1. EHS Issues in Academic Research Labs
Mary Corrigan
Associate Director
Harvard University
Environmental Health Safety

2. Objectives
Understand potential consequences of unsafe practices in academic labs
Highlight major regulations affecting academic research labs
Recognize Roles & Responsibilities for Safety
Identify EHS tools, resources, and types of services
Discuss case studies
Make suggestions about safety culture

3. Conducting good science includes conducting science safely

4. Risks from Laboratory Incidents
Health and safety of laboratory occupants
Liability – researcher and University
Civil
Criminal (focus on the PI)
Regulatory
University policy – fines are the responsibility of the department or laboratory
Reputational – University and personal
The most important risk is to the health and safety of lab workers, but there is also reputational risk, regulatory risk (and remember, you pay those fines) and liability. The PI in the UCLA incident is still awaiting a decision on indictment on criminal charges and the family has filed a civil suit. We’ve seen civil suits here at Princeton, too. And even worse, imagine having to explain to the parent of a 22-year-old in your lab why their son or daughter is severely injured when it could have been prevented.

5. Federal Regulations Occupational Safety & Health Administration
(Lab Safety, Blood borne Pathogens, Personal Protective Equipment Standards)
CDC Guidelines for Microbiological and Biomedical Research Labs
NIH Guidelines for rDNA Molecules
CDC/USDA Select Agents
DEA Controlled Substances
DHS Chemical Facility Anti-Terrorism Standard
Nuclear Regulatory Commission (Radioactive Material, Irradiator Security)
USDA Permits
EPA- Clean Air Act, Toxic Substances Control Act
DOT/IATA regulations affecting “dangerous goods” shipping

6. Regulated Materials=Dangerous Goods= Hazardous Materials
DOT/IATA regulated materials include:
Dry Ice
Infectious materials (including some BL1 organisms)
Regulated medical/biological waste
Liquid Nitrogen
Chemicals, e.g. ethanol
Lithium ion batteries
3/16/2011

7. Training is REQUIRED to ship regulated materials
If you ship regulated materials, you must take additional training that includes:
Classifying, packaging, labeling, and documentation for the specific material you are shipping
Contact the EH&S Office to schedule additional training
Exam required
Certificate issued by employer
Checked luggage and carry on are considered shipping!
3/16/2011

8. Massachusetts Regulations
Biological Waste and “Sharps disposal
Hazardous chemical waste disposal
Environmental compliance & emissions reporting (air, water, waste)
Registration of Class IIIb and IV lasers
Controlled and prescription drugs

9. Boston and Cambridge Requirements
Cambridge rDNA Technology Ordinance
BFD Lab Registration Ordinance/ Annual inspections
Boston Fire Protection Order: Lab inventory and hazard placarding
Biological Lab Ordinance : permitting & occupational illness reporting (BPHC)
Flame spread testing of installations
Nanotechnology, under consideration

10. Guidelines & Best Practices
NIH Guidelines for the Use of rDNA
CDC Biosafety in Microbiological and Biomedical Laboratories
National Fire Protection Association (NFPA)-use of flammables in labs
Grant agency requirements (e.g. Safety Plan for Department of Defense)

11. Everyone has responsibility for lab safety
Environmental Safety & Compliance Officer
Department Chairs
Department Administrators/Research Operations Managers
Principal Investigator/Faculty
Environmental Health & Safety Department
All researchers, staff, and students
Note: Harvard affiliates may have different organization structures

12. Institutional Safety Programs
Institutional/Responsible Official
Know the EHS officer at your lab
Check on local training and orientation requirements
Personal Protective Equipment
Medical surveillance
Oversight committees vary by location
Know the local policies

13. Principal Investigator/ Faculty
The PI is the person principally responsible for compliance in the lab
Ensures that conditions meet all program and regulatory requirements
Delegate the role to a Safety Coordinator

14. Lab Safety Coordinator
Assist PI in carrying out his/her responsibilities
Serve as point of contact for Program issues in the lab
Ensure training, safety documentation, safety equipment, procedures

15. Researcher Responsibilities
Obtain information and understand hazards of the materials & equipment used in your research
Properly use engineering controls (fume hood, biosafety cabinets), PPE, and other safeguards to protect yourself
Follow regulatory requirements & policies
Register protocols with Committees (COMS, RSC) & follow stipulations
Know what to do in an emergency

16. Minimizing Risks Risk Assessment: Training
EHS provides general training
Required for EVERY person in the lab – faculty, staff, graduate students, post-docs, visiting researchers
Lab must provide chemical or procedure-specific training
DOCUMENT the training
Document safety procedures (SOPs)
PPE Assessments and appropriate use
So what can we do about this? Training is key. EHS provides general training and it’s your responsibility to make sure that everyone in your lab attends it. But the lab needs to provide training on the chemicals, procedures, emergency equipment and risks in your lab and this training needs to be documented. EHS has a tool to help with that.

