Date: Wed, 5 Aug 2009 09:24:00 -0700
Reply-To: Laurence Doemeny <ldoemeny**At_Symbol_Here**COX.NET>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Laurence Doemeny <ldoemeny**At_Symbol_Here**COX.NET>
Subject: Re: Article from Chemical and Engineering - very complete
information about UCLA fatality
Comments: To: Ed Miller
In-Reply-To: <1593.137.142.126.83.1249398305.squirrel**At_Symbol_Here**webmail.plattsburgh.edu>
I would like to follow up on Ed's comments and could not agree more.  If
management does not actively involve itself in any activity, you cannot
expect the activity to be accomplished or sustained.  Here are my
suggestions for success:

Managers establish the mission, vision, and objectives to achieve their
organization's strategic goals. The responsibility of line management is 
to
share their organization's goals with all of their employees to 
facilitate
the development of a workable plan, in this case, to protect the health 
and
safety of people and the environment. This could be accomplished in some 
of
the following ways:
1.	Review and revise, as needed, employer mission, vision, and policy
statements related to the establishment of health and safety standard
operating procedures for managers and employees.
2.	Review and revise, as needed, comprehensive employer training
materials on the issue of health and safety for managers and employees.
3.	Review any existing labor agreements that represent employees in
your organization to determine if there is a health and safety clause. 
If
there is no health and safety clause, one should be created. Such a 
clause
should clearly state the responsibilities of the employer, managers, and
employees.
4.	Prepare position descriptions to include chemical safety
responsibilities for all personnel working in your organization.
5.	Develop a performance plan for each position. The health and safety
elements should define what is expected and include a relative score for
meeting, exceeding, or failing to meet the elements. These elements 
should
have sufficient force that could affect an employee's pay and employment
status.
6.	Consider a rewards system in your workplace. Generally, employees
appreciate seeing tangible results for meeting or exceeding 
expectations.
Many employers have a system in place that could be used for this 
purpose.
7.	Consult with staff members in your Human Resources Department. They
can provide you with guidance in dealing with management and labor 
unions,
as well as developing appropriate work plans and position descriptions.

I'll leave details to individual institutions.  They are in a better
position to fill in those details using established procedures.  
Clearly,
future employers are expecting graduates to have some knowledge of 
safety
and those with advanced degrees to show leadership not just in their 
chosen
field but also in safety and ethics.  Keep in mind that this plan goes
beyond chemistry.  It would include but not limited to the physical and 
life
sciences, agriculture, medical, dental and veterinary schools (their 
GLPs
and accreditation requirements most likely include laboratory safety),
engineering and facilities operations.

Laurence Doemeny

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of 
Ed
Miller
Sent: Tuesday, August 04, 2009 8:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very 
complete
information about UCLA fatality

Hi Harry and All:
  I agree with what Harry has said.  It don't believe that the problem
centers on the lack of rigor in the standards.  The problem, it seems to
what I have seen, is that they are not utilized as they should be. 
Accountability is absent many times.

  Before increasing the strength of the standards, we need to figure out
how to enforce - encourage academics to use them.  I would hope that a
community of educators could somehow be educated to know that they need
to be policing themselves so that the proper approach is shown to the
students. That hope being stated, I think everyone needs a system to
keep them honest and their practices relevant.  I think this will take a
combination of education of adminsitrators/faculty/staff on their "duty
of Care", as well as sticks and carrots.
Ed Miller

On Tue, August 4, 2009 7:46 am, Harry Elston wrote:
> Neal et al.:
>
>
>
> I'm going to fall on the other side of the fence on this one - I don't
> want
> to see the lab standard any stronger than what it is.
>
>
>
> Personally, I think that Cal-OSHA missed the boat on this one and the 
lab
> standard is fine as it's written.  There is far enough teeth in the
> statement regarding CHPs "...capable of protecting employees from the
> health
> hazards associated with hazardous chemicals in that laboratory..."
> (1450(e)(1)(i))
>
>
>
> Making the Lab Standard prescriptive would be counter-productive for
> safety
> in the laboratory.  Keeping the standard performance based places the
> burden
> of safety squarely where it should be:  Front-line management, or in 
this
> case, the PI.  A prescriptive plan places the safety burden on "The 
Safety
> Guy/Gal" who has to go around and look to insure that every jot and 
tittle
> of the standard has been met.
>
>
>
> H
>
>
>
>
>
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf 
Of
> NEAL LANGERMAN
> Sent: Monday, August 03, 2009 8:14 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very
> complete
> information about UCLA fatality
>
>
>
> Peter and others -
>
> Unfortunately, UCLA and the lab had a CHP which satisfied Cal-OSHA.  
The
> reason that there is little mention in the UCLA discussion of the Lab
> Standard and related is that UCLA is a good example of the standards
> weaknesses.
>
>
>
> Any yes, it would be great to strengthen 1910.1450 and there are
> discussions
> along those lines, but that takes changing an existing OSHA standard.  
Not
> easy.
>
>
>
> There are many ideas being discussed and this list is a good forum for 
the
> discussion.
>
>
>
> So, how would YOU suggest (1) improving the lab standard and (2) 
getting
> OSHA to do it?
>
>
>
> -------------------------------------------
> ---------------------------------------
>
> The information contained in this message is privileged and 
confidential
> and
> protected from disclosure. If the reader of this message is not the
> intended
> recipient, or an employee or agent responsible for delivering this 
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> to the intended recipient, you are hereby notified that any 
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> distribution or copying of this communication is strictly prohibited. 
If
> you
> have received this communication in error, please notify us 
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>
> NEAL LANGERMAN
> ADVANCED CHEMICAL SAFETY, Inc.
> 7563 CONVOY Ct
> SAN DIEGO CA 92111
> (858) 874 5577 (phone, 24/7)
> (858) 874 8239 (FAX)
> www.chemical-safety.com 
>
>
>
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf 
Of
> Reinhardt, Peter
> Sent: Monday, August 03, 2009 3:10 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very
> complete
> information about UCLA fatality
>
>
>
> Kudos to C&E News for this excellent review and analysis.
>
>
>
> I continue to be surprised that there is so little mention of OSHA's 
lab
> standard or Chemical Hygiene Plans, and no mention in this article. 
UCLA
> is
> required by California law to have a Chemical Hygiene Plan, and their
> internal report (and CalOSHA citation) mentions it. Experts in the 
article
> discuss the need for lab-specific risks assessment, policies, 
procedures
> and
> training. The Chemical Hygiene Plan is the tool for all these things. 
In
> response to this tragedy I think it would be good if ACS DivCHAS 
worked to
> strengthen the use and implementation of laboratory Chemical Hygiene
> Plans.
>
>
>
> Pete
>
>
>
> Peter A. Reinhardt
>
> Director, Office of Environmental Health & Safety
>
> Yale University
>
> 135 College St., Suite 100
>
> New Haven, CT   06510-2411
>
> (203) 737-2123
>
> peter.reinhardt**At_Symbol_Here**yale.edu
>
>
>
>   _____
>
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf 
Of
> Debbie M. Decker
> Sent: Monday, August 03, 2009 1:38 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: [DCHAS-L] Article from Chemical and Engineering - very 
complete
> information about UCLA fatality
>
>
>
> http://pubs.acs..org/cen/science/87/8731sci1.html
> 
>
>
>
> Debbie
>
>

Edward J. Miller, Ph.D.
Chairperson and Professor of Chemistry
SUNY Plattsburgh

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