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LABORATORY INSPECTIONS. Jerry Gordon Manager For Laboratory Safety Programs jpg29@cornell.edu. Who Is This Training For?.

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laboratory inspections

LABORATORY INSPECTIONS

Jerry Gordon

Manager For Laboratory Safety Programs

jpg29@cornell.edu

who is this training for
Who Is This Training For?
  • For all faculty, staff, graduate assistants, and DSRs who want to take a proactive approach to operating their labs safely by identifying potential issues through laboratory self inspections.
objectives
Objectives
  • Identify reasons to conduct self inspections of labs
  • Identify areas of concern and common issues found in labs
  • Identify corrective actions to take
  • Identify best management practices to address areas of concern
why inspect labs
Why Inspect Labs???
  • Determine compliance with regulations
    • Raise level of awareness for lab personnel
    • Identify and address issues before a “real” inspection
  • Opportunity for additional training
  • Health and safety check of laboratory facilities
  • Outlet for faculty, staff, and graduate student concerns
inspecting labs
Inspecting Labs
  • How to inspect labs
    • Use of checklists vs. “the walk around”
    • Include faculty, staff, and graduate students
    • Send a copy of the final report to the faculty
  • Best to go with experienced inspector first
    • It takes time and practice to be consistent
  • Cooperation vs. confrontation
  • Provide solutions, not just citations
inspecting labs6
Inspecting Labs
  • Recommended frequency of inspections
    • Weekly by lab occupants
      • e.g. Friday afternoon cleanups
    • Formal once-a-month by designated lab representatives or DSRs
    • Minimum once per semester
    • Voluntary yearly consultations by EH&S
      • Provides a second set of eyes
      • Incorporates any changes to the regulations
      • Can provide recommendations for similar issues from other labs
inspecting labs7
Inspecting Labs
  • What to bring along during an inspection
    • The checklist
    • A notepad and pen
    • Scotch tape
    • Permanent marker
    • Multi-tool (screwdrivers, wire cutters, etc)
    • Examples of signs and labels to hand out
    • Digital camera is useful for documentation and training pictures
inspecting labs8
Inspecting Labs
  • When issues are found:
    • Take corrective action to address the issue immediately
      • Do you need to document the issue if corrected in front of you?
    • Notify others in the lab of any issues discovered
    • Use labels and signs as reminders
    • Include as topics for discussion at lab group and safety committee meetings
for this training program
For This Training Program…
  • Should
    • Recommendation by EH&S as a best management practice for labs
    • Things that outside inspectors LIKE to see when they go through a lab
  • Must
    • Regulatory requirement involved
    • Specific items outside inspectors look for to determine compliance with regulations
inspection areas
Inspection Areas
  • Housekeeping
  • General Safety
  • Chemical Safety
  • Chemical Waste / EPA
  • Other Wastes
  • Other Regulations
  • Emergency
  • Communication
housekeeping
Housekeeping
  • Arguably THE most important issue in your lab
  • Gives a general impression of the overall condition of your lab
  • Can have a significant impact on the outcome of an inspection by an outside agency
  • Citable OSHA violation
    • Indication of more serious problems
housekeeping12
Housekeeping
  • Includes benches, hoods, cabinets, sinks, refrigerators and freezers
