From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Roger McClellan
Sent: Saturday, October 24, 2020 4:07 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EXTERNAL EMAIL: Focusing on Meeting Regulations When the Focus Should BE On What Makes Sense

Protecting Individuals and Institutions.

To all;

  I would like to offer a different opinion on the issues of creating and maintaining a culture of chemical health and safety, training/education and documentation. Recall this is the DIVISION OF CHEMICAL HEALTH AND SAFETY.

 Why is the focus repeatedly on what are the government regulations? I start with a different premise-- as professionals I expect the senior members of this section to know based on their scientific training and experience  what is appropriate and makes sense to protect workers, the environment and institutions.

 I view federal , state  and local government regulations as a starting point. It is given that  these regulations and rules must be followed. However, for any particular situation I expect  individuals (be they employees , students, senior staff, Professors, independent investigators or institutional officials) to subscribe to a culture of chemical health and safety ---- of knowing what is right and  doing what is right. 

Why does this group so often address a health and safety issue by first asking what are the government rules and regulations. Do the individuals asking the question not know what is the right thing to do?

One has to start with creating and maintaining a culture of chemical health and safety. A few weeks ago  some one on this web site  raised the issue of appropriate clothing when using a glove box. One individual responded by noting he liked his casual attire. In my opinion, that response was ridiculous! I hope his studends DO NOT FOLLOW HIS EXAMPLE.  I  start with the assumption that the glove box is being used because hazardous materials are being used and the glove box is within a laboratory. I  subscribe to a view that special clothing should always be used in the laboratory. That is part of creating a culture of health and safety. Adherence to that culture is part of the privilege of working in a laboratory.

 I learned the importance of a  culture of health and safety and training and education and proper procedures  as a summer intern when working at the Hanford Nuclear Labs in Richland, WA in 1957. It had been  reinforced  years earlier when my father , who worked in the Hanford Chemical Separations facility, explained to me what was in the grey box that periodically appeared on the doorstep. When asked he responded -  "those are my pee bottle. I work with some hazardous materials and they check my urine to see if I have been exposed to anything bad. Some times accidents happen!" That introduced me to the use of bioassays. I later learned he worked in the PUREX operation separating Plutonium from irradiated Uranium.

Most recently, the discussion has focused on training and documentation of training. I was the senior official at two major laboratories, the Lovelace Inhalation Toxicology Research Institute and the Chemical Industry Institute of Toxicology. We worked with some very hazardous materials. We aspired to maintain a culture of safety and health promotion. We did a lot of training and educating, using both group sessions and individual to individual sessions.  Internal training was augmented by off-site training. 

Yes, we maintained records documenting training. The government agencies and private entities that funded are worked expected us to have such records. However, that is not why we maintained the records. We maintained them because you can not be operating a program of promoting health and safety if you do not have appropriate documentation ( who gave the instruction, who participated, what was the subject matter, when were the sessions held, etc). We managed our operations, they were not "happenings". Management requires documentation, records are mandatory. My Board of Directors set high standards for me and they expected me to set an example and set high standards for all our employees and operations.

The next time some one (your colleague, your Institute's CEO or a colleague) asks you what are the applicable government regulations  for a situation respond by asking them to explain the situation and then tell you what they think is the right thing to do  and why --- before you quote the applicable regulation.

Quite frankly I think as members of the Division of Chemical Health and Safety  we need to closely examine our own culture and expectations in protecting the health and safety of our co-workers and students and the Institutions we serve. 

Respectfully,

   Roger O. McClellan