4.0 Administrative Controls (Top)
Administrative controls include policies and procedures that result in providing proper guidance for safe laboratory work practices and set the standard for behavior within the laboratory. Once developed, administrative controls must be implemented and adhered to by all personnel working in the laboratory.
Colleges and departments are responsible for developing policies and written guidelines to ensure laboratory workers are protected against exposure to hazardous chemicals as outlined in the OSHA Laboratory Standard and physical hazards that may be present, including the development of a written Chemical Hygiene Plan or adoption of this Laboratory Safety Manual.
It is the responsibility of the Principal Investigator and laboratory supervisor to ensure that personnel working in laboratories under their supervision are informed and follow laboratory specific, departmental, and campus wide policies and procedures related to laboratory safety – such as the guidelines and requirements covered in this Laboratory Safety Manual.
***In addition to meeting regulatory requirements identified within this Laboratory Safety Manual, colleges and departments are strongly encouraged to incorporate the recommendations and guidelines identified within this manual. While this Laboratory Safety Manual provides the minimum requirements and recommendations to meet the intent of the OSHA Laboratory Standard, colleges, departments, Principal Investigators, and laboratory supervisors have the authority to implement more stringent policies within laboratories under their supervision and are encouraged to do so.
4.1 Standard Operating Procedures (Top)
The OSHA Laboratory Standard requires that Chemical Hygiene Plans include specific elements and measures to ensure employee protection in the laboratory. One such requirement is Standard Operating Procedures (SOPs) “relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals.”
SOPs can be stand-alone documents or supplemental information included as part of research notebooks, experiment documentation, or research proposals. The requirement for SOPs is to ensure a process is in place to document and addresses relevant health and safety issues as part of every experiment.
At a minimum, SOPs should include details such as:
- The chemicals involved and their hazards.
- Special hazards and circumstances.
- Use of engineering controls (such as fume hoods).
- Required PPE.
- Spill response measures.
- Waste disposal procedures.
- Decontamination procedures.
- Description of how to perform the experiment or operation.
While the OSHA Laboratory Standard specifies the requirement for SOPs for work involving hazardous chemicals, laboratories should also develop SOPs for use with any piece of equipment or operation that may pose any physical hazards. Examples include:
- Safe use and considerations of LASERSs.
- Use of cryogenic liquids and fill procedures.
- Connecting regulators to gas cylinders and cylinder change outs.
- Use of equipment with high voltage.
SOPs do not need to be lengthy dissertations and it is perfectly acceptable to point laboratory personnel to other sources of information. Some examples of what to include as part of SOPs are:
“To use this piece of equipment, see page 4 in the operator’s manual (located in file cabinet #4).” “The chemical and physical hazards of this chemical can be found in the SDS – located in the SDS binder. Read the SDS before using this chemical.” “When using chemical X, wear safety goggles, nitrile gloves, and a lab coat.”
EH&S can assist laboratories with developing general and specific SOPs. Due to the variety of research and the large number of laboratories on the Cornell campus, it is the responsibility of each laboratory, department and college to ensure that SOPs are developed and the practices and procedures are adequate to protect lab workers who use hazardous chemicals.
It is the responsibility of the Principal Investigator and laboratory supervisor to ensure written SOPs incorporating health and safety considerations are developed for work involving the use of hazardous chemicals in laboratories under their supervision and that PPE and engineering controls are adequate to prevent overexposure. In addition, Principal Investigators and laboratory supervisors must ensure that personnel working in laboratories under their supervision have been trained on those SOPs.
Examples of Standard Operating Procedures and blank SOP templates include:
4.2 Form 10 (Top)
The Office of Sponsored Programs (OSP) administers awards for sponsored research, instruction, and extension projects at Cornell. The Form 10 is the internal academic approval form for sponsored programs. The form should be completed by the Principal Investigator and submitted with all proposals. Of particular note for laboratory personnel, compliance certifications are required for the following areas:
- Human Subjects
- Animal Use
- Recombinant DNA
- Genetically Modified Organisms
- Biological Agents and Toxins
- Hazardous Materials
As part of the Form 10 process, EH&S will be notified upon submittal of the Form 10 to OSP when one or more of the following compliance items have been checked: animals, rDNA, GMOs, radiation, hazardous materials, or biological agents or toxins. Once EH&S receives the Form 10, staff members within EH&S will contact the Principal Investigator listed to discuss general aspects of the grant proposal and to ensure health and safety aspects have been taken into account. During the review process, EH&S staff members will identify any special issues that may need to be addressed to ensure compliance with state or federal regulatory requirements.
