Lab Safety Culture atArizona State University

Michael R. CaplanSchool of Biological & Health Systems Engineering

Arizona State University

Committee Members

• Ranko Richert (Chair)• Michael Caplan• Julian Chen• Seth Rose• Barry Ritchie• Kevin Salcido• Jon Harrison• Ray Jensen• John Riley• Leon Igras• Kathy Bossert

And many others

• Jonathan Klane• Debra Murphy• Alana LaBelle

Fatal lab accidents at UCLA and Yale lead ASU administrators to ask the question: Could this happen here?

Answer: Probably

Q: How do we make sure that can’t happen here?

A: The only way to ensure that is to enlist every person in the labs (faculty, students, staff, EH&S, etc) to be a safety advocate, part of a safety culture.

Q: Can’t we just make sure every lab is in compliance?

A: You can only ensure compliance while your inspector is in the lab. As soon as the inspector leaves, you can’t ensure compliance.

Q: OK, then how do we build safety culture to get 100% participation?

A: Good question

Charge to the committee

Evaluate the following items and recommend any changes needed to improve laboratory safety culture at ASU:

• Recommendations of the American Chemical Society and US Chemical Safety Board Review of Research University Safety Culture

• Current program of laboratory inspections• Current processes for shutting down an ASU laboratory for a serious safety

violation• The ASU Compliance Officer program• Current role of Environmental Health and Safety

Recommend:

• Mechanism for including evaluations of the safety performance of both Faculty and Laboratory Staff

• Mechanism to require EH&S approval for certain categories of highly hazardous materials

Motivation (leadership)

Expertise (implementation)

Trust (reporting)

The Goal:

Credit: Sidney Dekker for framing the goal as this triad

Rules

(focus on compliance)

Inspection

(finding violations)

Distrust (concerns

about liability)

Where we are now:

Used as guide forcommittee discussions:

American Chemical Society's seventeen points for creating safety cultures in academic institutions

1. Establish the lines of authority for safety, develop a safety policy that includes laboratory safety, and include safety responsibilities in the job descriptions and performance plans of all employees.

2013 plan:• Every individual bears responsibility to:

• assess the risks of their activities,• stay up to date on required training,• follow appropriate safety procedures and• take a pro-active role in ensuring their safety and the safety of others

• Principle Investigator (PI) bears particular responsibility of laboratory safety and oversight of all her/his research members, with the unit chair and safety committee providing key support

• President of ASU is ultimately responsible for oversight of laboratory safety, with oversight proceeding through traditional academic lines of authority: President, Provost, Dean, Unit Chair, PI

1. Establish the lines of authority for safety, develop a safety policy that includes laboratory safety, and include safety responsibilities in the job descriptions and performance plans of all employees.

UPDATE:• Resolution made to Faculty Senate to amend ACD Manual

“Everyone working at ASU, paid or unpaid and including students, is responsible for safety. Each individual bears responsibility to assess the risks of their activities, to remain current on required training, follow safety procedures, and take a pro-active role in ensuring their personal safety and the safety of others.

Faculty, Academic Professionals, and others who supervise laboratories or similar areas (lab supervisors) where hazards or other risks to safety are present need to be especially alert to the personal safety of all people who have activities in the areas. Lab supervisors bear the obligation of stewardship of safe practices by research personnel (including students) under their supervision. Advice and guidance should be given to anyone who may be exposed to risk. The supervisors must coordinate with unit-level safety committees and EH&S to identify potential hazards and to implement policies and training to mitigate these risks. The importance of safety in the facilities should be made clear, especially to students. Such supervisors should ensure that all personnel have received the appropriate safety training, ensure that proper personal protective equipment is available in proper working order, and ensure that emergency procedures are known and posted. Supervisors should make good-faith efforts to ensure compliance with safety policies and make good-faith efforts to ensure that personnel conduct their work safely.”

