CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Collaborative Collaborative

Laboratory Laboratory

Inspection Inspection

Program at UNC Program at UNC

Chapel Hill-Ten Chapel Hill-Ten

Years LaterYears LaterJonathan Moore, MS, CHP, Associate RSOJonathan Moore, MS, CHP, Associate RSO

Dept. of Environment, Health & SafetyDept. of Environment, Health & Safety

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Presentation OutlinePresentation Outline

Brief Description of CLIPBrief Description of CLIP Key IndicatorsKey Indicators Standards / RegulationsStandards / Regulations Violations / SeverityViolations / Severity Assessment of Inspection ResultsAssessment of Inspection Results Future EHS Inspection IssuesFuture EHS Inspection Issues

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

What is CLIP?What is CLIP?

CCollaborativeollaborative

LLaboratoryaboratory

IInspectionnspection

PProgramrogram

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Strategic Planning Process-1997Strategic Planning Process-1997

Internal/External Customer SurveyInternal/External Customer Survey EHS RetreatsEHS Retreats Quality TeamsQuality Teams Organizational Changes/ProgramsOrganizational Changes/Programs

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Scope of CLIP ProgramScope of CLIP Program

80-90 inspections per month80-90 inspections per month

Comprehensive environment, health and Comprehensive environment, health and safety inspection done on all laboratories safety inspection done on all laboratories annually (462 total laboratories)annually (462 total laboratories)

Every principal investigator is considered to Every principal investigator is considered to have one laboratory, which may consist of have one laboratory, which may consist of several rooms.several rooms.

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Scope of CLIP ProgramScope of CLIP Program

Radiation laboratories (249 as of Radiation laboratories (249 as of June 2007) quarterly or semiannuallyJune 2007) quarterly or semiannually

Focus on radiation safetyFocus on radiation safety

GM and swipe surveys for removableGM and swipe surveys for removablecontaminationcontamination

Annual physical inventory for Annual physical inventory for radioactive materialradioactive material

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

UNC BENCHMARKSUNC BENCHMARKS

19981998 EHS StaffEHS Staff 38 38 Radioactive Materials UsersRadioactive Materials Users 278 278

Biological Safety CabinetsBiological Safety Cabinets 391 391 Research IncomeResearch Income $290M $290M Michael JordanMichael Jordan $100M $100M

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

What is a What is a CLIPper?CLIPper?

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

EHS Safety Officers (CLIPpers)EHS Safety Officers (CLIPpers)

Four from radiation safety sectionFour from radiation safety section

Two from fire safety and emergency response Two from fire safety and emergency response sectionsection

Two from the industrial hygiene and biological Two from the industrial hygiene and biological safety sectionsafety section

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

CLIP Team Leader DutiesCLIP Team Leader Duties

Assign inspectors by rotation. Assign inspectors by rotation. Each lab is inspected by Each lab is inspected by different inspectors.different inspectors.

Prior to inspection, print Prior to inspection, print contamination survey map contamination survey map and pre-inspection checklistand pre-inspection checklist

After inspection, review checklist and principal investigator After inspection, review checklist and principal investigator letter for accuracy, then forward to front officeletter for accuracy, then forward to front office.

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

CLIP Team Leader DutiesCLIP Team Leader Duties Conduct quarterly CLIP meetingsConduct quarterly CLIP meetings

Handle comments and questionsHandle comments and questions

Track inspection report responses, if requiredTrack inspection report responses, if required

Review written responses for adequacyReview written responses for adequacy

If a required response is not received, suspend privileges If a required response is not received, suspend privileges for ordering radioactive materialsfor ordering radioactive materials

Update survey contamination mapsUpdate survey contamination maps

Close inspection in HASMIS when responses are adequateClose inspection in HASMIS when responses are adequate

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Inspector Cross TrainingInspector Cross Training

All inspectors are required to learn all aspects of the comprehensive EHS inspection through:

Reading policies and proceduresReading policies and procedures

On-the-job training by shadowing inspections with the CLIP On-the-job training by shadowing inspections with the CLIP Team Leader and at least one safety officer from each EHS Team Leader and at least one safety officer from each EHS disciplinediscipline

Learn to use HASMIS database and how to enter data from Learn to use HASMIS database and how to enter data from written procedureswritten procedures

Attend quarterly CLIP meetingsAttend quarterly CLIP meetings

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Strategic Planning Process After 1997Strategic Planning Process After 1997 Utilization of the HASMIS database Utilization of the HASMIS database Continuing Quarterly CLIP meetingsContinuing Quarterly CLIP meetings Performance evaluation of Safety Officer –”Tag-a-Performance evaluation of Safety Officer –”Tag-a-

Longs”Longs” Expansion of Biological Safety Lab inspectionsExpansion of Biological Safety Lab inspections

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

UNC BENCHMARKSUNC BENCHMARKS

19981998 20062006 EHS StaffEHS Staff 3838 4242 Radioactive Materials UsersRadioactive Materials Users 278 278 249 249 Biological Safety CabinetsBiological Safety Cabinets 391 391 433 433 Research IncomeResearch Income $290M $290M $593M $593M Michael JordanMichael Jordan $100M $100M $32M $32M

