Department Safety Coordinator’s Seminar Enterprise Risk

Department Safety Coordinator’s Seminar Enterprise Risk Services/Environmental Health & Safety Tuesday, April 7, 2015

Agenda: 10:00 – 10:05 Welcome (Dan Kermoyan, EH&S) 10:05 – 10:25 Laboratory Safety Program Overview (Dan Kermoyan, EH&S) OSU Laboratory Safety Elements Laboratory Safety Assessments Program Recommendations 10:25 – 10:45 Chemical Inventory Guidelines (Lance Jones, EH&S) What should be included within your inventory? How do you file your chemical inventory? 10:45 – 11:00 Container Labeling Guidelines (Lance Jones, EH&S) Labeling of chemical and hazardous waste containers made easy ** 10-Minute Break ** 11:10 – 11:20 Chemical Hygiene Plan (Andy Kenst, EH&S) Does your laboratory have a chemical hygiene plan? Have your employees received training? 11:20 – 11:30 Occupational Medicine Services (Ariel Leshchinsky, Student Health) 11:30 – 11:40 Dangerous Goods Shipping (Kent Lanning, EH&S) 11:40 – 11:50 Q & A; Future topics?

Laboratory Safety Program Overview Dan Kermoyan, EH&S

Laboratory Safety Assessments Drivers Benefits Regulatory visits increasing Compliance and lower fines Recent events Reduce injuries and damages Granting Agencies Increase Research Accreditation Favorable exposure Our observations Decrease chemical and disposal costs Faculty needs help EH&S as a resource

How do we get there .? Lab Categories (LCAT) Laboratory categories grouped by materials used/stored. 1,618 spaces. Assigned an assessment frequency.

Lab Spaces by Lab Category 4% These labs will be categorized as lab assessments are completed. 5% 14% 36% 1,618 total 41% LCAT1 LCAT4 LCAT2 TBD LCAT3 High Low Risk and Activity Level Annual inspections needed

Lab Safety Assessment Process 1) 1-month advanced notice to Department Chairs and Safety Coordinators. 2) Use Laboratory Safety Assessment checklist. 3) Common areas to focus on before EHS visit: Chemical inventory Label and secure chemicals & waste containers Training (SDS, Lab, Haz Waste) Lab Chemical Hygiene Plan

Lab Safety Assessment Process Lab Visit appointment with PI or Supervisor. Nature of the Assessment? o Resource oriented. o 2-way dialogue; feedback useful. Lab Assessment Checklist: http://oregonstate.edu/ehs/ PI will receive Assessment Report via email. (Dept. Chair and Safety Coordinator copied)

Lab Assessment: Actions Needed Follow-up Times Routine Items – Routine lab safety items. 7 or 30 days No revisit by EH&S Special Conditions – Special hazard exists. Less than 7 days Revisit by EH&S Immediate Correction Needed – Imminent hazard exists. Immediate correction Revisit by EH&S

Actions Needed (w/i 7 days): Special Conditions

Actions Needed (immediately): Imminent Hazards

Leading Deficiencies identified in 189 Lab Safety Assessments 80 70 627 Deficiencies noted in 189 Assessments 73 60 50 40 30 38 36 35 29 29 20 10 0 *Includes Chemical Container and Hazardous Waste Labeling 27 22 21

Responding to the Lab Safety Assessments 9% PI response rate for 2014 (using database). PI can access the Assessment Results and enter corrections via the “Quick Links” drop down menu on the top/right side of the page at http://oregonstate.edu/ehs/. Select “Record Actions Taken on Lab Safety Assessments” Login with your ONID ID

Program Recommendations Annual Certification by the PI or Supervisor: Verify lab personnel and spaces. Review and update chemical inventories. Label all chemical and hazardous waste containers. Chemical Hygiene Plan is being maintained. Lab staff have completed Lab Safety/SDS/Waste training. Self-Assessment completed. “PI Lab Safety Assistant”

Other Lab Program Recommendations Test eyewashes w/i lab spaces monthly. Formalize line of authority for training and program documentation. Coordinated approach to repair and replacement of lab safety equipment. 30% Chemical Fume Hoods are nearing their end of life and need replacement. 10% Safety Showers need repair. 10% Lab Spaces need initial installation of eyewash units as none exist. 7% Existing eyewash units need repair.

