1. Department/Unit Safety Coordinator’s Seminar Enterprise Risk Services/Environmental Health & Safety Tuesday, December 3, 2013

2. Agenda: 10:05 – 10:25 How to Prepare for Regulatory Visits (Lance Jones, Dan Kermoyan, EH&S) 10:25 – 10:55 Laboratory Safety Program Overview (Dan Kermoyan, EH&S)  OSU Laboratory Categories (LCAT)  Laboratory Safety Assessments  Campus SOPs 10:55 – 11:00 Q & A ** 10-Minute Break ** 11:00 – 11:30 Regulatory Compliance Issues (Lance Jones, Pete Schoonover, Andy Kenst, Matt Philpott, Brian Lilley, EH&S)  Is your Chemical Inventory up to date?  Are your chemicals and wastes labeled and stored safely?  Does your laboratory have a chemical hygiene plan?  Have your employees received training?  Autoclaves, Eyewash-Shower testing 11:30 – 11:40 Waste minimization/recycling program (Kent Lanning, EH&S) 11:40 – 11:45 Safety Data Sheets (SDS) Resource (Lance Jones, EH&S) 11:45 – 11:55 Laboratory Safety & Haz Waste Training (Matt Philpott, Lance Jones, EH&S) 11:55 – 12:00 Q & A; Future topics?

3. How to Prepare for Regulatory Visits Lance Jones, Dan Kermoyan, EH&S

4. Potential Regulatory Agencies visiting the OSU campus Federal EPA: Hazardous waste; Environmental DOT: Shipping; Transportation NIH/CDC: Recombinant DNA/Select agents DHS: Chemicals of Interest APHIS: Plants, recombinant work State DEQ: Hazardous waste; Environmental OR-OSHA: Enforcement or Consultation Oregon Health Authority: Public Health; Drinking water; Radiation OR Dept. of Agriculture: Waste discharge; Disease prevention; Food

5. Potential Regulatory Agencies visiting the OSU campus County Agencies County Health: Public Health/Sanitation/Disease reporting County Env. Health: Water systems/Waste disposal City Agencies Public Works: Waste water/Storm water Corvallis Fire: Fire prevention inspections

6. What Occurs During an Inspection? 1.Unannounced – Injury; Incident; Complaint; Scheduled 2.Opening interview: ID, Why, What 3.Program review 4.Site visit 5.Performance-based review (observations, photos, review training records, review procedures, conduct interviews) 6.Closure and summary

7. Department/Unit Response  Contact EH&S  Limit conversation to what is directly requested  Q: “Have you received training on SDS’?” – A1: “Yes” or “No” – A2: “Yes, but I don’t know where they are…” – A3: “No and no one has ever offered training to me…”

8. Department/Unit Response  “Calm confidence” approach  “Interested compliance” attitude  If in doubt, ok to get back to them on an issue  OK to take:  Duplicate photos  Split samples  Notes  Inspection results will take awhile  Review notes with department and EH&S soon as possible

9. OR-OSHA Violations Classification types: Serious violation – substantial probability of serious physical harm to employee. Other than serious Minimal – no direct or immediate impact to health and safety of employee. Penalties assessed:  Serious: $300 - $7,000  Other than Serious or Minimal: $0 - $300  Can adjust downward for history, good faith effort, & immediate action.

12. EPA Hazardous Waste violations Waste label not properly filled out, incomplete information Hazardous waste training Open waste containers Spillage or leakage of waste (including contamination on the container) Failure to determine waste as hazardous (e.g. it is clearly waste like but there is no waste label) RCRA: Administrative, Civil, or Criminal Actions Compliance Action Corrective Action (release to environment) Imminent & Substantial Endangerment $5,500 - $27,500 per day, per violation Criminal Actions: $50,000 - $250,00 per day, per violation

13. EPA Hazardous Waste fines April 2003 - A private college in Long Island, NY was fined $112,310. October 2003 - A private university in upstate NY was fined $60,500. RCRA violations Failure to determine if the wastes generated were hazardous wastes; Failure to separate incompatible wastes.

14. EPA Hazardous Waste fines July 2003 – Medical school in New Jersey was fined $166,658. Failure to determine if the wastes generated were hazardous wastes. Failure to maintain the facilities to minimize the risk of releases of hazardous waste to the environment; did not ensure that its facility and staff received required training Failure to keep waste containers closed; and improperly disposed of hazardous wastes, such as solvents and mercury wastes.

