Chemical Hygiene Plan (CHP) Services for California Labs
Cal/OSHA requires a written plan for any workplace that meets the definition of a laboratory and uses hazardous chemicals.
If you’re searching for a Chemical Hygiene Plan provider, you already know the basics. Cal/OSHA requires a written plan for any workplace that meets the definition of a laboratory and uses hazardous chemicals. You want a plan that holds up to inspection, training that satisfies the regulation, and someone who knows the California framework, not just the federal one.
If you’re not sure whether your lab needs a CHP, or you’ve just been told you do, this page covers what the plan is, what California requires, what CDMS develops, and how to tell whether your situation triggers the requirement. Most of the labs we work with arrive saying something like “we’re setting up a BSL-2 lab and need to know what’s required” or “we have an EHS plan but Cal/OSHA asked for our chemical hygiene plan and we don’t know what that is.” Both are normal entry points.
Why California Labs Call Us
Calls about chemical hygiene plans usually come from one of five situations. If you recognize yours, you’re in the right place.
You’re setting up a new lab.
Most often a BSL-2 life-science or biotech lab. The founder is technical (often from a software or robotics background) and is trying to figure out what permits, plans, and programs are required before lab work starts. The CHP surfaces during that conversation along with an IIPP (Injury and Illness Prevention Program), a Hazard Communication Program, and an Emergency Action Plan. Above certain chemical thresholds, a Hazardous Materials Business Plan filed through CERS (the state’s online environmental reporting portal) also applies.
You finished a different project with us and the CHP gap surfaced.
We delivered an IIPP, a HazCom program, or an air-permit submittal, and during the wrap-up we asked whether you had a current Chemical Hygiene Plan. The answer was no, or “I think so but I’m not sure where it is.”
Cal/OSHA or your local CUPA (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) visited and asked for the plan.
Either you don’t have one, or what you have is generic and doesn’t reflect your actual lab. A site visit makes that obvious quickly.
You think you have an “EHS plan” but you’re not sure what it covers.
California doesn’t have one combined EHS plan. The regulation requires several specific written programs, and the CHP is one of them. If what you have is an IIPP or a HazCom program, you still need a CHP if you operate a lab with hazardous chemicals.
Your lab grew or changed.
You crossed the 10-employee threshold, added a new chemical class, brought a fume hood online, moved to a larger space, or added a process the current plan doesn’t address. Now you need the plan updated, the inventory current, and the training refreshed.
What a Chemical Hygiene Plan Is
A Chemical Hygiene Plan is the written chemical-safety program Cal/OSHA requires under 8 CCR Section 5191, the California Laboratory Standard. The federal equivalent is 29 CFR 1910.1450. The plan sets out the procedures, equipment, PPE (personal protective equipment), and work practices that protect employees from the chemicals they handle.
The CHP is your lab safety manual. There is no separate “lab safety manual” document above and beyond the CHP. When a regulator or an insurance carrier asks to see your lab safety manual, the CHP is what you hand them.
A compliant CHP must include the elements required by 8 CCR 5191(e). Those elements cover SOPs (standard operating procedures), exposure controls, fume hood performance, training, prior-approval procedures, medical consultation, the Chemical Hygiene Officer designation, and added protections for particularly hazardous substances. CDMS organizes those requirements into 14 practical sections so the plan is usable during training, inspections, and day-to-day lab work:
- General principles for working with laboratory chemicals
- Chemical hygiene responsibilities (Chemical Hygiene Officer, lab supervisor, lab worker)
- The laboratory facility (design and ventilation)
- General safety rules
- Chemical procurement, distribution, and storage
- Environmental monitoring
- Housekeeping, maintenance, and inspections
- Medical program
- Protective apparel and equipment
- Records
- Signs and labels
- Spills and accidents
- Information and training program
- Waste disposal program
The plan also identifies your designated Chemical Hygiene Officer, your chemical inventory (with CAS numbers and corresponding exposure limits), your SOPs as appendices, and your emergency medical facility. Each section connects to something specific about your lab. None of it is filler. For a deeper walk-through of the components and why a downloaded template creates compliance risk, see what a chemical hygiene plan actually contains.