Lab Assessment Schedules Spring Term Summer/Fall Term Oak Creek Crop Science Burt Wilkinson Wiegand Ag Field Stations Engineering Depts. Richardson Peavy

Chemical Inventory Guidelines Lance Jones, EH&S

Chemical Catalog Chemical/Physical Properties Hazards CAS# CAS# Synonym Table CAS# Inventory Record Responsible person Amount Location Physical State

Chemical Inventory Overview Used as the basis of several reports Homeland security, CRTK (SFM), local FD On-line with ONID access PI can set up others to access on their behalf Drop-down search boxes (CAS#, chem name) Can share list within department Can export list (PDF, Excel, HTML)

Chemical Inventory Specifics Location (from lookup) Chemical description Physical state # of containers Quantity per container Unit of measure CAS#

Inventory Data Integrity Quality descriptors added to chemical name Sodium chloride, 99% Sodium chloride, crystalline Punctuation or other characters in name or CAS# Silver (I) acetate vs. silver(I) acetate α,β Size & unit of measure in same data field 500g

Chemical Inventory - What to Exclude Water and non-hazardous buffers, sugars, salts Growth media Biochemicals (non-toxic) Commercial assay kits Biological specimens Radioactive materials counted on RUA Waste Retail products used in routine household-like manner

Chemical Inventory – What to Include Full list of chemicals that must be included is on safety instruction Chemical Inventory Guidelines Or Include it all

Chemical Labeling Guidelines Lance Jones, EH&S

NO!

Chemical Container Labels What rules apply? Lab: OSHA lab standard Non-lab: OSHA haz-com standard

Chemical Container Labels All containers need labels Contents: required Plain English chemical name Owner name: recommended Date: required for certain materials Hazard information Required for non-lab areas Recommended for lab areas HMIS or NFPA

Hazard Information HMIS format NFPA format

Pre-Printed Labels Reports available online Standard formats (Avery) Label Printer (Zebra) Barcode Inventory #

Waste Labels

Questions? 10-Minute Break

Chemical Hygiene Plan Andy Kenst, EH&S

OSU Chemical Hygiene Plan (CHP) OSHA’s definition: The CHP is a written program stating the policies, procedures and responsibilities that protect workers from health hazards associated with hazardous chemicals used in a particular workplace. Applies to all OSU labs and lab employees Lab Supervisors/Principal Investigators (LSs/PIs) Students Post-docs Lab techs and other laboratory staff OSU CHP Addresses/Describes: Local, state and federal laws and regulations University policies and protocols OSU EH&S services and reference material Recommended best practices and other guidance

Lab-Specific CHP (LCHP) OSU CHP is not sufficiently detailed to address all labs at OSU Each PI must create an LCHP LCHP Template online Add lab-specific SOPs as Appendix IV Ensure workers have read and understood the LCHP with documentation Make LCHP and SOPs available for employee reference Periodically review and update the LCHP http://oregonstate.edu/ehs/chp

Lab-Specific Chemical Hygiene Plan Why maintain an LCHP? Improve lab safety through documented training/education It’s the law. OSHA requires it and may ask to see it when they visit. Resource for lab workers Regulatory agencies like the EPA want to see it used in labs. May help reduce liability in the event of an accident.

CHP and LCHP contents (in general) Rights and responsibilities General lab practices Exposure monitoring and medical program Procedures for accidents and emergencies Personal Protective Equipment Emergency equipment (eye wash, safety showers, first aid kits, etc.) Employee training requirements and available resources Record keeping Working with carcinogens and highly toxic materials Operations requiring prior approval (e.g., Institutional Biosafety Committee or Radiation Safety oversight) Job Hazard Assessment and Standard Operating Procedure guidelines (written by LS/PI) Forms, designated area signs, and supplemental chemical information

Occupational Medicine Services Ariel Leshchinsky, Occupational Medicine

Shipping Dangerous Goods Through Printing and Mailing Kent Lanning, EH&S

Shipping of Dangerous Goods (DG) by air or ground is regulated by the DOT/IATA and requires specific training. Printing & Mailing handles shipments of DG for OSU. Environmental Health & Safety provides technical and chemical expertise to Printing and Mailing. There is substantial civil and criminal liability involved in shipping Dangerous Goods improperly. NEVER ship something you suspect as a hazardous material without ensuring it is properly packaged and labeled. At OSU only specific personnel at EH&S and Printing & Mailing are qualified to do this.

