Fellow Listers - Please see proof reading corrections in red below.
BruceV
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Bruce Van Scoy
Sent: Tuesday, February 8, 2022 7:38 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Operating Permits
John - I could not agree more.
Dr. Kaufman,
I have never worked as an EHS Professional in higher education. I have in commercial research organizations (CRO's) following Good Laboratory Practices meeting FDA and EPA GLP Standards.
Every action taken was governed by an SOP or Protocol. I reviewed each and every one (over 660 SOPs alone in one organization) inserting appropriate EHS requirements into each prioritizing engineering controls, PPE followed by administrative controls and we worked with some potent compounds that produced known effects in toxicological laboratories.
We assumed until it could be proven and progressed to IMPLIED when relying upon the expert input of known subject matter expert. I am referring to Nelson Schlatter from Ansell who was one of the first chemist who provided known degradation, permeation, etc., databases for Ansell (later Ansell-Edmont). Nelson helped me numerous times over the years where we would be using a novel compound with very limited availability, no potential for glove testing with known toxicological properties. In other words, there was not enough material in the world to allow testing to be performed, but since he had such an extensive database and testing knowledge would recommend a glove, or at times multiple gloves in layers based upon testing results from analogs. To my knowledge, we never had a potential exposure through PPE failure, even for those compounds positively known to cause health effects, i.e., Parkinson's disease.
We didn't have a "job description" but, we had SOPs and protocols based upon a step by step Job Hazard Analysis, with the potential risks identified at each step, recognizing the hazards and implementing controls (based upon the hierarchy of controls) to reduce risk. The job descriptions simply stated "Research Scientist" with the levels varying upon expertise. But the hazards identified were indeed based upon implied and assumed risks with the final control measures, e.g., Permits issued in the form of SOPs or Protocols. We ASSUMED these controls would be effective and in my experience were proven so.
My experience only,
BruceV
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of James Kaufman
Sent: Tuesday, February 8, 2022 10:49 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Operating Permits
"In higher education, there are seldom official documents giving someone authorization to do something,"
What do you call a job description?
PS. LSI now has virtual lab inspections, safety program evaluations, document reviews, plus courses and seminars ... all virtual
James A. Kaufman, PhD
Founder/President Emeritus
The Laboratory Safety Institute (LSI)
A Nonprofit Educational Organization for Safety in Science, Industry, and Education
192 Worcester Street, Natick, MA 01760-2252
(O) 508-647-1900 (F) 508-647-0062 (C) 508-574-6264 Skype: labsafe; 508-401-7406
jim**At_Symbol_Here**labsafety.org www.labsafety.org Teach, Learn, and Practice Science Safely
| 9:06 AM (1 hour ago) | |||
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I disagree.
As a safety person, I definitely use words like implied and assume, when they fit. Let me provide some definitions, so at least we may share a common frame of lexical reference going forward.
In higher education, there are seldom official documents giving someone authorization to do something, documents that fit the mold of an "operating permit." When faculty have been assigned space for research, it is suggested but not directly expressed that they will do so in accordance with the institution's policies and procedures. Other safety people may have other words for that - I use "implied."
Safety people assume things all the time - we could not live in a world where we do not make assumptions. Fire sprinkler systems save lives, when they are allowed to operate as designed. We are obliged, under code, to visually inspect the isolation valves monthly, or weekly if they are not supervised. It takes a few minutes to isolate a fire sprinkler system at such a valve, which would impair the system's ability to function in case of fire, with a much increase likelihood of death or serious physical injury to the occupants of the portion of the building that impaired sprinkler system would otherwise have protected. However, fire code allows owners to inspect a valve on the first day of a month and the last day of the subsequent month - as much as 25,000 times the duration of the activity that causes an impairment, and still assert the inspection program complies with code. We do not have proof that such valves are still open in the intervening time, yet code allows us to suppose this is the case. The other examples where this is the case are legion - when was the last time any of us used a four-gas meter in supplied air to simply gain entry to our offices? Other safety people may have other words for that - I use "assume."
I categorically reject the appeal to pity and the attempt to disprove the rule by pointing to the exception. There have been literally millions of staff hours in higher education laboratories, under no "operating permits" if my view is valid, since 2008 where no-one has died, where no-one has ben seriously injured, and where no environmental contamination has occurred. It is simply not the case that mayhem, death, serious physical injury, and environmental degradation necessarily attend teaching and research laboratories in higher education when a system of "operating permits" is not in place. The presence or absence of the "operating permit" does not make the lab safe.
I look forward to reading a re-written post that describes the reality of the pursuit of science, teaching, and discovery in a higher education context, and does not rely on implication or assumption. Have at it, sir.
John
John DeLaHunt, MBA, ARM
Risk and Life Safety Manager
Treasurer, CSHEMA - EHS Leadership in Higher Education
The University of Texas at San Antonio
Office of Risk and Emergency Management
One UTSA Circle
Central Receiving Warehouse 1.01.12D
CRW 1.01.12D/MC05500
San Antonio, TX 78249-3209
(210) 458-4420 voice
(210) 458-7450 fax
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