Findings and Recommendations
of the Senate Working Group on
Research Laboratory Safety
Michael Wong (CHBE)
Working Group Chair
Version 2.2
SWG Membership
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Beth Beason-Abmayr (Biochemistry and Cell Biology)
Raj Dasgupta (Earth Science)
Tom Killian (Physics and Astronomy)
Kevin Kelly (Electrical and Computer Engineering)
Qilin Li (Civil and Environmental Engineering)
Michael Wong (Chemical and Biomolecular Engineering)
ex officio members
• Kevin Kirby (Vice President for Administration)
• Vicki Colvin (Vice Provost for Research; Chemistry)
Faculty Senate members
• Jane Grande-Allen (Deputy Speaker; Bioengineering)
• Carl Caldwell (Speaker)
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Charges of working group
• To assess the state of research laboratory
safety across campus
• To propose a new organizational structure
that fosters and maintains a culture and
practice of lab safety
• To issue recommendations to improve the
process for safety training, oversight and
compliance
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From Chemical Safety Board findings (Oct. 19, 2011):
• Physical hazard risks of research were not effectively
assessed, planned for, or mitigated
• University lacked safety management accountability
and oversight
• Previous incidents with preventative lessons were not
documented, tracked, and formally communicated
Texas Tech: explosion and injury to grad student (Jan. 7, 2010)
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• First time that a U.S. professor faces a felony charge
in relation to the death of a lab worker
• Accused of failing to correct unsafe workplace
conditions and procedures in a timely manner, failing
to require work-appropriate clothing and personal
protective equipment, and failing to provide chemical
safety training to employees
UCLA: injury (12/29/08) and death of research staff (1/16/09)
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"Since 2001, the Chemical Safety
Board (CSB) has gathered
preliminary information on 120
different university laboratory
incidents involving chemicals"
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Los Alamos NL: laser eye injury to UG researcher (7/14/04)
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Lab research at Rice
• Most NSCI and ENG research activities
involve laboratory work throughout the
year
• Laboratory personnel includes faculty
members, undergraduates, graduate
students, post-doctoral associates, visiting
scholars, high school students, teachers,
and paid research staff members
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SWG assessment
• Compliance with local, state and federal agency codes and policies is
uneven
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Rice has a safety policy
Rice does not have a culture of safety
There is no centralized repository containing compliance information
Several safety committees exist, but they need strengthening
• Except for a few Departments, there is general lack of faculty
engagement in safety (but there is strong interest!)
• Oversight: no consistent enforcement of safety standards in the labs
– Perceived, stated, and actual roles of EH&S Department differ
– Is EH&S supposed to act as the "safety police"?
• Safety training for research personnel is not effective at University-level
– Training course required for grad students, not for undergraduates doing
laboratory research
– Additional training in the PI's lab is assumed to happen
– No online safety modules available on EH&S web site
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Weak safety culture signs
1.
No clear commitment of institutional administration to actively
promote safety at all levels (weak or deficient leadership in safety)
2.
Failure to establish accountability for safety among leaders,
managers, supervisors, employees, and students
3.
Lack of interest in spending significant time or resources on
safety
4.
Weak or missing safety management system
5.
Failure to adequately educate students in safety and to build
strong safety skills
6.
Failure to evaluate students’ safety knowledge and skills through
tests and observations
7.
Failure to build/maintain strong safety awareness and interest in
safety
8.
Failure to learn lessons from past incidents and implement
changes (improved safety practices) to prevent future incidents
9.
Weak collaborative interactions within the safety program and on
safety issues
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Ref: Creating Safety Cultures in Academic Institutions, ACS (2012)
2013 global safety survey
Survey further revealed
"mixed attitudes to the value
of safety training, inspections
and safety rules"
Ref: Nature 493, 9-10 (2013)
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Safety and misconduct
"Research misconduct means
fabrication, falsification or
plagiarism in proposing,
performing, or reviewing
research, or in reporting
research results."
"Research misconduct may
also include a failure to comply
with the federal requirements
for protecting researchers,
human and animal subjects
and the public."
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Sponsored research policy
"principle investigators shall…
provide for the health and
safety of students, post docs,
and research and support staff"
Refers to additional documents
Chemical Hygiene Plan 833-91
and Safety Policy 805-00
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Chemical Hygiene Plan
"This new regulation was developed to
provide a standard appropriate for situations
in which relatively small quantities of
multiple chemicals are used…."
"… applicable to all teaching and research
activities of Rice University."
"Other activities… may use toxic materials
or harmful physical agents in other than a
laboratory setting…"
"The designated Chemical Hygiene Officer (University Safety
Officer) will carry out such visits [supervision and enforcement]
and inspections, unannounced and announced…"
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Safety Policy
~1 page long
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~EHS
 University Safety Officer
 University Chemical
Hygiene Officer
http://safety.rice.edu/
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Current org chart
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Current org chart
EH&S
OSR
8 Depts.
6 Depts.
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Faculty-led committees
Required for all grad students, postdocs
Biosafety issues outside rDNA
http://comp.rice.edu/home/
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Oversight and compliance
EH&S: "Oversight on research involving potentially hazardous
activities are the responsibility of the university and PI to ensure
compliance with all state and federal guidelines."
• Chemicals (purchase and use)
– e.g., controlled substances
• Biological materials (purchasing and use)
– e.g., biological select agents or toxins
• Disposal of chemicals and biological materials
– Treat as hazardous waste
• Use of radiation and lasers (Texas Department of State
Health Services (DSHS) Radiation Control Program)
– Radioactive materials
– X-ray equipment, lasers (class 3B and 4)
• Import and export controls
– Inter-laboratory exchanges of regulated material is prohibited
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SWG recommendations
• Rice needs to improve its culture of safety, which will depend on…
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Strong commitment from administration through words and deeds
Active engagement of faculty
Service-oriented, collaborative approach by EH&S
Researchers performing in a responsible, conscientious and safe manner
• University Safety Policy needs updating to establish clear roles and
a clear problem resolution process
• EH&S needs to go from a just-in-time approach to a pro-active one
– By becoming an in-house consultant for researchers
– By developing lab safety profiles that can then be tailored to individual labs
– By partnering with PI's and Departments to develop safety training programs
and lab safety plans
– By assigning EH&S staff to buildings, to build relationships with individual labs
– By revamping its web site to be a user-centered, repository of information
• Safety training needs to be: tailored to each lab; high-quality;
recorded in a database; and available as in-person + online sessions
• Needed is a centralized repository containing compliance and
training information
• Rice needs a safety professional to lead this improvement effort
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Appendix A: references
• Chemical Safety Board, Texas Tech University,
Laboratory Explosion Case Study (No. 2010-05-I-TX)
• https://www.baycitizen.org/news/education/uclaresearchers-death-draws-scrutiny/
• Nature 493, 9-10 (03 January 2013)
doi:10.1038/493009a
• Creating Safety Cultures in Academic Institutions: A
Report of the Safety Culture Task Force of the ACS
Committee on Chemical Safety, American Chemical
Society (2012)
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Appendix B: best practices
Laboratory Safety Institute
• http://www.resources.labsafetyinstitute.org/Guid
elines.html
Stanford University safety online courses
• https://pselprd.stanford.edu/psc/pselprd/EMPLO
YEE/PSELPRD/c/STF_TOG_MENU.STF_TOG.
GBL
• e.g., Laser Safety, Chemical Safety for
Laboratories, General Safety, Injury Prevention,
Emergency Preparedness, and Compressed
Gas Safety
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