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Prudent Practices in the Laboratory: Handling and Disposal of Chemicals
One of the most effective safety tools a larger institution can employ is periodic peer-level inspections. Usually, the people who fulfill this role work in the organization they serve, but not in the area being surveyed. Individuals may function on an ad hoc basis, or the institution may select specific individuals and confer on them various formal appellations such as ''safety committee member." A peer inspection program has the intrinsic advantage of being perceived as less threatening than other forms of surveys or audits.
Peer inspections depend heavily on the knowledge and commitment of the people who conduct them. Individuals who volunteer or are selected to perform inspections for only a brief period of service may not learn enough about an operation or procedure to observe and comment constructively. On the other hand, people who receive involuntary appointments or who serve too long may not maintain the desired level of diligence. Peer-level inspectors generally perform best if they have some ongoing responsibility with regard to the safety program, such as consulting on experiment designs. They will be more familiar with the work and will conduct the review more effectively.
Having a high-quality peer-level inspection program may reduce the need for frequent inspections by supervisory personnel. However, peer inspections should not replace other inspections completely. Walkthroughs by the organization's leadership demonstrate commitment to the safety programs, which is key to their continuing success.
Another option is to have the organization's environmental health and safety staff conduct inspections. In a smaller organization, these types of inspections may adequately address the ILCI frequency recommendations. In larger institutions, the safety staff may be limited to semiannual or even annual walk-throughs. A more practical use of safety staff for inspections may be to target certain operations or experiments. Or the safety staff could focus on a particular type of inspection, such as safety equipment and systems. Finally, they could perform "audits" to check the work of other inspectors or look specifically at previous problem areas. It is important for the safety staff to address noted deficiencies with appropriate reminders and/ or additional training. Punitive measures should be employed, but only for chronic offenders or deliberate problems that pose a serious potential hazard.
Safety staff are not the only nonlaboratory personnel who should conduct safety inspections. Facility engineers or maintenance personnel may add considerable value to safety inspection programs. It also gives them the opportunity to gain a better perspective on the laboratory work.
Other types of inspections and audits use individuals or groups outside the laboratory organization to conduct the survey. Inspections may be mandatory, such as annual site visits by EPA to hazardous waste generators, or they may be surprise inspections with 24 hours notice or less given prior to the visit. Organizations subject to such inspections must keep their programs and records up-to-date at all times. In fact, all organizations should strive for that goal. Any significant incident or accident within a facility will trigger one or more inspections and investigations by outside organizations. If the underlying safety programs are found to be sound, that factor may help limit negative findings and potential penalties.
Many different types of elective inspections or audits can be conducted by outside experts or organizations. They may inspect a particular facility, piece(s) of equipment, or procedure either during the pre-experiment design phase or during operations.
Tours, walk-throughs, and inspections by outside organizations offer the opportunity to build relationships with governmental agencies and the public. For example, an annual visit by the fire department serving a particular facility will acquaint personnel with the operations and the location of particular hazards. If these individuals are ever called into the facility to handle an emergency, their familiarity with the facility will give them a greater degree of effectiveness. During their walk-through, they may offer comments and suggestions for improvements. A relationship built over a period of time will help make this input positive and constructive.
If a pending operation or facility change may cause public attention and concern, an invitation targeted to specific people or groups may prevent problems. Holding public open houses from time to time can help build a spirit of support and trust. Many opportunities exist to apply this type of open approach to dealing with the public. An organization only needs to consider when to use it and what potential benefits may accrue.
An industrial laboratory arranged an on-site visit for representatives from the Sierra Club and other local citizen action groups who had begun to raise objections to the approval of the site's RCRA Part B permit for a hazardous waste incinerator. Concerns about the noise, smoke, and smell from the incinerator were dispelled after the individuals stood right next to it and did not realize what it was and that it was operating at the time!