REM Plans for the Future with ISP
by Carol Shelby
Your colleagues at REM have been meeting to formulate a plan to change the way we communicate and implement environmental health and safety (EH&S) issues throughout the University. The plan is called the Integrated Safety Plan, or ISP. The desired outcomes are:
- Bring safety into the Total Quality Management Culture at Purdue and ensure individual accountability.
- Assure a "system" is in place to handle any safety issue, not just the crisis.
- Improve campus-wide regulatory compliance.
- Reduce injury rates of Purdue employees through effective and timely communication and training.
Currently, the plan has four key points for implementation:
1. Reconfirm and Re-Issue University Safety Policy
- Confirm the importance of EH&S at Purdue University
- Provide a policy that is workable at all levels of the University
2. Establish Performance Standards
The idea is to:
- Establish safety committees at all levels & define decision-making roles for each
- Establish safety goals at each level of organization
- Name a person to act as safety contact with REM
- Assign Department Head as Safety Chair
- Make safety a part of each staff meeting
3. Empower People to Implement Reasonable Solutions to Unsafe Conditions at Their Areas
- Remove constraints, either real or perceived, for people to act on EH&S issues as soon as they are identified
- Give EH&S issues the same weight in priority and urgency as normal business activity
- Improve regulatory compliance
4. Hold People Accountable for Safety Compliance
Here are some ideas about how we could accomplish this goal. Individual departments will add their own ideas.
- Including specific and measurable EH&S goals in individual performance expectations that are consistent with fulfillment of department, division, and/or school safety goals.
- Developing an indemnity policy for regulatory fines.
The last point, developing an indemnity policy, is one way to encourage compliance through effective incentives. You may have reviewed a memo sent out last year by Vice Presidents Kjonaas and Proenza, assigning financial responsibility for any regulatory fines as a result of non-compliance to the responsible researcher and/or department. This new indemnity policy will remove this financial responsibility from departments and researchers if they comply with the University's Integrated Safety Plan. The ISP will be implemented in stages throughout the University, allowing for a smooth transition.
We have begun implementation of this ISP with four pilot areas - Food Science, Chemistry, Wade Power Plant and Industrial & Physical Pharmacy. The next step is to develop performance criteria for the ISP.
For more information about the ISP, or to volunteer as a pilot area for the program, please contact Carol Shelby at 49-47504.
Coffee water? Think Again!
Bob Golden, Purdue's Environmental Health Officer, has received numerous inquiries as to the safety of distilled or deionized water for human consumption. This water has sometimes been used for drinking, coffee-making and culinary purposes. It is believed (erroneously) to be more pure than Purdue's tap water. The University has a series of wells which tap into an excellent source of ground water. To this water, the Utilities department adds chlorine at levels ranging from .5 to 1.0 ppm. This produces a tap water that has been proven, through hundreds of test results, to contain no microbial or chemical contamination.
Water processing (distillation/deionization) removes chlorine. Processed water, therefore, is considered unsafe for drinking. The only approved water sources for consumption at Purdue are drinking fountains and kitchenette sinks. Restroom sinks, mop closets and wall faucets are supplied with potable water, but are considered unsafe because of potential contamination presented by their locations. For any questions about water quality, call Bob Golden at 41496.
What to Do About Unknown Chemicals
by Michael T. Hills, REM Hazardous Waste Chemist
Whether working in a laboratory, maintaining equipment, or being responsible for a building on campus, everyone is occasionally faced with a container of some anonymous material bearing no label or other identification. You know it should be disposed of properly, but when you fill out REM's Hazardous Material Pickup Request, you have no information about the chemical composition. What do you do now? Here is why unknown chemicals are a problem, how to prevent their occurrence and how to make disposal of unknowns easier for you and for REM.
Unknown chemicals are a problem for several reasons. Purdue University's federal and state hazardous waste permits prohibit unknown materials from being received into the Laboratory Materials Storage Building (LMSB) where all of Purdue's hazardous wastes are processed for disposal. That is why detailed chemical composition information is required for each chemical on a pickup request. Federal and state regulations also require all hazardous waste containers to be properly labeled with their contents; large fines may be imposed for the violation of these laws. Finally, unknown chemicals require considerable time and money to characterize them sufficiently for safe disposal.
