supervisors are responsible for careful review of chemical synthesis in their lab. Experimental samples should be collected into a designated storage area that is prominently labeled "Experimental samples: Not tested for hazardous properties". Within the designated storage area, compatible experimental samples should be in a secondary container with a label that provides any known information about composition and hazards. If personnel leave experimental samples out unattended (such as during overnight reactions), the best practice is to label the reaction vessel or adjacent location with contact information, chemical composition, the intended reaction plan, and the schedule for check-ins on the experiment. Careful labeling of lab-synthesized chemicals helps to keep other personnel and emergency first-responders safe. Once the identity of a lab-synthesized chemical is known, it must be managed according to the general chemical safety rules for lab/research grade chemicals including addition to the chemical inventory.

Chemical Procurement

  • A new Chemical Procurement Form must be submitted before adding a new chemical to an inventory. This form must be submitted before the purchase or receipt of donations of lab/research grade chemicals. Replacement of chemicals that are already in a lab/shop chemical inventory does not require this form. 
  • You can email ehschemicalpurchasingrequests@sjsu.edu to arrange for bulk reviews for larger orders (over 15 new chemicals), for new projects, or for new lab/shop startups. 
  • SJSU Environmental Health & Safety does not expect non-hazardous, neutral chemicals or household consumer products to go through New Chemical Procurement Forms. If you are unsure, submitting the form is the most efficient way to receive feedback from safety staff. Review is usually completed within one business day. Submission of this form to get a preliminary risk assessment from safety staff is encouraged – responsibility for chemical safety begins when the chemical is actually added to the inventory, not as part of the procurement review process. 
  • Gases, dry ice, and cryogenic liquids: The New Chemical Procurement Form is required for these chemicals unless a submitted Fixtures, Furniture, and Equipment Permit already covers the change in scope.
    • Gas and Cryogen: Central Shops staff are responsible for procuring gases and cryogens that are required for teaching and research. Individual lab/shop personnel are not allowed to directly coordinate deliveries or pickups. Submit an iSupport ticket for assistance.
    • Dry Ice: Faculty/staff can directly procure up to 40 lbs of dry ice locally and transport this material when driving on university business such as from vendors on this website. Contact ehs@sjsu.edu for additional guidance if transportation of over 40 lbs of dry ice is necessary. Department of Transportation regulations do not apply when driving with dry ice on roads in a passenger vehicle. To safely transport up to 40 lbs dry ice, the container must be designed and constructed to permit the release of carbon dioxide gas in order to prevent a buildup of pressure that could rupture the container. A cooler would be appropriate. Additionally, the package must be marked “Carbon dioxide, solid” or “Dry Ice”. This Department of Transportation reference document describes best practices for packaging and labeling dry ice. Finally, windows should be open in the car as a precaution. Contact your department chair for further procurement instructions such as how to navigate reimbursement from research funds. Keep in mind that regulations apply to shipping, transportation by boat, and transportation in an aircraft – contact ehs@sjsu.edu for assistance with transportation through these routes. 

Chemical Deliveries

  • Field Work or Work at Off-Campus Facilities: Contact the College Safety Team for help.
  • SJSU Main Campus
    • Compressed Gases and Cryogenic Liquids: Department staff coordinate deliveries, collect empty cylinders or dewars for pickup, and disperse deliveries to labs/shops. Individual lab/shop personnel are not allowed to directly coordinate deliveries or pickups in order to avoid negative impacts on ENG Courtyard operations. Contact your department chair for more information.
    • Chemical Orders: All chemical orders must be addressed and delivered to the College Safety Team in Engineering Building 190 except for 1) “non-hazardous and neutral” chemicals or 2) "hazardous household consumer products.” This process helps to avoid unintentional delivery of hazardous materials to clean spaces like departmental offices. The College of Engineering Safety Team address follows: 
      San José State University
      Deliver to: Faculty/Staff Name,  Eng 190 (for final delivery to XXX – enter building and room number in place of XXX)
      129 South 10th Street
      San José, CA 95192
    • Chemical Delivery: Upon arrival, the College Safety Team makes a barcode and enters  chemicals into the lab/shop chemical inventory. Then, the College Safety Team brings the package to the lab unopened with a barcode on top. Lab/shop personnel must attach the barcodes to the containers when they open them and check that applicable Standard Operating Procedures are in place. 
  • Direct Delivery: Direct delivery to department offices, department service centers, or research labs is only allowed for household consumer products and non-hazardous and neutral chemicals.

