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1 The Culture of Laboratory Safety 1.A INTRODUCTION 2 1.B THE CULTURE OF LABORATORY SAFETY 2 1.C RESPONSIBILITY AND ACCOUNTABILITY FOR LABORATORY SAFETY 2 1.D SPECIAL SAFETY CONSIDERATIONS IN ACADEMIC LABORATORIES 3 1.D.1 High School Teaching Laboratories 3 1.D.2 Undergraduate Teaching Laboratories 3 1.D.3 Academic Research Laboratories 4 1.E THE SAFETY CULTURE IN INDUSTRIAL AND GOVERNMENTAL LABORATORIES 4 1.F OTHER FACTORS THAT INFLUENCE LABORATORY SAFETY PROGRAMS 5 1.F.1 Advances in Technology 5 1.F.2 Environmental Impact 5 1.F.3 Changes in the Legal and Regulatory Requirements 5 1.F.4 Accessibility for Scientists with Disabilities 5 1.G LABORATORY SECURITY 7 1.H STRUCTURE OF THE BOOK 7 1.I SUMMARY 7 1

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2 PRUDENT PRACTICES IN THE LABORATORY 1.A INTRODUCTION Laboratory personnel realize that the welfare and safety of each individual depends on clearly defined Over the past century, chemistry has increased our attitudes of teamwork and personal responsibility and understanding of the physical and biological world as that laboratory safety is not simply a matter of materi- well as our ability to manipulate it. As a result, most als and equipment but also of processes and behaviors. of the items we take for granted in modern life involve Learning to participate in this culture of habitual risk synthetic or natural chemical processing. assessment, experiment planning, and consideration of We acquire that understanding, carry out those ma- worst-case possibilities—for oneself and one’s fellow nipulations, and develop those items in the chemical workers—is as much part of a scientific education as laboratory; consequently, we also must monitor and learning the theoretical background of experiments or control thousands of chemicals in routine use. Since the step-by-step protocols for doing them in a profes- the age of alchemy, laboratory chemicals have demon- sional manner.2 strated dramatic and dangerous properties. Some are Accordingly, a crucial component of chemical edu- insidious poisons. cation at every level is to nurture basic attitudes and During the “heroic age” of chemistry, martyrdom for habits of prudent behavior so that safety is a valued the sake of science was acceptable, according to an 1890 and inseparable part of all laboratory activities. In this address by the great chemist August Kekulé: “If you way, a culture of laboratory safety becomes an internal- want to become a chemist, so Liebig told me, when I ized attitude, not just an external expectation driven worked in his laboratory, you have to ruin your health. by institutional rules. This process must be included Who does not ruin his health by his studies, nowadays in each person’s chemical education throughout his or will not get anywhere in Chemistry” (as quoted in her scientific career. Purchase, 1994). Today that attitude seems as ancient as alchemy. Over the years, we have developed special techniques 1.C RESPONSIBILITY AND for handling chemicals safely. Institutions that sponsor ACCOUNTABILITY FOR chemical laboratories hold themselves accountable for LABORATORY SAFETY providing safe working environments. Local, state, and Ensuring a safe laboratory environment is the com- federal regulations codify this accountability. bined responsibility of laboratory personnel, EHS Beyond regulation, employers and scientists also personnel, and the management of an organization, hold themselves responsible for the well-being of though the primary responsibility lies with the indi- building occupants and the general public. Develop- vidual performing the work. Of course, federal, state, ment of a “culture of safety”—with accountability and local laws and regulations make safety in the labo- up and down the managerial (or administrative) and ratory a legal requirement and an economic necessity. scientific ladders—has resulted in laboratories that Laboratory safety, although altruistic, is not a purely are, in fact, safe and healthy environments in which to voluntary function; it requires mandatory safety rules teach, learn, and work. Injury, never mind martyrdom, and programs and an ongoing commitment to them. is out of style. A sound safety organization that is respected by all requires the participation and support of laboratory 1.B THE CULTURE OF administrators, employees, and students. LABORATORY SAFETY The ultimate responsibility for creating a safe envi- ronment and for encouraging a culture of safety rests As a result of the promulgation of the Occupational with the head of the organization and its operating Safety and Health Administration (OSHA) Laboratory units. Leadership by those in charge ensures that an Standard (29 CFR § 1910.1450), a culture of safety con- effective safety program is embraced by all. Even a sciousness, accountability, organization, and education well-conceived safety program will be treated casually has developed in industrial, governmental, and aca- by workers if it is neglected by top management. demic laboratories. Safety and training programs, often Direct responsibility for the management of the labo- coordinated