Ralph has the ability to ask a succinct question but I lack the ability to provide a succinct answer!
"Is that part of the BCCE purview?"
I think that the "BCCE purview" extends to just about all topics that relate to chemical education. That doesn't narrow the field much, and surely the health and safety of both faculty and students falls in that category. I have organized a handful of safety symposia at the BCCEs to provide the forum and venue for discussions about safety amongst chemical educators. I have occasionally done this for ACS meetings in the CHED division, too.
From a regulatory view, the Lab Standard and the position of CHO should, in theory and practice, creates for small colleges (like all other institutions - either academic or not) the circumstance by which they must operate safely. This OSHA regulation technically applies only to employees but I think that most colleges "extend" the safety regulations and practices to students. If something "went wrong" and involved a student, I think a college would not want to try to explain a difference between "safety for employees" and "safety for students." So, on paper - whether a small college has an EH&S department or not (but almost certainly the situation is "not") - it surely needs to follow EPA and OSHA regulations and that should dictate a safe, law-abiding situation. The problem, I fear, that exists at many small colleges is that without EH&S safety professionals on campus in the past two decades, as various EPA and OSHA regulations have been promulgated there may have b!
een little awareness of the "new regulations" and the campus was, and may continue to be, unaware of how much they are not in compliance. This may seem shocking to safety professionals since, for example, the Lab Standard, has hardly been kept a secret. But, I suspect that there are still some colleges that don't have a CHO or CHP. If this seems astonishing, it simply reflects how a chemistry faculty (and perhaps the "stockroom manager" who almost certainly has no formal training in EH&S) and the administration are unaware of legal requirements. Further, I fear that many small schools have named a CHO and copied a boilerplate CHP to be in ostensible compliance, but that local circumstances of time and money undermine the proper implementation of the CHP and the function of the CHO. For example, many small school CHOs were simply "named the CHO" in past years but with no adjustment in their job description that really allowed the time to address the various tasks. Fu!
rther, some such CHOs are so otherwise occupied with teaching (for faculty) or stockroom management and lab preps (for non-faculty employees who got tagged as the CHO) that they don't have time both to learn what they need to do, and keep track of EPA and OSHA updates, much less "do it" properly.
What I suspect many small schools would appreciate is a clear statement from some authoritative organization (D-CHAS, CCS...) that makes it clear that the CHO is not just a label but that the position requires time (1.0 FTE 0.5 FTE? ... these are the units that mean something to administrators) to learn the job, do the job, and stay abreast of changes. (The value of these statements, much like the standards set forth by the ACS CPT, become very useful tools for leveraging changes that are administratively challenging.) This all sounds simple, but I cannot emphasize enough what financial stress many colleges are under these days as faculty lines are being cut and budgets are trimmed. This conspires to challenge a college to choose between "being in compliance" and "staffing a chemical faculty to teach even a bare-bones curriculum". And, the truth is, I suspect, since most small schools don't really expect to get a visit from OSHA or the EPA, they "do the best that t!
hey can with what they have" and cross their fingers that no major incident ever happens which would prompt an unwanted regulatory visit. Somebody at the school, or perhaps nobody, knows how much they are in or out of compliance but they are "mostly safe" (just as they genuinely wish to be) and this situation perpetuates.
Safety professionals know that the CHO is not a "one-hour-per-week venture", but I would guess that there are many small schools and colleges where this is the situation. Simply telling these folks that this is not acceptable does not solve the problem. What ideas and projects can CHAS and the CCS contemplate and develop to assist these folks? (I am aware of the CHAS workshops on "How to Be a More Effective CHO." This is a great workshop, but for some folks it only reveals to them all this things that they are NOT doing. It is not intended to solve the problem of "not having enough time to do the job".)
Finally, there are two "areas" on all campuses that require the focus of those who care about safety in the largest sense: 1) the safety of employees and the handling hazardous waste with regard to OSHA and EPA regulatory compliance, and 2) the instruction of undergraduate students and graduate students about the wide variety of safety issues about which we all want students (future employees/researchers) to be aware. The latter is largely a matter for faculty to address in courses and in their roles as research mentors for both undergraduate and graduate students (and post docs!). The former is "regulatory" in nature and falls under the purview of the CHO and other EH&S professionals (but also extends to faculty as the UCLA incident has revealed). All of this combines to generate, or not, a culture of safety. Things are better now, to be sure, than they were 20 and 10 years ago. However, there is much work to be done on both fronts.
(Does this suggest any papers for the BCCE contributed by safety folks?)
P.S. I was privately asked if there was a way to view the symposium list for the BCCE without "registering" in their system. (This is NOT "registering" for the conference; it's just creating an account for their system.) I will check into this, though.
David C. Finster
Professor, Department of Chemistry
University Chemical Hygiene Officer
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Ralph B. Stuart
Sent: Monday, January 27, 2014 12:54 PM
Subject: Re: [DCHAS-L] Call for abstracts for safety symposium at 2014 BCCE
> But many college folks in the audience will be in the situation where we have research labs but NO support whatsoever from the EH&S departments that don't exist on our campuses.
In my opinion, that's an important constituency for DCHAS to help. There's also the question about how to best teach lab safety concepts in the chemistry academic program. Fortunately, I'm aware of a good text on the topic. ;).
Is that part of the BCCE purview?
Ralph Stuart CIH
Chemical Hygiene Officer
Department of Environmental Health and Safety Cornell University
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