More information can be obtained from the Office of Sponsored Programs website – Form 10: Internal Academic Approval of Sponsored Programs.
4.3 Procedural Controls (Top)
Procedural controls incorporate best management practices for working in a laboratory. These practices serve not only to protect the health and safety of personnel, but are a common sense way of increasing productivity in a laboratory. Through implementation of good practices, laboratories can expect an increase in the efficient use of valuable lab space, in the reliability of experiments due to less potential contamination, and an increase in the awareness of health and safety issues by laboratory personnel. Following the practices outlined in this Lab Safety Manual should also result in a decrease in the number of accidents, injuries, and spills. This will result in a decrease in the overall liability for the Principal Investigator, laboratory supervisor, and the University. Procedural controls are fundamental to instilling safe work behaviors and helping to create a culture of safety within the laboratory environment.
4.4 Housekeeping (Top)
Housekeeping refers to the general condition and appearance of a laboratory and includes:
- Keeping all areas of the lab free of clutter, trash, extraneous equipment, and unused chemical containers. Areas within the lab that should be addressed include benches, hoods, refrigerators, cabinets, chemical storage cabinets, sinks, trash cans, etc.
- Keep all containers of chemicals closed when not in use.
- Cleaning up all chemicals spills immediately, regardless if the chemical is hazardous or not. When cleaning up a chemical spill, look for any splashes that may have resulted on nearby equipment, cabinets, doors, and counter tops. For more information on cleaning up spills, see the Chemical Spill Procedures section.
- Keeping areas around emergency equipment and devices clean and free of clutter. This includes items such as eyewash/emergency showers, electric power panels, fire extinguishers, and spill cleanup supplies.
- Keeping a minimum of three feet of clearance (as required by fire codes) between benches and equipment. Exits must be clear of obstacles and tripping hazards such as bottles, boxes, equipment, electric cords, etc. Combustible materials may not be stored in exits (including corridors and stairways), exit enclosures, boiler rooms, mechanical rooms, or electrical equipment rooms.
- When storing items overhead, keep heavier and bulkier items closer to the floor. New York State (NYS) Building Code prohibits the storage of combustible material (such as paper, boxes, plastics, etc.) within 24" of the ceiling in unsprinklered rooms. In sprinklered rooms, All storage, including both combustible and non-combustible materials, must be kept at least 18” below the level of the sprinkler head deflectors to ensure that fire sprinkler coverage is not impeded.
- Always use a stepladder when reaching for overhead items, do not stand on chairs or countertops. If you do not have a stepladder available, then contact your Building Coordinator.
In summary, good housekeeping has obvious health and safety benefits and can have a positive mental effect on laboratory personnel who work in a clean environment, which can lead to increased productivity. Also keep in mind that during an inspection by a state or federal regulatory agency, the general condition of the laboratory observed in the first few minutes of the inspection (the housekeeping of the lab) can have a significant impact (positive or negative) on the rest of the inspection process.
It is the responsibility of Principal Investigators and laboratory supervisors to ensure laboratories under their supervision are maintained in a clean and orderly manner and personnel working in the lab practice good housekeeping.
4.5 Personal Hygiene (Top)
Good chemical hygiene practices include the use of personal protective equipment (PPE) and good personal hygiene habits. Although PPE can offer a barrier of protection against chemicals and biological materials, good personal hygiene habits are essential to prevent chemical exposure, even when using PPE.
Some general guidelines that should always be followed include:
- Do not eat, drink, chew gum, or apply cosmetics in a lab or other area where chemicals are used.
- Do not store food or drink in refrigerators that are used to store chemicals.
