I will piggyback on James’ response as it extends the one I sent in my personal message to Jonathan. James considerations seems to be part of risk-based analysis, which should help with a decision.
ACS position is that students should not be working alone in the lab and this position aligns with recommendations in
Prudent Practices in the Laboratory by the National Research Council, which states that “it is prudent practice to avoid working alone at the bench in a laboratory building. Experiments known to be hazardous should not be undertaken by a worker who is
alone in a laboratory.” According to Prudent Practices in the Laboratory, the definition of “alone” is beyond visible or audible range of another individual for a few minutes at a time.
The following laboratory tasks should never be conducted when alone:
ACS however advocates risk -based safety rather than rigid rules. The safety decisions should be made based on recognizing hazards , assessing risks and making sure that to minimize risks from hazards, as well as prepare for emergency.
You should always document this risk management process as the due diligence records. I would also suggest that you also check with your administration as there might be internal rules about not allowing undergraduate students alone in the lab.
ACS has published this video that may help you with risk management process and final decision.
https://www.youtube.com/watch?v=Y8DBd45W4hY&list=PLLG7h7fPoH8IZ6i2rfDK0zVoompXayRL_&index=16
As far as I know, OSHA, which provides regulations for laboratory safety only covers employees but not students. Universities/colleges have responsibility to assure the safest learning environment for students.
Marta Gmurczyk
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of James Saccardo
Sent: Tuesday, July 5, 2022 2:32 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [EXT] Re: [DCHAS-L] Question regarding undergraduate research without the PI on site
[Actual Sender is owner-dchas-l**At_Symbol_Here**princeton.edu]
This is always a tough decision and many do not have a policy. We always want to foster a learning environment and facilitate research, and this can be difficult to do and remain in compliance with all rules and regulations.
In our jurisdiction, the local fire department issues a lab laboratory operating permit, the permit requires a certificate holder (certificate obtained by fire department) to be present when the lab is in operation.
Akin to driving, the permit is a registration and the certificate is a license. Usually our PI’s and graduate students have the certificate, and must be present when the undergraduates are working, as per the permit conditions.
What if the undergraduates run into a problem? Make a spill? Would you let an unlicensed driver operate a motor vehicle? May not be the best analogy, but it’s similar.
Finally, the ol’ saying, when the cat is away, the mice will….. while the two undergraduates are in the lab, unsupervised, they will have unabated access to the entire lab and may become curious and touch things they are not supposed to
be touching.
Having undergraduates working without supervision, increases risk. How would you address that increased risk. Some administrators will not allow under 18, or students from another home institution.
You can limit the time from 8 hrs to 1 hr. You can have colleagues from another lab supervise if they are willing.
Sorry I don’t have a clear answer, but I hope this has helped.
be well,
James
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Tammy M. Lutz-Rechtin
Sent: Tuesday, July 5, 2022 2:09 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Question regarding undergraduate research without the PI on site
I am uncertain as to “regulations for undergraduates.” If they are over 18, they are adults subject to the same regulations as us. Ultimately, this is a liability issue. However, my university as safety policy does require a “buddy system”
for undergraduates during working hours, supervision after-hours, or a “work alone” form. The “work alone” document establishes hours for working, communication requirements, and limits on the type of activities allowed. For example, a student with PI approval
may work on Saturdays between 9 am-5 pm if the PI is contacted by text when entering & leaving and only does activities outlined and considered low-risk by the PI.
Tammy Lutz-Rechtin
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Jonathan Dannatt
Sent: Tuesday, July 5, 2022 12:39 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] Question regarding undergraduate research without the PI on site
Dear Reader,
I am Jonathan Dannatt. I am a fairly new assistant professor at a primarily undergraduate institution, University of Dallas and was hoping you could guide me and our department
a bit.
We are currently re-writing our chemical hygiene plan and came across a dilemma. We are unsure if there are laws or ACS guidance surrounding undergraduate research students to perform
simple, PI approved tasks in the lab while the PI is not present. For example, if on a Saturday a water bath needs to be filled or a reflux needs to be stopped, are there laws or safety regulations prohibiting a pair of students coming into the lab and completing
this task? Is there any specific ACS guidance in this area?
Again thank you for any advice or assistance you can provide.
Best regards,
Jonathan
--
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Jonathan Dannatt, Ph.D. Assistant Professor Department of Chemistry University of Dallas O: (972) 721-5065 |
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