EHS Issues in Academic Research Labs Mary Corrigan Associate Director Harvard University Environmental Health Safety 617-496-4746 mary_corrigan@harvard.edu

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

Conducting good science includes conducting science safely

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.

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

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

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

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

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

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)

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

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

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

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

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

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.

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

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

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 email of incomplete training Lab specific/SOP/equipment safety/PPE training must be provided locally http://ehs.harvard.edu/training

Know the emergency procedures at your location(s)

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

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.

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.

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.

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

The death of a microbiologist Case Study The death of a microbiologist

The death of an undergraduate Case Study The death of an undergraduate

Case study Students Experience Eye Injuries After Lab

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

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.

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…

…or your Harvard affiliate EHS Office EHS: Here to help Environmental Health Safety & Department http://ehs.harvard.edu/laboratories Mary Corrigan 617.496.4746 mary_corrigan@harvard.edu …or your Harvard affiliate EHS Office