Hazardous Chemical Transport 

  • On-Campus Transportation: Use secondary containment and a cart when transporting chemicals in hallways or between buildings. Alternatively, hand carrying chemicals within secondary containment is acceptable within buildings for manageable container sizes (for example a chemical bottle carrier with a 1 gal container of 1 M hydrochloric acid). See your relevant lab/shop Standard Operating Procedures for more specific instructions. Do not transport hazardous chemicals in stairwells – chemical spills would block the emergency evacuation route for hundreds of occupants! 
  • Elevators: Do not transport hazardous materials in stairwells - use the elevators to transport hazardous materials between floors. Only the person transporting the hazardous material can be in the elevator when moving between floors – other people must be prevented from entering the elevator. When transporting over 450 mL of cryogenic liquid, the passenger elevator must be completely unoccupied or a dedicated hazardous material elevator must be used. See your relevant lab/shop Standard Operating Procedures for more specific instructions. 
  • Chemical Shipping: Contact university Environmental Health & Safety (ehs@sjsu.edu) for assistance with all shipping, international transportation, and passenger-carried aviation transportation of hazardous materials. Proactive incorporation of shipping instructions into your Standard Operating Procedures is strongly recommended. 
    • Export controls may apply to international shipments of research materials/equipment. Review university Research Compliance international shipment instructions for further assistance. 
    • You might violate federal and international laws if you attempt to ship, mail, or fly with any hazardous materials without help from the certified experts in university Environmental Health & Safety. You can face personal consequences such as jail or fines for getting caught in customs or security with illegal hazardous materials.  
    • The whole institution may be punished if you illegally transport hazardous materials on behalf of SJSU. Failure to comply can result in rejected shipments and civil penalties nearing $80,000 per day, per violation. For example, University of Wisconsin-Madison faced a $70,050 civil penalty due to 2 L of ethanol and 120 mL of epoxy hardener in a checked airline bag. 

SJSU Chemical Storage, Handling, and Spills

Labs/shops must follow the guidelines stated in the SJSU Chemical Hygiene Plan for storage, handling, and spills. Your lab/shop Standard Operating Procedures summarize the requirements for specific hazard classes and some particularly hazardous chemicals. Helpful chemical management and hazard communication summaries are available as Environmental Health & Safety One Page Lessons. The college follows university-wide best practices for these aspects of chemical management. Contact the College Safety Team if you need assistance with chemical storage, handling, or spills. Environmental Health & Safety also hosts office hours to provide assistance (RSVP to ehs@sjsu.edu). 

The College Safety Team is responsible for emergency first responses for chemical accidents during business hours. For emergencies outside of business hours, university Environmental Health & Safety are on-call through the SJSU University Police Emergency Dispatchers. If in doubt, contact the SJSU University Police Dispatchers directly to get assistance from on-call safety staff. More information is available on the SJSU Emergency Management page. 

Liquid or Solid Hazardous Chemical Waste

University Environmental Health & Safety provides lab and shop hazardous waste management guides that are posted in most labs and shops. Hazardous waste rules are enforced by university Environmental Health & Safety to comply with government regulations, waste removal contractor requirements, and best practices to protect safety staff and custodial staff. 
Submit an iSupport ticket when a chemical waste container is full or approaching 9 months of accumulation. The College Safety Team will arrange to pick up the waste within 3 business days.

  • Hazardous Chemical Waste Costs: University Environmental Health & Safety pays for almost all hazardous chemical waste disposal on campus. If an egregious hazardous waste management error occurs, the university may charge back to lab/shop supervisors, departments, or colleges.
  • Chemical Waste Containers: The College Safety Team provides chemical waste containers upon request. Container material type must be compatible with the waste it will hold. Submit an iSupport ticket to request a new container.
  • Chemical Waste Labels: Chemical waste must be collected in containers with appropriate chemical waste labels. Safety staff will reject a pickup if the waste label is not completed. Regulatory agencies can fine labs/shops if waste labels are not complete.
  • Chemical Waste Disposal Reminders: Improper waste disposal has caused serious accidents at SJSU!
    • Read the label and check if the bottle is the correct waste stream prior to placing your chemical in the bottle.
    • Safety Data Sheets should be carefully consulted to ensure correct disposal of any particular chemical.
    • Utmost care must be taken to avoid combining incompatible waste materials in the same container. Contact the lab/shop supervisor and/or the College Safety Team if you need help BEFORE you mix wastes together. Inappropriate mixes can be unsafe and/or very expensive to dispose of through our campus waste vendors. 
    • Promptly clean up any spills on the outside of the waste container. You must immediately replace the hazardous waste label if damaged. 
    • Do not overfill waste containers. Always leave headspace inside the container to account for the thermal expansion of liquids.
    • Use funnels to help prevent spills and more easily transfer chemicals. Remove the funnel and close the lid immediately after waste collection is completed. If the waste container has an Eco-funnel or similar safety funnel, the funnel can remain mounted on the hazardous waste container but the lid must be securely closed immediately after waste collection is completed.
  • Evaporating Hazardous Waste: Do not intentionally evaporate hazardous wastes into the chemical fume hood or other exhaust systems. Doing so requires a permit from the California Department of Toxic Substances Control.
  • Transporting Hazardous Waste: Hazardous waste may only be transported from labs/shops to the Environmental Health & Safety waste accumulation areas by staff with specialized training. Do not transport hazardous waste outside of the usual scope of your lab/shop without assistance from safety staff. Do not drop off hazardous waste at safety staff offices.
  • Empty Chemical Containers: If you are uncertain about the safety of empty chemical containers, request a hazardous waste pickup to avoid putting any custodial staff at risk. If you are confident that you can render a container non-hazardous through standard lab protocols, then proceed with the instructions on the lab and shop hazardous waste management guides from university Environmental Health & Safety.

Drain Disposal: 

Do not dispose of any chemical waste into sanitary sewer drains without approval from university Environmental Health & Safety (ehs@sjsu.edu). Never dispose of any chemical in a stormwater drain.

Compressed Gas and Cryogenic Liquid Wastes:

  • Central Shops staff are responsible for the return of empty or unnecessary cylinders and dewars to the vendor. Submit an iSupport ticket for service.