The responses to this issue appear to be split, with some indicating EH&S should rightfully have veto-control of chemical purchasing, and many others taking the opposite stance. I believe the specific conditions need to dictate the level of authority of an EH&S Manager.
First of all, this particular chemistry department has little to no research being performed. The chemicals being used are fairly routine, with little change from one year to the next. While the EH&S Manager could simply say he wants to know about highly reactive or toxic chemicals before they come on campus, that is not his stance. He wants an SDS sent to him before any purchase, as if a chemistry professor, one with significantly more chemical laboratory experience then him, can’t make a good decision. This EH&S Manager’s background is in fire safety. He has no advanced degrees, no apparent laboratory experience, and has shown no interest in working with the faculty on chemical safety & security. He has seized control not just of chemical purchasing, but also of access to routinely-used laboratory chemicals.
In the EH&S Manager’s correspondence, he has specifically referenced the “quantity” of chemicals stored for these security restrictions, not specific chemical hazards that represent a concern. If there were explosives, strong reactives, or “dual-use” chemicals, then perhaps these security measures would be appropriate. As it is, however, any of those chemicals that might represent a real hazard are stored separately under lock and key. This issue is specific to chemicals used on a daily basis in teaching laboratories.
He has restricted all laboratory assistants from access to the main chemical storeroom, where the chemicals used routinely in the teaching laboratories are stored. By restricting chemical storeroom access to faculty members with swipe cards, he ignores the basic reasons for having lab assistants – to help set up lab procedures, and to reduce the burden on faculty members. Since these assistants receive substantial safety training in the handling of chemicals, there does not appear to be a safety-based justification for this restriction, particularly since several chemistry faculty members have physical disabilities.
I believe the primary responsibility of a university EH&S Director is to be a resource - a partner with faculty & staff in enhancing laboratory safety. It is one thing to be a “safety cop”, but an entirely different thing to be a “safety dictator”.
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Concerned Safety Specialists,
Yes, campus wide chemical inventory was complicated and imperfect while I was CHO at Cal Poly San Luis Obispo. The campus had many years ago (early 1990's) began using procurement cards widely across the campus. Even I had one with moderate limits. The rationale for these was the dreadfully slow and undependable purchase order process the campus struggled with for years. I think the use of procurement cards is still ubiquitous on the campus.
Having many people/departments (at the time there were about 125 on campus) able to order anything on a Pcard with a phone call or mouse click made it necessary for me to contact all the departments with labs or shops (departments which had staff members that are "Instructional Support Technicians, "IST's) and ask for an annual inventory of their on-hand chemical stocks. Most were prompt. I had come from an IST background myself (Chemistry Department), so I already personally knew all the major players. Getting good information from Chemistry and Biology was a great advantage. Running the Hazardous Waste pickup program helped me get to know "all" of the others. Some of the smaller stashes I was able inventory by going there myself and creating a list. I was offering to help - "I'll make the list so you don't have to". At the same time I would evaluate the storage space they were using (Flammable Cabinet? Compatible Storage? Spill clean up kit nearby appropriate for chemicals present? Eyewash and/or shower present if chemical use requires? Dates of arrival/dates of opening written on labels? Other conditions I might notice...)
Each year after that I would send out a copy of the previous list and ask for significant changes (big increase in quantities or new items). What I was looking for were "Red Flag" items - peroxide formers, really aggresive oxidizers (90% H2O2 ?), things with a 4 in the yellow part of the NFPA diamond, substances with OSHA requirements, things that Homeland Security would be interested in, and so on. These "Red Flag" items are things that would have a big radar blip to anyone familiar with chemical hazards and regulations from EPA , OSHA, Fire Marshall, DHS, DOT, Fish and Game (CA) and local city issues, others I can't think of right now. I'm not sure how the campus process is working now. 2009 was the last time I had my hands on it.
There was no attempt to track, or approve/deny any chemical container that came onto the campus, because:
--> the amount of hours and paper would be ridiculously prohibitive. We would need a staff of dozens to prevent the approval process from degenerating into the same morass the Purchase Order process was.
--> the issue of SDS was addressed by requesting and getting specific approval from Cal OSHA for Cal Poly to provide access to electronic forms of safety data sheets. The deal was each lab or room where chemicals are used had to have a computer with unprotected access to the internet (no passwords, not behind a locked door). These days, every room, shop, lab on the campus had (usually many) computers like this. SDS documents are therefore available at the location where the information is needed - in the lab.
As far as "EHS being required by law" to maintain SDS records, 1910.1200(b)(3) et.seq. specifies that the "Employer" shall maintain SDS documents for access by the employees without specifying how the Employer is to do this. If your university has a requirement that EHS do this, it is a requirement placed there by an Administrative Vice President rather than "the Law".
---> at the time (mid 1990's when I was notified) our Executive vice president directed our EHS staff to function as an "on campus consultancy" (my label) rather than combing the campus for infractions and Enforcing the Rules. His position was that the Deans and Departments Heads were responsible for overseeing the work of their various staff. If they needed guidance or technical advice on how to accomplish this, EHS was there to help.
