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Subject:
Re: [DCHAS-L] Carpet in labs
Date:
Jun 26, 2024 15:40 UTC
Author:
Andy Glode <00001c047c05fd7f-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
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Subject:
Re: [DCHAS-L] Carpet in labs
Date:
Jun 26, 2024 16:24 UTC
Author:
Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
From:
Info <info**At_Symbol_Here**ILPI.COM>
Subject:
Re: [DCHAS-L] Carpet in labs
Date:
Jun 26, 2024 15:59 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<51F34129-CE60-4F50-A940-B2FD1358A89D**At_Symbol_Here**ilpi.com>
In-Reply-To:
<1FC969A8-842F-4DA3-AC8A-48C9BCD5EDD0**At_Symbol_Here**chem.ucla.edu>
True. I zeroed in on the recalcitrant demand to cite regulations and the blatant disregard for university policy. So my response was based on the impression the nice guy approaches had already been tried and failed. Certainly, one should always try to act as a partner (as Andy also pointed out) and it’s better to build bridges. I should have thought to preface my response with that and then presented the rest with “if all else fails”, thanks.
The cost sharing offer is a good idea. And how do you clean up after a safety shower release in that space - if it even has one, as Andy’s post also covered. Or even a simple spill?
Rob
On Jun 26, 2024, at 11:31 AM, Craig Merlic <merlic**At_Symbol_Here**CHEM.UCLA.EDU> wrote:
Alex,
Rather than playing hardball and upsetting everyone, this can also be an opportunity for collaboration to show how EH&S can both identify and solve issues.
Saying “will not prioritize” is another way of saying that they do not see a huge cost benefit up front. And given the usual tight budgets and inability to use say a federal research project grant on flooring it all comes down to cost. Assuming the lab is 1000 sf and an epoxy treatment or high quality linoleum is about $10 per sf, we are looking at a sizable $10,000 project. So can EH&S chip in $3333 and ask for matches from the Department and Dean? You can use some of Rob’s reasoning, but in a positive way to justify the expenditure.
Best,
Craig
Craig A. Merlic
Professor of Chemistry, UCLA Department of Chemistry and Biochemistry
Executive Director, UC Center for Laboratory Safety
Los Angeles, CA 90095-1569
The Laboratory Standard, 29 CFR 1910.1450 mandates a Chemical Hygiene Plan (CHP), and your CHP, while locally produced, is required under OSHA regs. And your Chemical Hygiene Officer (CHO), is *required* by the Lab Standard to provide the technical guidance to implement that plan, which they are refusing to do. And since you’ve tried nicely, now it’s time to play hardball.
Send these morons an email and cc everyone up your org chart to the presidents’s office, but *especially* the legal/risk management department, and use the exact words “appears to be a willful violation of OSHA regulation 29 CFR 1910.1450” (as well as University policy) and that you recommend all laboratory operations in the space be barred until the situation is rectified. Sometimes you have to be the Safety Nazi, so be it. The words “willful violation” should strike fear into the legal team as they open up the institution to triple penalties when cited, and it also puts in (discoverable) writing a potential liability that, if not acted upon, could be damning.
If you like overkill, get the local fire marshal involved. Invite them to come do an inspection and then poke them to think about the potential fire hazard of a highly flammable substance with a foam rubber backing (which produces thick toxic smoke when burned) covering the floor where a flammable material fire is already a significant hazard and risk.
We have a lab in our radiology department that stores and uses chemicals in space with carpeting. They have also conducted lead soldering in that space in the past. We state in our laboratory safety manual that carpet is not allowed in labs and we have noted this issue on all of their inspection reports, but they have said that they will not prioritize this unless there is a state or federal regulation that we can point to. We have explained that the manual is an institutional policy document, but that doesn’t seem to mean much to them. Does anyone here know of a regulation that specifically addresses this issue?