• ASU Faculty Senate tabled this resolution for future consideration• Concerns about transferring liability from University to PIs• Some recommended broadening to include campus safety (not just labs)

13. Establish a series of safety councils and safety committees from the highest level of management to the departmental level or lower. Each of these committees reports, in turn, to a committee that is higher in the hierarchy of the institution.

2013 plan:• An ASU Chemical Safety Committee, administered by EHS, will be

established under the Senior Vice-President for Research (OKED/ORI)• composed of faculty and staff• set ASU chemical safety policies,• identify chemicals that require specific Standard Operating Procedures,• reviewing SOP’s for these very hazardous chemicals,• determine safety metrics, and• track safety progress at the university level

• Similar safety committees should be established at all College/School levels

• Each unit must have a safety committee

13. Establish a series of safety councils and safety committees from the highest level of management to the departmental level or lower. Each of these committees reports, in turn, to a committee that is higher in the hierarchy of the institution.

UPDATE:• Faculty Senate approved creation of the University Safety Committee

• Members are being selected by Office of Research Integrity & Assurance• Committee is charged to work with Provost to oversee safety• Mostly faculty with staff and administration represented as well

• No systematic action at the College/School levels

• No systematic action at the unit level

• However…Many units are recognizing the gaps in the safety system and beginning to take action.

Example: SBHSE has instituted PI led safety training, recommended devoting 1st agenda item at faculty meeting to safety concerns, PI written safety self-study of lab safety checked by surprise inspection by compliance officer.

• However…Many units are recognizing the gaps in the safety system and beginning to take action.

Other things these unit level committee should be doing:

10. Establish and maintain an Incident Reporting System, an Incident Investigation System, and an Incident Database that includes not only employees, but students also—undergraduates, graduate students, postdoctoral scholars, and other nonemployees.

11. Establish an internal review process of incidents and corrective actions with the Departmental Safety Committee (faculty, staff, students, graduate students, and postdoctoral scholars), and provided periodic safety seminars on lessons learned from incidents.

12. Implement hazards analysis procedures in all new laboratory work, especially laboratory research.

8. In the preparation of grant proposal, researchers should include in their plans safety education and training (for undergraduate students, graduate students, and postdoctoral scholars participating in proposed research) and oversight of research for safety.

3. Establish a strong, effective safety management system and safety program for the institution, including laboratory safety.

4. a5. Ensure all faculty, staff, and graduate and undergraduate students involved in teaching,

managing, or overseeing students in laboratory courses and sessions have successfully completed a course in laboratory safety.

• No systematic actions taken by all units

• But piecemeal actions by units indicate that the message is taking hold and some units are building their own cultures

• EH&S tracks compliance of all ASU employees working in research and teaching labs.

• But volunteers, adjunct faculty, etc sometimes have not had lab safety.

• However, tracking compliance with taking one course does not ensure safety on a daily basis.

2. Encourage every leader to become a proponent of safety and safety education, and to demonstrate this care for safety in their actions with other staff members and students.

9. Adopt a personal credo: the “Safety Ethic”—value safety, work safely, prevent at-risk behavior, promote safety, and accept responsibility for safety.

• More awareness at unit level that safety responsibilities should be included in staff job descriptions where applicable, but not uniform implementation

• Tabled ACD Manual amendment was first step to adding safety metrics to annual performance evaluations of faculty and staff.

• No units have implemented this recommendation yet

4. Ensure graduating chemistry undergraduate students have strong skills in laboratory safety and strong safety ethics by teaching safety lessons in each laboratory session, and by evaluating and testing these skills throughout the educational process.

7. Build awareness and caring for safety by emphasizing safety throughout the chemistry curricula.

• Not just chemistry students. ALL students should have a strong safety ethic

• Changing syllabi, course goals, test questions, thesis dissertations, TA training to include significant focus on safety.

• Department of Chemistry & Biochemistry has made progress in this• It does not appear that any other unit has done this systematically

• Faculty Senate’s subcommittee on Research and Creative Activities (RCA) cited concerns about academic freedom in this recommendation.