- Do not ever try starting a siphon or pipette by mouth, doing so can result in ingestion of chemicals or inhalation of chemical vapors. Always use a pipette aid or suction bulb to start a siphon.
- Always confine long hair, loose clothing, and jewelry.
- Wear a lab coat when working with hazardous materials.
- Shorts and sandals should not be worn in a lab when anyone is using corrosives or other chemicals that present a skin contact hazard or where the potential for physical hazards such as dropping pieces of equipment or broken glass are present.
- Remove laboratory coats, gloves, and other PPE immediately when chemical contamination occurs. Failure to do so could result in chemical exposure.
- After removing contaminated PPE, be sure to wash any affected skin areas with soap and water for at least 15 minutes.
- Always remove lab coats, scrubs, gloves, and other PPE before leaving the lab. Do not wear lab coats, scrubs, or other PPE (especially gloves) in areas outside the lab, particularly not in areas where food and drink are served, or other public areas.
- Always wash hands with soap and water after removing gloves and before leaving the lab or using items such as the phone, turning doorknobs, or using an elevator.
- Always wash lab coats separately from personal clothing. Be sure to identify contaminated lab coats to commercial laundry facilities to help protect their workers by placing the contaminated lab coat in a separate plastic bag and clearly identifying the bag with a note or label indicating the lab coat is contaminated.
- Smoking is prohibited in all lab areas at Cornell.
4.6 Eating, Drinking, and Applying Cosmetics in the Lab (Top)
Chemical exposure can occur through ingestion of food or drink contaminated with chemicals. This type of contamination can occur when food or drinks are brought into a lab or when food or drinks are stored in refrigerators, freezers, or cabinets with chemicals. When this occurs, it is possible for the food or drink to absorb chemical vapors and thus lead to a chemical exposure when the food or drink is consumed. Eating or drinking in areas exposed to toxic materials is prohibited by the OSHA Sanitation Standard, 29 CFR 1910.141(g)(2).
A similar principle of potential chemical exposure holds true with regard to the application of cosmetics (make-up, hand lotion, etc.) in a laboratory setting when hazardous chemicals are being used. In this instance, the cosmetics have the ability of absorbing chemical vapors, dusts, and mists from the air and when applied to the skin and result in skin exposure to chemicals.
To prevent exposure to hazardous chemicals through ingestion, do not eat, drink, chew gum, or apply cosmetics in areas where hazardous chemicals are used.
Wash your hands thoroughly after using any chemicals or other laboratory materials, even if you were wearing gloves, and especially before eating or drinking.
To help promote awareness, refrigerators and freezers should be properly labeled:
- Refrigerators for the storage of food should be labeled, “Food Only, No Chemicals” or “No Chemicals or Samples”.
- Refrigerators used for the storage of chemicals should be labeled “Chemicals Only, No Food”.
Free refrigerator labels are available from the EH&S Signs and Labels webpage.
Keep in mind that some chemical exposure can result in immediate effects (acute exposure) while other effects may not be seen for some time despite repeated exposure (chronic exposure). Consuming food or drink or applying cosmetics in the lab can result in both types of exposure.
4.7 Working Alone (Top)
Whenever possible, laboratory personnel should avoid working alone when conducting research, especially when experiments involve hazardous substances and procedures. Laboratories should establish specific guidelines and standard operating procedures specifying when working alone is not allowed and develop notification procedures when working alone occurs. All work to be performed by someone working alone, and the monitoring system that is established, must be approved in advance by the Principal Investigator or laboratory supervisor. Check with your DSR to see if your department has specific requirements for working alone.
If a laboratory person determines it is necessary to work alone, consideration should be given to notifying someone else in the area – in an adjacent room, another lab on the same floor, or a lab on a different floor. It is recommended that a “buddy system” be established for regular, routine checks on personnel working alone, such as every 15 – 30 minutes, to ensure no accidents have occurred. This could be accomplished by physically walking to the room where the lab worker is or through the use of a phone. If the person working alone is doing highly hazardous work, then the person checking on the lab worker should not enter same room. A system of visual checks should be established to indicate there are no problems or to determine if help is needed.
