Original: August, 2007. Revised: Dec. 19, 2007 UBC DEPARTMENT OF MATERIALS ENGINEERING Guidelines for Workplace-Specific Safety Training Introduction This material provides an explanation of training requirements and a template for supervisors of new students and employees in research labs. Legislation enacted as of July, 2007 requires that all personnel be adequately trained prior to commencing work. Training and orientation are provided at two levels: (1) departmental/university, and; (2) by the supervisor. At departmental level the necessary safety training and orientation is outlined and documented in the MTRL Student and Employee Safety Training Checklist, available on the MTRL website, safety page. The document: Introduction to the MTRL Safety Program should be read over. It can be found on the MTRL website, safety page. Training to be provided by the supervisor covers the specific hazards associated with the individual labs or areas. This needs to be documented. A checklist can be developed to ensure the necessary topics are covered. Written information can be assembled for the student/staff to read. This document contains the following information and templates, which may be adapted for use in the laboratory. 1. Risk Management Workplace Safety Orientation: http://www.riskmanagement.ubc.ca/sites/riskmanagement.ubc.ca/files/uploads/Documents/Work place_Safety_Orientation.pdf This is an information and checklist document for providing safety training. Note: Some of what is covered in this is already covered in the Departmental Safety Orientation Seminar and the MTRL Student and Employee Safety Training Checklist, especially: Introduction to the Department's Health and Safety Program (p. 5) Personal safety checklist (pp. 8-9) 2. Example Laboratory Safety Orientation Checklist This may be useful as a template for safety training in labs. It can be modified as required. It follows on the next page. 1 Original: August, 2007. Revised: Dec. 19, 2007 Updated Mon/Day/Year Training provide by: Signature Name of student/employee Date: Student/Staff UBC policy 7 reviewed Provide Safety Orientation checklist Provide General Lab Guidelines Outline lab training requirements Review the lab working alone policy Explain right/duty to refuse unsafe work Review the safety inspection checklist Inform of need for: Lab Chemical Safety course Dept. safety seminar Tour around lab(s) Equipment Persons responsible for the lab(s) Type of work being done Use of fumnehoods Review the hazards in the lab Review the four hazard minimization methods Introduce to other group members Location of first aid kit Procedure for obtaining first aid Reporting accidents/incidents The eyewash station The safety shower 2 Original: August, 2007. Revised: Dec. 19, 2007 Safety glasses requirement Other PPE required No food in lab Keep work areas tidy Keep floors, aisles, window sills clear Location of chemicals/materials, including Inventories: Chemicals Other materials (if distinct, e.g. minerals) Location of equipment (shelves, benches) Accessing Stores Machine shop help Electronics shop help Surface analysis Transporting acids, solvents in large glass bottles (carriers) Ordering items through stores Sample labeling instructions Waste handling: Organic solvent waste Labeling Storage Disposal to sinks Treatment prior to disposal to sinks Commercial disposal Sharps Clean, broken glass Clean, unbroken glass Dirty, broken glass Plastic sample bottles Good chemical/materials handling practice: WHMIS Consult MSDS Acidic, basic chemicals 3 Original: August, 2007. Revised: Dec. 19, 2007 Corrosive, oxidizing, reactive, flammable, toxic, carcinogenic chemicals Use the right gloves Dust masks When to use fumehoods Small spills Avoiding contamination What to put in flammables cabinet (flashpoint <37.8°C) Difference between flammable and combustible (>37.8°C flashpoint) What to put in corrosives cabinet Non-explosion proof fridge use Training will be required for using pressurized gas cylinders Handling spills: The spill cart Getting help Courtesy: Replenish supplies: Operating equipment: Where training will be required Cautions Maintaining Inspecting Warning signage for experiments Locking up the lab 3. Instructing personnel in new tasks Adequate training must be provided for someone taking on a new task that is outside their current expertise. (For example, when someone needs to conduct new procedures with hazards they have not been previously trained to deal with.) This may take the following forms: Risk Management safety courses Documented safe work procedures (repetitive procedures without complex or variable hazards) Documented safe work protocols (for work that may have a variety of possible hazardous situations) Personal training form the supervisor or a designated person External training such as courses offered by a supplier or manufacturer A key facet of this training is that it