    • Chemical containers, sharps, trash, clutter
  • All chemical spills must be cleaned up
    • Includes drips from containers, splashes on cabinet fronts or in hoods, etc
  • Keep overhead storage to a minimum
    • Do not store heavy items overhead
housekeeping13
Housekeeping
  • When requesting maintenance work, please be considerate of maintenance staff by:
    • Ensuring all chemicals and apparatus have been removed from the work area
    • Ensuring the work area is clean of chemical spills or residue
    • Notifying them of any potential hazards or possible chemical contamination
general safety
General Safety
  • Personal Protective Equipment
  • Electrical Safety
  • Refrigerators
  • Machine Guarding
  • Fume Hoods
  • Gas Cylinders
  • Respirators
personal protective equipment
Personal Protective Equipment
  • The department or unit is responsible for deciding what PPE is required
  • Has the lab completed an assessment of the hazards in their work area and determined the appropriate PPE?
    • Assistance with hazard assessments and choosing the right PPE can be obtained from EH&S
    • Ex. See the glove selection chart in the CHP
personal protective equipment16
Personal Protective Equipment
  • Is the appropriate PPE available and in good condition?
  • Is the appropriate PPE being worn?
  • Have the lab workers been trained on proper use of the PPE?
  • Has this information been included in the lab’s Standard Operating Procedures?
electrical safety
Electrical Safety
  • Maintain plugs, cords, and equipment in good condition
    • Get repaired immediately if needed
    • Look for cracked cords, bare insulation
    • Electrical tape is not acceptable
  • Extension cords are for temporary use only
  • Use power strips if necessary
  • Do not cascade power strips and extension cords
electrical safety18
Electrical Safety
  • Do not block electric power panels
    • Need to maintain clearance and have ready access to breakers
  • Ensure all missing breakers are reported to building coordinator
    • Missing breakers need breaker caps installed
  • Emergency cut off switches and breakers must be labeled
    • Contact building coordinator for assistance
electrical safety19
Electrical Safety
  • Do not store oxidizers or flammables around power panels or other ignition sources
  • Be aware when using electrical devices around sinks and other sources of water
    • Use a Ground Fault Circuit Interrupter (GFCI) around wet areas
electrical safety20
Electrical Safety
  • Do not alter or repair fixed wiring in buildings
    • Contact building coordinator for assistance
  • All electrical devices or equipment must be third party tested
    • Underwriters Laboratories – UL listed
refrigerators
Refrigerators
  • Do not store food in chemical refrigerators
    • Chemical refrigerators should be labeled as “Chemicals Only, No Food”
  • For sample storage, include an identification key on outside of refrigerator
  • Should store liquid chemicals in secondary containers such as trays
  • Practice good housekeeping
    • Clean up all spills
refrigerators22
Refrigerators
  • Clean refrigerators on a regular basis
  • Defrost freezers on a regular basis
  • Only special rated flammable storage refrigerators may be used for storage of flammable liquids
refrigerators23
Refrigerators
  • All refrigerators should have an ECO disposal registration sticker
    • Check with your DSR or Building Coordinator OR
    • Contact Facility Coordinator or Anne Wildman at ECO at AW72@cornell.edu
cold rooms
Cold Rooms
  • Same principles of refrigerator storage apply
