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 Eric Clark, MS, CCHO, CHMM Safety & Compliance Officer Los Angeles County Public Health Laboratory >>> "Robin M. Izzo"
8/28/2010 6:39 AM >>> Rob, 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 http://www.SafetyEmporium.com esales**At_Symbol_Here**safetyemporium.com 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 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'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 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 necessary. 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 thread. ====================== ========================= ======= Safety Emporium - Lab & Safety Supplies featuring brand names you know and trust. Visit us at http://www.SafetyEmporium.com esales**At_Symbol_Here**safetyemporium.com 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. =09 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. =09 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. =09 Good luck. Dan Herrick =09 =09 =09 =09 EHS Coordinator =09 =09 =09 =09 Massachusetts Institute of Technology =09 =09 =09 =09 Mechanical Engineering Department, Research Laboratory of Electronics, =09 =09 =09 =09 Department of Aeronautics and Astronautics, Civil and Environmental Engineering Department =09 =09 =09 =09 herrickd**At_Symbol_Here**mit.edu ________________________________ 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 ldamon**At_Symbol_Here**fvcc.edu =09
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