Alex,

I’m sure his graduate students are smart enough to match specific chemicals to chemical class SOPs. I’m also sure that they’re human enough to perform that task with a non-zero error rate. As a compliance issue, you could argue, quite plausibly, that training on hazard recognition has met the standard. However, I expect as a general rule that regulators will use the fact of an incident as evidence that the safety system was inadequate.

I am curious, though, why this faculty member believes that requiring each student to make these determinations each time they run an experiment with a chemical they have not routinely used before is a better use of time than making all of those determinations once and leaving them in a format that can easily be referenced as needed.

Our approach to this has been to maintain an internal library of hazardous chemicals that has all of these assignments. We run each research group’s inventory against that master list, and provide them with a report showing which chemicals require an SOP, and which of our banded SOP templates applies to each.

Hope that helps!

Chris

Greetings,

One of our faculty members has brought into question the practice of identifying which chemical class SOP is used for which chemical in a lab. We tell our labs that they need to have some way for individuals to know which SOP is meant to be used for a specific chemical. For example, they can list the name of the chemical on the document or they can list the name of the SOP in their inventory list. The faculty member says that his graduate students are smart enough to just know which SOP to use based on the chemical’s hazard labels. I see this as a gap where incidents could happen – a person makes their best “guess” about which SOP to use, but it’s not the right one. Is it not a requirement to identify in some way which materials/chemicals an SOP applies to?

Your input on this is appreciated.

Regards

ALEX HAGEN, CCHO

Laboratory Safety Program Manager

fischera**At_Symbol_Here**uw.edu / www.ehs.washington.edu

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