UC Chemical Safety &
Security Initiative – A
Collaborative Approach
Erike Young, ERM Deputy & Director of
EH&S
Luanna Putney, Executive Director of
Ethics and Compliance
Goals
• Understand the risks related to chemical
safety and security in higher education
• Discuss considerations for prioritization of
key risks
• Provide input on risk mitigation activities
for sharing with UC Chemical Safety and
Security Workgroup during first meeting
in July
A Collaborative Approach
Compliance
Regulatory compliance describes the goal that corporations or public
agencies aspire to in their efforts to ensure that personnel are aware of
and take steps to comply with relevant laws and regulations.
The United States Sentencing Commission defines an effective
compliance program as one that:
1. Exercises due diligence to prevent and detect criminal conduct; and
2. otherwise promote an organizational culture that encourages ethical
conduct and a commitment to compliance with the law.
Risk Services
Risk management is the identification, assessment, and prioritization of
risks (defined in ISO 31000 as the effect of uncertainty on objectives,
whether positive or negative) followed by coordinated and economical
application of resources to minimize, monitor, and control the probability
and/or impact of unfortunate events to maximize the realization of
opportunities.
Managing Risk: Congruent Goals
• Targeted Risk
Assessment
• Risk Financing
• Risk Control /
Mitigation
• Promote culture of
risk awareness
Risk Services
Ethics & Compliance
• Assess Regulatory Risks
• Develop Mitigation Plan
• Monitor Key Mitigation
Activities
• Promote culture of
ethics and compliance
• Assess Key
Financial and
Operational
Controls
• Advisory Services
• Key Management
Business Partner
Internal Audit
Assisting Campus/Lab/OP to Meet Operational Needs
Across All Risk Venues
Campus/Lab/OP
Management
• Strategic Planning
• Managing Identified
Risks from all
Perspectives
Understanding the Risks
In the News…..
• UCLA Settlement
Agreement
• UCSF Lawsuit regarding
Richard Din
• UC Davis Chemical Surety
David Snyder
Understanding the Risks
Regulations galore….
• Cal/OSHA
• DOT
• DOE
• EPA
• FAA
• TSCA
Law enforcement….
Understanding the Risks
Enforcement focus…..
• Proposed Changes to
Cal/OSHA Section 334 Repeat Violations
– Current regulations allow for
Repeat Violation when same
violation occurs at same
campus/department
– Proposed Regulation would
allow for Repeat Violation
when “employer” has same
violation at another location in
state.
– Potential for increase for
• Repeat Violations - $18,000
• Serious and Willful - $70,000
National trade organization
attention….
What is “Risk”?
Risk is present in everything we do.
ISO 31000 definition of risk:
Risk = the effect of uncertainty on objectives.
Risk can be a threat or an opportunity
Anything that could harm, prevent, delay or enhance
your ability to achieve your objectives = risk
What is ERM?
(Enterprise) Risk Management is a coordinated effort
to direct and control all activities related to risk.
It defines risk as the effect of uncertainty on
objectives. It therefore ties the management of risk to
what is most important to the organization.
The responsibility for managing risk is spread across
the organization to those who have accountability and
authority – risk owners.
ANSI/ASSE/ISO 31000:2009
Types or Risk Exposures in ERM
 Hazard risk
◦
risks related to accidental losses, such as workplace injuries, liability torts, property damage,
and natural disasters.
 Financial risk
◦
risks related to financial activities, such as pricing, asset valuation, currency fluctuations, and
liquidity.
 Operational risk
◦
risks related to operations, such as supply chain, customer satisfaction, product failure, or loss
of key personnel.
 Strategic risk
◦
risks related with an organization’s long-term goals and management, such as partnerships,
mergers, and acquisitions.
 Compliance risk
◦
risks related to violations of or nonconformance with laws, rules, regulations, prescribed
practices, internal policies, and procedures, or ethical standards.
 Reputational risk
◦
risks related to the trustworthiness of business. Damage to a firm's reputation can result in lost
revenue or destruction of shareholder value.
Fire Extinguishers
• Cal/OSHA Title 8 CCR 6151- Fire Extinguishers
e) Inspection, Maintenance and Testing.
• (1) The employer shall be responsible for the inspection,
maintenance and testing of all portable fire extinguishers in the
workplace.
• (2) Portable extinguishers or hose used in lieu thereof under
Subsection (d)(3) of this Section shall be visually inspected monthly.
(d) Selection and Distribution.
• (1) Where portable fire extinguishers are provided for employee
use, they shall be selected and distributed based on the classes of
anticipated work place fires and on the size and degree of hazard
which would affect their use.
• (2) The employer shall distribute portable fire extinguishers for use
by employees on Class A fires so that the travel distance for
employees to any extinguisher is 75 feet (22.9m) or less.
Assessing the Risks
• Multiple models to identify and prioritize risks
Controlling Risks
• Concept of Undercontrolled and Overcontrolled
• What are examples of undercontrolled risk?
• What are examples of overcontrolled risks?
Case Study – Identifying the Risks
Billy is a 2nd year undergraduate at UCX and was just
accepted into a large prestigious lab to conduct
experiments related to the mammalian cell cycle. The
experiments he will conduct require use of several
dangerous chemicals to disrupt the cell cycle. He has
never worked in a laboratory before and will be
responsible for everything from ordering materials to
disposing of experimental waste. What operational,
strategic, financial, and compliance/ethics risks should
be considered when thinking about chemical safety and
security?
Case Study: Chemical Safety and
Security Risk Assessment
• Risk Ranking Tool -- Exercise
Prioritization of Risks: Risk Ranking Using the UCB Model
 First Meeting:
July 24, 2014
 What Does This
Group Need to
Know?
?
?
?