In the event of an emergency that requires the buddy to leave prior to the completion of an experiment involving highly hazardous chemicals, the buddy should notify Cornell Police at 607-255-1111 of the name, location, and end time of the experiment involved. The buddy should also notify the person conducting the experiment. The person conducting the experiment should make an effort to complete the experiment in a safe manner and notify Cornell Police upon completion of the experiment. Under no circumstances should the Cornell Police be used in place of a “lab buddy” as this will seriously undermine the safety of all involved.
Please note: For rooms that are locked due to security needs, prior arrangements are required to allow the designated buddy access. However, please be aware that the University does not have a standardized keying system and the EH&S Emergency Responders and Cornell Police may not always have immediate access to locked doors - which could result in a delay in response in the event of an emergency. Also understand that if the door to the lab does not have a window, or if the window is covered, then there is a chance that if something happened to a person working alone in a locked lab, then they may not be discovered until someone else from the lab goes into the room (which could be a day or more).
Examples of activities where working alone would be permissible include:
- Office work such as writing papers, calculations, computer work, and reading.
- Housekeeping activities such as general cleaning, reorganization of supplies or equipment, etc., as long as no moving of large quantities of chemicals is involved.
- Assembly or modification of laboratory apparatus when no chemical, electrical, or other physical hazards are present.
- Routine lab functions which are part of a standard operating procedure which has been demonstrated to be safe and not involve hazardous materials.
Examples of activities where working using a “buddy system” should be considered include:
- Experiments involving toxic or otherwise hazardous chemicals, especially poison inhalation hazards.
- Experiments involving high-pressure equipment.
- Experiments involving large quantities of cryogenic materials.
- Experiments involving work with unstable (explosives) materials.
- Experiments involving Class 3b or 4 Lasers.
- Transfer of large quantities of flammable materials, acids, bases, and other hazardous materials.
- Changing out compressed gas cylinders containing hazardous materials.
It is the responsibility of Principal Investigators and laboratory supervisors to ensure procedures for working alone are developed and followed by personnel working in laboratories under their supervision.
4.8 Phones in Labs (Top)
All labs are strongly recommended to have a means of communication in the event of an emergency. This can include a phone or cell phone (if service is available) or two-way radio within the lab or access to a central phone located in the hallway. If a phone is not available within the lab, it is advisable to post a sign and/or map indicating where the nearest phone is located.
4.9 Unattended Operations (Top)
Whenever it is necessary to have unattended operations occurring in a lab, it is important to ensure safeguards are put into place in the event of an emergency. Laboratory personnel are strongly encouraged to adhere to the following guidelines when it is necessary to carry out unattended operations.
For unattended operations involving highly hazardous materials, a light should be left on and an appropriate warning/explanation sign should be placed on the laboratory door, or in a conspicuous place that could be easily seen without putting someone else in danger in the event of an emergency. The warning sign should list the following information:
- The nature of the experiment in progress.
- The chemicals in use.
- Hazards present (electrical, heat, etc.)
- The name of the person conducting the experiment and a contact number. A secondary name and contact number is also recommended.
When setting up an experiment that will be left unattended, try to take into account potential incidents that could occur if something went wrong. For example:
- Use secondary containment such as trays to contain any spills that may occur.
- Use safety shields and keep the chemical hood sash down low to contain chemicals and glass in case an explosion occurs.
- Remove any chemicals or equipment that are not necessary for the experiment or items that could potentially react with the chemicals or other materials being used in the experiment.
- Whenever possible, use automatic shutoff devices to prevent accidents such as loss of cooling water shutoff, over-temperature shut off, etc.
- Use emergency power outlets for those pieces of equipment that could be negatively affected in the event electric service or other city utilities are interrupted.
It is the responsibility of Principal Investigators and laboratory supervisors to ensure procedures for unattended operations are developed and followed by personnel working in laboratories under their supervision.
4.10 Access to Laboratories (Top)
Access to Cornell University laboratories, workshops and other work areas housing hazardous materials or machinery is restricted to Cornell faculty, staff, students, or other persons on official business.
