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