The California Regulations That Drive the Plan
Most national CHP guidance starts and ends with federal OSHA. California has its own framework that overlaps but does not duplicate. Here are the regulations a California lab actually faces.
| Regulation | What It Requires | Who Enforces |
|---|---|---|
| 8 CCR Section 5191 | California Laboratory Standard. The written CHP, designated Chemical Hygiene Officer, exposure assessments, training, and recordkeeping. In effect since 1991. | Cal/OSHA |
| 8 CCR Section 5194 | Hazard Communication Standard (HazCom). SDS (Safety Data Sheet) management, container labeling, and employee right-to-know training. Your CHP must integrate with HazCom, not replace it. | Cal/OSHA |
| 29 CFR 1910.1450 | Federal Laboratory Standard. California’s 5191 is adopted from this; federal rules apply where Cal/OSHA jurisdiction does not reach. | Federal OSHA |
| California Health and Safety Code §§25500–25519 | Hazardous materials business-plan disclosure. Filed through CERS to your local CUPA when your chemical quantities meet reporting thresholds. | Local CUPA / CalEPA |
The two points labs most often miss: the CHP must integrate with the HazCom program (one does not replace the other), and depending on the volume and class of chemicals on site you may also have an HMBP filing obligation that runs in parallel. For a side-by-side breakdown of how the CHP differs from a HazCom program, see CHP vs. Hazard Communication.
“Do We Submit This to Anyone?”
No. The CHP is maintained on-site at your facility. It is not submitted to Cal/OSHA, to your CUPA, or to any other agency. It must be available for inspection when an agency asks for it.
This is the single most common misconception we hear. Founders ask us, “Where do we send the EHS plan?” The answer is nowhere. Keep it on-site, keep it current, keep it accessible to lab workers, and make sure your employees have been trained on it. That is what the regulation requires.
The HMBP (the chemical inventory and emergency-response data filed under §§25500–25519) is different. That submittal goes through CERS to your local CUPA. The CHP and the HMBP are often confused because both involve chemical information, but the requirements and the destinations are not the same.
What CDMS Develops and What We Collect
A Chemical Hygiene Plan that holds up to inspection is built from your facility, your chemicals, and your operations. A template won’t do that work for you. Here is what we deliver and what we collect from you to do it.
| What We Deliver | What We Need From You |
|---|---|
| Written CHP covering all 14 sections | Chemical inventory with CAS numbers, materials lists, example protocols |
| Chemical inventory with corresponding exposure limits | SDSs for each chemical (or a list of chemicals so we can pull them) |
| Exposure assessment based on use patterns and chemical classification | How chemicals are used, in what quantities, and how often |
| SOPs as appendices (handling, storage, spill response, waste disposal) | Facility layout, equipment list, and storage locations |
| Identified Chemical Hygiene Officer and three-tier responsibility structure | Designated CHO name, role, and authority within the company |
| Designated emergency medical facility and emergency procedures | Local hospital or clinic, after-hours contacts |
| Training program scoped to your chemicals and hazards | Headcount, growth plan, current training history |
| PPE specification by hazard | Manufacturer product numbers for PPE currently on site, or guidance on what to buy |
This is not a small data lift. It is also the reason a real CHP functions as a working safety system rather than a document.
How an Engagement Runs
For most labs the work moves in three phases: discovery, plan development, and training. Discovery may include a facility walk-through so the written plan reflects the actual lab. The deliverables are the Chemical Hygiene Plan and the training tied to it.
Discovery.
We talk through what you do, what chemicals you use, your lab layout, and what (if anything) you have in writing today. For pre-operational labs this is heavily educational. We separate EHS requirements (chemical safety, ventilation, PPE) from quality requirements (HEPA filtration, ISO clean room classifications). Founders often conflate the two, and they have different drivers.
Plan development.
We collect SDSs, review existing overlapping programs (IIPP, HazCom, Emergency Action Plan), build the chemical inventory with exposure limits, assess exposures, draft the CHP from your facility’s actual data, and develop SOPs as appendices. We send the draft for your review, incorporate edits, and deliver the final.
Training.
Per 8 CCR 5191(f)(3) and (4), lab employees must be trained on Cal/OSHA standards, exposure limits, SDS interpretation, signs and symptoms of exposure, detection methods, physical and health hazards, plan availability, and protective measures. We develop the training materials specific to your chemicals and deliver the session. Training records (names, dates, topics, sign-offs) become part of the plan.
