Hazardous chemicals, activities or devices

Index

Rules for ALL Projects Involving Hazardous Chemicals, Activities and Devices
Additional Rules for Specific Regulated Substances
Environmentally Responsible Chemistry
Sources

The following rules apply to research using hazardous chemicals, devices and activities. These include substances and devices that are regulated by local, state, country, or international law, most often with restrictions of their use by minors such as DEA-controlled substances, prescription drugs, alcohol, tobacco, firearms and explosives. Hazardous activities are those that involve a level of risk above and beyond that encountered in the student’s everyday life.

These rules are intended to protect the student researcher by ensuring proper supervision and the consideration of all potential risks so that the appropriate safety precautions are taken. Students are required to meet all standards imposed by ISEF, school, local, and/or regional fair(s).

Rules for ALL Projects Involving Hazardous Chemicals, Activities and Devices

1. The student researcher must conduct a risk assessment in collaboration with a Direct Supervisor or Qualified Scientist prior to experimentation. This risk assessment should be documented in the research plan to include the risk assessment process, transportation, usage, biosafety and appropriate methods of disposal. This risk assessment is also documented on Risk Assessment Form 3.

2. The use of hazardous chemicals, devices and involvement in hazardous activities require direct supervision by a Direct Supervisor, except those involving DEA-controlled substances, which require supervision by a Qualified Scientist.

3. Student researchers must acquire and use regulated substances in accordance with all local, state, U.S. federal and country laws. For further information or classification for these laws and regulations, contact the appropriate regulatory agencies.

4. For all chemicals, devices or activities requiring a federal and/or state permit, the student/supervisor must obtain the permit prior to the onset of experimentation. A copy of the permit must be available for review by adults supervising the project and the local, affiliated, and ISEF SRCs in their review prior to competition. All transportation and acquisition of materials must comply with all Federal and State laws and regulations.

5. The student researcher must minimize the impact of an experiment on the environment. Examples include using minimal quantities of chemicals that will require subsequent disposal; ensuring that all disposal is done in an environmentally safe manner and in accordance with good laboratory practices. Disposal procedures shall be described in sufficient detail to ensure compliance (Proper chemical, sharps and other hazardous materials disposal must follow local, state, and/or federal guidelines).

6. The following forms are required:
a. Checklist for Adult Sponsor (1), Student Checklist (1A), Research Plan, and Approval Form (1B)
b. Regulated Research Institution Form (1C), when applicable
c. Qualified Scientist Form (2), when applicable
d. Risk Assessment Form (3)

Additional Rules for Specific Regulated Substances

There are additional rules for the following regulated substances:

A. DEA-controlled Substances

B. Prescription Drugs

C. Alcohol & Tobacco

D. Firearms and Explosives

E. Regulated Drones

F. Radiation

A. DEA-Controlled Substances

The U.S. Drug Enforcement Administration (DEA) regulates chemicals that can be diverted from their intended use to make illegal drugs. Other countries may have similar regulatory bodies; students outside of the U.S. must adhere to their own country’s drug regulatory agency requirements in addition to U.S. DEA regulations. DEA-controlled substances and their schedule number are at the DEA website under Sources of Information. It is the responsibility of the student to consult this list if there is a possibility that substances used in experimentation could be regulated.

a. All studies using DEA-controlled substances must be supervised by a Qualified Scientist at a RRI (and must be conducted at a Regulated Research Institution) who is licensed by the DEA (or other international regulatory body) for use of the controlled substance.

b. All studies using DEA Schedule 1 substances (including marijuana) must have the research protocol approved by DEA before research begins. Schedule 2, 3 and 4 substances do not require protocol approval by DEA.

B. Prescription Drugs

In the United States, the Food and Drug Administration (FDA) tightly regulates the issuance of prescription drugs including non-controlled medications. State laws further regulate the use of prescription drugs, and it is unlawful for any person to knowingly or intentionally possess a noncontrolled medication unless it was obtained directly from a valid prescription or order of a practitioner while acting in the course of their professional practice. It is also unlawful to use a prescription for persons or purposes outside of the original intent of the prescription or for the person it was originally prescribed for. All applicable federal, state, and country laws must be followed.