Eventually, this took a lot of the onus out of my walking into a shop or lab unannounced. Eventually, fewer people saw me as "working for the campus cops". Originally (I started in 1993) EHS was part of Public Safety, which included Fire Prevention and the Campus Police. I did have some preconceptions to smooth out. It helped when we were moved to Risk Management and the campus cops were a separate entity.
I would have been happy to have a listing of all the really dangerous chemicals (my definition) on the campus while ignoring all the "generally recognized as safe" materials. There is a GRAS list out there. It's a short one. My own GRAS list might be a bit longer. I didn't have the time or inclination to chase down every bottle of sodium chloride, sodium bicarbonate, all the phosphate salts, all the carbohydrates ...
When I did do in individual inventory of a small department, my list usually omitted things similar to these just mentioned. I concentrated on "aggressive" materials: Acid storage, alkali storage, flammable storage, strong oxidizers, notoriously toxic things, (sodium azide ?) anything with a name I didn't recognize. There is a list of about 100 chemicals in the appendix to Prudent Practices (not the whole title. If you are unfamiliar with it, get one soon). This list is their Laboratory Chemical Safety Summaries (LCSS). These materials show up **all the time** in science labs and are my main source of big "radar blips" when I'm doing a quick eyeball inventory. DHS's list of Chemicals of Interest (COI) is another good list of things to look for in an inventory, even if you don't expect to find a big enough quantity to get DHS interested.
Cal Poly has been a LQG for a long time, so inventory size vs. quantity thresholds wasn't ever part of the calculation.
I think making and maintaining an accurate, detailed, "real time" inventory of every chemical on a medium or large campus is an arduous task requiring the work of many people. If you have the staff for it, a good reason to do it, and the cooperation of the campus campus community, my hat is off to you. Your local fire brigade will applause you for it, too. My experience was one of creating something that didn't exist before, where the campus population was accustomed to just "doing their own thing" without interaction with anyone outside the department. There was a learning curve for all involved, including me. When I had meetings with our local fire department they wanted to know the location of materials in 5 gallon drums or larger (especially 55 gallon drums) and any flammable gases the campus used, AND the location of the Chemistry Department, regardless of container sizes. Chemistry Departments are a big deal with fire brigades, and I understand why.
I will only add the informed opinion that whenever anyone working on the campus, staff, faculty, or student, obtains a supply of a material they think might raise a red flag with EHS, they will keep it a secret if they can.
Monona's description of Art and Architecture are spot on.
Thanks for listening.
Part-Time Faculty Member
and CHO (Retired) Cal Poly San Luis Obispo
From: DCHAS-L Discussion List <dchas-l**At_Symbol_Here**med.cornell.edu> on behalf of paulaavila**At_Symbol_Here**COMCAST.NET <paulaavila**At_Symbol_Here**COMCAST.NET>
Sent: Saturday, August 6, 2016 4:37 AM
Subject: Re: [DCHAS-L] SDS review of chemicals to be purchased--standard practice?
It is their place to ok a chemical when you the university as a whole has exceeded the storage threshold. For some extremely hazardous chemicals it could be a pound or 454 grams. They are only ensuring that it doesn't take them over the permissible disposal quantity or the change of generation status. If the university is large and has multiple satellites and counts them towards their generation status as a whole, believe me it can matter. Most cases, they won't deny the purchases of the chemicals, but they will review it for other safety protocols. Yes, it is silly when the chemical is sodium chloride and you lab has only 5 kilograms. By you giving them the updated SDS , it shows that you are actively using the chemical and not storing it for "maybe one day in the future" we could use it.
Chemistry Lab Tech,
University of Saint Francis
Sent from XFINITY Connect Mobile App
------ Original Message ------
From: Rita Kay Calhoun
Sent: August 5, 2016 at 8:58 PM
Subject: Re: [DCHAS-L] SDS review of chemicals to be purchased--standard practice?
No, this is NOT standard procedure, nor should it be. It is certainly reasonable for them to have access to copies of the SDS for chemicals on hand, but it is not their place to ok which chemicals you order. This is what it sounds like they want to do. You are the chemistry professor and you decide which experiments you have your students do and therefore which chemicals you need. The EH&S officer is supposed to aid you, not encumber you. Don’t give in to pressure to do this. It will be counterproductive in the long run.
Morehead State University
Our EH&S officer has decided that we have to send him the SDS for every chemical we are going to purchase so that he can review it before we are allowed to purchase the chemical. Then, he wants us to send him the SDS that came with the chemical.
Is this a standard practice? I can see reviewing SDS for very hazardous substances, but even for chemicals sodium chloride and sodium bicarbonate? I can understand his reviewing the SDS for substances we've never previously used on campus. However, I think he'll drive himself (and us) crazy if he looks over every single SDS every time we make a purchase.
I fought to get the administration to allow us to make purchases with a credit card so we could make purchases shortly before we used chemicals in class. This procedure let us order smaller quantities and has helped us reduce our inventory, since we no longer had to "over purchase", just to guarantee that we would have enough material for our classes should the purchasing paperwork get held up.
Please let me know what level of EH&S scrutiny of chemical purchases is considered standard practice at undergraduate academic institutions.
I look forward to your responses.
Janet Rogers, Ph.D.
230 Scotland Road
Edinboro, PA 16444
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