department/unit safety coordinator’s seminar
DESCRIPTION
Department/Unit Safety Coordinator’s Seminar. Enterprise Risk Services/Environmental Health & SafetyTuesday, December 3, 2013. Agenda: 10:05 – 10:25 How to Prepare for Regulatory Visits (Lance Jones, Dan Kermoyan, EH&S) - PowerPoint PPT PresentationTRANSCRIPT
Department/Unit Safety Coordinator’s Seminar
Enterprise Risk Services/Environmental Health & SafetyTuesday, December 3, 2013
Agenda: 10:05 – 10:25 How to Prepare for Regulatory Visits (Lance Jones, Dan Kermoyan, EH&S) 10:25 – 10:55 Laboratory Safety Program Overview (Dan Kermoyan, EH&S)
OSU Laboratory Categories (LCAT) Laboratory Safety Assessments Campus SOPs
10:55 – 11:00 Q & A ** 10-Minute Break **
11:00 – 11:30 Regulatory Compliance Issues (Lance Jones, Pete Schoonover, Andy Kenst, Matt Philpott, Brian Lilley, EH&S)
Is your Chemical Inventory up to date? Are your chemicals and wastes labeled and stored
safely? Does your laboratory have a chemical hygiene plan? Have your employees received training? Autoclaves, Eyewash-Shower testing
11:30 – 11:40 Waste minimization/recycling program (Kent Lanning, EH&S) 11:40 – 11:45 Safety Data Sheets (SDS) Resource (Lance Jones, EH&S) 11:45 – 11:55 Laboratory Safety & Haz Waste Training (Matt Philpott, Lance Jones, EH&S) 11:55 – 12:00 Q & A; Future topics?
How to Prepare for Regulatory Visits
Lance Jones, Dan Kermoyan, EH&S
Potential Regulatory Agencies visiting the OSU campus
Federal
• EPA: Hazardous waste; Environmental
• DOT: Shipping; Transportation
• NIH/CDC: Recombinant DNA/Select agents
• DHS: Chemicals of Interest• APHIS: Plants, recombinant
work
State• DEQ: Hazardous waste;
Environmental• OR-OSHA: Enforcement or
Consultation• Oregon Health Authority:
Public Health; Drinking water; Radiation
• OR Dept. of Agriculture: Waste discharge; Disease prevention; Food
Potential Regulatory Agencies visiting the OSU campus
County Agencies• County Health: Public
Health/Sanitation/Disease reporting
• County Env. Health: Water systems/Waste disposal
City Agencies• Public Works: Waste
water/Storm water• Corvallis Fire: Fire
prevention inspections
What Occurs During an Inspection? 1. Unannounced
– Injury; Incident; Complaint; Scheduled
2. Opening interview: ID, Why, What3. Program review4. Site visit5. Performance-based review (observations,
photos, review training records, review procedures, conduct interviews)
6. Closure and summary
Department/Unit Response
Contact EH&SLimit conversation to what is directly
requestedQ: “Have you received training on SDS’?”
– A1: “Yes” or “No”– A2: “Yes, but I don’t know where they are…”– A3: “No and no one has ever offered training to
me…”
Department/Unit Response
“Calm confidence” approach “Interested compliance” attitude If in doubt, ok to get back to them on an issue OK to take:
Duplicate photos Split samples Notes
Inspection results will take awhile Review notes with department and EH&S soon as
possible
OR-OSHA Violations
Classification types:Serious violation – substantial probability of serious physical harm to employee.Other than seriousMinimal – no direct or immediate impact to health and safety of employee.
Penalties assessed:Serious: $300 - $7,000
Other than Serious or Minimal: $0 - $300
Can adjust downward for history, good faith effort, & immediate action.
EPA Hazardous Waste violations Waste label not properly
filled out, incomplete information
Hazardous waste training Open waste containers Spillage or leakage of waste
(including contamination on the container)
Failure to determine waste as hazardous (e.g. it is clearly waste like but there is no waste label)
RCRA: Administrative, Civil, or Criminal Actions•Compliance Action•Corrective Action (release to environment)•Imminent & Substantial Endangerment•$5,500 - $27,500 per day, per violation
•Criminal Actions: $50,000 - $250,00 per day, per violation
EPA Hazardous Waste fines
• April 2003 - A private college in Long Island, NY was fined $112,310.
• October 2003 - A private university in upstate NY was fined $60,500.