through an office of environment, health, ratory safety program typically rests with the chemical and safety (EHS), have been implemented to monitor the handling of chemicals from the moment they are ordered until their departure for ultimate disposal and 2With regard to safe use of chemicals, the committee distinguishes between hazard, which is an inherent danger in a material or system, to train laboratory personnel in safe practices.1 and the risk that is assumed by using it in various ways. Hazards are dangers intrinsic to a substance or operation; risk refers to the prob- 1Throughout this book, the committee uses the word training in its ability of injury associated with working with a substance or carrying usual sense of “making proficient through specialized instruction” out a particular laboratory operation. For a given chemical, risk can with no direct reference to regulatory language. be reduced; hazard cannot.

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3 THE CULTURE OF LABORATORY SAFETY hygiene officer (CHO) or safety director; responsibility through postdoctoral training. Teaching and academic for working safely, however, lies with those scientists, institutions must accept this unique responsibility for technicians, faculty, students, and others who actu- attitude development. ally do the work. A detailed organizational chart with Resources are limited and administration must pro- regard to each individual’s responsibility for chemical vide support for teachers who are not subject matter hygiene can be a valuable addition to the Chemical experts. The manifold requirements for record keeping Hygiene Plan (CHP). (See Chapter 2, section 2.B.) and waste handling can be especially burdensome for In course work, laboratory instructors carry direct overworked teachers in high school or college labora- responsibility for actions taken by students. Instructors tories. Institutions with graduate programs teach, but are responsible for promoting a culture of safety as well they also conduct research activities that often involve as for teaching the requisite skills needed to handle unpredictable hazards. The safety goals and the al- chemicals safely. location of resources to achieve them are sufficiently As federal, state, and local regulations became more different for high school, undergraduate, and graduate stringent, institutions developed infrastructures to teaching laboratories that they are discussed separately oversee compliance. Most industrial, governmental, here. and academic organizations that maintain laboratory operations have an EHS office staffed with credentialed 1.D.1 High School Teaching Laboratories professionals. These individuals have a collective ex- pertise in chemical safety, industrial hygiene, engineer- Laboratory safety involves recognizing and evalu- ing, biological safety, environmental health, environ- ating hazards, assessing risks, selecting appropriate mental management (air, water, waste), occupational personal protective equipment, and performing the ex- medicine, health physics, fire safety, and toxicology. perimental work in a safe manner. Training must start EHS offices consult on or manage hazardous waste early in a chemist’s career. Even a student’s first chemi- issues, accident reviews, inspections and audits, com- cal experiments should cover the proper approach to pliance monitoring, training, record keeping, and understanding and dealing with the hazardous prop- emergency response. They assist laboratory manage- erties of chemicals (e.g., flammability, reactivity, corro- ment in establishing policies and promoting high stan- siveness, and toxicity) as an introduction to laboratory dards of laboratory safety. To be most effective, they safety and should also teach sound environmental should partner with department chairpersons, safety practice when managing chemical waste. Advanced directors, CHOs, principal investigators or managers, high school chemistry courses should assume the same and laboratory personnel to design safety programs responsibilities for developing professional attitudes that provide technical guidance and training support toward safety and waste management as are expected that are relevant to the operations of the laboratory, are of college and university courses. practical to carry out, and comply with existing codes and regulations. 1.D.2 Undergraduate Teaching In view of the importance of these offices, safety di- Laboratories rectors should be highly knowledgeable in the field and given responsibility for the development of a unified Undergraduate chemistry courses are faced with the safety program, which will be vetted by institutional problem of introducing inexperienced people to the authorities and implemented by all. As a result, EHS culture of laboratory safety. Although some students directors should also have direct access, when neces- enroll in their first undergraduate course with good sary, to those senior authorities in the institution who preparation from their high school science courses, are ultimately accountable to the public. many others bring little or no experience in the labo- ratory. They must learn to evaluate the