Office of Environmental Health & Safety

Chemical/Biological Safety Section

Chemical Hygiene Plan (CHP)


Table of Contents :
FORWARD

STANDARD OPERATING PROCEDURES (SOPs)
CHEMICAL INVENTORY
MATERIAL SAFETY DATA SHEETS (MSDSs)
CHEMICAL STORAGE
LABELING
ENGINEERING CONTROLS
PERSONAL PROTECTIVE EQUIPMENT
CHEMICAL WASTE DISPOSAL
INFECTIOUS WASTE DISPOSAL
ADMINISTRATIVE CONTROLS
MEDICAL CONSULTATIONS
CHEMICAL HYGIENE OFFICER/COMMITTEE
TRAINING
HOUSEKEEPING
RECORD KEEPING
REFERENCES
APPENDICES

FORWARD

        Virginia Commonwealth University/Medical College of Virginia/Medical College of Virginia Hospitals is committed to providing a safe working environment and believes employees have a right to know about health hazards associated with their work. So that employees can make knowledgeable decisions about any personal risks of employment, this Chemical Hygiene Plan includes policies, procedures, and responsibilities designed to develop in employees an awareness of potentially hazardous chemicals in the workplace and to train employees in appropriate, safe working conditions. 

        It is important that employers assume responsibility for laboratory safety. All employees will have access to pertinent safety information through their supervisory staff. The people who work in any given laboratory are best able to detect potential hazards in either the facility or in work procedures. When safety concerns arise, employees are encouraged to contact their supervisor. If additional assistance is needed, contact the Office of Environmental Health & Safety (OEHS), Chemical/Biological Safety Section at 828-1392. 

        The primary responsibility for training is with the supervisor. Additional training regarding laboratory safety is available as follows: 

The following training materials are offered: 
Additional information will be made available to inform the employee how best to handle hazardous chemicals and how to make use of the new law and regulations.

 
STANDARD OPERATING PROCEDURES (SOPs)

        Because few laboratory chemicals are without hazards, general precautions for handling all laboratory chemicals should be adopted to include minimizing exposure and assuming that any mixture of hazardous chemicals is more toxic than the most toxic component. 

        The following procedures are used when working with chemicals:

 
1. 
Accidents and spills



 
a. 
Eye contact: promptly flush eyes with water for a prolonged period (15 minutes) and seek medical attention. 
b.
Ingestion: seek immediate medical attention at Employee Health (828-0584) or the MCVH Emergency Room.
c.
Skin contact: promptly flush the affected area with water and remove any contaminated clothing; use a safety shower when contact is extensive. If symptoms persist after washing, seek medical attention.
d.
Clean-up: promptly clean up spills, using appropriate protective apparel and equipment and proper disposal. Contact the OEHS Emergency line at 828-9834 for assistance. 
e.
Record incidents involving hazardous substances in a spill log.  Injuries must be reported to Human Resources Services; property damage must be reported to the Office of Risk Management. 

