Introduction
Various entities may work in laboratories at the University; these may be students, volunteers, State or grant-funded employees, or other persons doing work related in some way to University activities. The University has an obligation to perform hazard assessment, inform lab workers of these hazards, and provide safety training that is appropriate for the work being performed. The following are procedures to ensure that all these persons are identified and appropriate hazard assessment and training is provided. The procedures are designed to reduce inefficiencies, eliminate unnecessary work, and ensure all who work in labs are properly trained.
Goal
The goal is to provide a consistent, comprehensive and efficient way of identifying all laboratory workers and providing appropriate hazard identification and training. This goal will require a formal administrative process and documentation.
Procedures
The University Chemical Hygiene Plan (CHP) assigns responsibility for hazard assessment and training. Academic staff and faculty are responsible student training, while EH&S provides CHP training for Faculty and staff (CHP sections 5 and 15). The CHP also provides standard training content for general lab safety training and a standard training documentation form (CHP appendix F).
Lab workers can be categorized into one of four groups based on the nature of their work. Every entity working in a hazardous materials lab must be placed in one of the following four categories:
1 Students in regularly scheduled laboratory classes
2 Faculty and Staff
3 Other persons who work independently (e.g. 494 students, volunteers, collaborators)
4 Other persons who do not work independently
Faculty members or lab managers must inform academic administrators of every entity who works in a lab under their supervision.
Procedures for each of these four groups are described below.
1 Students in regularly scheduled laboratory classes
Students in regularly scheduled lab classes are easily identified using class rosters. Before students begin work, lab safety training appropriate for the class is provided by technical staff or the lab section instructor. The content and provision of this training is documented on a standard training form that the student and trainer(s) sign. The rosters and hard-copy training forms are maintained in each program office for three years.
2 Faculty and Staff
The EH&S office provides CHP training for Faculty and permanent status staff. EH&S will contact Faculty Affairs each semester for a list of new laboratory faculty to be trained.
3 Other persons who work independently
These persons may be grant-funded students, volunteers, independent research students, or other entities. The following procedures will be used for this group.
Identify and empower a single administrative “gatekeeper” in Arts and Sciences for all persons who work in labs.
Establish key access as an administrative control mechanism
Key access is only provided when application or volunteer forms are filed and training documentation is complete.
Use a standard training documentation form that elicits a) hazard assessment b)mitigation c) documents training that addresses a & b. For all safety training use the Laboratory Safety Training Documentation form (CHP Appendix F).
Use a standardized application form for all these entities. This form will identify these persons, elicit information on supervision and the work to be performed, and will trigger appropriate training.
Use the campus volunteer form for any other non-employee entity working in a lab who is not otherwise identified.
Access rules prohibiting circumventing key access control of persons who enter
- All lab workers, regardless of status as student, volunteer, collaborator or visitor, must be identified to the “gatekeeper” by faculty members or lab managers
- No sharing access codes – each person working independently must have personal access code or key.
- No one may provide access for a lab worker unless they are trained.
- No guests/collaborators may be provided access without conforming with these following procedures.
Gatekeeper tasks
- Track all lab workers, i.e. student independent research (494) applications and class rosters, volunteer forms, or others identified by faculty or lab manager.
- E-mail faculty and ask about status of workers in that faculty member’s lab; are they continuing? No longer working? Any new workers?
- Maintain a file of applications for 494 work – ensure application has been approved by both the supervising faculty and chair. The application will contain information useful for hazard evaluation.
- 3-4 weeks into semester check 494 class rosters to ensure all enrolled students have application and safety documentation on file. Provide access only when proper documentation is complete.
- Maintain files of three forms for volunteers: volunteer form, identified risks of participation form, and safety training form. Ensure this documentation is on file before providing access.
- Track faculty sabbaticals and deny entry to that faculty member’s subordinate (potentially unsupervised) workers until proper supervision is identified.
- In general, provide key access only when training documentation is received.
Terminating access
- Normally key access is limited to a single semester
- Each semester review the list(s) of all those with key access and update the list by deletion of those who should no longer have key access.
- Forward this updated list of deletions to the lock shop to confirm termination of key access.
4 Other persons who do not work independently
If an entity does not require key access, e.g. the entity does not work independently and is directly supervised by a faculty member or lab manager, this entity can only be identified as a volunteer by the supervising faculty member or lab manager. Therefore it is particularly important that the faculty member or lab manager check every entity working in their lab to ensure that every worker has been “identified” to the administrative academic “gatekeeper.”.
Timeline/calendar
Student applications should be submitted no later than the last academic day of the previous semester. Students should not receive permission numbers to enroll in 494/Independent Research courses until an approved application is received by the program Analyst. Special cases (such as transfer students or applications received during Summer session) will need to be vetted by the AVP of Arts & Sciences (who has authority for allowing exceptions to the timeline). Volunteer personnel and other entities who may or may not need independent access to potentially hazardous areas need to work with the program or AVP to submit the application 30 days before access is required/entity will be on campus.
Faculty Responsibilities
- Faculty member (or lab manager) must inform academic administrators of every entity who works in a lab under their supervision.
- Faculty members must observe access rules (as specified in this document).
- Faculty members must evaluate hazards, determine and implement reasonable hazard mitigation measures, and convey this information to any entity who works under their supervision in the laboratory. This process will be documented on a standard form, the Laboratory Safety Training Documentation form. This form is located in the campus Chemical Hygiene Plan, Appendix F.
- Independent entities who work in labs must fill out an application. Faculty members must observe deadlines for submission of these applications. Exceptions will be referred to the AVP of Arts and Sciences.