Date: Tue, 1 Mar 2011 15:41:49 -0500
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From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Photographing non-compliance
In-Reply-To: <DC9B6B340B77DE43BFFBBFD7F28C2FD903A2A6**At_Symbol_Here**>

I think any protocol for disposal should be based on seriousness as well as track record.   That's why I, as a professor rather than EHS person, started documenting every serious laboratory incident in which I had firsthand knowledge or involvement.    After one explosion/fire in a colleague's laboratory, I noted deficiencies in the alarm system, emergency response (fire crews brought in 14 pieces of equipment and set up a command post but refused to come in the building for well over 25 minutes without even checking firsthand that no lives were in peril), failure to evacuate, etc.   I wrote it all up, sent it to my department chair and EHS, and filed it away in case this kind of nonsense ever happened again.   Because if it did happen again with the same failures and someone had been hurt or killed, I would have been the first one on the witness stand to testify against my own university.  Thankfully, it was not necessary because the folks in a position to effect changes made the ones I recommended.  Sometimes bureaucracy actually works.

However, I've seen too many academic institutions where the same safety mistakes are made over and over and over.   Knowing that others have documented evidence of repeated safety lapses/failures should be all the encouragement institutions need to ensure that such incidents are not repeated.  Yes, there is some potential there for an overzealous or unscrupulous lawyer (yes, I know, redundant...) to abuse such records, but the fact of the matter is that if a lab is repeatedly cited for poor safety policies and someone gets hurt/killed, the employer and supervisors in the chain of command *should* be held legally/ethically/morally accountable.  Obviously, we all dread being seen as the "EHS police", but if a recalcitrant PI persists in operating an unsafe laboratory, he/she leaves EHS and the administration no choice.

Obviously, for routine inspections and such, folks can improve with time and learn lessons, but I would want to see at least 3 near-perfect  inspections in a row before I'd be willing to throw away records that reveal a track record of poor safety/risk management practices.   Photographs are ideal because they provide a literal snapshot of what the inspector saw.

Rob Toreki

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On Mar 1, 2011, at 3:00 PM, Robin M. Izzo wrote:

We photograph what we can - it does help get the point across much more effectively than a written description alone.

However, you may want to check with your institution's general counsel.  If you are documenting an incident, the photos can be an important component, but if you are documenting non-compliance as part of an internal compliance inspection, you should have a protocol for what to do with the photos and the reports over time - how long and what to retain.  Our protocol is to toss the inspection records, including photos, after one year or once the next inspection takes place, whichever happens first.


Robin M. Izzo, M.S.
Associate Director, EHS
Princeton University
609-258-6259 (office)

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