2.
Avoid unnecessary exposure to chemicals.



 
a. 
Do not smell or taste chemicals. Apparatus that can discharge toxic chemicals (vacuum pumps, distillation columns, etc.) should be vented into local exhaust devices. 
b.
Inspect gloves for holes or tears and test glove boxes before use. 
c.
Do not allow release of toxic substances in cold rooms and warm rooms, since these have contained recirculated atmospheres. 
d.
Use only those chemicals for which the quality of the available ventilation system is appropriate. 
e.
Avoid eating, drinking, smoking, gum chewing, or applying cosmetics or lip balm in areas where laboratory chemicals are present. Wash hands before conducting these activities. 
f.
Do not store, handle, or consume food or beverages in storage areas, refrigerators, glassware, or utensils that are also used for laboratory operation. 
g.
Handle and store laboratory glassware with care to avoid damage; do not use damaged glassware. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals and fragments should implosion occur. Use equipment only for its designed purpose.
h.
Wash areas of exposed skin thoroughly before leaving the laboratory. 
i.
Avoid practical jokes or other behavior that might confuse, startle, or distract another worker. 
j.
Do not use mouth suction for pipetting or starting a siphon.
k.
Confine long hair and loose clothing. 
l.
Wear shoes at all times in the laboratory, but do not wear sandals, perforated shoes or "birkenstocks". 
m.
Keep the work area clean and uncluttered, with chemicals and equipment properly labeled and stored; clean up the work area on completion of an operation and at the end of each day. 
n.
Ensure that appropriate eye protection, where necessary, is worn by all persons, including visitors, in areas where chemicals are stored or handled. 
o.
Wear appropriate gloves when the potential for contact with toxic materials exists; inspect the gloves before each use, wash them before removal, and replace them periodically. 
p.
Use appropriate respiratory equipment when air contaminant concentrations are not sufficiently restricted by engineering controls. Inspect the respirator before each use. All respirator usage must be approved by OEHS (828-1392). 
q.
Use any other protective and emergency apparel and equipment as appropriate. 
r.
Avoid use of contact lenses in the laboratory unless necessary; if they are used, inform supervisor so special precautions can be taken.
s.
Remove laboratory coats immediately upon significant contamination.
t.
Seek information and advice about hazards, plan appropriate protective procedures, and plan positioning of equipment before beginning any new operation. 
u.
Leave lights on, place an appropriate sign on the door, and provide for containment of toxic substances in the event of failure of a utility service (such as cooling water) in an unattended operation. 
v.
Use a hood for operations that might result in release of toxic chemical vapors or dust. 
w.
As a rule of thumb, use a hood or other local ventilation device when working with any  volatile substance considered hazardous or toxic. 
x.
Confirm adequate hood performance before use: keep hood closed at all times except when adjustments within the hood are being made. Keep materials stored in hoods to a minimum, and do not allow materials to block vents or air flow. 
y.
Leave the hood "on" when it is not in active use if toxic substances are stored in it or if it is uncertain whether adequate general laboratory ventilation will be maintained when it is "off." 
z.
Be aware of unsafe conditions and see that they are corrected when detected.



 
CHEMICAL INVENTORY

        A chemical inventory is performed annually, listing all the hazardous chemicals in the laboratory. Chemicals listed are those classified as hazardous by the Department of Transportation (DOT), the Environmental Protection Agency (EPA), or displaying a 2 or greater number in any section of the National Fire Protection Association (NFPA) diamond. DOT and EPA classifications are in Appendices A and B.

        Chemicals are listed alphabetically by section according to the most commonly used name (e.g., bleach). A catalog number may be required by some manufacturers for MSDSs. The average quantity in storage on a monthly basis, as well as the physical state (e.g., solid, liquid, gas), is included. The NFPA hazard classification, if known, is listed along with the manufacturer's name and complete address. A comment section is provided to further identify the chemical's location (e.g., under the sink, third shelf in the safety cabinet, etc.) A complete chemical inventory is to be inserted as Appendix C.

        Inventories are computerized whenever possible to provide the capability of sorting according to manufacturer or location. A complete chemical inventory is located in the office of the Chemical Hygiene Officer.


 
MATERIAL SAFETY DATA SHEETS (MSDSs)

        Upon completion of the chemical inventory, material safety data sheets (MSDSs) are gathered for each chemical. MSDSs should reside in the office of the CHO. MSDSs can also be found in the OEHS Chemical/Biological Safety Section (room room 107, VMI Building). In either circumstance, all VCU/MCVH employees must be furnished with an MSDS during the same work shift it was requested.


 
CHEMICAL STORAGE

        Storage of laboratory chemicals presents an ongoing safety problem. Some storage charts assume an unlimited amount of cabinets. At VCU and MCVH laboratory space is sometimes limited, therefore an acceptable storage plan is essential to the safety of the laboratory. REMEMBER: alphabetic storage is not  practical. 

        The chemical inventory should be kept as small as possible. Storage on bench tops and in hoods may cause potential exposure to fire and spills. Ventilated cabinets and specially monitored refrigerators are used for chemical storage only. No food is permitted in these refrigerators. Flammable liquids are stored in flammable storage cabinets with self-closing doors and proper ventilation according to NFPA standards. Safety cans with a spring- loaded spout are used for transporting flammable liquids. 

        Toxic chemicals, including carcinogens, are stored in ventilated storage areas in unbreakable chemical-resistant secondary containers. These containers are labeled "CAUTION: HIGH CHRONIC TOXICITY OR CANCER SUSPECT AGENT." A separate inventory list of carcinogens and suspected carcinogens is maintained by the CHO according to federal and state regulations. In addition, a safe storage plan is available with this CHP. 

