Department of Environmental Health & Safety Washington University in St. Louis Bruce Backus, Assistant Vice Chancellor, 362-6816 backusb@msnotes.wustl.edu www.ehs.wustl.edu

Washington University in St Washington University in St. Louis Environmental Health & Safety Mission Statement Washington University is committed to conducting research, teaching and patient care in a safe and healthy environment, and to environmental stewardship. The University will: serve as a role model and community leader in these areas; continually review its impact on health, safety and the environment; seek innovative ways to prevent environmental pollution; and constantly examine its compliance with relevant legislation and regulations. Approved by the University Council, 7-1-02

EH&S Offices Biological and Chemical Safety Environmental Compliance Joe Kanabrocki, Ph.D. 747-0309 Tracy Brodt 362-6866 Protocol Review Inspections Grant Certifications Select Agents permitting Shipping Dangerous Goods Training* Environmental Compliance Linda Vishino 935-7864 Hilltop – Mike Clamors 935-4650 WUSM - Mike Kershaw 362-6735 Chemical, infectious & pathological waste disposal Emergency Spill Response Laboratory decommissioning Pollution Prevention, Recycling Underground Tanks, Air Permits, etc.

EH&S Offices General Safety / Industrial Hygiene* Radiation Safety Chris Short 362-6870 Paul Landgraf 935-5659 Accident Investigation Asbestos; Confined Space Ergonomics; Fire Safety Indoor Air Quality Exposure Monitoring Lock out/Tag out; Hearing Protection; etc. Radiation Safety Sue Langhorst, Ph.D. 362-2988 Radioactive materials Accelerator & x-ray safety Laser safety Broad Scope NRC License Delivery of Materials & Collection of Radwaste Surveys & Inspections Personnel Dosimetry Emergency Support Training/Responsibilities *Program coordinated with Risk Management/Insurance Office

Some of the Agencies Impacting Areas of EH&S Oversight Environmental Protection Agency (EPA) Occupational Health and Safety Administration (OSHA) Nuclear Regulatory Commission (NRC) National Institutes of Health (NIH) recombinant DNA (rDNA) Guidelines Centers for Disease Control and Prevention (CDC), U.S. Department of Agriculture (USDA) and Department of Justice (DOJ) Select Agent (SA) Transfer USA PATRIOT Act SA possession, management and control U.S. Department of Transportation (DOT), Federal Aviation Administration (FAA), International Air Transportation Association (IATA) - Shipping & Transporting Dangerous Goods National Fire Protection Association (NFPA) Building Officials Code Administrators (BOCA) St. Louis Metropolitan Sewer District (MSD) College of American Pathologists (CAP) Missouri Department of Natural Resources (MDNR) Alcohol, Tobacco and Firearms (ATF) Alcohol storage and use Drug Enforcement Agency (DEA) - disposal of certain regulated narcotics Department of Health and Human Services (DHHS), & local departments of health Coordinate with Infectious Disease Div. - Infection Control for WU Clinics Sanitation FBI, local law enforcement & fire departments Bioterrorism Joint Commission on the Accreditation of Healthcare Organizations (JCAHO) Environment of Care Local fire, building and health codes Federal Emergency Management Association (FEMA) - Disaster planning Granting Agencies: Department of Defense (DOD), National Science Foundation (NSF), American Heart & Lung Assoc., etc.

Federal regulatory guidance documents for the environment alone Federal regulatory guidance documents for the environment alone. Does not include state and local environmental requirements

Impacts on WU Driving EH&S Organizational Change U.S. EPA College and University Enforcement Initiative New bioterrorism legislation mandating increased security, research reagent inventories, accountability, and management oversight NIH requirements for institutions sponsoring recombinant DNA research and receiving NIH funding Increased enforcement of building and fire codes by local agencies Increased oversight by all federal, state and local regulatory agencies, e.g. CDC, DOT, EPA, FAA, MDNR, NRC, OSHA, USDA Consolidation of regulatory oversight programs (Radiation Safety, Medical School EH&S and Hilltop Environmental/Safety Services) Improved efficiencies through uniform EH&S policies, procedures and sharing of expertise It’s the right thing to do - Washington University seeks to be a leader in health, safety and environmental stewardship