must be documented. When a WorkSafeBC inspection is conducted this documentation may be requested. Failure to document the training provided may be taken as a violation of regulations and can result in sanctions. Documentation includes: 4 Original: August, 2007. Revised: Dec. 19, 2007 A description of the training required for various activities Training subject matter Records that the training was provided The records of training provided can be a training record sheet that is dated and initialed by the worker/student and the training provider. The supervisor or his/her designated training provider may do this. One form may be used and updated as required. All training documentation and records done under the auspices of the supervisor must be kept by the supervisor and must be readily accessible. Records of training required at the departmental level are maintained by department. Suitable in-house training depends on the complexity and hazards associated with particular activities. This may include: Verbal descriptions Written instructions Physical demonstrations In a research laboratory it may be difficult to cover all the bases. However, efforts must be made to ensure that adequate training is provided and documented. An example of a Laboratory Safety Orientation Checklist was provided above. This may be able to cover several of the bases. Each supervisor will need to set up their own system. 3. UBC Policy 7 This is reproduced in the Personal Safety Orientation Worksheet that all new personnel are required to complete. Part of the requisite safety training is to review policy 7 with the student/staff. 4. Right and responsibility to refuse unsafe work – the process Under WorksafeBC regulations an employee has the right and duty to refuse unsafe work. The associated process is explained here. The following material is derived from the UBC Risk Management safety committee training manual. “No member of the faculty, staff or student should be doing any activity if they believe that the activity would create an undue hazard to themselves or to others. Occupational Health and Safety Regulation (Section 3.12) of British Columbia (WCB) addresses this issue with regulations. Further, WCB legislation requires that all employees must be trained and be aware of all hazards to which they are likely to be exposed. Workers have a “Right to Know” the hazards of their work.” 5 Original: August, 2007. Revised: Dec. 19, 2007 1. When someone has reasonable grounds for believing that an activity they are about to do carries a risk of death, serious injury or serious illness towards any person, including themselves, they have the right and responsibility to report the circumstances to their supervisor (principle investigator). 2. The supervisor will investigate and (a) ensure that any unsafe condition is remedied without delay, or (b) if in his/her opinion the report is invalid, inform the one who made the report. (Discussion with the safety committee may be helpful.) 3. The supervisor may not assign the work to another person without informing them that the work has been refuse, the reason for refusal and their right to refuse the work. 4. When step 2. does not resolve the matter, the supervisor shall investigate it in the presence of the complainant and also: (a) a co-worker representative from the safety committee, or (b) a member of the union representing the worker, or if (a) and (b) are not available, (c) any reasonably available worker selected by the complainant. 5. If the matter is not resolved both the supervisor and complainant must notify a WorksafeBC officer who shall investigate without undue delay and issue necessary orders. Risk Management is also to be informed at this point. 6. The refusing worker may not be subjected to disciplinary action as he/she acted in compliance with 3.12 regulation. 7. A temporary assignment to alternative work (at no loss of pay) can be made. This shall not constitute disciplinary action. 5. Safety Rules (a) Lab/area specific safety rules Supervisors may have specific safety rules for their areas. These need to be posted and may be provided in written form. The supervisor is responsible to ensure that the safety rules are communicated and that they are followed. (b) Department safety rules These safety rules are general to students/staff working in the department. All personnel should become familiar with these basic safety rules. For individuals These apply to all labs (research and undergraduate), shops areas and all areas of the stores. 