Transforming the Culture of Safety at the University of...

Transforming the Culture of Safety at the

University of California

October 31, 2012

University of Texas Higher Education Chemical Safety Best Practices

Ken Smith CIH CHP RRPT

UC Office of the President, Laboratory Safety Manager

11/5/2012 Transforming Safety Culture at UC 1

Agenda

• Experimenting with Danger

• The UC Agreement

– Training

– PPE

– SOPs

• The Courage to Lead.


File://Files\Documents\UCOP\Video

http://www.youtube.com/watch?v=cg161rd7_1c

Experimenting with Danger


//Files/Documents/UCOP/Video









Statement of Facts

• For purposes of the Agreement, Regents do not dispute the following:

– Regents had not adequately trained Ms. Sangji

– Regents did not require appropriate PPE

– Regents did not establish SOPs for transferring pyrophoric agents

– Regents have implemented a comprehensive training and safety program at UCLA

– Regents have made a substantial and good faith effort to bring lab safety practices into compliance with Title 8


Common Questions

• Why did the Regents agree to a settlement?

• Who was involved in the negotiations?

• The accident occurred at UCLA, so why are all campuses required to comply with the settlement requirements?

• How does the settlement requirements compare to what Cal/OSHA currently requires?


Why did the Regents agree to a settlement?

• “The effect of a criminal conviction would negatively impact the University of California as a whole…., and many thousands of students, employees, and indirectly, the public, including potentially debarment, loss of funding, loss of licenses and exclusion from areas of research vital to public health, public safety, and national security.” (Executed agreement page 2, line 24)


Who was involved in the negotiations?

• Legal Team – Charlie Robinson – UCOP, Vice President and General Counsel for Legal Affairs – Karen Petrulakis – UCOP, Deputy General Counsel Litigation, Labor Employment , and Governance – Kevin Reed - UCLA, Vice Chancellor, Legal Affairs – Norm Hamill – UCOP, Senior Counsel – Craig Moyer - Manatt, Phelps & Phillips LLP – Nancy Whang - Manatt, Phelps & Phillips LLP – Truc Do - Munger, Tolles & Olson LLP

• Advisory Workgroup

– Nancy Wayne – UCLA, Associate Vice Chancellor for Research, Laboratory Safety – James Gibson – UCLA, EHS Director – Patrick Schlesinger – UCB, AVC Research Administration and Compliance – Fiona M. Doyle – UCB, Professor of Mineral Engineering and Past Chair of UCB Academic Senate – James Nowick – UCI, Professor of Chemistry – Petros Yiannikouros – UCLA, Chemical Hygiene Officer – Erike Young – UCOP, EHS Director – Dallas Rubenstein – UCR, Professor of Chemistry, Provost and Executive Vice Chancellor – Michael Pirrung – UCR, Distinguished Professor of Chemistry – David Vandenberg – UCSB, Laboratory Safety Program Manager – Marianne Generales – UCSD, AVC Research – Ken Smith – UCSD, Research Safety Division Manager – David Gardner – UCSF, Professor, School of Medicine – Bob Eaton – UCSF, EHS Director


The accident occurred at UCLA, so why are all campuses required to comply with the

settlement requirements?

• The criminal charges were filed against the UC Regents as the employer.

• “The effect of a criminal conviction would negatively impact the University of California as a whole…., and many thousands of students, employees, and indirectly, the public, including potentially debarment, loss of funding, loss of licenses and exclusion from areas of research vital to public health, public safety, and national security.” (Executed agreement page 2, line 24)


How does the settlement requirements compare to what Cal/OSHA currently

requires?

• Title 8 of the California Code of Regulations (“8 CCR”) applies systemwide to all Laboratory operations.

• The Agreement adds enhanced requirements for:

– SOP approval and documentation

– Serious injury reporting


Long Term Goal: Creating a Culture of Safety

• Since October 2010, 65 lab incidents have occurred resulting in 136 injuries and 2 deaths (Chemical Safety Board Incident Database).

• ACS and other institutions have identified the need to improve laboratory safety practices in Academic Institutions.

• Beyond the settlement requirements is the need to Integrate safety into research operations and curriculum


Leadership Commitment to Safety

• July 27, 2012 Settlement Agreement reached between the People of the State of California and the Regents of the University of California.

• August 3, 2012 UC-wide letter from Provost Aimee Dorr.

• August 28, 2012 letter from Vice President Steve Beckwith.

• Working collaboratively with Academic Senate.


Integrated Safety


Figure 1: Integration of Hazards Analysis with the Scientific Method © American Chemical Society, Washington, DC

TRAINING


Information and Training

• Laboratory workers must be provided with information and training relevant to the hazards of the chemicals present in their laboratory.

• The training must be provided at the time of initial assignment to a laboratory and prior to assignments involving new exposure situations.


Proposed Systemwide Policy on Training Currently under Review

• Proposed Systemwide Training Policy: Laboratory Safety Training Policy

• Submitted for OP review June 2012. – under adoption review

• Establishes: – Training needs assessment – Laboratory Safety Training

• Laboratory Safety Fundamentals • Site-Specific Safety Orientation • Hazard-Specific Safety Training

– Training Documentation

• Applies to all research areas and all faculty, staff, volunteer, or visitor/visiting scholars.