Hot Topics EH&S

EPA will inspect WU Proper labeling, storage and disposal of chemicals Use hazardous waste labels on waste containers Spell out chemical names, including inert material (e.g. water) Include percentages Date! All containers/beakers labeled in laboratories, shops and maintenance areas Will assume it is hazardous waste if it can not be identified Segregate containers by hazard class Use secondary containment Keep waste containers closed No full containers or multiple containers of same waste stream Send in Request for Pickup as soon as waste container is full Store for less than one year! Expired or old shock sensitive compounds will be regarded as hazardous waste Emergency phone numbers posted; spill supplies available

Regulated Materials Recycle through EH&S Collect Unwanted computers Monitors / televisions Electronic equipment Batteries with hazardous constituents Used oil Fluorescent lamps & ballasts Transformers Mercury containing devices Refrigerators Air conditioners, etc. Collect Unreacted / unpolymerized: Adhesives Resins Caulks Solvent-based paints Solvents Aerosol spray cans with residual propellant or contents Parts washer Oils Do not evaporate, dispose in sewer drain or trash

Preparing for the EPA Visit Assign a person from every laboratory / pilot plant / shop to be a safety coordinator Supply safety coordinator names, contact numbers and email addresses to Linda Vishino, vishinol@msnotes.wustl.edu, 935-7864 Have safety coordinators attend EH&S training Use safety checklists to self-audit departments Check all cabinets and drawers Send to EH&S unwanted materials for disposal/recycling EH&S can assist with on-site inspections, but EH&S staff are spread thin preparing for anticipated visit and dealing with waste disposal

Fines and Citations Columbia University Long Island University EPA 11/02 $797,000 Long Island University $220,000 NJ City University EPA, $88,000 University of Hawaii EPA 12/02 $1.7 Million University of Missouri - Columbia $257,000 plus > $2 Million in supplemental environmental programs (SEPs)

Emergency Preparedness Spills, fires, explosions, exposures Call University Police at 935-5555 Maintain spill response supplies Chemical spill kits, fire extinguishers, safety showers and eyewashes Housekeeping Universities cited for poor housekeeping Lack of preparedness and prevention Up-to-date Chemical Hygiene Plan

Chemical Exposure Monitoring Exposure monitoring is available for all employees working with chemicals Volatile solvents and metals e.g.. Aldehydes, chlorinated solvents, etc. Anesthetic gases (e.g. animal studies) Chemical Monitoring Devices Miran Infrared Gas Analyzer Vapor Monitoring Badges (h)(3)(i) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); EH&S can help with detect chemical by visual appearance, odor detection and chemical monitoring devices

Chemical Container Labeling Chemical containers should be labeled with the following when not in their original container Full chemical name Hazard class Concentration (if applicable)

Laboratory Apparel Provide Personal Protective Equipment (PPE) Lab coat, goggles, safety glasses, face shields, protective gloves, steel-toed shoes if needed, etc. Long pants or skirts No sandals or open-toed shoes

Laser Safety Program being established Contact Dan Szatkowski, 362-3479

Roles and Responsibilities http://roles.wustl.edu/

Department of Transportation (DOT) / Federal Aviation Administration (FAA) Training required prior to shipping samples Returning chemicals to vendor Dry ice Preservatives, e.g. formalin, alcohols Any “Dangerous Good” Contact EH&S for training www.ehs.wustl.edu New ‘Security Awareness’ training & exam required

Fire Marshall Concerns Small fires and explosions Hazardous materials Equipment in egress corridors Chemical inventories for emergency response Use HazTrak database Also inventory biological agents and radioactive materials

Issues We Face Potential fines, management systems imposed by regulators, and negative public relations… Rapid implementation of programs without the luxury of time to build support and buy-in with faculty and staff Hazardous waste compliance Housekeeping/emergency preparedness, particularly in chemical, biological and radioactive material areas Training that meets EPA and OSHA requirements Security, tracking/inventories and management of extremely hazardous materials

What we need from you... Support for institutional safety and compliance efforts Share information with your peers and staff Encourage all working with hazardous materials to attend EH&S training Training schedules on web page, www.ehs.wustl.edu Implement self-audit/correction-improvement programs within your departments

Contacting Environmental Health & Safety Call EH&S at (314) 362-6816 Fax EH&S at (314) 362-1995 Web: www.ehs.wustl.edu Email EH&S at: esafety@msnotes.wustl.edu Email Bruce Backus at: backusb@msnotes.wustl.edu