  • No storage of food
  • Should not store flammable liquids and cryogenic gases in cold rooms
    • Flammability and explosion hazard
    • Asphyxiation hazard
machine guarding
Machine Guarding
  • All moving parts need to be properly guarded
  • Includes belts, pinch points, and blades
    • Vacuum pumps, hydraulic presses, cutting devices, grinders, rotating shafts
fume hoods
Fume Hoods
  • Hoods are not storage cabinets
    • Temporary storage for experiments is acceptable
    • Excess storage interferes with air flow
    • Any equipment stored in hoods should be elevated to allow air to flow properly under equipment
  • Keep sash as low as possible
    • Safety measure during use
    • Energy conservation measure when not in use
fume hoods27
Fume Hoods
  • Hoods are not disposal devices
    • Illegal to evaporate hazardous waste
  • Do not use heated Perchloric acid in standard fume hoods
    • Vapors can form shock-sensitive compounds that can explode
    • Requires a Perchloric acid fume hood with a special wash down function
gas cylinders
Gas Cylinders
  • Must be secured upright at all times
    • Includes half size cylinders
    • Use of chains is preferred
  • Label with a Full/In Use/Empty tag
  • Replace cap when not in use
gas cylinders29
Gas Cylinders
  • Keep away from ignition sources
  • Separate Oxygen and fuel cylinders
    • At least by 20 feet or a half hour fire wall
  • Only order what you need – do not stockpile on loading docks
  • Just-In-Time delivery by Airgas
    • Next day service
respirators
Respirators
  • Includes half face and full face respirators
    • Does not include dust masks
  • Must be in the Cornell University Respirator Protection Program
    • If job requires a respirator
    • And for voluntary use
  • Contact Dustin O’Hara at 5-5082
chemical safety
Chemical Safety
  • Proper Labeling
  • Chemical Segregation
  • Chemical Storage
  • Peroxide Formers
chemical labeling
Chemical Labeling
  • All containers must be labeled
    • Includes wash bottles, reagent bottles, and other chemical containers
  • Labels must identify contents
  • For original containers
    • Tape label if it is falling off
    • Relabel with permanent label
  • Deface old labels that do not accurately describe contents of chemical containers
chemical labeling33
Chemical Labeling
  • Labels on non-original containers should include:
    • Full chemical name
    • Hazards present > flammable, corrosive, health hazards
  • If using structures, formulas, or abbreviations
    • Should have a key explaining abbreviations
  • Recommend using EH&S Right-To-Know labels (see www.ehs.cornell.edu)
chemical labeling34
Chemical Labeling
  • Should date containers when received and opened
    • Dispose of expired and old chemicals
  • Especially recommended for peroxide formers
chemical segregation
Chemical Segregation
  • Store chemicals according to hazard class
  • Do not store chemicals by:
    • Alphabetically
    • Carbon number (organic chemicals)
    • Liquids versus solids
    • Small bottles versus large bottles
    • Whatever fits on the shelf
  • Until chemicals have been segregated
chemical segregation36
Chemical Segregation
  • Benefits of segregation by hazard classes
    • Safer storage
    • Increase knowledge about the chemical
    • Identify potentially explosive chemicals
    • Identify multiples of the same chemical
  • Read container labels and MSDSs
  • Assistance with lab cleanouts and segregating chemicals is available, contact EH&S for more information
    • Email chemwaste@cornell.edu
general hazard classes
Flammable liquids

