Date: Fri, 27 Aug 2010 17:52:23 -0400
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From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Safety Training
Comments: cc: "Robin M. Izzo"
In-Reply-To: <D6A894F6502BDF43AF0C4A59BB97404F079652AE**At_Symbol_Here**>

I worked in four major research university labs from 1985 through 2000 - in virtually every possible capacity: undergraduate researcher, graduate student, postdoc, professor, and I understand very well the complexities/nuances/conflicts.  You've summarized them nicely for those who may not be aware, thanks.

It's your first line that caught me there - "If only it were that simple".   That's my point.  It *should* be that simple.  Academia is bound by the "this is the way it has always been done" and "we can't change the system" mindsets (probably inherited from university bureaucracies).  Not only with respect to safety and lab procedures, but rules in general.

There is no good reason why it CAN'T be that simple.  When you get employed, you head off to the university employment office and they have to get your W-9 (citizenship) and W-4 (tax withholding) etc. set up.   You can't work until they have those.  Period.

"There is not a single system for entering the laboratory environment" - that's my point, too.  There should be.  And it starts with a simple requirement that you don't perform lab work until you have a piece of paper saying that you are cleared to work in the lab.  No PI or supervisor can accept someone into the lab without safety training.  Period.  It's a really good incentive to get your training done.

We have all kinds of OSHA and workplace rules regarding training requirements - no one drives the forklift without being certified.  No one draws blood without BOP training.   Would anyone here like have their kidney dialysis treatment performed by someone who is planning on "getting around to" blood-borne pathogen training next week?  So why would something that ridiculous be acceptable in a lab that uses t-butyllithium?  As a former professor, I'm ashamed that chemistry and EHS departments have the audacity to claim that their situation is "different" and merits permitting untrained folks to perform tasks that require training.

Safety is the first and foremost concern in *every* laboratory operation.  Period.  You relax that rule, bend it, or break it and the consequences (as we have seen) can be fatal.  Reinforcing the importance of safety by *requiring* safety training before *any* work begins telegraphs the role of safety and is an important first step (of many) that academia needs to take to embrace the safety culture mindset.

Rob Toreki

Safety Emporium - Lab & Safety Supplies featuring brand names
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On Aug 27, 2010, at 4:54 PM, Robin M. Izzo wrote:

