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Date: Tue, 4 Aug 2009 13:09:29 -0400
Reply-To: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: 6 postings Re: [DCHAS-L] OSHA Lab Standard Effectiveness
From: kauletta**At_Symbol_Here**notes.cc.sunysb.edu
Date: August 4, 2009 11:45:30 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
The OSHA lab standard could use some work. I was a compliance officer
when it was 1st published & it was confusing to us then. Now that I
have to comply with it, its even more confusing. Yes, performance
standards are a better model, but they need to be clear.
And now that I'm on the other side of the compliance issue, I've found
that written programs, at least at a university, are not as important
and protective as we thought they were at OSHA. I've also found that
most PIs do not know much about OSHA nor do they give the OSHA regs
much thought or feel they need to comply with them (they think they're
for industry). What PIs do pay attention to is the granting agency
requirements - that's where the lab safety info/compliance needs to be
strengthened. The granting agencies should know that they're money is
going to a safe program. The PIs also pay attention to any
requirements for purchasing/receiving materials (eg DEA license,
alcohol permit). There should be some requirement to document/prove
you know how to handle a pyrophoric before you can use your credit
card to buy enough to kill a researcher.
my opinion only - definitely not that of my university.
Kim Auletta
Lab Safety Specialist
EH&S Z=6200
Stony Brook University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
EH&S Web site: http://www.stonybrook.edu/ehs/lab/
Remember to wash your hands!
===
From: "Dr. Jay A. Young"
Date: August 4, 2009 11:30:48 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
Neal,
I was not aware that UCLA and the lab had a CHP which satisfied Cal-
OSHA. Obviously, if in fact the CHP was any good, then it follows
that the people in charge paid little attention to its requirements.
=46rom that fact, I conclude that some way must be found to make them
(not other people in other labs who, I will assume, do pay attention
to their CHP requirements) pay attention.
And, since they are adults who did, or should have, know(n) better,
they ought to personally pay a BIG fine and/or serve a proper prison
sentence.
I don't think this requires any change in that particular OSHA
regulation. What it does cry out for is a change in the enforcement
of the OSHA regulations.
Jay
===
From: "NEAL LANGERMAN"
Date: August 4, 2009 11:44:16 AM EDT (CA)
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
I do not think that the OSHA regulations, OSHA or State OSHA
enforcement is the root cause. They clearly contribute, but the root
cause lies in the entire paradigm of safety culture within the
academic community. Administrators do not hold PIs responsible for
anything other than grants and publications; PIs only care about
productivity - Harran admitted he treated Ms. Sangji as a "student"
and thought she had publications reporting her work with reactive
materials; campus safety staff (our friends and colleagues) provide
guidance; often based on one lab visit a year. In the UCLA case,
there was a serious breakdown in the safety office - Harran
communications, because Harran was in temporary lab space and both he
and the UCLA safety office figured they could hold off resolving lab
safety until he moved into his permanent space. And finally, ACS, ACS
technical divisions, funding agencies (NSF, NIH, HHMRI, NASA, etc) pay
lip service to safety; and if the visit a lab, they are interested
primarily (exclusively) in research productivity.
Bottom line - the system is seriously broken and must be fixed.
===
From: anonymous
Sent: Tuesday, August 04, 2009 4:43 AM
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
I do have a suggestion - develop a voluntary consensus standard (VCS)
that is a stronger version of 1910.1450. Perhaps ACS, which is
considered a VSC body, would consider sponsoring a =93standard=94 on
laboratory safety. While ACS is not as prolific as ANSI, I think it
could handle it - so could the National Research Council, ANSI, AIHA,
etc. After all, Prudent Practices was used heavily in non-mandatory
Appendix B of 1910.1450. One could write a VCS that was stronger, yet
compliant with 1910.1450. There are lots of guides and best practices
out there; why not tie the right ones into a VCS? Back in the early
1990s there was so much guidance going around it was hard to choose
between them. And there=92s plenty more now, so it is not like it would
be difficult to gather background reference material.
Though not the same thing, there are many examples of OSHA adopting
VCS standards (all those in 1910.6). I think it unlikely OSHA would 1)
adopt a VCS over or in conjunction with 1910.1450 or 2) incorporate by
reference a VCS covering the lab standard. But I do not think it is
unreasonable for institutions to use a VCS that more strongly covers
1910.1450 and better protects the employees as well as the employers.
I wonder whether how many CHPs are so poorly written and implemented
that they are inadequate to protect employees, and whether if, a VCS
that directed better CHP content and implementation, would be of
interest and help to solve that problem.
So if a VCS that was stronger, yet compliant with 1910.1450 could
garner any interest, OSHA need not be involved and it would not take
any legislation. Such a document could be submitted to OSHA so they
know it is there and offer their (guarded) opinion that it meets the
requirements of 1910.1450. So if this were to happen, the choice
becomes - do the people want something more stringent or are they ok
with the way things are.
===
From: "Lawrence M Gibbs"
Date: August 4, 2009 1:01:29 PM EDT (CA)
Subject: RE: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
An interesting discussion, to say the least. I do believe that one
could enhance a laboratory safety plan by including the basis elements
of risk assessment as a requirement for laboratory protocols. I don't
believe that the OSHA lab standard will be able to be changed, or that
it should, but there is a demonstrated need to develop a process to
ensure that research faculty and researchers themselves better
understand the risk assessment process when working with hazardous
materials. This is not taught in most US colleges or universities,
either at the undergrad or graduate level. For the long term, I
believe those of us working in the academic EH&S area need to develop
a means to influence and ensure that the science laboratory
undergraduate programs and graduate programs both include elements of
hazardous materials risk assessment into the curriculum. For the
short term, we need to utilize other avenues of evaluation of PI
management performance to emphasize that research supervision and
oversight is a management responsibility of each PI. We have begun
one approach to this at Stanford, which we hope to write up for one of
the CHAS upcoming publications. We are now working with the
institution's Internal Audit folks and have completed a pilot program
where the Internal Audit program has evaluated the implementation and
management of the CHP as an element for overall evaluation of the PI's
management responsibilities. Although in its preliminary stages, this
appears to be a way to ensure the CHP is viewed as a lab safety
management program for which the PI has responsibility.
More to come on this in an upcoming issue of CHAS (if we can get the
time
to write it all up).
Larry
Lawrence M. Gibbs
Associate Vice Provost for EH&S
Stanford University
480 Oak Road
Stanford, CA 94305
lgibbs**At_Symbol_Here**stanford.edu
650.723.7403
===
From: "Harry J. Elston"
Date: August 4, 2009 11:33:15 AM EDT (CA)
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very
complete information about UCLA fatality
RE: Chemical Hygiene Committees:
Please refer to Elston's management axiom #3: When a committee is in
charge, no one is in charge.
H
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