6 Original: August, 2007. Revised: Dec. 19, 2007 (a) Suitable eye protection must be worn at all times, in laboratories and other indicated hazardous areas, by all personnel and visitors. (Suitable eye protection depends on the area and activities. Supervisors are to determine the minimum requirements.) (b) Lab coats have to be worn by in all laboratories where chemical hazards exist. Lab coats are required for all undergraduate labs. (c) No bare legs are permitted in any laboratory (research or undergraduate) or any shops area or in any area of stores. (d) No open-toed footwear is permitted in any laboratory (research or undergraduate) or any shops area or in any area of stores. Footwear must cover the whole foot. (e) Long hair must be tied back on any person when present in any laboratory (research or undergraduate), shops area and stores. (f) Eating and storage of food or drink items is not permitted in any laboratory (research or undergraduate), the shops or any area of stores. (g) “Horesplay”, practical jokes, unnecessary running, threats, assaults and fighting are prohibited. (h) All employees and students are required to maintain clean and tidy work areas and keep aisles and exits clear of clutter. (i) Emergency equipment must be readily accessible at all times. Examples include: eyewashes, safety showers, electrical panels, fire extinguishers, fire alarms etc. (j) In some areas steel-toed footwear may be required if deemed necessary by the supervisor or the department. (k) Defective equipment and facilities must be repaired prior to use or measures must be put in place to prevent use by others until repaired. (l) Dangerous goods (as defined by the transport of dangerous goods regulations) may not be shipped from, or received into the department except by trained and qualified personnel. (The stores keeper has TDG certification.) (m) All personnel must receive adequate safety training prior to commencing any work. (n) Building entrance doors may not be left propped open. This may pose a security risk to other occupants. (o) No earphones may be used in lab or shops areas. 7 Original: August, 2007. Revised: Dec. 19, 2007 (p) Working alone outside of normal weekday hours in a lab or shops area may be done only as per the supervisor's working alone policy. For supervisors Supervisor's responsibilities are set out in UBC policies and in law. A summary is provided here. (a) Supervisors must ensure that adequate training is provided for all potentially hazardous activities conducted in their areas prior to work being commenced. This includes sending personnel to university or departmentally required safety courses, reviewing written procedures and demonstration of methods and procedures as required. (b) Supervisors are responsible to develop written safe work procedures for repetitive tasks with an associated hazard. These must be posted in the area associated with the equipment or materials involved. Supervisors must ensure that all personnel performing these tasks read and follow these instructions. (c) Where deemed necessary supervisors are responsible to develop written safe work protocols (guiding principles) for complex and varied tasks with a variety of associated possible hazards. Supervisors must ensure that all personnel performing these tasks read and follow the guidelines and instructions. (A generic statement describing the nature of the hazards associated with the work in a particular research lab, principles of how to control and minimize hazards and responses to emergencies may suffice where deemed adequate.) (d) The supervisor must perform monthly safety inspections of his/her area using monthly inspection form. This is available on the MTRL website safety page: http://www.mtrl.ubc.ca/safety/Supervisor%27s_monthly_lab_inspection_form.doc The form may be modified as necessary. The supervisor may designate someone in the lab to perform the inspection. The supervisor then must ensure that the designated inspector is suitable for this duty. The supervisor must ensure that safety violations are corrected promptly. The completed safety inspection forms need to be posted in the area. (e) Supervisors shall ensure that all hazardous materials in their areas are appropriately labeled. This includes the name of the person responsible for the sample or material, the composition of the material (written in words, no chemical formulas alone), concentrations and principal hazards. If the sample is to be sent out for analysis or testing the added phrase, "Hazardous Laboratory Sample" is required for WHMIS-controlled materials. A labeling guide is available: http://www.mtrl.ubc.ca/safety/labels.xls 8 Original: August, 2007. Revised: Dec. 19, 2007 (g) Emergency procedures, access to MSDS information and location of the spill cart must be posted in every laboratory (research and undergraduate). (h) Supervisors must maintain an up-to-date chemical inventory of all chemicals in each laboratory or area. It must be updated at least once per year. The inventory must be posted in the lab or area. (i) Supervisors need to review training requirements of their personnel at least annually. (As per WorksafeBC regulations, training for new tasks and activities must be provided prior their commencement.) 