If only it were that simple=85 an outright ban on laboratory work until the worker has completed safety training.   In a way, we have that, but it is so much more complicated and I honestly believe that only those who work in academia can appreciate that.
First, let=92s talk about WHO these laboratory workers are.  There are several types, here are a few:
-          Faculty, who rarely actually work in the lab, but are ultimately responsible.
-          Staff - it is a true luxury for a lab to have a professional staff member.  This is a rarity.
-          Post-doctoral associates - in the lab for months or years.  For the most part, they have spent nearly all of their time in academic teaching labs or university research labs where the =93safety culture=94 varies from institution to institution and from department to department.  They are making very little money and don=92t see themselves as employees.  They are the prodigal stepchildren of the university.
-          Graduate students - technically, they are not employees, but in most cases, the veteran grad students will have at least some leadership responsibilities in the lab.  Depending on their degree, they could be there for 6 months to 6 years.
-          Visiting researchers - may be in the lab for weeks or months or years, depending on the project.  May officially be an employee or student of another institution
-          Undergraduate students - may be in the research lab for an academic project, as a volunteer, as a part-time employee
-          High school students - may be in the research lab for an academic project, may volunteer for =93experience=94, may be a part-time employee.
Now, how do they get here?
-          Faculty - spend weeks or months preparing for start-up.  Depending on how the university is set up, their hiring may be separate from staff hiring.  At Princeton, the Dean of Faculty hires faculty and lab staff, while Human Resources hires admin staff.  They have different rules, procedures, etc depending on which group hires them.
-          Staff - may be hired through the Dean of Faculty (apart from the Human Resources side of things) or through the same route as a standard employee.  May arrive any time of the year.
-          Post-docs - may arrive any time of the year, usually by arrangement with the department
-          Graduate students - usually arrive at the beginning of a semester or during the summer
-          Visiting researchers - may arrive any time of the year, usually by arrangement with the department
-          Undergraduate student - may start working in the lab any time and if not paid, nobody outside the lab might even know they are associated with the lab
-          High school students - may arrive any time of the year, but usually during the summer.  If paid, perhaps HR knows.  Many will volunteer and it could be that only the principal investigator knows that they are associated with the lab.
So, already things are complicated.  There is not a single system for entering the laboratory environment.  Thus, for most universities, it is the responsibility of the principal investigator/faculty to ensure that all have been through training, among many, many other  responsibilities, including teaching, writing, mentoring, etc.
At Princeton, it is mandatory for anyone working in research laboratories to attend the 3 hour laboratory safety training provided by EHS.   That is a University Policy and there are consequences for non-compliance.  It applies to faculty, staff, post-docs, students, visitors, paid or unpaid.  Our degree of compliance varies:
-          Faculty - 100% compliance.  EHS receives reports from the Dean of Faculty of all new faculty hires.  EHS contacts the department to see if they will have a research lab.  If they will, we contact them and tell them of the requirement for Laboratory Supervisor briefing - a one-on-one training session that focuses on their role as a supervisor and introduces them to the safety culture.  If they give us a hard time about making arrangements, we will escalate from the Chair to the Dean of Research.  So far, in 10 years we have never had to do that.
-          Staff - there are not many and we have very good compliance
-          Graduate students - excellent compliance - our training is part of their orientation
-          Undergraduates - very good compliance - our training is part of the curriculum for most science and engineering majors, but non-majors may be an issue
-          Post-docs and visiting researchers - variable.  Truly depends on how much the department knows of what is happening in the labs and the how well the PI is paying attention.
-          High school students - recently banned, but we had excellent compliance because there was a formal program for review and approval of minors in the lab and they could not begin work until they attended training.
Lab Safety Training is instructor-led classroom training.  We offer it at least once a month.  We simply don=92t have the staffing to do much more than that, but in February, June and September, when most are beginning their stint at Princeton, we conduct numerous sessions.  If someone is not able to attend before they are scheduled to begin in the lab, then they can work in the lab only if someone in the lab who has been trained is willing to take responsibility for them and they are supervised at all times by a trained individual.  They must attend the next session.
As for undergraduate teaching labs, Teaching Assistants and instructors are given safety curriculum to provide to all students, and safety is written directly into the procedures.
I don=92t think Princeton=92s approach is unique, yet we still don=92t have 100% compliance.  We take it very seriously and are constantly looking for ways to improve, but it is an uphill battle, not because people don=92t care and not because people complain, but because universities are incredibly decentralized and it is unrealistic to expect that every faculty member is going to be vigilant about it.  If they are not, the decentralized nature means that there may not be enough additional checks and balances.
That=92s my 2 cents (given the length, maybe more like $2).
Robin M. Izzo, M.S.
Associate Director, EHS
Princeton University
609-258-6259 (office)
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When you stumble, make it part of the dance. - Unknown
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From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of ILPI
Sent: Thursday, August 26, 2010 10:50 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Safety Training
Academia needs to wake up and have a simple outright ban on all laboratory work until the worker has completed their mandatory safety training.    We don't allow folks to start driving and then "get around to" getting their driver's licenses, do we?
I agree that most EHS departments have enough grief being seen as an arcane enforcer rather than safety/productivity partner in academia, however this one simple rule needs to be written in stone so it isn't unwritten in blood.
In my 4 years at MIT, not one person ever said "I can't wait to start work but have to take my training class first."   They just started in the lab.  Now, that was back in the days when the web was still a twinkle in Tim Berners-Lee's eye and things have likely improved to a fair degree.  However, the attitude of "work now and safety when I get around to it" is still rampant at most academic institutions and is a direct result of failure to promote safety culture.   
I conjecture that this failure of academic institutions to teach and promote safety culture in their curriculum and department is the root cause of the vast majority of accidents at such institutions.  Training should start on day 1 with the formal presentations, and on day 1 the message should be that safety is an integral part of planning every single laboratory operation (not just experiments, either).  Safety planning/procedure should be written into the laboratory notebook of every undergraduate student (and for that matter, graduate student and postdoc).  Only then can our system start graduating students competent in safety culture - students who can then go on to industry without culture shock or into academia with the seeds of long-overdue change.
Rob Toreki
PS: One other issue at the major institutions is that it is simply impossible for the PI of a 20-person group to be on top of all safety matters in their operation.  Authority is delegated or diffused to the point that folks are basically winging it in many cases.  I know people who saw their research advisor perhaps once every two or three weeks and they were lucky to talk to him or her for 20 minutes.  Those previous moments will focus on one's thesis work results from the past 2 weeks and plans for the coming 2 weeks are the reason for the meeting; safety will never, *ever* come up.  But this digresses into another conversational thread.
 ====================== ========================= =======
Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at
esales**At_Symbol_Here**  or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
On Aug 26, 2010, at 9:53 AM, Dan Herrick wrote:

As others have noted, the approach that works well in industry won't work as well in academia.  If the people not attending training are employees of the academic institution (facilities staff, maybe?), you may be able to implement some of the performance-based consequences whcih have been suggested.  For faculty, undergrads, grad students, and post-docs, this is not realistic.  

We have web-based training for a number of modules (Haz Waste, General Chem, etc) and we require documentation of Lab Specific training every year.  All training is also recorded in a system where we can track metrics by PI and follow up on incomplete training.  For continually non-compliant folks, I try all the usual channels - multiple emails, reminders of when live courses are given, attempts to give live courses to an entire research group at a group meeting all at once, etc.  Usually people complete training eventually, if only because they are sick of my repeated emails.  Sometimes it comes down to individual visits with individual PIs - they may not be actively "avoiding" training , they may just legitimately be extremely busy.  If one "sells" it right, this can come across not as "You didn't do your training!" but "How can I help you ensure the safety of your laboratory in the most effective way?"  In the long run, the latter is more helpful than the former.

A lot of it does come down to the safety culture that is created within the academic institution.  If EHS is viewed as a helpful partner in ensuring that research proceeds in an effective manner, and if there is buy-in from University leadership and Departmental leadership regarding established safety programs, then "escalating" the continually non-compliant to the next level of "management" is straight-forward and should produce results.  If EHS is viewed as merely an ancillary part of the campus that enforces regulatory codes or as a group which tends to impede research being done, or if top level folks at the University are not interested in or engaged in safety, the task is much harder.

Good luck.

Dan Herrick

EHS Coordinator

Massachusetts Institute of Technology

Mechanical Engineering Department, Research 
Laboratory of Electronics,

Department of Aeronautics and Astronautics, 
Civil and Environmental Engineering Department


Date: Wed, 25 Aug 2010 16:01:19 -0600
From: ldamon**At_Symbol_Here**FVCC.EDU
Subject: [DCHAS-L] Safety Training
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

I am wondering how others address employees =93blowing-off=94 safety training.  There always seem to be the few employees that invariably are no shows for the trainings.


Thanks in advance for your replies=85


Laura Damon

Coordinator of Instructional Safety and Chemical Hygiene

Flathead Valley Community College



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