Laboratory/Technical Area Safety Policy

Purpose

The purpose of the University of Dayton (University) Laboratory/Technical Area Safety policy and accompanying Integrated Health & Safety Manual is to provide guidance and procedures to work safely in University laboratories/technical areas.  The University is committed to provide a safe and healthy working and learning environment for all faculty, students, employees, visitors, volunteers and contract employees and to maintain compliance to federal, state and local health and safety regulations.

Scope

This policy applies to all laboratories/technical areas and laboratory/technical area workers, researchers, faculty, students, visitors and volunteers working in laboratories, technical areas or other similar work spaces.

Policy History

Effective Date:  January 25, 2016

Approval:  February 9, 2023

Policy History: 

• Approved in original form:  January 25, 2016
• Approved as amended:  February 9, 2023

Maintenance of Policy:  Assistant Vice President for Compliance, Environmental Health & Safety, Division of Audit, Risk and Compliance

Definitions

(a)  “Laboratory/Technical Area”: A laboratory/technical area is any location where hazardous materials or equipment may present a potential hazard are used or stored.  It includes, but is not limited to research laboratories, teaching laboratories, QA/QC and analytical laboratories, chemical storage rooms, waste accumulation areas/locations, cold rooms, vivarium, engineering and machine rooms, workshops, art studios and theater areas.

(b)  “Supervisor”: For purposes of this policy, a supervisor is an employee who may have authority to hire personnel, evaluate performance, direct work assignments, apply progressive discipline, direct resources to correct identified safety issues.  This would include a principal investigator, researcher, faculty and staff.  Unless defined in writing, the default “supervisor” in laboratory/technical areas is the Principal Investigator.

(c)  “Integrated Health & Safety Manual”: Comprehensive written manual containing guidance and procedures for safely working in laboratory/technical areas.

(d)  “Training needs assessment”: An assessment of safety training needs will occur and be documented for all workers before the worker undertakes their work duties.  This will include completing the hazard assessment and online training for laboratories/technical areas through the enterprise training management platform, and assessing for site-specific training needs.

(e)  “Worker” For purposes of this policy, a worker is an individual who actively performs work functions.  A “worker” may be faculty, staff, volunteer, undergraduate student, graduate student or visitor/visiting researcher or scholar working in the laboratory/technical area.  For the purpose of this definition, “worker” excludes individuals who only passively participate in tours, lectures, conferences, etc. and enrolled undergraduate students in a teaching laboratory/technical area.

Policy

This policy defines work practices and procedures as well as roles, responsibilities and enforcement of policy, and response to non-compliance to protect laboratory workers, researchers, faculty, students, and visitors and volunteers working in laboratories, technical areas or other similar work spaces and to maintain a safe and healthy working and learning environment.

I.  ROLES AND RESPONSIBILITY

Deans, Directors, Department Chairs, Heads of Academic and Research Units have the primary responsibility for the health and safety of their staff and students, and are responsible for:

• Communicating, promoting and enforcing this policy in areas under their control.
• Collaborating with faculty and staff to implement the Integrated Health & Safety Manual into the function of the laboratory/technical area.
• Making budget arrangements for health and safety requirements and improvements.

Supervisors/Principal Investigators are responsible for implementing the Integrated Health & Safety Manual in their work areas.  Responsibilities include but are not limited to:

• Promote a culture of safety and teach the requisite skills needed to work safely in laboratory/technical areas.
• Complete the training assessment for workers and students and verify they have completed the necessary training.  Retain training records and all related documentation.
• Implement and enforce the requirements of the Integrated Health & Safety Manual for laboratories/technical areas under their supervision.
• Conduct hazard reviews of all laboratory procedures and equipment and have written operating procedures or protocols.
• Post door hazard signage to communicate the hazards associated with the laboratory/technical area.
• Maintain compliance of the laboratories/technical areas, including the work practices for workers and students.
• Make available and enforce the use of the following: appropriate personal protective equipment, Safety Data Sheets (SDS’s), and chemical inventories.
• Conduct internal inspections of the laboratory/technical areas according to the Integrated Health & Safety Manual guidelines.
• Correct deficiencies in a timely manner.
• Dispose of waste in accordance with environmental regulations in coordination with EHS.
• Request assistance from EHS as needed to report and assist with spills or other incidents, assist with a hazard analysis, developing training, etc.
• Notify EHS of a change to a laboratory/technical area use, such as establishing, repurposing, renovating, or closure of a space.