Flammable solids

Water reactives

Oxidizers

Cyanides

Compressed gases

Poisons

Organic acids

Inorganic acids

Nitric acid

Perchloric acid

Bases

Radioactive

Biohazards

General Hazard Classes
chemical storage
Chemical Storage
  • Minimize amount of chemicals stored
    • Take advantage of Just-In-Time delivery
  • Store small bottles in front of large bottles
  • Store with labels facing out
chemical storage39
Chemical Storage
  • Store older and used bottles in front of full containers
    • Use up the older containers and containers with smaller amounts remaining first
  • Do not store hazardous liquids above eye level
    • Especially no acids or bases
    • Other chemicals injurious to the eyes
chemical storage40
Chemical Storage
  • Recommend storing chemicals in secondary containers such as trays, buckets, or bottle holders
  • Recommend labeling cabinets and storage areas with hazard class labels
  • Rule of thumb - should not store more than 10 gallons of flammables outside a flammable cabinet
    • Includes flammable chemicals in use
peroxide formers
Peroxide Formers
  • Hazards of peroxide formers
    • Flammable
    • Can form potentially explosive crystals
  • All peroxide formers should be tested for peroxides every 6 months from the date opened
    • Record test date and results on container
    • Should also record date opened
    • Test strips available at Chemistry stockroom
  • Minimize quantities stored
peroxide formers42
Peroxide Formers
  • Common examples include:
    • Ethyl ether
    • Dioxane
    • Tetrahydrofuran
    • Sodium amide
    • Potassium metal
  • There are many others out there – read material safety data sheets
chemical waste epa
Chemical Waste / EPA
  • Hazardous Waste Issues
  • Satellite Accumulation Areas
  • Other Wastes
  • Universal Wastes
  • Used Oil
hazardous waste issues
Hazardous Waste Issues
  • All hazardous waste containers must be labeled with the words “Hazardous Waste” and with words identifying the contents
  • All hazardous waste containers must be kept closed
  • Containers must be in good condition
    • EPA and “Inherently waste-like”
hazardous waste issues45
Hazardous Waste Issues
  • Do not store chemicals in or around sinks without secondary containment
  • Waste should be stored in secondary containment
    • Trays, buckets, etc
    • Segregate by hazard class
hazardous waste issues46
Hazardous Waste Issues
  • Leave some airspace in waste containers
  • Do not accumulate excessive amounts of waste
  • Accumulate waste in the smallest size container needed for the experiment
  • Date containers when you are ready to submit a waste tag to EH&S
hazardous waste issues47
Hazardous Waste Issues
  • Satellite Accumulation Area
    • The term EPA uses for where you generate your waste
  • Hazardous waste must be stored at or near the point of generation
    • Means in the lab the waste was generated
    • Do not move waste between rooms
      • EPA would interpret this as creation of a 90 day storage area similar to what EH&S maintains
other wastes
Other Wastes
  • Check with building manager first to see what program they have for other wastes
  • Universal wastes
  • Used oil
  • Solutions containing Silver
universal wastes
Universal Wastes
  • Includes used batteries and light bulbs
  • Needs to be labeled with the words “Universal Waste _______”
  • Universal waste needs to have an accumulation start date
  • Dispose of within one year
    • Recommend disposal within 9 months
used oil
Used Oil
  • Must label container with the words “Used Oil”
  • Must store used oil in a proper container in good condition
  • Keep containers closed to minimize spills
    • Should store in secondary containers such as trays
used oil51
Used Oil
  • Do not mix other waste with used oil
    • Doing so can result in hazardous waste
  • Contact your building manager for the location of used oil drum in the building
solutions containing silver
Solutions Containing Silver
  • EH&S has a program to recycle Silver
    • Using a Silver filtering unit
  • Examples include:
    • Photographic fixers
    • Silver nitrate staining solutions
  • Contact your DSR for the location of the nearest Silver filtering unit or call Nathan Clark at EH&S at 4-8068
other regulations
Other Regulations
  • Radioactive Materials
  • Biohazardous Materials
  • Lasers
  • Pesticides
  • Shipping
  • Security
radioactive materials
Radioactive Materials
  • All rooms using radioactive materials must be listed on the radioactive materials permit
  • Exposure areas marked