It is the responsibility of the Department Chairperson, Principal Investigators, and laboratory supervisors to restrict access of visitors, children and volunteers to areas under their supervision when potential health and physical hazards exist.
Due to the potential hazards and liability issues, other persons, in particular children under the age of 16 are not permitted in hazardous work areas, with the exception of University-sanctioned activity, e.g., tours, open houses, or other University related business as authorized by the Principal Investigator or laboratory supervisor. In these instances, all children under the age of 16 must be under careful and continuous supervision. Check with your DSR to see if your department has specific procedures or policies in place for visitors.
There are potential risks associated with allowing access to labs and equipment by visiting scientists. These risks include: theft or questions of ownership for intellectual property, bodily injury, and property damage. Colleges and units should verify that all users of the lab have the required safety and health training
prior to allowing access to the lab and/or specialized equipment. It is the user’s responsibility to have or obtain the appropriate training. Units are advised to consult with the University’s Office of Risk Management and Insurance
and/or Office of University Counsel
to obtain contracts and agreements to minimize risks associated with the use of labs and equipment by visiting scientists and others.
The Cornell University Policy 2.8 – Pets on Campus
, specifically states that pets are prohibited “from university-controlled buildings, except for those animals that are specifically exempted by this policy. In addition, while on university-controlled property, animals must be attended and restrained at all times.
4.11 Chemical Purchasing (Top)
Before ordering new chemicals, search your existing inventories and use those chemicals currently in stock. An accurate and up-to-date chemical inventory can help to minimize purchase of chemicals already on hand and can facilitate acquisition of Safety Data Sheets (SDS). Cornell has an institutional subscription to the Vertere chemical inventory system that can help facilitate maintaining a chemical inventory. If you are interested in learning more about the Vertere system, then contact the EH&S Chemical Inventory contact or call EH&S at 607-255-8200.
If it is necessary to purchase new chemicals, laboratory personnel should order the smallest size necessary to carry out the experiment. Avoid ordering extra quantities because the chemical “might be needed in the future”. Try to take advantage of chemical vendors “Just-In-Time” delivery rather than stockpiling chemicals in your lab. Before ordering chemicals, be sure to check Cornell purchasing guidelines for preferred vendors and pricing.
Some chemical purchases may require special approval or permits, such as those chemicals that are Drug Enforcement Agency (DEA) or Alcohol, Tobacco, and Firearms (ATF) listed substances, select agents (contact the Biosafety Officer at EH&S for more information), or particularly hazardous substances. There are also building and fire codes that restrict the amount of flammable materials that can be stored in any one room, floors, and buildings at a time. For more information, contact EH&S at 607-255-8200.
4.12 Ordering New Equipment (Top)
Whenever large pieces of equipment are planned to be purchased and installed in laboratories, especially equipment that is required to be hooked up to building utility services such as electric, water, or gas, laboratory personnel must first consult with Facilities Engineering, EH&S, and the appropriate PDC shops to ensure the building has the necessary resources to support the new piece of equipment. Lab personnel should not assume they can purchase equipment first and then expect the building to be able to handle the service requirements later. By preplanning and communicating well in advance with appropriate campus groups (such as Facilities Engineering and EHS), any potential issues can be identified ahead of time, which in turn will help make the transition to getting new pieces of equipment up and running quickly after the purchase is made.
Additionally, as with installation of fume hoods, certain pieces of equipment require special installation due to their potential impact on the rest of the building ventilation system and utilities, and cannot be hooked up by laboratory personnel, building managers, or private contractors without first consulting with Facilities Engineering and EH&S. Laboratory personnel are strongly encouraged to be proactive and to consult with the appropriate departments ahead of time, before purchasing new pieces of large equipment.
Laboratory personnel are strongly encouraged, as responsible campus members, to give consideration to purchasing “Energy Star” energy efficient pieces of equipment to help conserve natural resources and long-term operating costs. When discussing purchases of equipment with vendors and equipment manufacturers, ask about what “Energy Star” alternatives they carry. For more information, see Energy Conservation in Laboratories.
Before ordering new equipment, check the Cornell purchasing guidelines for preferred vendors and pricing.
