Laboratory supervisors and Principal Investigators have direct responsibilities for the safety of their workers under campus policy (Policy #5400) and UC policy. To assist in understanding these issues, below is an overview of some specific tasks needed to meet your responsibilities. 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 committees exist (see Authorizations below). Please contact UCSB Environmental Health & Safety with questions.
1. Training: In general, workers need to be made aware of the significant hazards of their workplace by their supervisor, or designee, via documented training. Appropriate 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 to the workplace, etc. If there is an injury, or employee complaint to Cal-OSHA, investigators will probably ask for training records for your workers.
To assist supervisors with the above, EH&S offers baseline laboratory safety orientations - both live and Web-based. Per campus policy one of these trainings is mandatory for individuals working in laboratories. The version of training required varies by position of the individual. However, it only covers basic issues and some topics that specific OSHA standards mandate training for, e.g., fume hoods, waste disposal. EH&S training is not a complete substitute for laboratory-specific documented training. When workers complete the EH&S orientation, a training checklist provided to the supervisor includes a place to document training that occurred in the laboratory. Supervisors can search the EH&S training database by trainee, or their name.
2. 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 binder to each PI, which includes template forms for customizing the CHP to your local laboratory operations. Note that if the generic binder is not customized, it probably does not meet the standard of a CHP. The focus of your CHP should be on Standard Operating Procedures for safely handling Particularly Hazardous Substances, which Cal-OSHA defines as Carcinogens, Reproductive Toxins and Acute Toxins. Your CHP must be shared with your workers and this should be documented in the binder. Your CHP must be updated at least annually per OSHA.
3. Occupational Exposure Limits- Chemical: Per Cal-OSHA, over 500 chemicals have Permissible Exposure Limits (PEL) for inhalation due to their inherent hazard. PELs are time-weighted concentration averages expressed in parts per million 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 supervisorís responsibility to ensure that their workers are not exceeding PELs. With volatile materials, this is generally satisfied by working in a fume hood, glove box, or completely sealed systems. Also, some PELs note that the material is readily absorbed through the skin.
- Heat: Researchers who work outdoors are subject to the Cal-OSHA Heat Illness Prevention regulation that mandates a written plan (provided by EH&S) and training on appropriate protective measures.
- Noise: Occupational limits on noise exposure are rarely an issue in laboratories. Contact EH&S for help with any exposure-related issues.
4. Material Safety Data Sheets (MSDS): Per OSHA, all chemical users must know what an MSDS 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 MSDS within the laboratory are preferable, but electronic access is acceptable - all workers should bookmark the UC MSDS site.
5. Personal Protective Equipment (PPE): Per campus policy, specific PPE are required for lab workers. The specific PPE varies depending on the material/process used, e.g., corrosives, oxidizers, high-pressure work, etc. A poster mounted in every lab summarizes the requirements. Supervisors are responsible for ensuring PPE is being used per policy.
6. Authorizations:Certain types of work require authorization from a campus committee, or notification of EH&S. Authorization requests must be approved before any work may commence. 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. ventilation, utilities) 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 (9-911) 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 Accident 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 is out of date at any time.
9. Inspections: Per OSHA and the State Fire Marshal, laboratories must do periodic self-inspections (recommended at least twice a year). EH&S does annual laboratory inspections per campus agreement with SB County Fire. However, the EH&S inspections do not alleviate the need for supervisors to do their own inspections/corrections.
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 of workers on legal chemical waste handling is covered in the EH&S orientation noted in #1.