wide range of hazards in laboratories and learn risk management 1.D SPECIAL SAFETY CONSIDERATIONS techniques that are designed to eliminate various po- IN ACADEMIC LABORATORIES tential dangers in the laboratory. Academic laboratories, like industrial and govern- Undergraduate laboratory instruction is often as- mental laboratories, are concerned with meeting the signed to graduate—and in some cases undergraduate— fundamental safety goals of minimizing accidents and teaching assistants, who have widely different back- injuries, but there are differences. Forming the foun- grounds and communication skills. Supervising and dation for a lifelong attitude of safety consciousness, supporting teaching assistants is a special depart- risk assessment, and prudent laboratory practice is an mental responsibility that is needed to ensure the safe integral part of every stage of scientific education— operation of the undergraduate laboratories in the de- from classroom to laboratory and from primary school partment. The assistants are teaching chemistry while

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4 PRUDENT PRACTICES IN THE LABORATORY they are trying to learn it and teaching safety when they safety training and seminars for incoming graduate may not be prepared to do so. However, they are in a students. However, in many cases these sessions are position to act as role models of safe laboratory practice designed to prepare graduate students for their work for the students in the laboratory, and adequate sup- as teaching assistants rather than for their work as port and training are required for them to fill that role research scientists. appropriately. Formal safety education for advanced students and To this end, a manual designed and written specifi- laboratory personnel should be made as relevant to cally for teaching assistants in undergraduate laborato- their work activities as possible. Training conducted ries is an extremely effective training tool. The manual simply to satisfy regulatory requirements may seem can include sections on principles of laboratory safety; like compliance, and researchers may sense that the laboratory facilities; teaching assistant duties during training does not have the leader’s full support. EHS the laboratory session; chemical management; applica- offices and researchers can work together to address ble safety rules; teaching assistant and student apparel, such concerns and to design training sessions that teaching assistant and student personal protective fulfill regulatory requirements, provide training per- equipment; departmental policy on pregnant students ceived as directly relevant to the researchers’ work, in laboratories; and emergency preparedness in the and provide hands-on experience with safety practices event of a fire, chemical spill, or injury in the laboratory. whenever possible. There should be resolute commitment by the en- Safety training is an ongoing process, integral to the tire faculty to the departmental safety program to daily activities of laboratory personnel. As a new labo- minimize exposure to hazardous materials and unsafe ratory technique is formally taught or used, relevant work practices in the laboratory. Teaching safety and safe practices should be included; however, informal safe work practices in the laboratory should be a top training through collegial interactions is a good way priority for faculty as they prepare students for careers to exchange safety information, provide guidance, and in industrial, governmental, academic, and health sci- reinforce good work habits. ences laboratories. By promoting safety during the Although principal investigators and project man- undergraduate and graduate years, the faculty will agers are legally accountable for the maintenance of have a significant impact not just on their students safety in laboratories under their direction, this activ- but also on everyone who will share their future work ity, like much of the research effort, is distributable. environments. Well-organized academic research groups develop hierarchical structures of experienced postdoctoral research associates, graduate students at different 1.D.3 Academic Research Laboratories levels, undergraduates, and technicians, which can Advanced training in safety should be mandatory for be highly effective in transmitting the importance of students engaged in research, and hands-on training is safe, prudent laboratory operations. Box 1.1 provides recommended whenever possible. Unlike laboratory some examples of how to encourage a culture of safety course work, where training comes primarily from re- within an academic laboratory. peating well-established procedures, research often in- When each principal investigator offers leadership volves making new materials by new methods, which that demonstrates a deep concern for safety, fewer may pose unknown hazards. As a result, workers in people get hurt. If any principal investigator projects academic research laboratories do not always operate an attitude that appears to be cavalier or hostile to the from a deep experience base. university safety program, that research group and oth- Thus, faculty