        Cylinders of compressed gases are strapped or chained to a wall or bench top and are capped when not in use.  Appendix D contains safe handling practices and procedures for gas cylinders.


 
LABELING

        The 29 CFR 1910.1450 contains specific labeling requirements. Labeling must be done on all hazardous chemicals that are shipped and used in the workplace. Labels must not be removed or defaced. 

        Chemical manufacturers, importers, and distributors make sure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked with the following information: 

        1.         Identity of the hazardous chemical 

        2.         Appropriate hazard warnings 

        3.         Name and address of the chemical company (i.e., manufacturer). 

        Each hazardous chemical transferred outside the laboratory that is not in its original container must also be labeled. These workplace labels must contain: 

        1.         Identity of the hazardous chemical 

        2.         Route of entry (e.g., eyes, nose, mouth, skin) 

        3.         Health hazard 

        4.         Physical hazard 

        5.         Target organ affected.


 
ENGINEERING CONTROLS

        All biohazard and fume hoods are inspected annually and certified by ______________________ (telephone ____________). Any hood not passing inspection is taken out of service immediately and not used until the hood has passed inspection. It is the responsibility of the employer, through the efforts of VCU's Physical Plant, to purchase the parts and to replace the unit in a timely fashion so as not to endanger the health and well-being of an employee or place the facility at risk. 

        Eyewash fountains are inspected annually and records kept by the OEHS Fire Safety Section (telephone 828-7899). (Portable eyewash stations are the responsibility of the laboratory manager). 

        Safety showers are inspected, tested, and flushed annually and records maintained by the OEHS Fire Safety Section (telephone 828-7899). 

        Fire extinguishers are inspected at least quarterly by the OEHS Fire Safety Section (telephone 828-7899). 

        All chemical stockrooms/storerooms are adequate and well ventilated and located in room(s) _______________________. 

        Ventilated storage cabinets for chemicals are provided as needed and have a separate exhaust duct. These cabinets are located in room(s) ___________________. 

        Exhaust air from glove boxes and isolation rooms is passed through scrubbers before being released into the regular exhaust system. 

        Cold rooms and warm rooms have provisions for rapid escape and also for escape in the event of electrical failure. 

        Air flow through the laboratory should be relatively uniform and be exhausted to the exterior of the building. Quality and quantity of ventilation are monitored as needed and records maintained by the CHO. 

        All chemical hygiene related equipment is monitored continuously and modified if inadequate.


 
PERSONAL PROTECTIVE EQUIPMENT

        Employees are required to wear gloves when the employee has the potential for direct skin contact with blood, hazardous chemicals, and infectious materials. 

        Lab coats are to be worn only in the laboratory area and are to be buttoned to protect the employee's clothing. Lab coats are provided by the laboratory manager. 

        In areas where chemical splashes are great an impervious apron appropriate for the task is worn. 

        All personal protective equipment is removed immediately upon leaving the work area (or as soon as possible) and placed in an appropriate laundry hamper located in room(s)________________. 

        Masks and eye protection or chin-length face shields are worn to prevent splashes or sprays of blood, infectious materials, or hazardous chemicals if there is a potential for eye, nose, or mouth contamination. This equipment is located at ____________________. 

        Where the use of respirators is necessary to maintain exposure below permissible exposure limits, the laboratory manager provides, at no cost to the employee, the proper respiratory equipment located at ____________________. The respirators shall be selected and used in accordance with the requirements of 29 CFR 1910.134 (OSHA's Respiratory Protection Standard). Contact OEHS for selection of appropriate respiratory protection equipment.


 
CHEMICAL WASTE DISPOSAL

        The University/Hospital Chemical Waste Disposal Program, (located on the OEHS webpage), specifies how waste is to be collected, segregated, stored, and transported and includes consideration of what materials can be incinerated.  All disposal is done in accordance with EPA/Virginia Department of Waste Management regulations. 

        Hazardous chemical wastes are accepted for disposal by OEHS on an appointment-only basis each Tuesday and Thursday from 9:00 a.m. to 9:30 a.m. at the Sanger Hall loading dock.  Wastes are accepted in properly sealed and labeled disposable bottles or containers, accompanied by a signed Hazardous Waste Disposal Form.  A reproducible copy of this form is found in Appendix E and on the OEHS webpage. 