1. Students are prohibited from the use of prescription drugs in their study outside the authority of a practitioner or researcher that has obtained the non-controlled medication with appropriate approvals and is using the medication for the purpose for which it was prescribed.
2. Exemptions include research and educational products purchased that are considered research grade and not pharmaceutical grade, therefore not for human consumption.
3. In the case of prescription drugs administered to vertebrate animals, this may only be done under a veterinarian’s supervision and with prescriptions provided for this specified purpose.

C. Alcohol and Tobacco

The U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates the production of alcohol and distribution of alcohol and tobacco products. Many such products are restricted by age for purchase, possession and consumption.

1. Fermentation studies in which minute quantities of ethyl alcohol are produced are permitted.

2. The Direct Supervisor is responsible for the acquisition, usage and appropriate disposal of the alcohol or tobacco used in the study.

3. Production of wine or beer by adults is allowable in the home and must meet TTB home production regulations. Students are allowed to design and conduct a research project, under direct parental supervision, involving the legal production of the wine or beer.

4. Students are prohibited from conducting experiments where consumable ethyl alcohol is produced by distillation. However, students are allowed to distill alcohol for fuel or other non-consumable products. To do so, the work must be conducted at school or a Regulated Research Institution and follow all local and country laws. See the Alcohol and Tobacco Tax and Trade Bureau (TTB) website for details.

D. Firearms and Explosives

The U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), along with state agencies, regulates the purchase and use of firearms and explosives. A firearm is defined as a small arms weapon from which a projectile is fired by gunpowder. An explosive is any chemical compound, mixture or device, the primary purpose of which is to function by explosion. Explosives include, but are not limited to, dynamite, black powder, pellet powder, detonators, and igniters.

The purchase of a firearm by a minor is generally unlawful. The use of a firearm, without proper state certification, is illegal. Students should check the training and certification requirements of individual states and countries.

  1. Projects involving firearms and explosives are allowable when conducted with the direct supervision of a Direct Supervisor and when in compliance with all federal, state and local laws.
  2. A fully assembled rocket motor, reload kit or propellant modules containing more than 62.5 grams of propellant are subject to the permitting, storage and other requirements of federal explosive laws and regulations.
  3. Potato guns and paintball guns are not firearms unless they are intended to be used as weapons. However, they must be treated as hazardous devices.

E. Regulated Drones

Projects involving unmanned aircraft systems (UAS)/drones must follow all state, Federal, and country laws. See the Federal Aviation Administration(FAA) for more details (www.faa.gov.uas/registration).

F. Radiation

Projects involving radionuclides (radioisotopes) and X-rays must involve a careful examination of the risks associated with the study and appropriate safety precautions must be taken. Depending upon the level of exposure, radiation released from these sources can be a health hazard.

1. All studies may not exceed the dose limits set by the Nuclear Regulatory Commission of 0.5 mrem/hr or 100 mrem/year of exposure.

2. If the voltage needed in the study is <10 kvolts, a risk assessment must be conducted. The study may be done at home or school, and SRC preapproval is not required.

3. A study using 10-25 kvolts must have a risk assessment conducted and must be preapproved by the SRC to assess safety. Such a study must be conducted in a metal chamber using a camera only, not direct view through glass. A dosimeter or radiation survey meter is required to measure radiation exposure.

4. All studies using > 25 kvolts must be conducted at an institution with a Licensed Radiation Program and must be preapproved by the Institution’s Radiation Safety Officer or the Committee which oversees the use of ionizing radiation to ensure compliance with state and federal regulations.

Guidance for Risk Assessment

WHEN USING THE FOLLOWING: HAZARDOUS CHEMICALS, HAZARDOUS DEVICES, RADIATION

1. Hazardous Chemicals

A proper risk assessment of chemicals must include review of the following factors:

    1. Toxicity – the tendency of a chemical to be hazardous to health when inhaled, swallowed, injected or in contact with the skin.
    2. Reactivity — the tendency of a chemical to undergo chemical change.

      Environmentally Responsible Chemistry

      The mission of environmentally responsible (green) chemistry is to avoid the use or production of hazardous substances during chemical processes. The principles of green chemistry are described on the EPA website in the Sources of Information section. Whenever possible the following principles should be incorporated into the research plan.

      • Waste prevention
      • Use of the safest possible chemicals and products
      • Design of the least possible hazardous chemical syntheses
      • Use renewable materials
      • Use catalysts in order to minimize chemical usage
      • Use of solvents and reaction conditions that are safe as possible
      • Maximization of energy efficiency
      • Minimization of accident potential
    3. Flammability — the tendency of a chemical to give off vapors which readily ignite when used under normal working conditions.
    4. Corrosiveness — the tendency of a chemical, upon physical contact, to harm or destroy living tissues or physical equipment.

