Department/Unit Safety Coordinator’s Seminar

1. Department/Unit Safety Coordinator’s Seminar Enterprise Risk Services/Environmental Health & Safety Tuesday, December 3, 2013

2. Agenda: • 10:05 – 10:25 How to Prepare for Regulatory Visits (Lance Jones, Dan Kermoyan, EH&S) • 10:25 – 10:55 Laboratory Safety Program Overview (Dan Kermoyan, EH&S) • OSU Laboratory Categories (LCAT) • Laboratory Safety Assessments • Campus SOPs • 10:55 – 11:00 Q & A • ** 10-Minute Break ** • 11:00 – 11:30 Regulatory Compliance Issues (Lance Jones, Pete Schoonover, Andy Kenst, Matt Philpott, Brian Lilley, EH&S) • Is your Chemical Inventory up to date? • Are your chemicals and wastes labeled and stored safely? • Does your laboratory have a chemical hygiene plan? • Have your employees received training? • Autoclaves, Eyewash-Shower testing • 11:30 – 11:40 Waste minimization/recycling program (Kent Lanning, EH&S) • 11:40 – 11:45 Safety Data Sheets (SDS) Resource (Lance Jones, EH&S) • 11:45 – 11:55 Laboratory Safety & Haz Waste Training (Matt Philpott, Lance Jones, EH&S) • 11:55 – 12:00 Q & A; Future topics?

3. How to Prepare for Regulatory Visits Lance Jones, Dan Kermoyan, EH&S

4. Potential Regulatory Agencies visiting the OSU campus Federal State DEQ: Hazardous waste; Environmental OR-OSHA: Enforcement or Consultation Oregon Health Authority: Public Health; Drinking water; Radiation OR Dept. of Agriculture: Waste discharge; Disease prevention; Food • EPA: Hazardous waste; Environmental • DOT: Shipping; Transportation • NIH/CDC: Recombinant DNA/Select agents • DHS: Chemicals of Interest • APHIS: Plants, recombinant work

5. Potential Regulatory Agencies visiting the OSU campus County Agencies City Agencies Public Works: Waste water/Storm water Corvallis Fire: Fire prevention inspections • County Health: Public Health/Sanitation/Disease reporting • County Env. Health: Water systems/Waste disposal

6. What Occurs During an Inspection? • Unannounced • Injury; Incident; Complaint; Scheduled • Opening interview: ID, Why, What • Program review • Site visit • Performance-based review (observations, photos, review training records, review procedures, conduct interviews) • Closure and summary

7. Department/Unit Response • Contact EH&S • Limit conversation to what is directly requested • Q: “Have you received training on SDS’?” • A1: “Yes” or “No” • A2: “Yes, but I don’t know where they are…” • A3: “No and no one has ever offered training to me…”

8. Department/Unit Response • “Calm confidence” approach • “Interested compliance” attitude • If in doubt, ok to get back to them on an issue • OK to take: • Duplicate photos • Split samples • Notes • Inspection results will take awhile • Review notes with department and EH&S soon as possible

9. OR-OSHA Violations Classification types: • Serious violation – substantial probability of serious physical harm to employee. • Other than serious • Minimal – no direct or immediate impact to health and safety of employee. Penalties assessed: • Serious: $300 - $7,000 • Other than Serious or Minimal: $0 - $300 • Can adjust downward for history, good faith effort, & immediate action.

12. EPA Hazardous Waste violations • Waste label not properly filled out, incomplete information • Hazardous waste training • Open waste containers • Spillage or leakage of waste (including contamination on the container) • Failure to determine waste as hazardous (e.g. it is clearly waste like but there is no waste label) RCRA: Administrative,Civil, or Criminal Actions • Compliance Action • Corrective Action (release to environment) • Imminent & Substantial Endangerment • $5,500 - $27,500 per day, per violation • Criminal Actions: $50,000 - $250,00 per day, per violation

13. EPA Hazardous Waste fines • April 2003 - A private college in Long Island, NY was fined $112,310. • October 2003 - A private university in upstate NY was fined $60,500. • RCRA violations • Failure to determine if the wastes generated were hazardous wastes; • Failure to separate incompatible wastes.