4.13 Work Orders and Ticket Requests (Top)
In the event of a maintenance issue or if repairs are needed to equipment, laboratory personnel should first consult with their Building Coordinator, who will submit the appropriate paperwork with Customer Service to have repairs initiated. Please note that due to NYS building codes and liability issues, laboratory personnel must not try to repair utility services (such as electrical, plumbing, or gas issues) by themselves. These repairs must be handled by qualified personnel only.
Whenever maintenance workers will be working on your hood system or in your laboratory, please remove all chemicals, laboratory apparatus, and equipment from the area requiring maintenance work. Ensure the work area is clean and inform the maintenance workers of any potential hazards present in the near vicinity either verbally or by leaving a sign with the appropriate information.
4.14 Changes in Lab Occupancy (Top)
Changes in laboratory occupancies can occur when faculty retire, new faculty come to campus, new lab staff are hired, students graduate or leave for another university, or when facility renovations take place. When changes in lab occupancy occur, it is important to address any potential issues BEFORE the occupants leave.
Failure to address the change in occupancy can result in:
- Old, unlabeled chemicals, samples, or hazardous waste being left behind in refrigerators, freezers, and cabinets.
- Valuable furniture or equipment being moved or thrown away.
- Unknown chemical spills or contamination being present.
These issues can result in costly remediation efforts and wasted resources for both the department and the University.
If you are planning to leave your laboratory or if you know of a research group or students that are planning to leave, there are a few simple steps that can be followed to ensure a smooth transition:
- Notify your department chairperson, lab supervisor, and DSR well in advance of the planned move.
- Ensure all chemical containers are properly labeled.
- Properly dispose of any hazardous and chemical waste left in the laboratory.
- Ensure all chemical spills and contamination has been cleaned up.
- Review the EHS Lab Move Guide.
4.15 Laboratory Design and Construction (Top)
To provide the best service during the construction/renovation process for laboratories, it is important to take health and safety considerations into account up front during the design process. Project Managers planning a new lab construction or renovation, please contact the Chemical Hygiene Officer with the following information:
- Contact name, phone number, email
- Department, building and room(s) the project will occur in
- Expected start date for project
- Equipment planning to be installed - fume hoods, biosafety cabinet, other capture devices, eyewash and emergency shower, toxic gas cabinet and monitoring devices, etc..
- NOTE: A list of chemicals, including approximate usage (weekly/monthly) and storage quantities will be needed during the process to ensure proper ventilation rates and engineering controls.
CU Design Standards
To facilitate the commissioning process, EH&S has developed commissioning forms for installation of new fume hoods and emergency showers/eyewashes. Before EH&S will certify new fume hoods, emergency showers, or eyewashes, the following commissioning forms must be completed, signed, and submitted to the Chemical Hygiene Officer at EH&S.
4.16 Ventilation Rates (Top)
As part of energy conservation measures, ventilation rates for laboratories are determined based on the occupancy and the type of research being conducted. Please see the Laboratory Ventilation page on this website for further information about the program.
If the function of a room changes due to new researchers coming to campus notify EH&S through AskEHS about the change. EH&S will then verify if the ventilation rate for a given room is appropriate for the type of research being conducted.
Research laboratories should be negative to the hallways and offices. When positive air pressure occurs, more air is being supplied to the room than what is being removed by the fume hood or general exhaust. This can result in air from the laboratory (including chemical vapors and dusts) being blown out into the hallway outside of the lab and chemical odors permeating the hallways and surrounding rooms.
Ensure the entrance door to the laboratory is closed.
If you notice odors that seem to be escaping from a lab, then please contact your Building Coordinator for assistance.
4.17 Energy Conservation in Laboratories (Top)
Laboratories are energy intensive facilities, consuming many times the energy use of the average non-lab academic buildings. Laboratories use large quantities of air for ventilation and fume hoods; electricity to operate fans, lighting, and specialized lab equipment; and large quantities of water and process chilled water. Some laboratory facilities also use substantial quantities of natural gas.
