UC Regents Agreement Impacts: Lab Safety Requirements & Training

Impacts of UC Regents Agreement with LA District Attorney and Cal OSHA Settlement only dismisses charges against Regents Four year Agreement with Annual Reporting/Audit Identify all UC Chemistry and Biochemistry Labs Regents acknowledge responsibility for conditions with the laboratory was operated on December 29, 2008. Establish a Sheharbano Sangji Scholarship at UC Berkeley Law endowed for $500,000. Pay Cal/OSHA investigation costs not to exceed $50,000 Hard Deadlines for Chemistry, but requirements are for everyone - and if something happens in another lab

Impacts of UC Regents Agreement with LA District Attorney and Cal OSHA (cont.) Mandatory Lab Safety Manual Mandatory Lab Safety Training Mandatory Written SOPs Required Procedures/training/PPE for Pyrophorics Enhanced Reporting Requirements Increased CalOSHA Scrutiny UCOP will assist with Centralized Resources (Powers of 10) Funding solutions and coordinating Campus efforts UCSD Chemical Hazard Use Authorization (CHUA) Databanks for SOPs, Training, etc.

Laboratory Safety Manual and CHP Each campus must maintain a formal Laboratory Safety Manual Chemical Hygiene Plan Must Include all applicable Title 8 regulations Manuals must be provided/maintained in each lab within 60 days of agreement Electronic copies are acceptable UCSC is Developing an on-line Safety Manual Will include revised CHP plus expanded information beyond Slug Binder. EH&S will roll out to labs within the next few months Some items may be kept in the Lab SOPs, Inspection, Correction and Training Documentation incorporated as needed by specific lab Biosafety, Rad Safety, Laser Safety and other existing manuals will be incorporated as needed as well as SOPs

Lab Safety Training Lab Safety Training policy nearing final approval On-line Training for Everyone to Complete & Pass the Test Additional Discussion Sections, Refresher and Function- specific Training will be required as needed/determined PIs will receive additional Roles and Responsibilities Briefing Robust E-Course Fast-tracked for Development Upon approval, outline and PowerPoint will be provided to conduct in-person training to commence training within 60 day time period (for Chemistry to meet deadline) Online version expected to be completed this Fall with soft roll-out UCSC combo E-Course/ILT starting early 2013 Test/assessment will be required for completion, whether in-person or online

Mandatory Written SOPs SOP approval required for 10 categories of chemicals totaling ~500 substances (per LADA Agreement Exhibit 1) SOPs must be reviewed by qualified personnel and lab specific procedures reviewed/authorized by PI PI and all lab personnel must sign SOP acknowledging the contents, requirements, responsibilities outlined in SOP SOP amendment subject to PI approval Electronic copies acceptable if readily accessible to laboratory personnel with documentation of PI authorization and researcher review (e-commons likely distribution/documentation mechanism)

Pyrophorics All locations must have written procedures, but at a minimum follow UCLA policy UCSC adopted the UC System guidance document on air sensitive materials as template Edit with lab s specific use procedures and PI Authorization Review and sign Prior to Using Pyrophorics Ensure proper procedures and PPE are used Proper PPE includes Nomex lab coat and Nomex pilots gloves, plus other means as necessary or appropriate PPE Assessment must take place prior to use

Personal Protective Equipment PPE policy in Final Approval Process Many Campus reps put in many hours (including PhD Chemists, ACS/DCHAS Reps, Certified CHO, etc.) Initial review included UC Faculty Senate Assessment Procedures to determine level of PPE Labs and Technical Areas where hazardous chemicals are used and stored will require Shoes, Pants, Lab Coat and Eyewear plus gloves as appropriate to material/process Location specific not just when using specific hazardous chemical Not popular but the law, UC Policy and PI responsibility

Inspections, Corrections and Escalation System-wide Lab Audit/inspection tool under development Enhanced documentation accessibility/accountability up through Chancellor Escalation procedure for non-compliance/failure to correct issues Compliance status of PI and lab rolls up to Chancellor s Report Card External Review/Audit of Compliance and Safe Practices

Enhanced Reporting Requirement PIs required to immediately notify EHS/CalOSHA of reportable injuries Serious injuries: Death, amputation, disfigurement, hospitalization over 24 hours or if unsure Immediately contact Campus Dispatch and ask for EH&S if EH&S is unavailable, then PI Must contact CalOSHA Director immediately (within 4 hours) Call: (510) 286-7013 E-mail: dgold@dir.ca.gov Secured incident scene required for 24 hours for Cal/OSHA to respond (Possible inspection by CalOSHA Enforcement and Bureau of Investigation) Must still report to Local CalOSHA Office within 8 hours

More to Come As more information is available PIs and LSRs will receive updates to inform researchers Info on implementation of Training and PPE Policies E-Procedures for developing & maintaining SOPs Info and procedures for accessing mandatory Lab Safety Training and LMS resources Centralized CHUA and Chemical Inventory systems Lessons Learned, Research Safety Seminars and Cultural Opportunities via Centers for Excellence