Workers are responsible for working safely in the laboratory/technical area and will:

• Complete all required safety training.
• Read, understand and follow the Integrated Health & Safety Manual and other related safety policies and procedures for the laboratory/technical area.
• Plan and conduct each laboratory/technical area operation in accordance the Integrated Health & Safety Manual or standard operating procedures developed by the supervisor.
• Notify the supervisor of any hazardous conditions or unsafe work practices in the work area.
• Work within designated engineering controls and wear appropriate personal protective equipment as required.
• Immediately report any injury or illness, including near misses, to the supervisor and fill out any necessary paperwork.

Environmental Health & Safety (EHS) is responsible for providing interpretation and clarification regarding this Policy.

• Review and update the Integrated Health & Safety Manual according to changes in safety regulations and best practices.
• Provide consultation and tools to assist supervisors in performing the safety training needs assessment and with developing training.
• Conduct safety inspections.
• Provide technical guidance and investigations for laboratory/technical area mishaps, accidents and injuries.
• Provide management oversight and assistance with environmental compliance, transport and disposal of hazardous waste.
• Enforce this policy and assist to correct deficiencies in a timely manner in the laboratory/technical area.

II.   ENFORCEMENT OF POLICY AND RESPONSE TO NON-COMPLIANCE

A program of periodic inspection helps keep laboratories/technical areas in safe operating condition.  Inspections safeguard the quality of the University’s safety program and embrace the following goals:

• Principal investigators, faculty, staff, researchers, students and visitors are to follow safety policies and procedures, and complete training.
• Activities should be conducted in a manner to avoid exposure to hazards.
• Maintain facilities and equipment in a safe, code-compliant operating condition.

Environmental Health & Safety provides oversight for the inspection and compliance program and has the authority to take corrective action to address non-compliance.

The compliance program requires laboratory/technical area supervisors and other responsible parties to take appropriate and effective correction action upon notice of a deficiency or non-compliance.  Deficiencies are required to be corrected in a timely manner.  Failure to take corrective actions in a timely manner will result in a repeat deficiency finding and an escalation of the notification to the Department Chair, Dean and/or Vice President of Research or Provost.  Depending on the severity of the deficiency, EHS has authority to suspend activities until the deficiency is corrected.

III.   TRAINING

Effective training is critical to facilitate a safe and healthy work environment and prevent accidents.  All principal investigators, faculty, staff, researchers, students, visitors and volunteers must complete the required safety training.  EHS offers general classroom and online training through an enterprise training management platform, plus resource materials to assist with site-specific training.

Trainings include:

• All laboratory/technical area personnel must complete general and site-specific safety training before beginning work, prior to new exposure situations, and as work conditions change.  Training is based on job activity and hazards encountered in their work and should provide information regarding job hazards, possible health effects and required work practices and procedures.
• Training must be completed annually, or other frequency as specified.
• Faculty are responsible for student safety training prior to any activity that has a potential for a safety concern i.e., lab, field trip, internship, field study, etc., and must maintain documentation of the training.
• Supervisors/principal investigators have the specific responsibility to perform a training assessment, communicate training requirements, and provide and document site-specific training for staff and students in their jurisdiction, including safety meetings, one-on-one training, classroom and online training.

IV.   MINORS AND VISITORS

Faculty, staff and researchers that have minors working in the laboratories/technical areas under their jurisdiction must review and understand the Children on Campus and Working with Minors Policy.  For their own safety and protection, minors are not permitted to be or work in a laboratory/technical area alone.  All minors who are participating in a University program or a program taking place on the University campus must be supervised by an authorized adult(s) at all times in accordance with the Children on Campus and Working with Minors Policy.

Reference Documents

1. Safety Training Policy
2. Children on Campus and Working with Minors Policy
3. Integrated Health & Safety Manual
4. Environmental Health and Safety Policy

Applicable Regulations

1. OSHA 29 CFR 1910.1450 Occupational exposure to hazardous chemicals in laboratories