There are a number of things that lab occupants can do to reduce the overall consumption of energy:
4.18 Green Labs (Top)
Green chemistry, also known as sustainable chemistry, is the design of chemical products and processes that reduce or eliminate the use or generation of hazardous substances. Green chemistry applies across the life cycle of a chemical product, including its design, manufacture, and use.
Substitute hazardous chemicals with less hazardous alternatives or chemicals that are drain disposable
Redesign chemical processes to reduce hazardous chemical use and/or exposure to technicians
Maintain an ongoing inventory of chemicals and dispose of outdated chemicals on a regular basis.
Find additional information on Greening your lab and certifying your lab as a Green Lab:
EPA Pollution Prevention website for Green products
Green Your Lab
ACS Green Chemistry
Additional information on energy conservation for both work and home can be found on the Department of Energy's website: Energy Efficiency and Renewable Energy. Find energy savings tips for the home, office, and lab by going to the Utilities Department Energy Saving Tips webpage.
4.19 Research Area Inspections (Top)
Laboratories and other research areas are regulated by OSHA laboratory safety standards and general industry regulations, EPA and DEC hazardous waste regulations, DOH regulations, NFPA life and fire safety standards, and building codes. Additionally, accreditation and granting agencies such as CDC, NIH, and USDA are increasing scrutiny over researchers and their compliance with state and federal laws. To assist researchers to be in compliance with these regulations and standards, Environmental Health & Safety (EH&S) will conduct required inspections of all campus research areas.
The purpose of the inspections is to assist responsible faculty and staff members in identifying and correcting potential regulatory compliance issues or other issues that could affect granting activities, and identify potential health and safety hazards that could pose an unreasonable risk to laboratory personnel, students, and the campus community. To facilitate the correction of deficient items, a corrective action process has been implemented and will be tracked. EH&S will schedule inspections by working with college-level contacts, Department Safety Representatives, Building Coordinators and staff throughout the colleges, departments, and buildings.
Research areas are strongly encouraged to conduct their own self inspections prior to EH&S conducting an inspection of their research area to address any potential issues before the EH&S inspection and to provide a training opportunity for research staff. To facilitate the self inspection process, EH&S is providing research areas with the following self inspection checklist and explanation key which identify the same topics covered during an EH&S inspection.
An important part of any research safety program is implementation of self inspections. Self inspections provide a number of useful benefits and further help to create a culture of safety within the lab. Benefits of self inspections include:
- Raising the level of awareness of laboratory personnel and determining the level of compliance with state and federal regulations.
- Identifying and addressing any potential issues before an inspection by a state or federal regulatory agency.
- Providing an opportunity for lab specific training by identifying potential issues within the lab and then training lab personnel to look for these issues.
- Serving as a regular health and safety check of laboratory facilities.
- Serving as an outlet for faculty, staff, and student concerns.
- EH&S recommends the following frequency for self inspections:
- On a daily basis lab personnel should maintain good housekeeping within their lab.
- Informal weekly lab walkthroughs or “Friday afternoon cleanups”.
- Ideally, self inspections should occur once per month. These could include participation of research staff, DSRs, and/or safety committee members, and use of an inspection checklist.
- At least once per semester research personnel should perform a formal self inspection utilizing the EH&S self-inspection checklist and explanation key.
The benefits of conducting inspections of laboratories on a regular basis cannot be overstated. In addition to providing for a healthier and safer work environment, lab inspections can reduce legal liability by identifying potential issues, and training lab personnel to look for and correct potential issues.
Inspections by state and federal regulatory agencies can occur at any time and can result in citations and significant fires for the university. The best way to be prepared for these inspections is to understand what regulations apply to your area and what you need to do to comply with those regulations. You can obtain this information from resources such as this Laboratory Safety Manual, by conducting your own self inspections, and by calling EH&S at 607-255-8200. You can find additional information on the EH&S web page on what to do during an OSHA inspection
and what to do during an EPA inspection
If a state or federal inspector shows up in your work area unescorted, ask them to please wait and contact EH&S immediately at 607-255-8200.