17. EHS Topical Areas Biological Safety rDNA Radiation Safety
Chemical Safety
Fire Safety
Environmental Compliance
Emergency Response
Pest Control
Public Health/Food
Occupational Safety
Construction Safety
Waste compliance
Noise & Air Monitoring
Industrial Hygiene

18. Lab Safety Support from EHS
Training
Inspections
Regulatory Liaison
Technical Consultations
Lab Waste disposal oversight
Regulatory submittals & documentation
SOPs for of hazardous materials in research animals
Hazard Assessment Tools
Regulatory Documentation Templates
Registration of rDNA
Use of hazardous materials in research animals
Emergency Planning
Emergency Response
Evaluation of experiment/material/hazard
Review of Hazardous Waste Satellite Accumulation Areas
Fire Drills
EHS/Sustainability efforts
Compliance sampling for waste water
Laser & Irradiator Safety
Information sharing/Fact Sheets/ Regulatory Updates
Respirator Fit-testing

19. Training
Specific training based on requirements is assigned by Training Manager
Lab members are added to roster to access (mostly online) training
PI will receive of incomplete training
Lab specific/SOP/equipment safety/PPE training must be provided locally

20. Know the emergency procedures at your location(s)

21. Trends in Laboratory Safety
Increased regulatory scrutiny
Recent national incidents are prompting more attention at colleges and universities
OSHA is considering need for new regulations
US Chemical Safety Review Board has tasked American Chemical Society with studying
Granting agency- greater safety emphasis

24. UCLA research assistant “Sheri” Sangji dies from lab fire
Began at UCLA two months earlier.
In December, she worked with a bottle of t-butyl lithium (pyrophoric) dissolved in pentane, wearing nitrile gloves, safety glasses rather than goggles and a synthetic sweater with no lab coat.
Drawing ~20 mL of the material into a 60-mL syringe the syringe plunger was ejected or pulled out of the syringe. Liquid splashed, igniting into flames and impacted her hands, arms and torso.

25. RESULT
California/OSHA issued findings critical of UCLA's lab safety inspection follow-up, training and record-keeping programs and its failure to ensure the use of personal protective equipment and fined the campus $31,875.
California/OSHA - lack of a lab coat was the single most significant factor in the severity of the burns that led to death.
PI faces trial for 4 felony charges.

27. Injuries
On June 28, 2010, an explosion caused by hydrogen gas in a University of Missouri biochemistry research lab injured four researchers and destroyed the laboratory.
Texas Tech University graduate student was working to synthesize and characterize an energetic material (nickel hydrazine perchlorate) when an explosion occurred. Brown lost three digits on his left hand, severely lacerated his right hand, perforated his left eye, scratched his right eye and had superficial cuts to the parts of his body that were exposed.

28. CSB INCIDENT ANALYSIS
Reason, J. Human error: models and management. British Medical Journal, 320, 2000;

29. The death of a microbiologist
Case Study
The death of a microbiologist

30. The death of an undergraduate
Case Study
The death of an undergraduate

31. Case study
Students Experience Eye Injuries After Lab

32. National Academy of Science Committee:
“Promoting a Culture of Safety in Academic Lab Research”

33. Establishing and Promoting a Culture of Safety in Academic Laboratory Research
Open (Public) Session
We ask that each of you prepare some brief remarks to orient the Committee to your position to share some thoughts regarding your perspective and the university’s culture of safety in research laboratories.
Please consider commenting on any limitations or barriers you see to creating or maintaining a culture of safety and highlighting any particular successes or successful approaches within your institution or lab.

34. Participant Feedback Workload leads to short-cuts
Blanket approaches are not relevant, don’t work, are ignored
Design for safety
Better awareness
Inspections (Enforce and Encourage)
Make PPE & safety equipment readily available
The Leadership (“everyone higher”) must follow the safety procedures, wear the PPE, long pants, shoes, etc…

35. …or your Harvard affiliate EHS Office
EHS: Here to help
Environmental Health Safety & Department
Mary Corrigan
…or your Harvard affiliate EHS Office