RCRA violations
Failure to determine if the wastes generated were hazardous wastes;
Failure to separate incompatible wastes.
EPA Hazardous Waste fines
• July 2003 – Medical school in New Jersey was fined $166,658.
Failure to determine if the wastes generated were hazardous wastes.
Failure to maintain the facilities to minimize the risk of releases of hazardous waste to the environment; did not ensure that its facility and staff received required training
Failure to keep waste containers closed; and improperly disposed of hazardous wastes, such as solvents and mercury wastes.
University of Hawaii
EPA hazardous waste violations in October 1997 at the University of Hawaii:•$1.7 Million settlement; $1.2 Million towards environmental projects; received settlement in 2001.•Inspectors found improperly stored and labeled chemicals including flammables, corrosives, poisons, mercury and hundreds of other unknown chemicals. •The Department of Health continued to inspect other facilities within the university system and found similar violations at
– Kauai Agricultural Center – Waiakea Agricultural Experiment Station in Hilo
What will they see? The Good
The Bad
The Ugly
Questions?
Laboratory Safety Program Overview
Dan Kermoyan, EH&S
Lab Safety Program: Identifying Needs
• Fallacy: compliance = 0 risk, OSHA << EPA
• Regulatory agencies• Observations/Knowledge of programs• Discussions with campus
• ISO 14001 Analytical Model
• Quantify, Rank, Prioritize• 2009/2010
Vulnerability Analysis compliance vs. risk
OSHA << EPA
Risk Identification & Analysis• Most new employees are not
enrolled in a health & safety training program; new employee health & safety training is not mandatory.
• Probability x Magnitude• Impacts: Human, Facilities,
Institutional
• HIGH Risk rank; Scored 14.2
Prioritization/Mitigation Plan• Health & Safety Training
Required for all Faculty & Staff: All faculty, staff, and student employees to obtain health & safety training according their job roles. Training shall be documented and kept on file with the supervisor and employee.
Vulnerability Analysis
Risk Identification & Analysis
• Safety equipment testing is sporadic and not funded; emergency eyewash/showers, air balancing of fume hoods and room air, etc.
• Probability x Magnitude• Impacts: Human, Facilities,
Institutional
• HIGH Risk rank; Scored 14.2
Prioritization/Mitigation Plan
• Preventative Maintenance Budget for Building Safety Equipment: Fund PM program for testing and repair of building safety equipment: Emergency eyewash and showers, fume hoods, biosafety cabinets, and air balancing.
Vulnerability Analysis
Risk Identification & Analysis
• No formal lab safety audit program is occurring.
• Probability x Magnitude• Impacts: Human, Facilities,
Institutional
• HIGH Risk rank; Scored 15.8
Prioritization/Mitigation Plan• Work-place Health & Safety
Audits: Supervisors to conduct annual self-audit of work areas and work practices under their control. EH&S to conduct routine audits of work areas based on a priority, hazard level designation. Corrective actions to be implemented by the supervisor or university.
Addressing the Vulnerabilities
Training modules, Safety Instructions, Web resources
EHSA data base/Qualtrics
Equipment testing program
Lab Safety Assessments
Policy/SOP development
Health & Safety Training Required
Training shall be documented
Emergency eyewash and showers, fume hoods, biosafety cabinets
Work-place Health & Safety Audits
Laboratory Policy/SOPs
Lab Categories (LCAT)
• “Laboratory” defined• Planning’s data: 1,100 spaces• Planning + EHS data: 1,618 spaces• Grouped according to materials used/stored• Assigned an assessment frequency
LCAT1 LCAT2 LCAT3 LCAT4 TBD Grand Total68 73 233 669 575 1618
Laboratory Safety Assessments
For 1,100 spaceso50% follow up anticipatedoConsolidated auditsoEfficiencies/software exploredo5.2 FTE
For 1,618 spaceso7.7 FTE
EH&S to start with LCAT 4 spacesAssigning spaces nowWill start with Gilbert HallResource-based/Pre-notice February 1st or soonerSelf-Audits will be needed
Enterprise Risk Services │ Environmental Health & Safety
Laboratory Safety Assessment form; revised 11/2013
Date: PI/Lab Contact:
Assessment Completed by:
Room: Department: Action Needed Comments
1Lab Hazard / Contact Information sign is current, accurate, and clearly posted at entrance(s)
2OSU Laboratory Safety Quick-Reference Guide posted in a visible location near entrance(s)
3Areas requiring specific personal protective equipment, training, clearance, etc., posted