Training

Safety Training New (Existing) PI Training • Roles and Responsibilities relating

to Health and Safety at each of these stages: – General Administrative

– Preparation of Scientific Proposal

– Proposal Budget

– Protocol Preparation and Review

– Award Acceptance (Terms and Conditions)

– Conduct of Research

– Serious Adverse Events

– Reporting

– Project Closeout

Laboratory Safety Fundamentals

SOP Training (In Lab)

Hazard Specific Safety Training

Work assignment / access may now be granted Laboratory Area

Work with Higher Risk Agent May be granted.

Laboratory Site Safety Orientation


NAS Workshop Report Aug 2012

• Why are US (UC) Chemistry graduates not a preferred new hire choice by companies?

– DOW Chemical Outreach to UC

– Sigma-Aldrich

– Risk Assessment Tool


STANDARD OPERATING PROCEDURES (SOP)


SOPs

• While the term SOP is used in different contexts, it appears that most guidance documents and the Laboratory Standard itself establish a tiered system of controls for hazardous chemicals when used in the laboratory.

1st tier

• The first tier is the highest and broadest control. It is described in the Chemical Hygiene Plan (CHP) and includes a list of instructions that all laboratory personnel need to follow when working with laboratory scale hazardous chemicals.

• These statements are universal, covering all chemicals.

2nd tier.

• The second tier of instructions is a stricter control that is narrower in its scope but still usually found in the Chemical Hygiene plan. 2nd tier controls are only applicable to a hazard class of chemicals (materials sharing a common hazardous physical property; reactivity property or a common health hazard.) These instructions may describe that hazard and when it could become a risk. The 2nd tier instructions may provide requirements for additional engineering controls (e.g. fume hoods), administrative controls (e.g. chemical degradation testing procedures) and/or additional PPE (e.g. face shields) that need to be followed when working with that chemical family.

• Only some of the hazard classes or chemical families have 2nd tier instructions. Most do not.

3rd tier

• The third tier of controls is a specific set of detailed instructions that are particular to a list of chemical reagents used in an experiment. The 3rd tier includes detailed information about the amount of chemicals used and the specific properties of those chemicals. It lists the health and safety information about those chemicals such as warning signs and symptoms of exposure. At the 3rd tier, an experimental process is described that typically designates the work area where the experiment may be performed. It describes the equipment to be used, and the experimental process, and the exact engineering, administrative and PPE controls to be followed when working with the material. Individuals who perform this activity may require prior approval before doing so.

• There is a stated set of criteria that define what experiments (procedures and/or chemicals) trigger this 3rd tier. It is only a defined subset of chemicals for which this third level is performed.

UC Laboratory Safety

Phase 1

Settlement Obligations

Phase 2

“Culture of Safety”


ucsop.com

free RADiCAL

free RADiCAL

free Risk Assessment Determinations in Chemical Academic Laboratories


free RADiCAL

An SOP to Enable Safe Science

The Elevator Pitch

• For researchers • who work with chemicals • “RADiCAL” • is a Chemical Risk Management Tool • that quickly determines banded safety operating

parameters or if a detailed SOP is needed. • Unlike static safety data sheet (SDS) our project is

research environment-centric and communicates pertinent information to the researcher so they can safely conduct an experiment (SOP).


PPE


Proposed Systemwide Policy on PPE Currently Under Review

• Proposed Systemwide Training Policy: PPE Policy

• Submitted for OP review June 2012. – under adoption review

• Establishes: – Perform Hazard Assessment – Identify Required PPE

• Minimum PPE Requirements – Training – Maintenance and Replacement – Evaluating the Appropriateness of Identified

PPE

• Applies to all research areas and all faculty, staff, volunteer, or visitor/visiting scholars.


UC Proposed PPE policy

• For workers: – Perform Hazard Assessment – Identify Required PPE – Training – Maintenance and Replacement – Evaluating the Appropriateness of Identified PPE

• Worker: For purposes of this policy, a worker is an individual who

actively performs work functions with hazardous materials or equipment in a laboratory/technical area. A “worker” may be faculty, staff, student volunteer assisting in a non-academic class, or visitor/visiting scholar. For the purpose of this definition, “worker” excludes individuals who only passively participate in tours, lectures, conferences, etc.


UC Proposed PPE policy

Minimum Personal Protective Equipment Requirements for Laboratories/Technical Areas

• When occupying a Laboratory/Technical Area

– Full length pants, or equivalent, and closed toe/heel shoe attire must be worn at all times

– Protective eyewear must be worn at all times

• When working with or adjacent (within 2 meters) to hazardous material use areas within a Laboratory/Technical Area

– Laboratory coats, or equivalent protective garments

• Laboratory coats must be appropriately sized for the worker

• Flame Resistant (FR-rated) laboratory coats must be worn when working with any amount of pyrophoric materials or quantities of flammable liquids as described in the hazard assessment.

• Campuses are responsible for providing suitable laundry services to maintain required laboratory coats.

• When working directly with or handling hazardous materials

– Protective gloves must be worn while using any hazardous materials, hot or cold liquids (including cryogenics) or objects that pose a risk of thermal burns, items having physical hazards, or equipment that may cause hand injury.


Control Band - PPE


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Would a systemwide funding mechanism be of help?

FR

Hazardous Materials & Operations

• Ensure that staff: – Wear appropriate PPE

– Are trained & competent

– Follow SOPs

• Fix hazards immediately – Contact EH&S if you

need assistance.


What’s wrong with this picture?

Leading our Safety Culture

• Questions?

• Challenges?

• Ideas?


Transforming the Culture of Safety at the University of...

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