For the sake of continuing this discussion, I=E2=80=99m leaning on Harry=E2=80=99s side of the fence (see, we can agree on some things, Harry).

 

As noted, prescriptive-based standards are what resulted in OSHA getting slammed in its early days-  guard rails at specific heights, toilet seats=E2=80=99 dimensions not to exceed=E2=80=A6. etc, etc  (My wife worked for OSHA in =E2 =80=9976-  she quickly went over to the industrial sector)

 

I am, however , open to incorporation of Behavior-based compliance language into the standard;  Chemical Hygiene Committees may meet the requirements of the standard, but, as with many/ most committees, what gets said around a conference table doesn=E2=80=99t always get mandated in the laboratory.& nbsp; A safety program in an individual laboratory is only as good as the occupants want it to be.  Changing behavi or is not easy, and, some will say, near impossible.  So, how does a univ ersity offer incentive to not only develop but sustain safe laboratory practices?  Administrative example-  if the Department Head is not on board, why should the PI=E2=80=99s comply?   If there are no regularly-scheduled departmental meetings in which safety is on the agen da EVERY time, then there is no sustainability.  If there are no regul arly scheduled meetings led by the PI, in which safety procedures are discuss ed for the SPECIFIC experiments being conducted, then everyone assumes everyone knows safe procedures for working with reactives.   It=E2=80=99s  all about communication, and that can be a sensitive topic.   (We had a fire here due to a researcher=E2=80=99s error in mistaking sodium hydride for sodium hydroxide).  A new graduate student does not want to appear to be uninformed on a laboratory technique-  this is where senior researc hers need to step up-  there=E2=80=99s nothing like shared experience as a training tool.   That line goes far beyond the realms of laboratories.& nbsp; (Reading a manual on how to replace pads on disc brakes and having someo ne show you how is a perfect example.)

 

As a performance-based standard, Harry is right that the CHP is direct & straightforward.  What it cannot do is change behavior- unfortunate ly that sometimes only happens as a result of fire, explosion, or death.

 

-Stefan Wawzy niecki, CIH, CHMM

 NRCC-CH O

University of Connecticut

 

 

 

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From:< /SPAN> DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Harry Elston
< SPAN style="FONT-WEIGHT: bold">Sent: Tuesday, August 04, 2009 7: 46 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very complete information about UCLA fatality

 

Neal et al.:

< /FONT> 

I'm goin g to fall on the other side of the fence on this one - I don't want to see th e lab standard any stronger than what it is.

< /FONT> 

Personal ly, I think that Cal-OSHA missed the boat on this one and the lab standard is fine as it's written.  There is far enough teeth in the statement regard ing CHPs "...capable of protecting employees from the health hazards associa ted with hazardous chemicals in that laboratory..."  (1450(e)(1)(i))

< /FONT> 

Making the Lab Standard prescriptive would be counter-productive for safety in the laboratory.  Keeping the standard performance based places the burd en of safety squarely where it should be:  Front-line management, or in this case, the PI.  A prescriptive plan places the safety burden on "The Safety Guy/Gal" who has to go around and look to insure that every jot and tittle of the standard has been met. 

< /FONT> 

H

< /FONT> 

< /FONT> 

From:< /SPAN> DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of NEAL LANGERMAN
Sent: Monday, August 03, 2009 8:1 4 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very complete information about UCLA fatality

 

Peter and others =E2=80=93

Unfortuna tely, UCLA and the lab had a CHP which satisfied Cal-OSHA.  The reason th at there is little mention in the UCLA discussion of the Lab Standard and related is that UCLA is a good example of the standards weaknesses.

 

Any yes, it would be great to strengthen 1910.1450 and there are discussions along those lines, but that takes changing an existing OSHA standard.  Not easy.

 

There are many ideas being discussed and this list is a good forum for the discussion.

 

So, how would YOU suggest (1) improving the lab standard and (2) getting OSHA to do it?

 

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From:< /SPAN> DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Reinhardt, Peter
Sent: Monday, August 03, 2009 3:1 0 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Article from Chemical and Engineering - very complete information about UCLA fatality

 

Kudos to C&a mp;E News for this excellent review and analysis.

 

I continue to be surprised that there is so little mention of OSHA=E2=80=99s lab standard or Chemical Hygiene Plans, and no mention in this article. UCLA is required by Calif ornia law to have a Chemical Hygiene Plan, and their internal report (and CalO SHA citation) mentions it. Experts in the article discuss the need for lab-specific risks assessment, policies, procedures and training. The Ch emical Hygiene Plan is the tool for all these things. In response to this trage dy I think it would be good if ACS DivCHAS worked to strengthen the use and implementation of laboratory Chemical Hygiene Plans.

 

Pete< /FONT>

 

Peter A. Reinhardt

Director, Of fice of Environmental Health & Safety

Yale< /FONT> University

135 College St., Suite 100

New Haven, CT   06510-2411

(203) 737-2123

peter.reinha rdt**At_Symbol_Here**yale.edu

 

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From:< /SPAN> DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Debbie M. Decker
Sent: Monday, August 03, 2009 1:3 8 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Article from Chemical and Engineering - very complete informat ion about UCLA fatality

 

http://pubs.ac s..org/cen/science/87/8731sci1.html

 

Debbie

< /DIV>