        Certain laboratory-generated wastes such as needles, broken glass and infectious waste (see Infectious Waste Disposal Section) are not accepted on this basis. 

        Non-infectious needles, broken glass, and other sharps should be enclosed in appropriate sharps containers and disposed of along with other routine solid waste.  Sharps containers can be obtained from Central Supply. 

        Incineration in an environmentally acceptable manner is the most practical disposal method for combustible laboratory waste.  Indiscriminate disposal by pouring waste chemicals down the drain or adding them to mixed refuse for landfill burial is unacceptable.  Hoods are not to be used as a means of disposal for volatile chemicals.  Disposal by recycling or chemical decontamination is used when possible. 

        Questions regarding VCU's Hazardous Chemical Disposal Program should be directed to OEHS, Attn: Chemical Waste Technician (828-1392).


 
INFECTIOUS WASTE DISPOSAL

        Infectious wastes are managed in accordance with the Virginia Department of Waste Management's Infectious Waste Management Regulations. Laboratories generating regular amounts of infectious waste must set up a contract for periodic removal (828-9444). Autoclave waste must be packaged in orange biohazard bags, autoclaved under the mandated pressures and time, and placarded with a label of ownership that can be obtained through OEHS.  Infectious waste issues are ever changing. It is the responsibility of the Principle Investigator or the Laboratory Manager to familiarize themselves with the latest information and  requirements. A convenient resource is the OEHS webpage located at http://www.vcu.edu/oehs/chemical/IW.html which updates regularly.


 
ADMINISTRATIVE CONTROLS

        The Laboratory Manager is responsible for the safe operation of the area.  All activities and procedures require the Laboratory Manager's approval.  Environmental monitoring is required in all laboratories for the following chemicals as required by applicable regulatory agencies: 

asbestos                                                       tremolite 

anthophoyllite                                               actinolite 

coal tar pitch volatiles                                    4-nitrobiphenyl 

alpha-naphthylamine                                      methyl chloromethyl ether 

3,3'-dichlorobenzidine                                   bis-chloromethyl ether 

beta-naphthylamine                                       benzidine 

4-aminodiphenyl                                           ethyleneimine 

beta-propiolactone                                       2-acetylaminofluorene 

4-dimethylaminoazobenzene                          N-nitrosodimethylamine 

vinyl chloride                                                 inorganic arsenic 

lead                                                               benzene 

coke oven emissions                                      cotton dust 

1 ,2-dibromo-3-chloropropane                      acrylonitrile 

ethylene oxide                                                formaldehyde 

nitrous oxide                                                  glutaraldehyde 

        Laboratories utilizing any of the above chemicals should contact OEHS for appropriate environmental monitoring if it is not currently being conducted. 

        Chemical spills are contained using the Think C.L.E.A.N. Plan: 

             Contain the spill 

             Leave the area 

             Emergency: eye wash, shower, medical care 

             Access MSDS 

             Notify a supervisor. 

        All laboratories utilizing hazardous chemicals must have appropriate spill kits, located at ____________________.  Spills of hazardous substances are recorded in this Chemical Hygiene Plan.  Personal injuries are reported to Human Resources Services; and the Office of Risk Management is notified of any property damage.  Assessment of significant risk of all operations is made by the Laboratory Manager or CHO.  Chemical hygiene and safety policies will be established for each task performed and engineering controls or personal protective equipment assigned.  An attached list, submitted by the CHO,  identifies each work-station/task in the laboratory and the required controls and equipment. 

Appendix F lists the important telephone numbers for the laboratory.


 
MEDICAL CONSULTATIONS

        All employees needing medical attention use the employee health services at 828-0585. All required medical examinations and consultations are performed by or under the direct supervision of a licensed physician without cost to the employee, without loss of pay, and at a reasonable time and place. 

The employee is sent for medical evaluation:

 
1. 
Whenever signs and symptoms associated with a hazardous chemical develop. 
2.
When environmental monitoring reveals an exposure level routinely above the action level. 
3.
Whenever an event takes place in the work area such as a spill, leak, or explosion resulting in hazardous chemical exposure. The laboratory provides the following information to the physician: 



 
a. 
Identity of the hazardous chemical(s) to which the employee may have been exposed 
b.
A description of the conditions under which the exposure occurred--including quantitative exposure data (if available) 
c.
A description of the signs and symptoms of exposure 
d.
A copy of the MSDS for the chemical(s) involved.