After delivery, the employer and designated Chemical Hygiene Officer are responsible for annual review, inventory maintenance, and updates when the lab changes. CDMS can create a revised CHP and deliver training on the revised program when a new plan is needed. For more on review triggers and internal upkeep, see Chemical Hygiene Plan annual review.
Related Chemical Hygiene Plan Requirements
Two requirements sit close to CHP creation and training and come up frequently with the same clients.
Fume hood testing requirements.
Cal/OSHA’s Laboratory Standard requires lab ventilation to perform adequately for the chemicals in use. The CHP should identify applicable hood documentation, operating practices, and training. CDMS does not perform fume hood testing. Your facility must arrange equipment testing with a qualified fume hood testing provider. For an educational overview of the method and the records a lab should retain, see fume hood testing requirements.
The Chemical Hygiene Officer role.
Every CHP names an internal CHO. The regulation requires someone with knowledge of lab operations, experience with the chemicals in use, and authority to enforce the plan. CDMS defines the role in the written CHP and trains the person the employer designates. For qualifications and a breakdown of CHO responsibilities, see the Chemical Hygiene Officer role.
“Does This Even Apply to Us?”
A few situations trip people up. If any of these describe you, the CHP requirement likely applies and a conversation with us is the fastest way to confirm.
- “We’re really a software company, we just have a small lab.” The regulation applies to the activity, not the company type.
- “Our lab uses mostly media and reagents, not ‘real’ chemicals.” Many media components, growth factors, fixatives, stains, and buffer components are hazardous chemicals under the regulation. Read more for biotech labs using cells, media, and reagents.
- “We only have three employees.” Headcount affects some requirements (and what kicks in past 10), but it does not exempt you from the CHP itself.
- “We have an EHS plan.” There is no combined “EHS plan” in California. The regulation requires several specific plans (IIPP, HazCom, CHP, EAP). What you have is probably one of them.
- “We’re setting up a BSL-2 lab.” Then you almost certainly need a CHP along with several other plans. See the EHS requirements checklist for a new BSL-2 lab.
- “Our chemical inventory is small.” The CHP requirement is triggered by hazardous chemical use, not by quantity. The inventory feeds parallel filings (HMBP/CERS) when quantities meet thresholds. Read more about building a lab chemical inventory for both purposes.
Frequently Asked Questions
Do we submit the Chemical Hygiene Plan to Cal/OSHA or our CUPA?
No. The CHP is kept on-site and made available on request. The Hazardous Materials Business Plan (the chemical inventory filed under HSC §§25500–25519) is the document that gets submitted, and it goes through CERS to your local CUPA. People often confuse the two because both involve chemical information.
Can we just use a template from the internet?
A generic template creates compliance risk because the CHP is required to reflect your actual chemicals, exposures, SOPs, ventilation, and facility. A plan that doesn’t match your operation won’t survive an inspection. The gap between the plan and reality is exactly what an inspector looks for. The CHP is a functioning safety system, not a fill-in form.
Our lab uses cell media, growth factors, and reagents. Do those count as hazardous chemicals?
Many of them do. Fixatives, stains, solvents, some buffer components, and a range of common reagents carry hazard classifications even in small quantities. A materials-list review against current SDSs is the only reliable way to confirm what triggers the requirement.
Do we need both a Chemical Hygiene Plan and a Hazard Communication Program?
Almost always, yes. The CHP covers laboratory work with hazardous chemicals. The HazCom program covers chemical use across the rest of the workplace. The two integrate. The CHP is more prescriptive about what must be shared with lab employees; HazCom is broader and applies to non-lab chemical use.
Who can serve as our Chemical Hygiene Officer?
The CHO must have knowledge of lab operations, experience with the chemicals being used, and authority to enforce the plan. There is no required certification. For many smaller labs the CHO is the lab manager or the senior scientist. During CHP creation and training, CDMS defines the role and trains the internal CHO designated by the employer.
How often does the CHP need to be reviewed?
8 CCR 5191 requires the employer to review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as necessary. Annual review is the regulatory minimum, not just a best practice. The plan must also be updated sooner when chemicals, procedures, equipment, or facility conditions change in a way the current plan does not address. Mid-cycle triggers include adding a new chemical class, bringing a new fume hood or process online, a facility move, a Cal/OSHA visit, or any chemical exposure incident.
Talk to CDMS About Your Lab’s Chemical Hygiene Plan
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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