The best solution to unknown chemicals is to prevent their occurrence. Periodically inspect all chemical containers for missing or damaged labels, immediately replacing or supplementing hard to read labels with essential information. Never collect any material in an unmarked container with the intent of labeling it later -- label it now! Label commercial products not only with their names, but also the manufacturer's name and address. This latter information is essential to obtaining an MSDS for the material.
Depending upon your personal experience, knowledge and comfort level with handling chemicals, here are some steps you can take to help REM personnel dispose of your unknown. It is not necessary to obtain all the following information, but any information you can provide will make disposal faster, safer and cheaper.
1) Gather as much physical information as possible about the unknown:
- Is it a solid, liquid, gas or mixture? What does it look like?
- What type of container is it in -- a can, screw cap bottle, gas cylinder, septum covered bottle?
- What is the container size and how much is in the container?
- What type of materials/chemicals are commonly used in the area/shop/lab where the container was found?
- What do you think it might be?
2) If you have experience handling chemicals, gather as much chemical information as possible about the unknown (do NOT open air tight containers or gas cylinders):
- What is its pH?
- Is it organic or inorganic?
- Is it soluble in water?
- Anything else you can safely determine?
3) If you have the equipment and chemical expertise, basic qualitative analysis and other tests can be performed on the unknown chemical. Spectroscopic techniques can also provide valuable information. REM will place you in contact with laboratories on campus providing these analytical services.
Please contact REM at 49-40121 for further assistance in managing your unknown materials/chemicals.
References for methods of identifying unknown chemicals: Blaine C. McKusick, "Classification of Unlabeled Laboratory Waste for Disposal" Journal of Chemical Education, Volume 63, Number 5, May 1986, pp. A128-A131. Shriner, R.L.; Fuson, R.C.; Curtin, D.Y.; Morrill, T.C., "The Systematic Identification of Organic Compounds," 6th ed.: Wiley: New York, 1980.
Solutions for Open Hazardous Waste Containers
Open containers of hazardous waste are one area of compliance to which the EPA is particularly sensitive, because waste solvents from the open container evaporate into the air, contributing to air pollution. However, closing the container after each use is not always convenient for some researchers, especially those generating hazardous waste many times a day. Quite often a funnel is left in the waste jug all of the time. Because of this problem, REM staff looked at what was on the market to help researchers keep their waste closed and found two suitable devices..
The first is a Justrite(TM) Liquid Safety Disposal Can from Fischer Scientific. The can features a wide mouth with a spring loaded stainless steel lid and is widely used by research institutions and industry. Call 1-800-766-7000 for more information
The second product comes from a researcher, and Purdue Chemistry alumnus, in California. He has invented a device called the ECO Funnel. This is a funnel that fits onto a standard waste jug and is designed with a lid and a ballcock so that the funnel may be easily closed after each use. The lid and ballcock prevent the waste solvent from evaporating. Several researchers at Purdue have tried the ECO Funnel and are pleased with the design and the convenience it affords. Interested parties may contact California Pacific Lab Consulting at 1-415-753-6053.
What is the Norm for Safety in Your Department?
Naturally Occurring Reactive Management (NORM) is the typical approach to health and safety in business and industry today, according to Dr. Alfred Capuano. At the Hoosier Safety Council Congress in Indianapolis on February 25, 1997, Dr. Capuano captivated the audience with his talk on the topic of WORLD CLASS SAFETY'S KEY INGREDIENT.
World Class Safety is the highest goal, and yes, there is a key ingredient, a secret ingredient without which World Class Safety is unattainable. Without this ingredient, any employer's efforts toward on-the-job safety will be, at best, mediocre. The NORM is mediocre. But let's back up a bit and start a step below the NORM, in the SWAMP:
- Safety Without Any Management Process
- accidents are accepted as the cost of doing business
- "stuff" happens
- there is almost no planning
- no one takes nor wants responsibility for safety
- safety is regarded as A BURDEN
The SWAMP model, or elements of it, are probably recognizable to most of us from past experience, but it does not describe the status of safety and health management in most areas of the University. We are, by and large, part of the NORM.
- Naturally Occurring Reactive Management
- accidents are blamed on people/circumstances
- eliminating hazardous conditions will eliminate accidents
- little planning, many half-way measures
- no one understands who is responsible for safety, except maybe a "safety manager" (REM...?)