The physician provides a written opinion that will not reveal specific finding of diagnosis unrelated to the exposure but will include:

 
1. 
Any recommendation for further medical follow-up 
2.
Results of the medical examination and any associated tests 
3.
Any medical conditions that may be revealed in the course of the examination that may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace 
4.
A statement by the physician that the employee has been informed of the consultation/examination results and any medical condition that may require further examination or treatment. 



 
CHEMICAL HYGIENE OFFICER/COMMITTEE

        The chemical hygiene responsibilities rest with the Chemical Hygiene Officer who is appointed by the Laboratory Manager and receives backing from the Department Director or Principal Investigator. The Chemical Hygiene Officer must:

 
1. 
Work with administrators and other employees to develop and implement appropriate 1chemical hygiene policies and practices. 
2.
Support the use of protective equipment when required.
3.
Monitor procurement, use, and disposal of chemicals used in the lab. 
4.
Know the current legal requirements concerning regulated substances.
5.
Ensure that the chemical inventory list is conducted and updated as needed. 
6.
Seek ways to improve the chemical hygiene program.

The immediate supervisor has overall responsibility to:

 
1. 
Ensure that workers know and follow the chemical hygiene rules, that protective equipment is available and in working order, and that appropriate training has been provided. 
2.
Provide regular, formal chemical hygiene and housekeeping inspections including routine inspections of emergency equipment. 
3.
Know the current legal requirements concerning regulated substances.
4.
Determine the required levels of protective apparel and equipment.
5.
Ensure that facilities and training for use of any material being ordered are adequate.

The laboratory employee is responsible for: 

1.      Planning and conducting each operation in accordance with the institutional chemical hygiene procedures

2.      Developing good personal chemical hygiene habits. 

At least one member from each laboratory section will be appointed to serve on the Laboratory Safety Committee, which will meet no less than four times a year to discuss safety and chemical hygiene issues.


 
TRAINING

        Training is a necessary and important part of the Chemical Hygiene Plan. All employees must attend Safety Awareness orientation at the time of the employee's initial assignment to a work area where hazardous chemicals are present and before assignments involving new exposure situations. Refresher information and retraining sessions are held periodically. Training is conducted by the employee's immediate supervisor who was appropriately trained. All training is documented in writing by attendance records. 

        Before training can begin, a lesson plan outlines the expectations of the program and the time frame for the learning outcome. The lesson plan includes:

 
I. 
OBJECTIVES 
Upon completion of the Chemical Hygiene Training Program, the employee will be able to: 


 
A. 
Locate the Potentially hazardous chemicals in the workplace 
B.
Recognize the chemical labeling and its meaning 
C.
Locate the MSDS book in the workplace 
D.
Locate the health hazard, physical hazard, environmental protection, and special protection sections of the MSDS and explain their use 
E.
Identify the department Chemical Hygiene Officer by name and title 
F.
Discuss the major components of the laboratory's labeling system 
G.
Identify the appropriate protective clothing for the area and demonstrate its use 
H.
Demonstrate emergency procedures in the event of a hazardous chemical spill 
I.
Describe the environmental monitoring protocol 

II.
ACTIVITY PLAN 



 
A. 
A list of audiovisuals used and directions 
1.      Videotape or slide/tape 

2.      Equipment instructions 

3.      Handouts 

B.
An outline guide of what to say and the time limits for each discussion
C.
Topics to be covered 



 
1. 
Content of the lab standard
2.
Location of the CHP
3.
Identification of hazardous chemicals 
a.      location of the chemical inventory 

b.      location of MSDSs 
         i.      obtaining a copy 

c.      labeling information 
         i.      hazard warnings 
         ii.     carcinogen warnings 
         iii.     location in workplace 

4.
Procedures for handling hazardous chemicals 
a.      work practices 

b.      proper moving, storing, and use 

c.      PEL for specific chemicals used by the employee 

d.      visual appearance of chemicals used by the employee 

e.       environmental monitoring required 

f.       signs and symptoms of exposure 

g.      protective equipment used to prevent overexposure 

h.      conditions to avoid 

5.
Environmental protection 
a.       emergency procedures 

b.       spill containment 

c.       medical consultation procedures 

6.
Documentation of initial and annual training 

III.
Summary 
A.       Restate the objectives 

B.       Restate the main points 

C.       Answer any questions to clear up misunderstandings.



 
HOUSEKEEPING

        Floors are cleaned regularly by housekeeping. All employees of the housekeeping department are formally trained in the risks associated with working in the laboratory. 

