Research Compliance Summary Research Administrators Council August 7, 2003 Carnegie Mellon University Mark Banister, CIH, CCHO

What About This is Important to Me?  Administration is a key component to the compliance of the college/university with EPA, DOT and OSHA requirements  Research grants often request information on regulatory compliance—how do you know you meet these requirements?

What We Will Talk About  Subjects you need to address Laboratory safety Chemical/general safety Hazardous waste Respiratory protection Transportation  Things you may need to show to others Written programs and procedures Training records Inspection results Performance tests/records Licenses/registrations

Laboratory Safety  Requirements Training Procedures (esp. PHS) Medical monitoring Labels/ MSDS Air monitoring Written program Chemical Hygiene Officer  Documentation Chemical Hygiene Plan Chemical handling procedures Training records and training subjects Lab inspections or air test results

General Chemical Safety  Requirements Hazard Communication Chemical Inventory Training Labels/MSDS Written program  Documentation Training records and topics Inventory Written Program Inspection and air test results

Respiratory Protection  Requirements Identify employee needs Training Medical evaluations Fit testing Written program Overseeing person  Documentation Medical approvals Training records and topics Written program Fit test records

Hazardous Waste  Requirements Procedures/protocols Waste accumulation Label and seal container Proper storage and removal Training of generators and program operators  Requirements EPA Generator Number EPA Generator Status Waste minimization program (if large quantity generator) Biennial reporting Good lawyers

Hazardous Waste, part deux  Documentation Written procedures Training records and topics, including annual refreshers in certain areas Records of identification of waste streams  Documentation Inspection results Waste manifests and exception reports Biennial reports Do you include light tubes, computer monitors, mercury items?

Transportation/Shipping  Why? Do your people cross public streets (in a vehicle) with hazardous materials of any kind? Does anyone prepare packages of hazardous materials for shipment by any carrier? That’s why!

Transportation/Shipping  Requirements DOT training for all applicable vehicle operators DOT training for all packers and shippers of hazardous materials  Documentation Training records and training topics Transfer manifests

Miscellaneous Items  Freon control Training Records Reporting  TSCA Imported chemicals Developed of synthesized chemicals  Asbestos Proper maintenance, removal and disposal Renovation issues Training  Lead Proper handling during renovation

Environmental Management Systems  A facility-wide comprehensive approach to environmental compliance and responsibility  Currently fairly rare in c/u settings, though more common in industry  An EMS is a lot of work and often a part of a c/u settlement after an EPA inspection, in partial exchange for fines

Environmental Management Systems  Requests and demand for this are definitely on the rise among people supporting research  Often centered around the ISO standard  Official registration of your EMS is possible

Isn’t This All Someone Else’s Job?  Yes  However, as administration you need to ensure that certain things really happen! For regulatory compliance For research implications  You are often the best contact to indicate new personnel or research activities to EH&S

How Do I Know We Are Doing All This Stuff?  Become good friends with your EH&S department, take them to lunch, ask discrete questions to see what they know...  They will be probably tickled that you are interested  Consider performing and internal or external audit of these functions

What’s Coming Up  Possible “Chemical Security Act” Bill before Senate, re-introduced in 2003 Opposed by chemical manufacturers; White House has not taken official position Tom Ridge thinks is may not be necessary My guess is that passage is not going to happen real soon...

Potential Impacts of a Chemical Security Act  Development of “inherently safer technologies”  Use less hazardous materials and smaller amounts  Reduce hazardous temperatures/pressures  Reduce human error and equipment failure

Potential Impacts of a Chemical Security Act  Improve inventory control and chemical use efficiency  Reduce or eliminate transportation, handling, disposal and discharge  Enhance security  Increase use of secondary containment

Potential Impacts of a Chemical Security Act  Buffer zones between chemical sources and schools, hospitals and population centers  Employee training increase  Personnel background checks  May include all CERCLA materials (i.e., very many common hazardous chemicals)

Concerns About the Proposed Acts  The acts are very broad and somewhat vague  Puts industry in the position of fighting terrorism—(and us perhaps, as there is no college and university exemption currently)  May cause the victim of a crime to be a criminal!  Intrusions between conflicting agencies

Any Final Questions?  Good luck!