is expected to provide a safe environ- ers can mirror the poor example and exhibit behavior ment for research via careful oversight of the student’s that sets the stage for potential accidents, loss of insti- work. Responsibility for the promotion of safe labora- tutional property, and costly litigation. tory practices extends beyond the EHS department, and all senior researchers—faculty, postdoctoral, and 1.E THE SAFETY CULTURE IN INDUSTRIAL experienced students—should endeavor to teach the AND GOVERNMENTAL LABORATORIES principles and set a good example for their associates. The ability to maintain a safe laboratory environment The degree of commitment to EHS programs varies is necessary for a chemist entering the workforce, and widely among companies and governmental laborato- students who are not adequately trained in safety are ries, as well. Many chemical companies recognize both placed at a professional disadvantage when compared their moral responsibility and their own self-interest in with their peers. To underscore the importance of developing the best possible safety programs, extend- maintaining a safe and healthy laboratory environ- ing them not just to employees but also to contractors. ment, many chemistry departments provide laboratory Others do little more than is absolutely required by

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5 THE CULTURE OF LABORATORY SAFETY nology, environmental impact, and changes in legal and regulatory requirements. BOX 1.1 Tips for Encouraging a Culture of Safety Within 1.F.1 Advances in Technology an Academic Laboratory In response to the increasingly high cost of chemical • ake a topic of laboratory safety an item on every M management, from procurement to waste disposal, a group meeting agenda. steady movement toward miniaturizing chemical oper- • eriodically review the results of laboratory inspec- P ations exists in both teaching and research laboratories. tions with the entire group. This trend has had a significant effect on laboratory • ncourage students and laboratory employees to E design and has also reduced the costs associated with contact the EHS office if they have a question about procurement, handling, and disposal of chemicals. safe methods of handling hazardous chemicals. Another trend—motivated at least partially by safety • equire that all accidents and incidents, even those R concerns—is the simulation of laboratory experiments that seem minor, are reported so that the cause can by computer. Such programs are a valuable conceptual be identified. adjunct to laboratory training but are by no means • eview new experimental procedures with students R a substitute for hands-on experimental work. Only and discuss all safety concerns. Where particularly students who have been carefully educated through hazardous chemicals or procedures are called for, a series of hands-on experiments in the laboratory consider whether a substitution with a less hazardous have the confidence and expertise needed to handle material or technique can be made. real laboratory procedures safely as they move on to • ake sure the safety rules within the laboratory (e.g., M advanced courses, research work, and eventually to putting on eye protection at the door) are followed their careers in industry, academe, health sciences, or by everyone in the laboratory, from advisor to under- government laboratories. graduate researcher. • ecognize and reward students and staff for attention R 1.F.2 Environmental Impact to safety in the laboratory. If a laboratory operation produces less waste, there is less waste to dispose of and less impact on the envi- ronment. A frequent, but not universal, corollary is that law and regulations. Unfortunately, bad publicity from costs are also reduced. The terms “waste reduction,” a serious accident in one careless operation tarnishes “waste minimization,” and “source reduction” are of- the credibility of all committed supervisors and em- ten used interchangeably with “pollution prevention.” ployees. Fortunately, chemical companies that excel in In most cases the distinction is not important. However, safety are becoming more common, and safety is often the term “source reduction” may be used in a narrower recognized as equal in importance to productivity, sense than the other terms, and the limited definition quality, profitability, and efficiency. has been suggested as a regulatory approach that man- The industrial or governmental laboratory environ- dates pollution prevention. The narrow definition of ment provides strong corporate structure and disci- source reduction includes only procedural and process pline for maintaining a well-organized safety program changes that actually use less material and produce where the culture of safety is thoroughly understood, less waste. The definition does not include recycling or respected, and enforced from the highest level of treatment to reduce the hazard of a waste. For example, management down. New employees coming from changing to microscale techniques is considered source academic research laboratories are often surprised to reduction, but recycling a solvent waste is not. discover the detailed