If you're a Series A biotech that just signed a lab lease, you will get a lot of opinions about what EHS programs you need. Some will come from your landlord. Some from your insurer. Some from a well-meaning advisor who saw a compliance checklist once. Very few will distinguish between what's legally required, what's operationally sensible, and what can wait.
Here's a practical breakdown for a typical 20–60 person company with BSL-1 or BSL-2 labs in California.
Legally required from day one
These programs are required by federal or California law. A regulator can cite you for not having them the first day you have employees working with hazardous materials.
- Chemical Hygiene Plan (CHP) — required under OSHA 29 CFR 1910.1450 for any lab using hazardous chemicals.
- Hazard Communication (HazCom) program — required under OSHA 29 CFR 1910.1200. Includes an SDS library and labeling system.
- Emergency Action Plan (EAP) — required under OSHA 29 CFR 1910.38 for any site with 10+ employees.
- Bloodborne Pathogens (BBP) Exposure Control Plan — required under OSHA 29 CFR 1910.1030 if any employee has occupational exposure to blood or OPIM.
- Hazardous Materials Business Plan (HMBP) — required in California under Health and Safety Code 25500 if you store hazardous materials above threshold quantities.
- Hazardous waste generator compliance — EPA/state requirements as soon as you generate your first drum of hazardous waste.
Operationally necessary within 90 days
These aren't always cited at small sites on day one, but they're the programs that prevent incidents and make inspections survivable.
- Lab-specific SOPs for your highest-risk operations (fume hood use, cryogenic handling, pyrophorics if applicable).
- Training matrix and documented initial training records for every employee.
- Waste stream profiles and accumulation area setup — before your first disposal event, not after.
- Fire Prevention Plan, coordinated with building facilities.
- Eyewash and safety shower inspection log — ANSI Z358.1 requires weekly flushing documentation.
Nice to have but not yet urgent
These programs matter but can be phased in after the basics are solid, typically 6–12 months in.
- Respiratory Protection Program — only required if employees use respirators. Don't issue respirators unless you're ready to stand up the full program (medical eval, fit test, training).
- Hearing Conservation Program — required at 85 dBA TWA. Rare in early-stage biotech.
- Lockout/Tagout (LOTO) — required if employees service energized equipment. Usually needed when you have your own facilities/maintenance staff.
- Contractor EHS management — important when you start managing construction or installation vendors.
What to sequence
The most practical order for a Series A that needs to stand up programs fast: CHP + HazCom + EAP together (they share the same chemical inventory foundation), HMBP immediately if you're storing above thresholds, BBP if you have any biological work, and waste setup before you generate your first drum. Everything else can follow the 90-day arc.
If you're at Series A and trying to figure out what to build in what order, we can scope it in a single call. The answer is almost always more specific to your chemistry and headcount than any generic checklist can capture.