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Standards / Regulations 2007Standards / Regulations 2007Increased focused on the following since 1998Increased focused on the following since 1998

OSHA Bloodborne StandardOSHA Bloodborne Standard

CDC/NIH’s Biosafety in Microbiological and CDC/NIH’s Biosafety in Microbiological and Biomedical Laboratories (4Biomedical Laboratories (4thth Edition) Edition)

New since 1998New since 1998

Export ControlsExport Controls

Enhanced Security Measures for Certain Enhanced Security Measures for Certain Radioactive MaterialsRadioactive Materials

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

UNC LAB ENVIRONMENTUNC LAB ENVIRONMENT

19981998 20062006 Radioactive Materials UsersRadioactive Materials Users 278278 249249 Biological Safety Level 1Biological Safety Level 1 121121 127127 Biological Safety Level 2Biological Safety Level 2 52 52 186186 Biological Safety Level 3Biological Safety Level 3 6 6 13 13 Total # Principal Investigators Total # Principal Investigators 423423 462462 Total # Laboratory WorkersTotal # Laboratory Workers 2, 0772, 077 3,4863,486

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Key IndicatorsKey Indicators RecordsRecords

Personal Protective EquipmentPersonal Protective Equipment

Chemical StorageChemical Storage

Hazardous WasteHazardous Waste

Laboratory FacilitiesLaboratory Facilities

Life / Fire SafetyLife / Fire Safety

General Lab SafetyGeneral Lab Safety

Biological safetyBiological safety

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Laboratory FacilitiesLaboratory Facilities

Chemical HoodsChemical Hoods

Pertinent Information included Pertinent Information included

on pre-inspection info sheeton pre-inspection info sheet

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Fire/Life SafetyFire/Life Safety

Fire Prevention and Fire Prevention and Detection EquipmentDetection Equipment

CLIPpers trained on CLIPpers trained on

annual checks of fire annual checks of fire extinguishersextinguishers

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Biological SafetyBiological Safety Infectious Waste handling/processingInfectious Waste handling/processing Bloodborne Pathogens standard enforcement Bloodborne Pathogens standard enforcement

(training, Hep B vaccination, etc)(training, Hep B vaccination, etc) Recombinant DNA protocol verificationRecombinant DNA protocol verification Sharps precautions/minimizationSharps precautions/minimization Biosafety Level 2 containmentBiosafety Level 2 containment

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Laboratory Safety ViolationsLaboratory Safety ViolationsDe minimisExample: observe lack of personal Example: observe lack of personal protective equipment when it is protective equipment when it is appropriateappropriate

Non-seriousExample: Omitted monthly self-Example: Omitted monthly self-survey for removable contaminationsurvey for removable contamination

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Laboratory Safety ViolationsLaboratory Safety ViolationsSeriousExample: No lid or label on a Example: No lid or label on a hazardous waste containerhazardous waste container

Safety Officers have discretion to judge any violation as serious due to special circumstances.

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Overall CLIP Assessment CriteriaOverall CLIP Assessment CriteriaLab

(Non-Radiation)Lab

With Radiation

Outstanding No violations for two inspections in a row

ExcellentNo violations or1 de minimis violation

No violations or< 5 de minimis violation

Good1 non serious and/or5 or < de minimis

< 5 non serious and/or5 or > de minimis

PoorAny repeat violation and/or5 or > de minimis

Any repeat violation and/or5 or > Non Serious

Unacceptable Any serious violation Loss of radioactive material

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

What has not workedWhat has not worked

Use of tablet PC for data collection during lab Use of tablet PC for data collection during lab inspectionsinspections

Single Assessment of Laboratory SafetySingle Assessment of Laboratory Safety

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Future EHS Inspection IssuesFuture EHS Inspection Issues

Better enforcement of EHS rules in non-Better enforcement of EHS rules in non-radioactive laboratories who do not correct radioactive laboratories who do not correct serious violations or do not respond when serious violations or do not respond when required.required.

CLIPper’s participating in the UNC planned CLIPper’s participating in the UNC planned EPA Self-Audit.EPA Self-Audit.

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

SummarySummary

““Front line” of EHSFront line” of EHS Less distraction in labs by EHSLess distraction in labs by EHS Increase Safety Awareness Increase Safety Awareness All laboratories Inspected at least annuallyAll laboratories Inspected at least annually Optimum Utilization of staffOptimum Utilization of staff

CSHEMA 2007, BOSTON, MA

CLIP AT UNC CHAPEL HILL-TEN YEARS LATER

Questions?Questions?Jonathan Moore

Department of Environment, Health & Safety

University of North Carolina

1120 Estes Drive Extension CB# 1650

Chapel Hill, NC 27517-4440

http://ehs.unc.edu

jdmoore@ehs.unc.edu

919-962-5713