14. EPA Hazardous Waste fines • July 2003 – Medical school in New Jersey was fined $166,658. • Failure to determine if the wastes generated were hazardous wastes. • Failure to maintain the facilities to minimize the risk of releases of hazardous waste to the environment; did not ensure that its facility and staff received required training • Failure to keep waste containers closed; and improperly disposed of hazardous wastes, such as solvents and mercury wastes.

15. University of Hawaii EPA hazardous waste violations in October 1997 at the University of Hawaii: • $1.7 Million settlement; $1.2 Million towards environmental projects; received settlement in 2001. • Inspectors found improperly stored and labeled chemicalsincluding flammables, corrosives, poisons, mercury and hundreds of other unknown chemicals. • The Department of Health continued to inspect other facilities within the university system and found similar violations at • Kauai Agricultural Center • Waiakea Agricultural Experiment Station in Hilo

16. What will they see? The Good

17. The Bad

18. The Ugly

19. Questions?

20. Laboratory Safety Program Overview Dan Kermoyan, EH&S

21. Lab Safety Program: Identifying Needs • Fallacy: compliance = 0 risk, OSHA << EPA • Regulatory agencies • Observations/Knowledge of programs • Discussions with campus • ISO 14001 Analytical Model • Quantify, Rank, Prioritize • 2009/2010

22. Vulnerability Analysis compliance vs. riskOSHA << EPA Risk Identification & Analysis Prioritization/Mitigation Plan Health & Safety Training Required for all Faculty & Staff: All faculty, staff, and student employees to obtain health & safety training according their job roles. Training shall be documented and kept on file with the supervisor and employee. • Most new employees are not enrolled in a health & safety training program; new employee health & safety training is not mandatory. • Probability x Magnitude • Impacts: Human, Facilities, Institutional • HIGH Risk rank; Scored 14.2

23. Vulnerability Analysis Risk Identification & Analysis Prioritization/Mitigation Plan Preventative Maintenance Budget for Building Safety Equipment: Fund PM program for testing and repair of building safety equipment: Emergency eyewash and showers, fume hoods, biosafety cabinets,and air balancing. • Safety equipment testing is sporadic and not funded; emergency eyewash/showers, air balancing of fume hoods and room air, etc. • Probability x Magnitude • Impacts: Human, Facilities, Institutional • HIGH Risk rank; Scored 14.2

24. Vulnerability Analysis Risk Identification & Analysis Prioritization/Mitigation Plan Work-place Health & Safety Audits: Supervisors to conduct annual self-audit of work areas and work practices under their control. EH&S to conduct routine audits of work areas based on a priority, hazard level designation. Corrective actions to be implemented by the supervisor or university. • No formal lab safety audit program is occurring. • Probability x Magnitude • Impacts: Human, Facilities, Institutional • HIGH Risk rank; Scored 15.8

25. Addressing the Vulnerabilities • Training modules, Safety Instructions, Web resources • EHSA data base/Qualtrics • Equipment testing program • Lab Safety Assessments • Policy/SOP development Health & Safety Training Required Training shall be documented Emergency eyewash and showers, fume hoods, biosafety cabinets Work-place Health & Safety Audits Laboratory Policy/SOPs

26. Lab Categories (LCAT) • “Laboratory” defined • Planning’s data: 1,100 spaces • Planning + EHS data: 1,618 spaces • Grouped according to materials used/stored • Assigned an assessment frequency

27. Laboratory Safety Assessments For 1,100 spaces 50% follow up anticipated Consolidated audits Efficiencies/software explored 5.2 FTE For 1,618 spaces 7.7 FTE EH&S to start with LCAT 4 spaces Assigning spaces now Will start with Gilbert Hall Resource-based/Pre-notice February 1st or sooner Self-Audits will be needed

28. Campus Policies/SOPs “Wait-on” (2 policies) “Green light” (5 policies) Lab Categorization and Laboratory Assessments Annual Chemical Inventories Chemical Hygiene Plan Authority to Abate “Hazardous Conditions” Mandatory Lab Safety Training for all PIs and staff • Campus Department Safety Coordinators (DUSC) Maintains chemical inventories, proper labeling of chemicals and wastes, maintains training records for their lab staff, and conducts yearly self-audits. • Campus Laboratory Safety Committee (LSC) • Issues Chemical Use Authorizations. • Conducts auditing of OSU’s Laboratory Safety Program and reviews safety assessment results.

29. Questions? 10-Minute Break