- safety is regarded as A COST
Do you recognize Purdue in any of this? Recognize attitudes or behaviors in your department?
World Class Safety
- accidents are intolerable, no excuses
- behaviors/attitudes can be as hazardous as "conditions," and therefore deserve as much attention
- long range (3 - 5 years) planning for safety and health
- everyone is responsible for safety
- safety is regarded as A GOOD INVESTMENT
What is the secret ingredient? How do we attain "World Class Safety" or whatever cute name that might form a better acronym for it? The secret ingredient is accountability.
"Without accountability there is no accepted responsibility."* A worker will perform in such manner as his/her supervisor holds him/her accountable to perform. But how does a research advisor hold a graduate student or postdoctoral associate accountable for safety, for example? Who holds the research advisors accountable for safety, and how? Well, nobody said it would be easy in a University setting. TQM refers to this as being taken out of your "comfort zone."
It's going to have to happen, however. Whether it happens sooner or later will determine the University's very future, to a large measure. The strength of regulatory sanctions and public opinion will force the changes, and those among us who regard safety as something somebody else takes care of, as something that is separate from and less important than our work, will become extinct.
Avoid the rush, start shifting your paradigm today!
*Dan Petersen, Techniques of Safety Management, 3rd Ed., Alloray.
U. Texas Austin Chemical Fire
by Dr. Linda Swihart
One morning in October 1996, a postdoctoral research associate in the chemistry department at Welch Hall poured what he thought was a completely quenched sodium/alcohol mixture into his fifth floor lab sink. A "tiny amount" of sodium caught fire, as sodium does when exposed to water and air. Ethanol being extremely flammable, there was immediately a "small" fire in the sink.
The postdoc attempted to relocate a glass container of acetone that was in the sink, but accidentally broke it into the sink. Now there was a rather large fire in the sink. The lab staff closed the door and called 911. A passerby finally pulled a fire alarm, but since the building had separate alarm systems, quite a number of people were unaware of the fire well after it was on its way to doing $300,000 worth of damage. It took 90 firefighters with 25 fire engines six hours to finish it off.
Miraculously, no one was hurt! The real hoo-ha started a day or two after the fire, when the City Fire Chief (UTA has no campus fire department), remarked that he would be "hesitant" to send firefighters into the Welch building again if there were another fire. He noted too many life-threatening problems with chemical storage and labeling, and was hesitant to expose his firefighters.
Why is it still news? The story continues interestingly. The city of Austin gave the University a November 15 deadline to begin fire safety improvements. The Fire Chief was quoted by the Texas Daily as saying "The Fire Department cannot accept the suggestion that this grievous track record must be tolerated to support high quality academic research." (The grievous record included four previous fires in 31 months, although none nearly as serious as this last one.)
In mid-November, UTA announced a $14.6 million fire safety renovation project promising additional exits in laboratories, chemical storage cabinets and a sprinkler system on the fourth and fifth floors. This figure had risen to $24 million by mid-January, after "recalculating the fire's damage and adding the cost of renovations." A 1/27/97 headline in the WebTexan announced Welch improvements delaying $53 million in other renovations.
What can we learn from this? For one thing, it's real easy to have a devastating little mishap. For another, safety is an odd business. We spend incredible time and effort working to prevent things that almost never happen. BUT! This doesn't mean we couldn't have a "silly, contrived, catastrophic incident" here. All it takes is a little lapse, a little mishap in the wrong place at the wrong time.
Security of Laboratories: We need Your Help!
Recent Nuclear Regulatory Commission (NRC) inspections have placed emphasis on the security of radioactive material because of incidents at other research institutions. A recent NRC inspection at Purdue identified several laboratories containing radioactive materials that were left unoccupied and unlocked. This will probably result in an NRC violation, since current regulations do not set "de minimus" quantities of activity that are exempt from security requirements. Radioactive materials can be secured, when no one is present, by locking doors and/or locking areas where radioactive materials are stored (e.g. refrigerators). A recurring violation could lead to more frequent and more rigorous NRC inspections, and possibly to monetary penalties. Proper contamination surveys and security audits should help prevent future violations. If you need further information about lab security, please call Josh Walkowicz at extension 4-6367.