Hi Hugo,

My experience is focus on the basics.  Implement a Management of Change (MOC) Program.  Perform a baseline risk assessment.  Require the departments that if any deviations are made from that baseline, e.g., introduce a new chemical into a new space, a requirement should exist to specify what specifically, how much, how it will be used, when, etc., and include if the departments want to make building modifications, e.g., are permits required, any risks elevated, if so, how do they plan on controlling, etc. 

Different types of occupancies within the same structure can introduce multiple hazards that could affect more than any individual occupant’s potential exposure, but in the case noted below, the risk is shared by the same institution – along with the liability. 

Best practice: Obtain all specific information from each Department Head, when you have obtained ALL relevant information and determined the overall risk, coordinate the risk with each department and elevate to their (and your next higher level of management), apply the hierarchy of controls and document!  In my experience, the higher authority having power will specify limits when necessary if your advice/limitations are not followed.  If not, the department head will know you’ve covered all your bases.  Eliminate plausible deniability and only settle on accountability. 

Any others?

BruceV

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