Laboratory supervisors and Principal Investigators have direct responsibilities for the safety of their workers under campus policy (Policy #5400), UC policy and the law. To assist in understanding these responsibilities, below is an overview of some specific safety tasks. Note that you may delegate specific tasks, but you can not delegate your supervisory responsibilities for safety. Items below are not meant to be a list of all possible safety responsibilities. For example, it does not address the specific requirements associated with radiation use, or use of infectious materials for which specialized safety regulations and committees exist (see Authorizations below). Please contact EH&S with questions.
Per OSHA, workers need to be made aware of the significant hazards of their workplace via documented training. Safe work practices must be conveyed, particularly for: new employees; employees given new work assignments for which training has not been previously received; when new hazards are introduced, etc. If there is an injury, or employee complaint to OSHA, investigators will probably ask for training records of your workers.
To mirror the above requirements, UC instituted a Laboratory Safety Training Policy in 2013. The policy and associated procedures are described in Sec. II of the UCSB Laboratory Safety Manual and Chemical Hygiene Plan. Covered therein are:
- summary of the policy;
- directions for accessing the live or online Fundamentals of Laboratory Safety* class mandated by the policy for every lab worker;
- access to EH&S training records;
- purpose and use of the Training Needs Assessment (TNA) form required under the policy. The form will walk researchers through the above requirements and provides a place to document their completion. The TNA is also a good checklist of all the basic administrative tasks to cover for a new lab worker – including those below.
*The Fundamentals class only covers basic issues and some topics for which specific OSHA standards mandate training, e.g., fume hoods, waste disposal, emergency procedures. EH&S training is not a complete substitute for lab-specific documented training.
2. Personal Protective Equipment (PPE)
Per OSHA, PPE is required to be provided, documented and properly used by workers. UC/UCSB policies and procedures on PPE are described in Sec. II of the UCSB Laboratory Safety Manual and Chemical Hygiene Plan. Covered therein are:
- the UC PPE policy;
- use of the required Laboratory Hazard Assessment Tool (“LHAT”) to identify/document the specific PPE needed, provide PPE training and issue a voucher for free lab coats and eyewear;
- free lab coat laundering
3. Chemical Hygiene Plan (CHP)
Each laboratory using chemicals must maintain a written CHP per Cal-OSHA. The intent of the CHP is to reduce employee exposure to chemicals. EH&S provides the generic CHP to each PI, which includes template forms and a Standard Operating Procedure library for customizing the CHP to your local operations. Note that if the generic binder is not customized, it probably does not meet the standard of a CHP. Your CHP must be shared with your workers and this should be documented. Per OSHA, your CHP must be reviewed/updated at least annually – EH&S updates the generic portions annually.
4. Occupational Exposure Limits
- Chemical: Per OSHA, over 500 chemicals have Permissible Exposure Limits (PEL) for inhalation due to their inherent hazard. PELs are time-weighted concentration averages, generally in ppm and can apply to short or long-term exposures. For example, for formaldehyde the PELs are 2 ppm (15 min) and 0.75 ppm (8 hr), respectively. It is the supervisor’s responsibility to ensure that their workers are not exceeding PELs. This is generally satisfied by working in a fume hood, glove box, or sealed systems.
- Heat: Outdoor workers fall under the OSHA Heat Illness Prevention regulation that mandates a written plan and training (both provided by EH&S) specific prevention measures.
- Noise: Individuals exposed to noise levels above an 8-hour Time Weighted Average of 85dBA (very rare in labs) must be enrolled in the UCSB Hearing Conservation Program.
5. Safety Data Sheets
(formerly known as MSDS)
Per OSHA, all chemical users must know what an SDS is; their relevance to their health and safety; and how to access them. EH&S covers this for you in the baseline training noted in #1. Hard copy SDS within the laboratory are preferable, but electronic access is acceptable - all workers should bookmark the UC SDS site.
Certain types of work require pre-authorization from a campus committee, or EH&S. Examples: Controlled substances/drugs (DEA authorization); Ionizing radiation; Infectious agents; Human or primate fluids/tissues; Toxic or pyrophoric gases use; Respirators; SCUBA diving; Animal use and Human subjects. To initiate an authorization, contact EH&S, or other relevant campus office. Also, modifications to the infrastructure of your spaces (e.g. utilities, walls) require authorization from Facilities Management and the Fire Marshal.
7. Fire and Injury Response/Reporting
All laboratory workers should know how to respond appropriately to reasonably foreseeable emergencies. Emergency response is covered in the EH&S orientation noted above in #1 and every laboratory should have a completed copy of the UCSB Emergency Information Flipchart posted. Fires must be promptly reported to the campus Dispatcher (911) even if the fire is out, especially if there is property damage, injury or extinguisher usage. All work-related injuries must be reported as soon as possible via your departmental office to EH&S and an Incident Report form filed.
8. Laboratory Door Placards
To aid emergency responders, every corridor entrance to laboratories has a placard conveying information regarding the types of hazards within and laboratory emergency contacts. The information is updated annually, but laboratories should contact EH&S if the placard becomes out of date at any time.
EH&S does annual laboratory inspections per OSHA. Labs should do periodic self-inspections (recommended at least twice a year) and are clearly more familiar with local safety issues.
10. Waste disposal
Generation of chemical waste, radioactive waste and some biological wastes are heavily regulated and penalties for non-compliance can be severe. Chemical wastes must be properly labeled at the time of initial generation and disposed of via EH&S within 9 months. Basic training on legal chemical waste handling is covered in the EH&S orientation noted in #1.
11. Minors in Laboratories and Shops
A UC policy describes the limitations on minors working in these campus areas. Lab supervisors have important and specific responsibilities under the policy. A summary of the policy can be found here.