In addition to ‘laboratory chemicals’ Dangerous Goods includes many common items that you can buy at a grocery store or hardware store but are considered regulated when being shipped. Common examples of DG include: Aerosol cans Cleaners Flammable Liquids Corrosives Batteries Preserved or Diagnostic Specimens Infectious Substances Equipment containing any of the above

When Shipping DG through Printing and Mailing there are several things that will help your shipment go smoothly. Identify whether the material is hazardous/non-hazardous before attempting to ship it. Listed materials are found in the 49CFR 172.101 Hazardous Materials Table. All hazardous materials have specific packaging, labeling, and handling requirements for shipping. When in doubt contact EH&S. If you believe the material is hazardous contact Printing & Mailing or EH&S ahead of time to confirm what special packaging or handling is required. Locate an SDS/MSDS for the material and provide it to Printing & Mailing when shipping materials. An SDS includes information on both hazards and specific shipping requirements for the material and makes shipping substantially easier. Do NOT bring a sealed box with hazardous material inside to Printing & Mailing since it will have to be inspected by Printing & Mailing’s DG specialist to ensure compliance before being shipped. Do NOT bring a DG shipment to Printing and Mailing half an hour before it needs to go out and expect it to ship. Most DG shipments will take 24 hours to process before shipment.

Consider alternatives to shipping DG Dangerous Goods shipments are expensive, time consuming, and incur significant liability to the University. FedEx, for example, adds an automatic 40 - 80 surcharge to dangerous goods shipments depending on the class of material. Special DG rated packaging for materials that require it add even more to this cost. This is in addition to the actual shipping cost. Consider having the manufacturer of the material ship it directly to the destination for you. This removes liability from the University and is often cheaper as well. Dangerous Goods can often be shipped in very small amounts under the ‘Excepted Quantities’ rule. This means they wont be considered DG and wont require special packaging or a surcharge. A 100ml bottle of a flammable liquid would require rated packaging and a DG surcharge but 4 bottles of 30ml or less in the same box wouldn’t. This would save close to 100 and be much quicker and easier to ship. Printing & Mailing or EH&S can look up a material and determine if Excepted Quantities can be applied. Most DG packaging cannot be reused. If you received a chemical as Dangerous Goods it CANNOT be repackaged in the same cardboard box and reshipped or returned to the manufacturer. Even though the labeling and marking may be correct the container is not rated for multiple shipments. It is often cheaper to dispose of a chemical than return it to the manufacturer.

Summary For Shipping DG Identify whether the item is a hazardous material ahead of time. Contact EH&S/Printing & Mailing before shipping to determine if special packaging needs to be obtained and if the material might qualify for Excepted/Limited Quantities shipping. Provide an SDS with the shipment to EH&S/Printing & Mailing or if the material does not have an SDS then information about the material’s hazards must be communicated by a knowledgeable person. Bring the material to Printing & Mailing in a sturdy container to prevent leaks/spills during transit. Do not bring a sealed box or attempt to pack the material yourself. Do not reuse old DG packaging. This includes repacking the material in the same box you received it in. Printing & Mailing will provide a new UN rated package with new labels for any shipment.

EH&S Contacts Phone - 737-2273 Email - [email protected] Webpage – oregonstate.edu/ehs Additionally EH&S personnel with specific shipping expertise can be contacted directly according to the matrix below: Material to be shipped: Primary Contact: Secondary Contact: Bio-Hazardous Materials 737-3127 Pete Schoonover 737-4557 Matt Philpott Hazardous Materials Pete Schoonover 737-3127 Kent Lanning 737-8359 Radioactive Materials Dan Harlan 737-7082 David Horn 737-4060

Questions/Future Topics? Presentation will be available for viewing at: http ://oregonstate.edu/ehs/training Thank You for Attending!