Date: Mon, 30 Aug 2010 09:56:15 -0700
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Eric Clark <erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
Subject: Re: Safety Training
In-Reply-To: <D6A894F6502BDF43AF0C4A59BB97404F2C3E2D**At_Symbol_Here**>
I worked both sides of this one.  When I was a chemistry graduate student, 
I did the usual research like everyone else, and I finished up my research 
project and wrote a thesis.  Then I was done and I was gone.  Safety and 
compliance issues were not my problem; it was academic freedom at it's 
best.  I received no instructions and I didn't have a clue.  

Ten years later I visited the same university as a state hazardous waste 
compliance inspector.  And I found, among other things, several gallons of 
my own research waste still stashed in the cabinets beneath the instruments
 where I worked at the time!    

Eric Clark, MS, CCHO, CHMM
Safety & Compliance Officer 
Los Angeles County Public Health Laboratory 

>>> "Robin M. Izzo"  8/28/2010 6:39 AM >>>

I don't think any of us in academia that our situation "merits permitting 
untrained folks to perform tasks that require training."   That's my point 
- we have a structure and policies in place, but he reality is that the 
decentralized nature of a university makes it easier to have some people 
in the lab that have not attended this required training.

You say that nobody should be permitted to work in the lab until they can 
show proof of training.  I agree.  But think about it - who is permitting 
people to work in the lab?  Who is the gatekeeper?  For the most part, it 
is faculty and if that faculty member does not make it a priority to check 
on training - there's the disconnect.

We are constantly impressing upon faculty the importance of training.  We 
send reminders several times a year.  When we inspect a lab, we talk to 
the people working in the lab and check their training records.  Our level 
of compliance continues to improve, but it is not perfect.  We share 
stories of incidents that occur on our campus and elsewhere, illustrating 
the consequences.  We go to faculty meetings, we make things as simple as 
we can for them.

Further complicating things is that so many of us use the term "lab 
worker".  Most of the lab population in academia don't see themselves as 
"workers".  It is an academic pursuit.  We don't differentiate between 
students and staff when it comes to training requirements, but we have to 
be very careful of semantics.  If I say that anyone who works in a lab 
must attend training, the person who did not attend training will explain 
that he or she did not think it applied to them.

The people in these labs tend to be young.  This generation of students 
ignores e-mail and uses Google to answer their questions.  It is a 
challenge just making them aware of the training requirements.  

Please don't confuse frustration with giving up and accepting the status 
quo.  It's a major challenge and we have been chipping away at it.  I 
think that the best thing we have going for us is that our training 
program is well-executed and has a very positive reputation.   But the 
fact is, it is "different" than a lab of research professionals and our 
level of control is simply not the same.  We are not giving up or giving 
in and, frankly, every time I hear someone outside of academia suggest 
that it can't be so complicated, I find it difficult not to feel insulted, 
as if we don't agonize over the issue and don't care.

Robin M. Izzo, M.S.
Associate Director
Environmental Health and Safety
Princeton University
262 Alexander St.
Princeton, NJ 08544

-----Original Message-----
From: DCHAS-L Discussion List on behalf of ILPI
Sent: Fri 8/27/2010 5:52 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU 
Subject: Re: [DCHAS-L] Safety Training
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/nu
ances/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 requiremen
ts - 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
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 27, 2010, at 4:54 PM, Robin M. Izzo wrote:

		If only it were that simple. 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's 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 "safety 
culture" varies from institution to institution and from department to 
department.  They are making very little money and don't 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 "experience", may be a part-time 
	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 
	-          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't 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't think Princeton's approach is unique, yet we still don't 
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't 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's my 2 cents (given the length, maybe more like $2).
	Robin M. Izzo, M.S.
	Associate Director, EHS
	Princeton University
	609-258-6259 (office)
	Leap and the net will appear. - Zen Saying
	When you stumble, make it part of the dance. - Unknown
	Save a tree...please don't print this or any document unless truly 
	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/proce
dure 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 
	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-complian
t 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 
	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 "blowing-off" safety 
training.  There always seem to be the few employees that invariably are 
no shows for the trainings.


	Thanks in advance for your replies.


	Laura Damon

	Coordinator of Instructional Safety and Chemical Hygiene

	Flathead Valley Community College



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