planning and extensive safety Many advantages are gained by taking an active checks that are required before running experiments. In pollution prevention approach to laboratory work, and return for their efforts, they learn the sense of personal these are well documented throughout this book. Some security that goes with high professional standards. potential drawbacks do exist, and these are discussed as well and should be kept in mind when planning activi- ties. For example, dramatically reducing the quantity 1.F OTHER FACTORS THAT INFLUENCE of chemicals used in teaching laboratories may leave LABORATORY SAFETY PROGRAMS the student with an unrealistic appreciation of his or Several key factors continue to affect the evolution her behavior when using them on a larger scale. Also, of laboratory safety programs in industry, government, certain types of pollution prevention activities, such and academe. These factors include advances in tech- as solvent recycling, may cost far more in dollars and

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6 PRUDENT PRACTICES IN THE LABORATORY time than the potential value of recovered solvent. For research institutions. Although the priority assigned more information about solvent recycling, see Chapter to safety varies widely among personnel within aca- 5, section 5.D.3.2. Before embarking on any pollution demic departments and divisions, increasing pressure prevention program, it is worthwhile to review the comes from several other directions in addition to the options thoroughly with local EHS program managers regulatory agencies and to the potential for accident and to review other organizations’ programs to become litigation. In some cases, significant fines have been fully aware of the relative merits of those options. imposed on principal investigators who received Perhaps the most significant impediment to compre- citations for safety violations. These actions serve to hensive waste reduction in laboratories is the element increase the faculty’s concern for laboratory safety. of scale. Techniques that are practical and cost-effective Boards of trustees or regents of educational institutions on a 55-gal or tank-car quantity of material may be often include prominent industrial leaders who are highly unrealistic when applied to a 50-g (or milligram) aware of the increasing national concern with safety quantity, or vice versa. Evaluating the costs of both and environmental issues and are particularly sensi- equipment and time becomes especially important tive to the possibility of institutional liability as a result when dealing with very small quantities. of laboratory accidents. Academic and government laboratories can be the targets of expensive lawsuits. The trustees assist academic officers both by helping to 1.F.3 Changes in the Legal and Regulatory develop an appropriate institutional safety system with Requirements an effective EHS office and by supporting departmental Changes in the legal and regulatory requirements requests for modifications of facilities to comply with over the past several decades have greatly affected safety regulations. laboratory operations. Because of increased regula- Federal granting agencies recognize the importance tions, the collection and disposal of laboratory waste of sound laboratory practices and active laboratory constitute major budget items in the operation of every safety programs in academe. Some require documenta- chemical laboratory. The cost of accidents in terms of tion of the institution’s safety program as part of the time and money spent on fines for regulatory violations grant proposal. When negligent or cavalier treatment of and on litigation are significant. Of course, protection laboratory safety regulations jeopardizes everybody’s of students and research personnel from toxic materials ability to obtain funding, a powerful incentive is cre- is not only an economic necessity but an ethical obli- ated to improve laboratory safety. gation. Laboratory accidents have resulted in serious, debilitating injuries and death, and the personal impact 1.F.4 Accessibility for Scientists with of such events cannot be forgotten. Disabilities In 1990, OSHA issued the Laboratory Standard (29 CFR § 1910.1450), a performance-based rule that Over the years, chemical manufacturers have mod- serves the community well. In line with some of the ernized their views of safety. Approaches to safety developments in laboratory practice, the commit- for all—including scientists with disabilities—have tee recommends that OSHA review the standard in largely changed in laboratories as well. In the past, current context. In particular, the section on CHPs, full mobility and full eyesight and hearing capabilities 1910.1450(e), does not currently include emergency were considered necessary for safe laboratory opera- preparedness, emergency response, and consideration tions. Now, encouraged legally by the adoption of the of physical hazards as well as chemical hazards. In Americans with Disabilities Act of 1990 (ADA) and the addition, this book provides guidance that could be a ADA Amendments Act of 2008, leaders in laboratory basis for strengthening