From: kauletta**At_Symbol_Here**notes.cc.sunysb.edu 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 kauletta**At_Symbol_Here**notes.cc.sunysb.edu 631-632-3032 EH&S Web site: http://www.stonybrook.edu/ehs/lab/ 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 Neal, 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 sentence. 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. Jay === From: "NEAL LANGERMAN" 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 time to write it all up). Larry Lawrence M. Gibbs Associate Vice Provost for EH&S Stanford University 480 Oak Road Stanford, CA 94305 lgibbs**At_Symbol_Here**stanford.edu 650.723.7403 === 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. H
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