Findings and Recommendations of the Senate Working Group on Research Laboratory Safety

1. Findings and Recommendations of the Senate Working Group on Research Laboratory Safety Michael Wong (CHBE) Working Group Chair Version 2.2

2. SWG Membership • Beth Beason-Abmayr (Biochemistry and Cell Biology) • Raj Dasgupta (Earth Science) • Tom Killian (Physics and Astronomy) • Kevin Kelly (Electrical and Computer Engineering) • Qilin Li (Civil and Environmental Engineering) • Michael Wong (Chemical and Biomolecular Engineering) ex officio members • Kevin Kirby (Vice President for Administration) • Vicki Colvin (Vice Provost for Research; Chemistry) Faculty Senate members • Jane Grande-Allen (Deputy Speaker; Bioengineering) • Carl Caldwell (Speaker)

3. Charges of working group • To assess the state of research laboratory safety across campus • To propose a new organizational structure that fosters and maintains a culture and practice of lab safety • To issue recommendations to improve the process for safety training, oversight and compliance

4. From Chemical Safety Board findings (Oct. 19, 2011): • Physical hazard risks of research were not effectively assessed, planned for, or mitigated • University lacked safety management accountability and oversight • Previous incidents with preventative lessons were not documented, tracked, and formally communicated Texas Tech: explosion and injury to grad student (Jan. 7, 2010)

5. First time that a U.S. professor faces a felony charge in relation to the death of a lab worker • Accused of failing to correct unsafe workplace conditions and procedures in a timely manner, failing to require work-appropriate clothing and personal protective equipment, and failing to provide chemical safety training to employees UCLA: injury (12/29/08) and death of research staff (1/16/09)

6. "Since 2001, the Chemical Safety Board (CSB) has gathered preliminary information on 120 different university laboratory incidents involving chemicals"

7. Los Alamos NL: laser eye injury to UG researcher (7/14/04)

10. Lab research at Rice • Most NSCI and ENG research activities involve laboratory work throughout the year • Laboratory personnel includes faculty members, undergraduates, graduate students, post-doctoral associates, visiting scholars, high school students, teachers, and paid research staff members

11. SWG assessment • Compliance with local, state and federal agency codes and policies is uneven • Rice has a safety policy • Rice does not have a culture of safety • There is no centralized repository containing compliance information • Several safety committees exist, but they need strengthening • Except for a few Departments, there is general lack of faculty engagement in safety (but there is strong interest!) • Oversight: no consistent enforcement of safety standards in the labs • Perceived, stated, and actual roles of EH&S Department differ • Is EH&S supposed to act as the "safety police"? • Safety training for research personnel is not effective at University-level • Training course required for grad students, not for undergraduates doing laboratory research • Additional training in the PI's lab is assumed to happen • No online safety modules available on EH&S web site

12. Weak safety culture signs • No clear commitment of institutional administration to actively promote safety at all levels (weak or deficient leadership in safety) • Failure to establish accountability for safety among leaders, managers, supervisors, employees, and students • Lack of interest in spending significant time or resources on safety • Weak or missing safety management system • Failure to adequately educate students in safety and to build strong safety skills • Failure to evaluate students’ safety knowledge and skills through tests and observations • Failure to build/maintain strong safety awareness and interest in safety • Failure to learn lessons from past incidents and implement changes (improved safety practices) to prevent future incidents • Weak collaborative interactions within the safety program and on safety issues Ref: Creating Safety Cultures in Academic Institutions, ACS (2012)

13. 2013 global safety survey Survey further revealed "mixed attitudes to the value of safety training, inspections and safety rules" Ref: Nature 493, 9-10 (2013)

14. Safety and misconduct "Research misconduct means fabrication, falsification or plagiarism in proposing, performing, or reviewing research, or in reporting research results." "Research misconduct may also include a failure to comply with the federal requirements for protecting researchers, human and animal subjects and the public."

15. Sponsored research policy "principle investigators shall… provide for the health and safety of students, post docs, and research and support staff" Refers to additional documents Chemical Hygiene Plan 833-91 and Safety Policy 805-00

16. Chemical Hygiene Plan "This new regulation was developed to provide a standard appropriate for situations in which relatively small quantities of multiple chemicals are used…." "… applicable to all teaching and research activities of Rice University." "Other activities… may use toxic materials or harmful physical agents in other than a laboratory setting…" "The designated Chemical Hygiene Officer (University Safety Officer) will carry out such visits [supervision and enforcement] and inspections, unannounced and announced…"

17. Safety Policy ~1 page long

18. ~EHS  University Safety Officer  University Chemical Hygiene Officer http://safety.rice.edu/

19. Current org chart

20. Current org chart EH&S OSR 8 Depts. 6 Depts.

21. Faculty-led committees Required for all grad students, postdocs Biosafety issues outside rDNA http://comp.rice.edu/home/

22. Oversight and compliance EH&S: "Oversight on research involving potentially hazardous activities are the responsibility of the university and PI to ensure compliance with all state and federal guidelines." • Chemicals (purchase and use) • e.g., controlled substances • Biological materials (purchasing and use) • e.g., biological select agents or toxins • Disposal of chemicals and biological materials • Treat as hazardous waste • Use of radiation and lasers (Texas Department of State Health Services (DSHS) Radiation Control Program) • Radioactive materials • X-ray equipment, lasers (class 3B and 4) • Import and export controls • Inter-laboratory exchanges of regulated material is prohibited

23. SWG recommendations • Rice needs to improve its culture of safety, which will depend on… • Strong commitment from administration through words and deeds • Active engagement of faculty • Service-oriented, collaborative approach by EH&S • Researchers performing in a responsible, conscientious and safe manner • University Safety Policy needs updating to establish clear roles and a clear problem resolution process • EH&S needs to go from a just-in-time approach to a pro-active one • By becoming an in-house consultant for researchers • By developing lab safety profiles that can then be tailored to individual labs • By partnering with PI's and Departments to develop safety training programs and lab safety plans • By assigning EH&S staff to buildings, to build relationships with individual labs • By revamping its web site to be a user-centered, repository of information • Safety training needs to be: tailored to each lab; high-quality; recorded in a database; and available as in-person + online sessions • Needed is a centralized repository containing compliance and training information • Rice needs a safety professional to lead this improvement effort

24. Appendix A: references • Chemical Safety Board, Texas Tech University, Laboratory Explosion Case Study (No. 2010-05-I-TX) • https://www.baycitizen.org/news/education/ucla-researchers-death-draws-scrutiny/ • Nature 493, 9-10 (03 January 2013) doi:10.1038/493009a • Creating Safety Cultures in Academic Institutions: A Report of the Safety Culture Task Force of the ACS Committee on Chemical Safety, American Chemical Society (2012)

25. Appendix B: best practices Laboratory Safety Institute • http://www.resources.labsafetyinstitute.org/Guidelines.html Stanford University safety online courses • https://pselprd.stanford.edu/psc/pselprd/EMPLOYEE/PSELPRD/c/STF_TOG_MENU.STF_TOG.GBL • e.g., Laser Safety, Chemical Safety for Laboratories, General Safety, Injury Prevention, Emergency Preparedness, and Compressed Gas Safety