6. Hazards and rules associated with working alone Working alone in a hazardous environment (laboratory or shop) may be necessary, but there are associated WorkSafeBC requirements. In our department we have opted to do the following: hazard assessments for each lab are done by the supervisor. The supervisor determines what activities may not be done while working alone. Certainly this should include work with materials and processes that have a significant potential to be life threatening if something goes wrong. The policy is posted in the lab. If potentially hazardous work is to be done by someone working alone, and if the consequences of an accident are likely to be serious, a formal contact procedure is required. Regulations and procedures around working alone are available in a Risk Management publication: http://www.riskmanagement.ubc.ca/sites/riskmanagement.ubc.ca/files/uploads/Documents/Work ing%20Alone%20Guidance%20Document%20Nov%202011.pdf To summarize, the following steps would be required. A written and implemented procedure for maintaining contact with the isolated person, including time interval. This is supposed to be done in consultation with the Safety Committee. A procedure for response if contact is not made. Documentation of contact including names, places and times. A final contact check when the person leaves work. Training must be provided specifically for procedures related to working alone. The person with whom contact is made (outside the lab) must be trained in what to do if contact cannot be made. The procedure must be documented. 9 Original: August, 2007. Revised: Dec. 19, 2007 Issues related to personal security must be included in the training. UBC resources for persons on campus outside of normal working hours need to be presented, such as evening Safewalk services, shuttle buses to remote parking areas and blue light phones. See Campus Security website at: http://www.security.ubc.ca/ The simplest way to deal with working alone is requiring the presence of another student or worker as well. Contact may be set up with other persons also working in the department at the same time. This would need to be documented. 7. First aid/medical treatment: reporting injuries/illness First aid kits are kept in all laboratories and shops areas. The supervisor must ensure that they are adequately stocked. The semi-annual safety inspections check for this as well. A treatment record form must be kept with the kit and completed by anyone who uses it. Failure to do so is a violation of WorksafeBC regulations. Compensation claims stemming form an unrecorded accident may be denied. There are first aid attendants in the building. These people may be accessed in the event of an accident. UBC also provides a first aid 24 hours/day, 365 days/year. This may be accessed by phoning (604) 822-4444. If first aid personnel in the department are not available, then this service should be tried first. In the event of a serious emergency requiring paramedics, 911 should be called. If in doubt, 911 should be called. If 911 is called, UBC first aid should be called immediately afterwards; they may well be able to arrive first and provide help. Someone must go to the main entrance to meet emergency personnel. All lost time accidents involving employees must be reported to WorksafeBC and Risk Management within 24 hours. If a worker or student seeks medical treatment of any sort for injury or illness stemming form an activity at UBC, then we need to notify either WorksafeBC (for staff) or Risk Management (for students) within the 24 hour period. Failure to report may result in a large fine to the department. This is levied by WorksafeBC. Students and workers must be instructed about this requirement. Medical personnel will report all such occurrences to WorksafeBC, so it cannot be avoided. All the following types of accidents must be reported by law: Lost time accidents Accidents resulting in damage to property Large chemical spills (large is defined by whether the spill is large enough to be reportable. See the UBC Chemical Safety Manual.) Fires Explosions 10 Original: August, 2007. Revised: Dec. 19, 2007 An accident investigation report form is available at the main office. The Safety Committee and possibly the supervisor will be called upon to conduct the investigation. The procedure is available in part on the form. Contact someone from the safety committee for assistance. The Safety Committee will review all accidents and make suitable recommendations to the department Head as well. Incidents are events that have the potential for serious consequences, but which for one reason or another do not result in such consequences. An example is a failure in a pressurized gas regulator that resulted in gas escaping, but not injuries or damage. Incident reporting and investigation forms are available from the main office as well. Instructions on completing it are on the form. 11