14. Establish a close working relationship with EHS personnel at every departmental level seeking their advice and experience in safety and offering departmental and faculty advice to EHS based upon their experience with knowledge of chemistry.

2013 Plan:• The role of EHS is to

• support safety compliance at every level,• participate in the ASU University Safety Committee, and• assist with providing metrics regarding unit and PI safety performance.

• EHS shall communicate incident reports/analyses and lessons learned to the Unit Safety Committees for dissemination of relevant topics to the PI's within unit.

• EHS should support safety culture through awards to Compliance Officers that demonstrate excellence in safety.

• EHS should NOT enforce anything (to avoid being the adversary)

14. Establish a close working relationship with EHS personnel at every departmental level seeking their advice and experience in safety and offering departmental and faculty advice to EHS based upon their experience with knowledge of chemistry.

UPDATE:• EH&S, Unit-level Compliance Officers, and other administrators have been

extremely supportive.

• Sometimes TOO supportive.• Urgency can lead to frustration. If frustration leads to punitive action,

gains in culture can be lost (Us vs. Them attitude)

• Goals for safety personnel: help implementation, don’t “catch” violations

17. Identify the ongoing need to support a strong safety culture and work with administrators and departmental chairs to establish a baseline budget to support safety activities on an annual basis.

2013 plan:• In support of an ongoing safety culture improvement, it is also recommended

that funds for rectifying laboratory or building safety issues be set aside and used for improvements according to a prioritized list of a safety problem inventory.

• Recommended procedure:• Unit level committees create a list of safety-related items, renovations,

etc that they believe are needed including prices, justifications, and ranking of importance

• College/School committees take all unit level lists and rank order each item into one master list for that School/College

• The ASU Chemical Safety Committee compiles all School/College lists into one rank-ordered list for the entire university

• Funds are appropriated to items near the top of the list with plans made to work through all items on the list within approximately five years.

17. Identify the ongoing need to support a strong safety culture and work with administrators and departmental chairs to establish a baseline budget to support safety activities on an annual basis.

UPDATE:• ASU administration has been supportive of the idea

• No units or colleges have made systematic requests so no 5-year plan has been created

• EH&S did make a request for approximately $100,000 to create a fund for safety improvements

• The request was supported by administration officials (ORIA, OKED)

Next steps

10,000 foot view:Change from focus on “compliance” to focus on:1. Motivation (leadership needs to help PIs and students see the critical

importance of all of the work they need to do on a daily basis) 2. Expertise (safety personnel needs to provide PIs and students with the

knowledge and skills they need to accomplish those daily activities)3. Trust (PIs and students need to know that they will be rewarded for

openly discussing problems in safety or even how an incident occurred. Only lack of participation in safety culture or gross negligence is unacceptable)

In the trenches view:4. Change focus from “safety violations” to celebrating PIs and students who

self-identify and report things they can do better to be more safe.5. Work with PIs to resolve concerns about transferring liability.6. Help units begin to implement pieces of the puzzle.7. Help leadership motivate safety culture rather than punish violators

Rules

(focus on compliance)

Inspection

(finding violations)

Distrust (concerns

about liability)

Where we are now:

Motivation (leadership)

Expertise (implementation)

Trust (reporting)

The Goal: President, provost, deans, chairs must motivate PIs & students to spend significant time on safety

Lead by example

Reward safety consciousness

Make part of annual performance evals

Unit safety committees

Standard operating procedures

Review of new hazardous proceduresInclusion of safety in curriculum

Support from EH&S

Financial support from university

PI self-studies

Unit-level sharing of safety concerns

Reporting incidents

No-blame reception of reports of incidentsor concerns

Committee Members

• Ranko Richert (Chair)• Michael Caplan• Julian Chen• Seth Rose• Barry Ritchie• Kevin Salcido• Jon Harrison• Ray Jensen• John Riley• Leon Igras• Kathy Bossert

And many others

• Jonathan Klane• Debra Murphy• Alana LaBelle