Date: Tue, 4 Aug 2009 13:09:29 -0400
Reply-To: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: 6 postings Re: [DCHAS-L] OSHA Lab Standard Effectiveness

From: kauletta**At_Symbol_Here**
Date: August 4, 2009 11:45:30 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality

The OSHA lab standard could use some work. I was a compliance officer  

when it was 1st published & it was confusing to us then. Now that I  
have to comply with it, its even more confusing. Yes, performance  
standards are a better model, but they need to be clear.

And now that I'm on the other side of the compliance issue, I've found  

that written programs, at least at a university, are not as important  

and protective as we thought they were at OSHA. I've also found that  
most PIs do not know much about OSHA nor do they give the OSHA regs  
much thought or feel they need to comply with them (they think they're  

for industry). What PIs do pay attention to is the granting agency  
requirements - that's where the lab safety info/compliance needs to be  

strengthened. The granting agencies should know that they're money is  

going to a safe program. The PIs also pay attention to any  
requirements for purchasing/receiving materials (eg DEA license,  
alcohol permit). There should be some requirement to document/prove  
you know how to handle a pyrophoric before you can use your credit  
card to buy enough to kill a researcher.

my opinion only - definitely not that of my university.

Kim Auletta
Lab Safety Specialist
EH&S    Z=6200
Stony Brook University
EH&S Web site:

Remember to wash your hands!

From: "Dr. Jay A. Young" 
Date: August 4, 2009 11:30:48 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality


I was not aware that UCLA and the lab had a CHP which satisfied Cal- 
OSHA.  Obviously, if in fact the CHP was any good, then it follows  
that the people in charge paid little attention to its requirements.

 =46rom that fact, I conclude that some way must be found to make them  

(not other people in other labs who, I will assume, do pay attention  
to their CHP requirements) pay attention.

And, since they are adults who did, or should have, know(n) better,  
they ought to personally pay a BIG fine and/or serve a proper prison  

I don't think this requires any change in that particular OSHA  
regulation.  What it does cry out for is a change in the enforcement  
of the OSHA regulations.


Date: August 4, 2009 11:44:16 AM EDT (CA)
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality

I do not think that the OSHA regulations, OSHA or State OSHA  
enforcement is the root cause.  They clearly contribute, but the root  

cause lies in the entire paradigm of safety culture within the  
academic community.  Administrators do not hold PIs responsible for  
anything other than grants and publications; PIs only care about  
productivity - Harran admitted he treated Ms. Sangji as a "student"  
and thought she had publications reporting her work with reactive  
materials; campus safety staff (our friends and colleagues) provide  
guidance; often based on one lab visit a year.  In the UCLA case,  
there was a serious breakdown in the safety office - Harran  
communications, because Harran was in temporary lab space and both he  

and the UCLA safety office figured they could hold off resolving lab  
safety until he moved into his permanent space.  And finally, ACS, ACS  

technical divisions, funding agencies (NSF, NIH, HHMRI, NASA, etc) pay  

lip service to safety; and if the visit a lab, they are interested  
primarily (exclusively) in research productivity.

Bottom line - the system is seriously broken and must be fixed.

From: anonymous
Sent: Tuesday, August 04, 2009 4:43 AM
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality

I do have a suggestion - develop a voluntary consensus standard (VCS)  

that is a stronger version of 1910.1450.  Perhaps ACS, which is  
considered a VSC body, would consider sponsoring a =93standard=94 on  
laboratory safety.  While ACS is not as prolific as ANSI, I think it  
could handle it - so could the National Research Council, ANSI, AIHA,  

etc.  After all, Prudent Practices was used heavily in non-mandatory  
Appendix B of 1910.1450.  One could write a VCS that was stronger, yet  

compliant with 1910.1450.  There are lots of guides and best practices  

out there; why not tie the right ones into a VCS?  Back in the early  
1990s there was so much guidance going around it was hard to choose  
between them.  And there=92s plenty more now, so it is not like it would 
be difficult to gather background reference material.

Though not the same thing, there are many examples of OSHA adopting  
VCS standards (all those in 1910.6). I think it unlikely OSHA would 1)  

adopt a VCS over or in conjunction with 1910.1450 or 2) incorporate by  

reference a VCS covering the lab standard.  But I do not think it is  
unreasonable for institutions to use a VCS that more strongly covers  
1910.1450 and better protects the employees as well as the employers.

I wonder whether how many CHPs are so poorly written and implemented  
that they are inadequate to protect employees, and whether if, a VCS  
that directed better CHP content and implementation, would be of  
interest and help to solve that problem.

So if a VCS that was stronger, yet compliant with 1910.1450 could  
garner any interest, OSHA need not be involved and it would not take  
any legislation.  Such a document could be submitted to OSHA so they  
know it is there and offer their (guarded) opinion that it meets the  
requirements of 1910.1450.  So if this were to happen, the choice  
becomes - do the people want something more stringent or are they ok  

with the way things are.


From: "Lawrence M Gibbs" 
Date: August 4, 2009 1:01:29 PM EDT (CA)
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality

An interesting discussion, to say the least.  I do believe that one  
could enhance a laboratory safety plan by including the basis elements  

of risk assessment as a requirement for laboratory protocols.  I don't  

believe that the OSHA lab standard will be able to be changed, or that  

it should, but there is a demonstrated need to develop a process to  
ensure that research faculty and researchers themselves better  
understand the risk assessment process when working with hazardous  
materials.  This is not taught in most US colleges or universities,  
either at the undergrad or graduate level.  For the long term, I  
believe those of us working in the academic EH&S area need to develop  

a means to influence and ensure that the science laboratory  
undergraduate programs and graduate programs both include elements of  

hazardous materials risk assessment into the curriculum.  For the  
short term, we need to utilize other avenues of evaluation of PI  
management performance to emphasize that research supervision and  
oversight is a management responsibility of each PI.  We have begun  
one approach to this at Stanford, which we hope to write up for one of  

the CHAS upcoming publications.  We are now working with the  
institution's Internal Audit folks and have completed a pilot program  

where the Internal Audit program has evaluated the implementation and  

management of the CHP as an element for overall evaluation of the PI's  

management responsibilities.  Although in its preliminary stages, this  

appears to be a way to ensure the CHP is viewed as a lab safety  
management program for which the PI has responsibility.

More to come on this in an upcoming issue of CHAS (if we can get the  
to write it all up).


Lawrence M. Gibbs
Associate Vice Provost for EH&S
Stanford University
480 Oak Road
Stanford, CA  94305


From: "Harry J. Elston" 
Date: August 4, 2009 11:33:15 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very  
complete information about UCLA fatality

RE:  Chemical Hygiene Committees:

Please refer to Elston's management axiom #3:  When a committee is in  

charge, no one is in charge.


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