The housekeeping supervisors conduct periodic inspections of the lab areas to assess whether: 

1.      Stairwells and hallways are free of obstruction 

2.      Waste is deposited in appropriate receptacles and properly removed from the laboratory 

3.      Chemical spills are cleaned according to established protocol 

4.      Proper storage is accomplished to minimize clutter


 
RECORD KEEPING

        The laboratory has established and maintained an accurate record for each employee of environmental monitoring, medical consultations, and examinations, including tests or written opinion required.  A spill log of incidents involving hazardous substances is also maintained. 

        Accident records are initiated by the employee and supervisor and retained by Human Resources Services (HRS) (telephone 8-1533).  Property damage is reported to the Office of Risk Management (University: 8-6533; Hospital: 6-1707). 

        Environmental monitoring records are maintained by OEHS, Chemical/Biological Safety Section (telephone 828-4866).  Results must be made available to all employees who work in the area(s) monitored. 

        Medical consultation records are maintained by Employee Health Services (EHS) (telephone 828-0585). 

        Training attendance records are maintained by the CHO. 

        All records are kept, transferred, and made available in accordance with 29 CFR 1910.20.


 
REFERENCES

The following references were used to assist in the preparation of this document:

 
1. 
U.S. Department of Labor, final rule part II. Federal Register 29 CFR Part 1910. Occupational Exposure to Hazardous Chemicals in Laboratories, Wednesday, January 31,1990.  Copies of this document may be obtained from OEHS. 
2.
National Research Council. Prudent Practices for Handling Hazardous Chemicals in Laboratories, National Academy Press, 1995. Copies of this document may be ordered from the MCV Bookstore (approximate cost: $20.00). 
3.
National Research Council. Prudent Practices for Disposal of Chemicals from Laboratories, National Academy Press, 1981.



 
APPENDICES

A.     DOT Hazard Classification List

B.    EPA Hazard Classification List

C.    Chemical Inventory

D.    Compressed Gas Information Sheet

E.     Hazardous Waste Disposal Form

F.     Important Telephone Numbers For The Laboratory

G.    Glossary


 
APPENDIX A


DOT HAZARD CLASSIFICATION LIST



 
Hazard Classifications


 Explosive A & B 
 Explosive C 
 Blasting agents 
 Radioactive material 
 Flammable liquids 
 Pyrophoric liquids 
 Non-flammable compressed gases 
 Flammable gases 
 Combustible liquids 
 Flammable solids 
 Oxidizer 
 Corrosive material 
 Irritating material 
 Poison A 
 Poison B 
 Organic peroxide 
 ORM(1)-A 
 ORM-B 
 ORM-C 
 ORM-D 
 ORM-E 
 Etiological agents 

1     ORM = Other Regulated Material 

Example


Dynamite 
Fireworks 
Plastic explosives 
CO-60 or I-130 
Alcohol 
Phosphorus hydrids 
Nitrogen 
Oxygen 
Kerosene 
Picric acid/10% wet 
Nitric acid 
Hydrochloric acid 
Lacramator 
Heptachlor 
Phenol 
Benzoyl peroxide 
Formaldehyde 
Mercury 
Asbestos 
Bleach 
Ferric sulfate 
Microorganisms (E. coli)



 
APPENDIX B


EPA HAZARD CLASSIFICATION LIST

1. IGNITABLE WASTE -            Flash point < 1400

                                                  Flammable solids 

                                                   Oxidizers 

                                                    Flammable gases 

                                                    Some combustible liquids 

                                                    Pyrophoric liquids 

2. CORROSIVES -                      Any liquid of pH 2 or 12.5 

3. REACTIVE -                           Explosives A, B, or C 

                                                    Water reactive 

                                                    Cyanide or sulfide 

                             &nbs