the employee information and design and management realize that a nimble mind training section, 1910.1450(f). Finally, the nonmanda- is more difficult to come by than modified space or tory Appendix A of the Laboratory Standard was based instrumentation. on the original edition of Prudent Practices in the Labora- As a result, assistive technologies now exist to cir- tory, published in 1981 and currently out of print. The cumvent almost any inaccessibility, and laboratories committee recommends that the appendix be updated can be equipped to take advantage of them. Many to reflect the changes in the current edition in both of the modifications to laboratory space and fixtures content and reference. have benefits for all. Consider, as a single example, the The Laboratory Standard requires that every work- assistance of ramps and an automatic door opener to place conducting research or training where hazardous all lab personnel moving a large cart or carrying two chemicals are used develop a CHP. This requirement heavy containers. has generated a greater awareness of safety issues at all It is a logical extension of the culture of safety to in- educational science and technology departments and clude a culture of accessibility. For information about

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7 THE CULTURE OF LABORATORY SAFETY compliance with the ADA in the laboratory, see Chap- Emergency Planning and one on Laboratory Security, ter 9, section 9.B.8. described above, and the discussion of EHS manage- ment systems has been extensively revised. Chapters 2, 3, and 10 cover administrative and organizational 1.G LABORATORY SECURITY concerns that affect the laboratory environment; Chap- Laboratory security is an issue that has grown in ters 4–8 discuss practical concerns when working in a prominence in recent years and is complementary to laboratory; Chapter 9 discusses laboratory facilities; laboratory safety. In short, a laboratory safety program and Chapter 11 provides an overview of federal regula- should be designed to protect people and chemicals tions that affect laboratory activities. Acknowledging from accidental misuse of materials; the laboratory the stronger regulatory environment that exists today, security program should be designed to protect work- this edition provides more references to relevant codes, ers from intentional misuse or misappropriation of standards, and regulations than the prior versions. materials. Security procedures and programs will no This is not intended to imply that safety has become a doubt be familiar to some readers, but others may matter of regulation rather than of good practice; it is a have encountered it only in the context of locking reflection of laboratory practice today and is intended the laboratory door. However, in the coming years, to provide a resource for personnel who must remain a working awareness of security will likely become a in compliance with these regulations or face legal common requirement for anyone working in a chemi- consequences. cal laboratory. Risks to laboratory security include theft or diversion of high-value equipment, theft of 1.I SUMMARY chemicals to commit criminal acts, intentional release of hazardous materials, or loss or release of sensitive A strong culture of safety within an organization information, and will vary with the organization and creates a solid foundation upon which a successful the work performed. Chapter 10 of this book provides laboratory health and safety program can be built. As a broad introduction to laboratory security, including part of that culture, all levels of the organization (i.e., discussions of the elements of a security program, administrative personnel, scientists, laboratory techni- performing a security vulnerability assessment, dual- cians) should understand the importance of minimiz- use hazards of laboratory materials, and regulations ing the risk of exposure to hazardous materials in the that affect security requirements. The chapter is not laboratory and should work together toward this end. intended to provide all the details needed to create a In particular, laboratory personnel should consider security program, but rather to acquaint laboratory the health, physical, and environmental hazards of personnel with the rationale behind developing such a the chemicals that will be used when planning a new program and to provide the basic tools needed to begin experiment and perform their work in a prudent identifying and addressing concerns within their own manner. However, the ability to accurately identify laboratories. and assess hazards in the laboratory is not a skill that comes naturally, and it must be taught and encouraged through training and ongoing organizational support. 1.H STRUCTURE OF THE BOOK A successful health and safety program requires a daily This edition of Prudent Practices in the Laboratory commitment from everyone in the organization, and builds on the work provided in previous editions. setting a good example is the best method of demon- Among other changes, it has two new chapters, one on strating commitment.

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