04.0 Chemical Carcinogen Memorandum of Understanding and Agreement (CMUA)

The CMUA gives a PI or supervisor the authority to order, receive and use the select carcinogens specified in the CMUA.

An authorized MUA user is a Center faculty (member, associate member, assistant member), staff scientist, director or other qualified personnal recognized by EH&S to have sufficient knowledge, experience, and training to fulfill the role and responsibilities of holding an MUA. MUA holders are responsible for complying with Center, local, state, and federal regulations for health and safety with respect to the specific MUA (carcinogens, etiologic agents, and radioactive materials).

All use of select carcinogens requires an approved CMUA. A select carcinogen is a chemical classified as:

1. Group 1, Carcinogenic to Humans, by the International Agency for Research on Cancer (IARC); or

2. A known carcinogen (KC) by the National Toxicology Program (NTP); or

3. A regulated carcinogen under the Washington Industrial Safety and Health Act (WISHA).

4.1 Application

When an investigator uses a select carcinogen for a project, a CMUA must be submitted to EH&S. To determine whether or not a CMUA is required, check Table 12.11. CMUA and CMUA Amendment Forms are available electronically on EH&S.

These forms are also available from EH&S directly.

The CMUA requests the following information:

1. Name of chemical carcinogen to be used;
2. Maximum volume to be used;
3. Brief description of the purpose for using the carcinogen;
4. Specific lab procedures to be followed;
5. Special instructions for use;
6. Personal protective equipment required;
7. Medical surveillance requirement;
8. Emergency contact information; and
9. Disposal Procedure.

4.2 Approval Criteria

All CMUA applications are reviewed by the Chemical Hygiene Officer (CHO) prior to approval. The following criteria must be met:

1. The CMUA is satisfactorily completed, signed, and returned to the CHO.
2. The appropriate PPE is listed and available.
3. The safety, spill clean-up, and disposal procedures are adequate.
4. Hazard awareness training has been provided to the staff listed on the CMUA. Each user must initial the form acknowledging having received such training.

Once approved, the investigator is authorized to use the specified select carcinogen(s) for a period of three years.

4.2.1 Amendments

Revisions to an existing CMUA must be submitted to EH&S on the CMUA Amendment Form. Contact EH&S for a copy of the form.

Amendments are required for the following circumstances:

1. A change, addition or deletion of a select carcinogen(s);
2. A change in labs or room numbers;
3. A change in procedure that would increase the risk of exposure to lab staff; or
4. The removal or addition of one or more staff members working with the chemical carcinogen.

4.2.2 Renewals

A CMUA can be amended for three years. At the end of five years, EH&S will ask the PI or authorized MUA holder to submit a new CMUA form incorporating all the amendments from the previous five year period. EH&S will notify the PI or authorized MUA holder prior to the expiration of the CMUA.