LABORATORY INSPECTIONS

1. LABORATORY INSPECTIONS Jerry Gordon Manager For Laboratory Safety Programs jpg29@cornell.edu

2. 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.

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. Inspection Areas • Housekeeping • General Safety • Chemical Safety • Chemical Waste / EPA • Other Wastes • Other Regulations • Emergency • Communication

11. 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

12. 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

13. 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

14. General Safety • Personal Protective Equipment • Electrical Safety • Refrigerators • Machine Guarding • Fume Hoods • Gas Cylinders • Respirators

15. 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

16. 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?

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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

26. 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

27. 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

28. 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

29. 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

30. 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

31. Chemical Safety • Proper Labeling • Chemical Segregation • Chemical Storage • Peroxide Formers

32. 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

33. 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)

34. Chemical Labeling • Should date containers when received and opened • Dispose of expired and old chemicals • Especially recommended for peroxide formers

35. 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

36. 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

37. 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

38. 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

39. 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

40. 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

41. 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

42. Peroxide Formers • Common examples include: • Ethyl ether • Dioxane • Tetrahydrofuran • Sodium amide • Potassium metal • There are many others out there – read material safety data sheets

43. Chemical Waste / EPA • Hazardous Waste Issues • Satellite Accumulation Areas • Other Wastes • Universal Wastes • Used Oil

44. 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”

45. 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

46. 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

47. 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

48. Other Wastes • Check with building manager first to see what program they have for other wastes • Universal wastes • Used oil • Solutions containing Silver

49. 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

50. 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