4.20 Research Area Space Registration Using HASP (Top)
All research spaces are required to be registered with the Department of Environmental Health and Safety (EH&S) using the online Hazard Assessment Signage Program (HASP). While Facilities Services Space Inventory accounts for room function and type, Research Area Space Registration accounts for hazards present in rooms to facilitate regulatory compliance, identify training requirements, communicate hazards, and improve emergency response.
Research areas must be reviewed and registered on an annual basis, when roster or hazard information changes and upon notification by EH&S. The registration process consists of using the online HASP tool and entering contact information, hazards present in the room, risk levels of hazards, access limitations, warning messages, and emergency response information. The entire process of completing HASP for one room should only take a few minutes for each room. Once a research area has been initially entered into the system, annual updates can be completed in less time. Only certain research area rooms types are required to be registered. The list of space inventory room types of interest that will be required to complete annual Research Space Registration using the online HASP tool can be found on the Research Area Space Registration webpage.
The following outlines responsibilities for implementation of Research Area Space Registration using HASP:
The Department of Environmental Health and Safety is responsible for:
- Providing information and assistance with the HASP system.
- Granting access to the users for their locations within the HASP system.
- Providing guidance and assistance on the identification of hazard types.
- Providing information, training, notifications, reports, and updates from the information provided.
Deans and Department Chairpersons are responsible for:
- Ensuring that research areas within their departments and units are registered in a timely manner upon notification by EH&S and updated annually.
Principal Investigators and Research Area Supervisors are responsible for:
- Registering (or designating someone to register) their research areas using HASP in a timely manner upon notification by EH&S.
- Updating their Research Area Space Registration using HASP when any new hazards or significant change of existing hazards occurs.
- Updating their Research Area Space Registration annually in a timely manner upon notification by EH&S.
EH&S will work with Department Safety Representatives (DSRs) and Building Coordinators to facilitate the implementation of Research Area Space Registration. Before getting started, persons completing the registration process (DSRs, Building Coordinators, Principal Investigators, research staff, or other college and department designated personnel) will first need to be given authorization to the HASP system for their organization, building, department, and/or specific rooms. To obtain authorization for specific areas, please contact "askEHS". For more information on using the online HASP tool and how to get started with the program, see the online training program for using HASP.
It is the responsibility of the Principal Investigator and individual supervisors to ensure research areas under their supervision have been registered using the online HASP program.
4.21 Laboratory Security (Top)
Laboratories need to take specific actions in order to provide security against theft of highly hazardous materials, valuable equipment, and to ensure compliance with state and federal regulations. EH&S encourages each unit (college, department, and research group) to review and develop procedures to ensure the security of all hazardous materials in their area of responsibility.
Many laboratories already implement various means of security, including requirements to lock up controlled substances, syringes and needles, and radioactive materials. EH&S recommends you review and assess the hazardous materials in your laboratory and consider security issues in protecting those materials. The intent is to minimize the risk of theft, especially targeting the five-minute window when the lab is left unattended.
***One easy way to increase security is to make sure that your laboratory door is locked whenever the lab is left unattended, even for a few minutes.
The following are guidelines designed to minimize opportunities for intentional removal of any hazardous materials from your laboratory:
Recognize that laboratory security is related to, but different from laboratory safety. Security is preventing intrusion into the laboratory and the theft of equipment or materials from the lab.
Develop a site-specific security policy. Make an assessment of your laboratory area for hazardous materials and particular security issues. Then develop and implement lab security procedures for your lab group and train lab group members on security procedures and assign responsibilities.
Control access to areas where hazardous chemicals are used and stored. Limit laboratory access to only those individuals who need to be in the lab and restrict off-hours access only to individuals authorized by the Principal Investigator.
- Be sure to lock freezers, refrigerators, storage cabinets, and other containers where stocks of biological agents, hazardous chemicals, or radioactive materials are stored when they are not in direct view of workers (for example, when located in unattended storage areas).
- Do not leave hazardous materials unattended or unsecured at any time. Most importantly, close and lock laboratory doors when no one is present.
- Note: If staff work alone and use the buddy system with someone outside of the research group, allowing access for that individual will need to be addressed prior to the initiation of working alone.