staying in compliance - overview of regulatory challenges
TRANSCRIPT
Navigating Safety-Related Compliance
Karen Gillis, MS, CBSPAssoc. Director, Research ServicesUF Division of Environmental Health & Safety TEL: [email protected]
Why safety compliance matters
• Loss of reputation (institution, PI)
• Loss of funding (lab, Dept., institution)
• Legal action
• Civil or criminal penalties
• Fines
Risks to doing the work or science !
More importantly…..Risks to people
Lapses?
Sheri Sangji, Lab Research Assistant, Harran labUCLA, 2009
� Died 2.5 weeks after severe burns
� Accident during transfer of
pyrophoric chemical
� No lab coat, insufficient training
� First criminal case from a lab
accident
� UCLA paid >$4.5 million in legal
fees
PI Responsibilities◦ Facilitate open dialog on safety
◦ Do risk assessments
◦ Ensure all get sufficient training
◦ Lead by example
◦ Discuss safety aspects of their work in funding proposals, lab meetings, conferences, etc
◦ Discuss lessons learned
◦ Assume ultimate responsibility for safety in your area
How does EHS know when you’re in compliance?
� Satisfactory inspections
� No issues with regulatory agencies
� No complaints
� No incidents/accidents
Compliance Check Points
� EHS-Ufirst: Award Compliance form
� EHS-OTL: MTAs
� EHS-IACUC: protocol approval
� EHS-Purchasing: Purchase of certain
equipment or hazardous materials
Dr. William ProperzioDirector, EH&S
Computational Support & Reception
Fiscal Support
Associate Director
Research Services
Associate DirectorFacility Support Services
Associate DirectorOccupational Safety &
Risk Management
Biosafety
Radiation Control
HazardousMaterials
Management
Laboratory Safety
Building Codes
Fire Code Enforcement
Fire Equipment Services
Pest Control
Americans with Disabilities Programs
Industrial Hygiene
Occupational Medicine
Training Support
Insurance Programs
Risk Management
Dive Safety
EHS = Safety in the work, teaching, clinical, & research environment
Gator TRACS
Web Portal• Lab’s safety “dashboard”
• Lab members (roster)
• All member’s training
• Lists all hazards in the lab &
hazard mitigation plans
(“LATCH”)
• Lab Inspection Results (with
photos!)
• Email reminders
• Portable device friendly
Key Areas for Biosafety Compliance
� Register biohazard use projects with EHS◦ A subset will go to the Institutional Biosafety
Committee (IBC) for approval◦ Update these annually
� Get any State or Federal permits needed, read & comply with permit requirements, send Biosafety a copy, keep permit up to date
� Know how to dispose of biological waste� Get training on shipment of biohazards
Key areas for Laboratory Safety Compliance
� Each lab needs lab-specific Chemical Hygiene Plan or “LATCH” …. fundamental
� Keep the chemical inventory up to date –ChemTracker Program
� Store & label chemicals safely� Manage chemical waste properly� Register projects/work involving Minors in labs
(Science Fair, summer camp programs, etc)
Key Points: Pesticide Use� Medical Surveillance Program:
◦ All users of Toxicity Class I (Danger or Poison Label)
◦ Frequency of more than 4 days per month and volume greater than 16 fl. oz.
◦ Cholinesterase baseline (for OPs and carbamates)
◦ Medical Monitoring/testing – initial, periodic, & exit
◦ Applicators medically cleared for respirator
� Annual training & fit testing
� Include material in the Chemical Hygiene Plan/LATCH
� Track quantities in ChemTracker
� PPE & Training required
Other IFAS-relevant areas:� UAS (Drones) [email protected]
◦ FAA license, register drone w/ FAA & EHS, Register all flights w/ EHS
� Hearing Conservation - initial & annual audiograms
� Forklift training
� 15-Passenger van training
� Heat stress training
� Tractor safety
� Radioactive Material Use Authorization
� Laser / X-ray System Registration
� Etc…..
New PI?