    • All rad work surfaces must be labeled with rad signs or tape around the perimeter
  • No food or drink are allowed in rad labs
radioactive materials55
Radioactive Materials
  • Radioactive stocks must be locked up if no one is in the lab
  • Contact Agnes Morris with questions at 5-5600
biohazards
Biohazards
  • Requirements for Biohazardous materials
    • Access to room must be restricted
    • Includes proper signage on door
    • Hygiene and decontamination protocols are required
    • No food or drink are allowed in labs with biohazardous materials
biohazards57
Biohazards
  • Biological Safety Cabinets
    • Used for containment procedures for aerosols/splashes
      • Not designed for use as a chemical fume hood
    • Requires annual certification by an outside contractor
      • Vet school has a contract with B&V Testing
      • Other schools need to make their own arrangements
biohazards58
Biohazards
  • Training may include Blood Borne Pathogen and/or Basic Biosafety training
  • Self audit form available on the EH&S webpage
    • http://www.ehs.cornell.edu/bio/Selfaudit.htm
  • Contact the Biosafety Officer - Frank Cantone at 4-4888 with any questions
biohazard sharps
Biohazard Sharps
  • Sharps that require disposal in a sharps container
    • Needles and syringes
    • Or any item contaminated with a biohazardous agent or used in a biomedical laboratory
      • Pasteur pipettes, razor blades, scapels, microscope slides, and broken glass
biohazard sharps60
Biohazard Sharps
  • Must use a commercially available sharps container
    • Puncture resistant
    • Leakproof
    • Labeled with the biohazard symbol
  • Used food containers are NOT acceptable
biohazards61
Biohazards
  • All Regulated Medical Waste non-sharp items must be placed in red biohazard bags
    • Plasticware, gloves, toweling, etc
  • Must have a completed Cornell University Medical Waste Tracking Tag for disposal of Regulated Medical Waste
biohazards62
Biohazards
  • Dispose of Regulated Medical Waste through EH&S
    • Vet College has separate procedures
  • Contact Kevin Fitch with questions at 5-4624
lasers
Lasers
  • There are special requirements for class 3A and higher Lasers
lasers64
Lasers
  • Class 3A Lasers must be labeled with
    • The words “Caution” or “danger”
    • The hazard class
    • Power output
    • Type of laser
    • Wavelength
    • Pulse duration, if applicable
    • The room/work area must also be labeled with this information
lasers65
Lasers
  • Class 3B or 4 Laser requirements
    • Labeling similar to Class 3A requirements
    • Signs, including lighted signs when in use
    • Proper eye protection
    • Interlocking and/or blocking
    • Power control / cutoff switches
    • Standard Operating Procedures
lasers66
Lasers
  • There are special requirements for class 3A and higher Lasers
  • Proper training is also required
    • EH&S offers a Laser Safety training class
    • Contact Cindy Martin at 4-4473 for more information
pesticides
Pesticides
  • Pesticide use requirements
    • Proper labeling of containers
    • Proper training
    • Proper certification
  • Agricultural use, including greenhouses, require Worker Protection Standard (WPS) training
  • Contact Eric Harrington at 5-0485 or eh22@cornell.edu
shipping
Shipping
  • If shipping hazardous materials (including packages with dry ice), then you need proper training
    • DOT Hazardous Materials Shipping training
  • EH&S offers this training class
    • Contact Mike Lonon at 5-6995 for more information
security
Security
  • Understand that security of laboratories is a real issue in today’s world
  • Recognize that security is related to but different than laboratory safety
    • Accidental vs. intended
  • Realize there are simple steps you can take to help protect your laboratory and your research materials
security steps you can take
Security Steps You Can Take
  • First identify what items you should try to protect
    • Take a fresh look at your building and work areas
  • Minimize the quantities of highly hazardous materials kept on hand
    • Utilize substitution or disposal
  • Control access to research areas
    • Keep doors locked when no one is present
security steps you can take71
Security Steps You Can Take
  • Secure your highly hazardous materials
    • Locked storage cabinets
  • Know who is in research areas
    • Question people you don’t know
      • “Can I help you?”
    • Consider using ID badges
  • Be informed and train research group members on your security policy
security72
Security
  • Highly recommend attending the new EH&S training program:

“Security of Hazardous Materials

Used in Research”

  • Contact Czora at EH&S at 4-4693 for more information
emergency
Emergency
  • Aisle Space
  • Fire Extinguishers
  • Combustible Storage
  • Spill Kits
  • Emergency Procedures
  • Eyewash/Showers
  • HASP
emergency74
Emergency
  • Keep corridors and hallways clear of equipment, boxes, and other items
  • Aisle space
    • Storage of bottles, waste, boxes, equipment, wires, cords on floors
    • Need minimum of 36” aisle space between benches and equipment
fire extinguishers
Fire Extinguishers
  • Do not block fire extinguishers
  • Check to make sure extinguishers are fully charged
    • If not, contact Clayton Bronson at 5-8200
  • Do not block or wedge fire doors
combustible storage
Combustible Storage
  • Combustibles include:
    • Wood, paper, boxes, plastics
  • Keep amount of combustibles stored to a minimum
  • Keep away from sources of ignition
    • Electric power panels, open flames, etc
combustible storage77
Combustible Storage
  • Ceiling clearance for the entire room
    • Sprinklered areas - must not store combustibles within 18” below the crown of the sprinkler head
    • Nonsprinklered areas - must not store any combustibles within 2 feet of ceiling
eyewash showers
Eyewash/Showers
  • Ensure easy access to eyewash and emergency showers
    • Handheld bottles not acceptable
  • Should test eyewashes weekly
    • Run/flush for 2-3 minutes
    • EH&S does annual inspections
  • Contact EH&S at 5-5237 when new units are installed
spill kits
Spill Kits
  • In case of an emergency or when in doubt, CALL 911 or
    • Call 255-1111 when using a cell phone
  • Spill kits are recommended, but need proper procedures and training
  • EH&S offers the training class “Cleaning Up Small Spills”
hazard assessment signage program hasp
Hazard Assessment Signage Program (HASP)
  • All labs shouldhave HASP signage on outside of door
  • HASP will be available on the EH&S webpage soon
  • Need to submit updates to your DSR
    • HASP files need to be sent to EH&S to convert the updates for you
    • Contact Robin Goodloe at 5-5613 or jag16@cornell.edu
communication
Communication
  • Chemical Hygiene Plan
  • Standard Operating Procedures
  • Material Safety Data Sheets
  • Training
chemical hygiene plan
Chemical Hygiene Plan
  • Chemical Hygiene Plan (CHP) needs to be readily available
    • Required by OSHA
    • Recommend keeping hard copy in lab
    • Electronic version is acceptable
  • As part of the campus CHP, you still need to have site specific standard operating procedures
slide83
SOPs
  • Standard Operating Procedures (SOPs) are required for handling highly hazardous materials:
    • Highly toxic chemicals
    • Carcinogenic materials
slide84
SOPs
  • SOPs include information such as:
    • Chemical hazards
    • Authorized personnel
    • Training requirements
    • Use location
    • Personal Protective Equipment
    • Waste disposal
    • Decontamination
    • Exposure
    • Spill control
slide85
SOPs
  • See Chemical Hygiene Plan for more information
    • Generic and specific examples are available via the EH&S webpage - ww.ehs.cornell.edu
    • EH&S offers a “Writing SOPs” training class
material safety data sheets
Material Safety Data Sheets
  • Responsibility of supervisors to ensure MSDSs are accessible
    • Paper or electronic format
    • Should have MSDS websites bookmarked
    • Should be able to produce a MSDS within 5 minutes
  • EH&S recommends keeping hard copy of MSDSs in the lab
  • Always read the MSDS before working with new chemicals
training
Training
  • All lab workers are required to attend laboratory safety training
    • Should attend the EH&S training program “Chemical Safety for Laboratory Workers - Graduate Students and Employees”
  • Recommend hazardous waste training provided by EH&S for all generators of hazardous waste
    • Required by some departments and colleges
training88
Training
  • To see a complete list of EH&S training, go to www.ehs.cornell.edu and point to Training, then click on Safety Education Course Listing
keys to success
Keys To Success
  • Cooperation vs. confrontation
  • Provide solutions, not just citations
  • Be patient and persistent with changes
  • Be proactive and schedule a Laboratory Workplace Consultation with EH&S to get started NOW!
    • Voluntary assistance
    • Includes a consultation report
    • Contact EH&S at chemwaste@cornell.edu
    • Or call Agnes Morris at 5-5600
my offer to you
My Offer To You….
  • This training is available to all DSRs, faculty, staff, and graduate assistants at your location
  • “Hands On” In-Lab training is also available
    • You do the inspections
    • I’ll provide assistance and advice
  • Email to set up a time for this training program or for In-Lab training on inspecting your labs
questions

QUESTIONS???

Your comments are appreciated, please fill out a training evaluation form. Thank You!

Jerry Gordon

Manager For Laboratory Safety Programs

jpg29@cornell.edu