DOE's somewhat dated home page for "Integrated Safety Management" is at
http://www.hss.doe.gov/healthsafety/ism/ For a diagrammatic representation click to enlarge the image at http://orise.orau..gov/safety/integrated-safety-management.aspx
The diagram (center circle) defines seven over arching Guiding
Principles for working safely. The peripheral circles describe
five Core Functions for performing work, with initiation being "Define
the Scope of Work." Together, the Principles and Functions define a
process defined by the Department of Energy as "Integrated Safety
Management" (ISM).
Implementation of ISM is applicable to all
work, including bench-scale research with hazardous chemicals and
microorganisms. ISM is the "high bar" that the Department of Energy has
established for all of its research laboratories.
Although
with different vocabulary, ISM seems to approximate the "high bar"
established by the UC-LADA agreement. A few examples follow:
The
principle "Hazard Controls Tailored to the Work Performed" addresses
the questions asked about the differences in the rigor of hazard
protection when (for example) working with concentrated nitric acid vs. a
dilute solution of 0.1-1N nitric acid. The principles "Line
Management Responsibility" and Roles and Responsibilities" corresponds
to the clearly understood roles of the institution, the principal
investigator, and the worker. The core function (outer circle) "Develop
and Implement Hazard Controls" corresponds to the preparation and use
of an SOP. The Principle "Competence Commensurate with
Responsibilities" corresponds to the training/mentoring and experience
level of the person performing the work. The UC-LADA agreement is an
extreme example of the core function "Provide Feedback and Continuous
Improvement."
I hope that other similarities between the ISM diagram and the UC-LADA agreement are intuitively obvious.
For those who may wish to delve deeper, see the ongoing refinements and more contemporary ISM documents at:
http://www.hss.doe.gov/healthsafety/ism/https://www.directives.doe.gov/directives/0450.4-APolicy-a/viewhttps://www.directives.doe.gov/directives/0450.4-EGuide-1c/viewDavid Haugen
Retired from a DOE research laboratory
From: "NEAL LANGERMAN" <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM>
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Sent: Sunday, July 29, 2012 11:41:40 AM
Subject: [DCHAS-L] UC - LADA Agreement
The complete Agreement between UC and the LADA related to
the Sangji fatality is posted on the CHAS website at:
http://tinyurl.com/uc-lada-agreement
This Agreement has two precedent-setting conditions which
will set a new, high bar for academic safety performance. In Appendix A -
Sections 3 and 4, PIs and visiting PIs are not allowed to perform any work or
supervise any activity until they receive formal laboratory safety training..
This is a powerful requirement which will clearly redefine
the position of laboratory safety in the activities of each PI.
In Appendix A section 6, the Agreement requires that SOPs
for a list of specific chemicals and chemical classes be written by the lab's
most experienced person and be signed off by the PI. CHAS has broken this
list of chemicals out of the Agreement and it can be found as a stand-alone
document at the URL above.
These powerful requirements apply to the entire UC
system. As such, they will set a performance bar for research
institutions across the country.
Please read these documents and share your thoughts with the
CHAS community. As time goes on, we will revisit these requirements and
learn how their implementation is playing out.
Stay safe out there!
Neal
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