When assessing risk, the type and amount of exposure to a chemical must be considered. For example, an individual’s allergic and genetic disposition may have an influence on the overall effect of the chemical. The student researcher must refer to Safety Data Sheets provided by the vendor (SDS) to ensure that proper safety
precautions are taken. Some SDS sheets (e.g., Flinn) rank the degree of hazard associated with a chemical. This rating may assist students and adult sponsors in
determining risk associated with the use of a chemical.

A risk assessment (documented on Form 3) must include proper disposal methods for the chemicals used in an experiment. The Flinn Catalog (referenced in the Sources of Information section) provides information for the proper disposal of chemicals. If applicable, the student researcher must incorporate in the research plan disposal procedure required by federal and state guidelines.

 2. Hazardous Devices

The documentation of risk assessment (Form 3) is required when a student researcher works with potentially hazardous/dangerous equipment and/or other devices, in or outside a laboratory setting that require a moderate to high level of expertise to ensure their safe usage. Some commonly used devices (Bunsen burners, hot plates, saws, drills, etc.) may not require a documented risk assessment, assuming that the student researcher has experience working with the device. Use of other potentially dangerous devices such as high vacuum equipment, heated oil baths, NMR equipment, and high-temperature ovens must have documentation of a risk assessment. It is recommended that all student designed inventions also have documentation of a risk assessment.

3. Radiation

A risk assessment (documented on Form 3) must be conducted when a student’s project involves radiation beyond that normally encountered in everyday life. Non- ionizing radiation includes the spectrum of ultraviolet (UV), visible light, infrared (IR), microwave (NW), radiofrequency (RF) and extremely low frequency (ELF).

Sources: Hazardous Chemicals, Activities or Devices

General Lab/Chemical Safety
1) Safety in Academic Chemistry Laboratories, Volumes 1 and 2, 2003. Washington, DC: American Chemical Society.
Order from (first copy free of charge):
American Chemical Society
Publications Support Services
1155 16th Street, NW
Washington, DC 20036
phone: 202-872-4000 or 800-227-5558
email: help@acs.org,
www.acs.org/education
2) General
Howard Hughes Medical Institute as a resource for working with cell cultures, radioactive materials, and other laboratory materials.
http://www.hhmi.org/developing-scientists/resources
3) Environmental Protection Agency (EPA) website for green chemistry
www.epa.gov/greenchemistry
4) Safety and Data Sheets (SDS)
http://www.flinnsci.com/msds-search.aspx/
A directory of SDS sheets from Flinn Scientific Inc. that includes a ranking of hazard level and disposal methods
www.ilpi.com/msds/index.html – A listing of numerous sites that have free downloads of SDS sheets
5) Pesticides
National Pesticide Information Center
http://npic.orst.edu/ingred/products.html
Describes the various types of pesticides and the legal requirements for labeling. Provides links and phone numbers to get additional information.
Environmental Protection Agency
http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1
A database of product labels. Enter the product name or company name to view the approved label information of pesticides which are registered with the agency.
6) DEA Controlled Substances
Drug Enforcement Agency website:
www.justice.gov/dea/index.htm
Controlled Substance Schedules – a list of controlled substances: www.deadiversion.usdoj.gov/schedules/
7) Alcohol, Tobacco Firearms, and Explosives
Alcohol and Tobacco Tax and Trade Bureau
www.ttb.gov
Bureau of Alcohol, Tobacco, Firearms, and Explosives
www.atf.gov
8) Radiation
Radiation Studies Information (CDC)
www.cdc.gov/nceh/radiation/default.htm
9) CDC Laboratory Safety Manuals
www.cdc.gov/biosafety/publications/index.htm
10) Occupational Safety and Health Administration
www.osha.gov
Safety and Health Topics:
www.osha.gov/SLTC/
www.osha.gov/SLTC/reactivechemicals/index.html
www.osha.gov/SLTC/laserhazards/index.html
www.osha.gov/SLTC/radiationionizing/index.html
11) U.S. Nuclear Regulatory Commission
Material Safety and Inspection Branch
One White Flint North
11555 Rockville Pike
Rockville, MD 20852
phone: 301-415-8200; 800-368-5642
www.nrc.gov