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Date: Tue, 1 Mar 2011 15:41:49 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
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From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Photographing non-compliance
In-Reply-To: <DC9B6B340B77DE43BFFBBFD7F28C2FD903A2A6**At_Symbol_Here**CSGMBX200W.pu.win.princeton.edu>
I think any protocol for
disposal should be based on seriousness as well as track record.
That's why I, as a professor rather than EHS person, started
documenting every serious laboratory incident in which I had firsthand
knowledge or involvement. After one explosion/fire in a
colleague's laboratory, I noted deficiencies in the alarm system,
emergency response (fire crews brought in 14 pieces of equipment and set
up a command post but refused to come in the building for well over 25
minutes without even checking firsthand that no lives were in peril),
failure to evacuate, etc. I wrote it all up, sent it to my
department chair and EHS, and filed it away in case this kind of
nonsense ever happened again. Because if it did happen again with
the same failures and someone had been hurt or killed, I would have been
the first one on the witness stand to testify against my own university.
Thankfully, it was not necessary because the folks in a position
to effect changes made the ones I recommended. Sometimes
bureaucracy actually works.
However, I've seen
too many academic institutions where the same safety mistakes are made
over and over and over. Knowing that others have documented
evidence of repeated safety lapses/failures should be all the
encouragement institutions need to ensure that such incidents are not
repeated. Yes, there is some potential there for an overzealous or
unscrupulous lawyer (yes, I know, redundant...) to abuse such records,
but the fact of the matter is that if a lab is repeatedly cited for poor
safety policies and someone gets hurt/killed, the employer and
supervisors in the chain of command *should* be held
legally/ethically/morally accountable. Obviously, we all dread
being seen as the "EHS police", but if a recalcitrant PI persists in
operating an unsafe laboratory, he/she leaves EHS and the administration
no choice.
Obviously, for routine inspections
and such, folks can improve with time and learn lessons, but I would
want to see at least 3 near-perfect inspections in a row before
I'd be willing to throw away records that reveal a track record of poor
safety/risk management practices. Photographs are ideal because
they provide a literal snapshot of what the inspector
saw.
Rob Toreki
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On Mar 1, 2011, at 3:00 PM, Robin M. Izzo
wrote:
We photograph what we can - it does help get the
point across much more effectively than a written description
alone.
However, you may want to check with your institution's
general counsel. If you are documenting an incident, the photos
can be an important component, but if you are documenting non-compliance
as part of an internal compliance inspection, you should have a protocol
for what to do with the photos and the reports over time - how long and
what to retain. Our protocol is to toss the inspection records,
including photos, after one year or once the next inspection takes
place, whichever happens first.
Robin
Robin M. Izzo,
M.S.
Associate Director, EHS
Princeton University
609-258-6259
(office)
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