Staying in Compliance - Overview of Regulatory Challenges ...

Navigating Safety-Related Compliance

Karen Gillis, MS, CBSPAssoc. Director, Research ServicesUF Division of Environmental Health & Safety TEL: [email protected]

Why safety compliance matters

• Loss of reputation (institution, PI)

• Loss of funding (lab, Dept., institution)

• Legal action

• Civil or criminal penalties

• Fines

Risks to doing the work or science !

More importantly…..Risks to people

Lapses?

Sheri Sangji, Lab Research Assistant, Harran labUCLA, 2009

� Died 2.5 weeks after severe burns

� Accident during transfer of

pyrophoric chemical

� No lab coat, insufficient training

� First criminal case from a lab

accident

� UCLA paid >$4.5 million in legal

fees

PI Responsibilities◦ Facilitate open dialog on safety

◦ Do risk assessments

◦ Ensure all get sufficient training

◦ Lead by example

◦ Discuss safety aspects of their work in funding proposals, lab meetings, conferences, etc

◦ Discuss lessons learned

◦ Assume ultimate responsibility for safety in your area

How does EHS know when you’re in compliance?

� Satisfactory inspections

� No issues with regulatory agencies

� No complaints

� No incidents/accidents

Compliance Check Points

� EHS-Ufirst: Award Compliance form

� EHS-OTL: MTAs

� EHS-IACUC: protocol approval

� EHS-Purchasing: Purchase of certain

equipment or hazardous materials

Dr. William ProperzioDirector, EH&S

Computational Support & Reception

Fiscal Support

Associate Director

Research Services

Associate DirectorFacility Support Services

Associate DirectorOccupational Safety &

Risk Management

Biosafety

Radiation Control

HazardousMaterials

Management

Laboratory Safety

Building Codes

Fire Code Enforcement

Fire Equipment Services

Pest Control

Americans with Disabilities Programs

Industrial Hygiene

Occupational Medicine

Training Support

Insurance Programs

Risk Management

Dive Safety

EHS = Safety in the work, teaching, clinical, & research environment

Our Programs

www.ehs.ufl.edu

Gator TRACS

Web Portal• Lab’s safety “dashboard”

• Lab members (roster)

• All member’s training

• Lists all hazards in the lab &

hazard mitigation plans

(“LATCH”)

• Lab Inspection Results (with

photos!)

• Email reminders

• Portable device friendly

Key Areas for Biosafety Compliance

� Register biohazard use projects with EHS◦ A subset will go to the Institutional Biosafety

Committee (IBC) for approval◦ Update these annually

� Get any State or Federal permits needed, read & comply with permit requirements, send Biosafety a copy, keep permit up to date

� Know how to dispose of biological waste� Get training on shipment of biohazards

Key areas for Laboratory Safety Compliance

� Each lab needs lab-specific Chemical Hygiene Plan or “LATCH” …. fundamental

� Keep the chemical inventory up to date –ChemTracker Program

� Store & label chemicals safely� Manage chemical waste properly� Register projects/work involving Minors in labs

(Science Fair, summer camp programs, etc)

Key Points: Pesticide Use� Medical Surveillance Program:

◦ All users of Toxicity Class I (Danger or Poison Label)

◦ Frequency of more than 4 days per month and volume greater than 16 fl. oz.

◦ Cholinesterase baseline (for OPs and carbamates)

◦ Medical Monitoring/testing – initial, periodic, & exit

◦ Applicators medically cleared for respirator

� Annual training & fit testing

� Include material in the Chemical Hygiene Plan/LATCH

� Track quantities in ChemTracker

� PPE & Training required

Other IFAS-relevant areas:� UAS (Drones) [email protected]

◦ FAA license, register drone w/ FAA & EHS, Register all flights w/ EHS

� Hearing Conservation - initial & annual audiograms

� Forklift training

� 15-Passenger van training

� Heat stress training

� Tractor safety

� Radioactive Material Use Authorization

� Laser / X-ray System Registration

� Etc…..

New PI?