15. University of Hawaii EPA hazardous waste violations in October 1997 at the University of Hawaii: $1.7 Million settlement; $1.2 Million towards environmental projects; received settlement in 2001. Inspectors found improperly stored and labeled chemicals including flammables, corrosives, poisons, mercury and hundreds of other unknown chemicals. The Department of Health continued to inspect other facilities within the university system and found similar violations at – Kauai Agricultural Center – Waiakea Agricultural Experiment Station in Hilo

16. What will they see? The Good

17. The Bad

18. The Ugly

19. Questions?

20. Laboratory Safety Program Overview Dan Kermoyan, EH&S

21. Lab Safety Program: Identifying Needs Fallacy: compliance = 0 risk, OSHA << EPA Regulatory agencies Observations/Knowledge of programs Discussions with campus ISO 14001 Analytical Model Quantify, Rank, Prioritize 2009/2010

22. Vulnerability Analysis compliance vs. risk OSHA << EPA Risk Identification & Analysis Most new employees are not enrolled in a health & safety training program; new employee health & safety training is not mandatory. Probability x Magnitude Impacts: Human, Facilities, Institutional HIGH Risk rank; Scored 14.2 Prioritization/Mitigation Plan Health & Safety Training Required for all Faculty & Staff: All faculty, staff, and student employees to obtain health & safety training according their job roles. Training shall be documented and kept on file with the supervisor and employee.

23. Vulnerability Analysis Risk Identification & Analysis Safety equipment testing is sporadic and not funded; emergency eyewash/showers, air balancing of fume hoods and room air, etc. Probability x Magnitude Impacts: Human, Facilities, Institutional HIGH Risk rank; Scored 14.2 Prioritization/Mitigation Plan Preventative Maintenance Budget for Building Safety Equipment: Fund PM program for testing and repair of building safety equipment: Emergency eyewash and showers, fume hoods, biosafety cabinets, and air balancing.

24. Vulnerability Analysis Risk Identification & Analysis No formal lab safety audit program is occurring. Probability x Magnitude Impacts: Human, Facilities, Institutional HIGH Risk rank; Scored 15.8 Prioritization/Mitigation Plan Work-place Health & Safety Audits: Supervisors to conduct annual self-audit of work areas and work practices under their control. EH&S to conduct routine audits of work areas based on a priority, hazard level designation. Corrective actions to be implemented by the supervisor or university.

25. Addressing the Vulnerabilities Training modules, Safety Instructions, Web resources EHSA data base/Qualtrics Equipment testing program Lab Safety Assessments Policy/SOP development  Health & Safety Training Required  Training shall be documented  Emergency eyewash and showers, fume hoods, biosafety cabinets  Work-place Health & Safety Audits  Laboratory Policy/SOPs

26. Lab Categories (LCAT) “Laboratory” defined Planning’s data: 1,100 spaces Planning + EHS data: 1,618 spaces Grouped according to materials used/stored Assigned an assessment frequency

27. Laboratory Safety Assessments For 1,100 spaces o 50% follow up anticipated o Consolidated audits o Efficiencies/software explored o 5.2 FTE For 1,618 spaces o 7.7 FTE  EH&S to start with LCAT 4 spaces  Assigning spaces now  Will start with Gilbert Hall  Resource-based/Pre-notice  February 1 st or sooner  Self-Audits will be needed

28. Campus Policies/SOPs “Wait-on” (2 policies) 1)Campus Department Safety Coordinators (DUSC) Maintains chemical inventories, proper labeling of chemicals and wastes, maintains training records for their lab staff, and conducts yearly self-audits. 2)Campus Laboratory Safety Committee (LSC) – Issues Chemical Use Authorizations. – Conducts auditing of OSU’s Laboratory Safety Program and reviews safety assessment results. “Green light” (5 policies) 1)Lab Categorization and Laboratory Assessments 2)Annual Chemical Inventories 3)Chemical Hygiene Plan 4)Authority to Abate “Hazardous Conditions” 5)Mandatory Lab Safety Training for all PIs and staff

29. Questions? 10-Minute Break