4 "In Case of Emergency" Poster displayed5 Chemical Hygiene Plan available in lab
6Lab-specific Standard Operating Procedures (SOPs) available in lab
7 Safety Data Sheet (SDS) information accessible
8 Chemical Inventory recorded into EHS database
9No Food or Drink in areas where hazardous substances are used or stored
Action Needed Comments
10Workers have completed Laboratory Safety Training
11Workers have completed Hazardous Waste training
12Workers have completed Safety Data Sheet (SDS) training
13Workers have completed Fire Extinguisher training
14 ALL training is documented for each employee Action Needed Comments
15Chemical fume hood(s) survey current; air flow is adequate; sash position markedFume hoods are used with sash in appropriate positionFume hood vents (baffles) unobstructedOther local exhaust devices (e.g. gas cabinets, snorkel hoods) functional
17 Water aspirators have functional traps18 Fire alarm pull stations unobstructed19 Building fire extinguishers unobstructed
20Eyewash and safety showers available and unobstructed
21Eyewash and Emergency Shower tested regularly
22 Autoclave available, tested regularly
23BioSafety Cabinet present / located & used appropriately / certified
24 Spill control materials available and adequate Action Needed Comments
25Appropriate clothing (no shorts or open toed shoes) worn by all in lab
26Appropriate PPE (i.e. lab coats, nitrile gloves, safety glasses, etc.) used as necessaryRespirator use:
a. Users enrolled in respiratory protection programb. Appropriate respirator & cartridge usedc. Respirators and cartridges stored properly
Action Needed Comments
28Flexible cords not cracked/frayed/run under doors, rugs, etc.
29Power strips plugged directly into an outlet (not chained together)
30No improvised electrical devices in use (space heaters, fans)
31Circuit breaker panels unobstructed (30" clearance)
32Drying ovens are posted with safety procedures on front of the oven
Action Needed Comments
33Chemical Inventory recorded into EHS database reflects actual storage in lab
34Containers clearly labeled with chemical name(s) and hazard rating (HMIS or NFPA)
35Containers compatible with the chemical; Container integrity maintained
36 Chemicals segregated to avoid incompatibilities
37 Chemical's shelf-life not expired38 Containers kept closed except during transfers
39Secondary containers prvided for storage of solvents and concentrated acids or bases
40Secondary containers used during transportation of all hazardous chemicals
41Secondary containers used during storage of all hazardous chemicals on the floor; No glass storage containers permitted on floor
42 Chemical storage cabinets properly labeled
43Chemical storage shelves equipped with a restraint lip or other system
44Flammable and combustible liquids exceeding ten (10) gallons are stored inside an approved flammable storage cabinet.
45Refrigeration units approved for flammables storage
46Flammables separated from oxidizers, acids, bases
47Highly toxic gases stored in ventilated gas cabinet
48 Limit storage in actively used fume hoods49 Gas cylinders secured; caps on; tubing labeled
Action Needed Comments
50Container contents with "hazardous waste", chemical name(s) and concentration or %
51Containers sealed except during additions or removal
52Containers compatible with waste and in good condition
53Primary containers stored within secondary containment
54Sharps and biohazardous waste disposal appropriate
55Segregation / decontamination of potentially infectious wastes
56Drain disposal is safe and allowed per local limits
Additional Recommendations / Observations:
Report sent to Lab Contact Follow-up Needed within 7 / 30 / 60 days
Actions Needed have been satisfied
Chemical Storage
Laboratory Safety Assessment
Electrical Hazards / Fire Safety
Building:
27
16
Information / Postings
Equipment
Personal Protective Equipment (PPE)
Employee Training
Waste Disposal
Campus Policies/SOPs“Wait-on” (2 policies)1) Campus Department Safety
Coordinators (DUSC)Maintains chemical inventories, proper labeling of chemicals and wastes, maintains training records for their lab staff, and conducts yearly self-audits.
2) Campus Laboratory Safety Committee (LSC)–Issues Chemical Use Authorizations. –Conducts auditing of OSU’s Laboratory Safety Program and reviews safety assessment results.
“Green light” (5 policies)
1) Lab Categorization and Laboratory Assessments
2) Annual Chemical Inventories
3) Chemical Hygiene Plan4) Authority to Abate
“Hazardous Conditions”5) Mandatory Lab Safety
Training for all PIs and staff
Questions?
10-Minute Break