Roles and Responsibilities
Responsibility for the Lab Safety Program resides at all levels. Within this framework, the Principal Investigator and Laboratory Personnel have specifically defined roles and responsibilities detailed below. The Principal Investigator (PI)/Laboratory Supervisor has responsibility for the health and safety of all laboratory personnel working under their authority or within their research facilities. The PI/Laboratory Supervisor may delegate the safety duties for which they are responsible, but must ensure delegated duties are performed and obligations met. Laboratory Personnel who work in research facilities have the right to be informed about the potential health hazards of the chemicals in their work areas and to be properly trained to work safely with those substances.
Laboratory personnel also have the right to report workplace hazards without fear of reprisal in accordance with the Cal/OSHA Injury and Illness Prevention Program requirements (8 CCR 3202 (a)(3)). Principal Investigators are responsible for informing researchers how to access and submit a Hazard Alert form by having hard copies available or directing individuals to the EH&S on-line form. Hazard Alert forms, whether hard copy or electronic, can be submitted anonymously.
Chancellor and Vice Chancellors
The University of California Policy on Environmental Health and Safety gives ultimate responsibility for the Injury and Illness Prevention Program (IIPP) and the Chemical Hygiene Program (CHP) to the Chancellor. Vice Chancellors assist the Chancellor and have direct responsibility for Divisions/Units under their authority. The UCSC Vice Chancellor for Research published "Procedures for Assurance of Laboratory Safety Compliance" in October of 2013. This document outlines the steps followed in assuring compliance with laboratory safety requirements.
Deans have direct responsibility for ensuring compliance in Units and Departments under their authority.
Department Chairs and Unit Heads have direct responsibility for IIPP and Chemical Hygiene at the departmental level. They may delegate authority for implementing the program; however, this does not eliminate personal responsibility for the program.
Principal Investigator/Laboratory Supervisor
The Principal Investigator (PI)/Laboratory Supervisor has responsibility for the health and safety of all laboratory personnel working under their authority or within their research facilities. The PI/Laboratory Supervisor may delegate the safety duties for which they are responsible, but must ensure delegated duties are performed and obligations met.The PI/Laboratory Supervisor is responsible for:
- Knowing applicable health and safety rules and regulations, training and reporting requirements, and standard operating procedures associated with laboratory safety;
- Identifying hazardous conditions or operations in the lab, determining safe procedures and controls, and implementing and enforcing standard safety procedures;
- Establishing standard safe operating procedures (general and protocol specific) and performing literature searches relevant to health and safety that is appropriate for the work;
- Providing prior-approval for the use of hazardous materials in the laboratory;
- Consulting on use of higher risk materials, such as use of particularly hazardous chemicals, biological agents, or radioactive materials, so that special safety precautions are taken;
- Maintaining an updated chemical and hazardous material inventory for the laboratory;
- Designating a Laboratory Safety Representative and providing documentation by completing Appendix A of the laboratory Injury and Illness Prevention Program.
- Ensuring laboratory personnel under his/her supervision have access to and are familiar with the appropriate laboratory safety manuals (online Laboratory Safety Manual, Standard Operating Procedures, Biosafety, Radiation Safety);
- Training all laboratory personnel he/she supervises to work safely with hazardous materials and maintain written or electronic records of laboratory-specific training. Training must include informing laboratory personnel of the location and availability of hazard information such as Material Safety Data Sheets;
- Notifying EH&S and/or Facilities Management as soon as possible should he/she become aware that work place engineering controls (e.g., fume hoods) and safety equipment (e.g., emergency showers/eyewashes, fire extinguishers, etc.) become non-operational;
- Ensuring all appropriate personal protective equipment (PPE) (e.g., lab coats, gloves, eye protection, etc.) is provided and maintained;
- Conducting annual PI inspections of all laboratory spaces and ensuring that quarterly self inspections are performed within the lab. Maintaining records of inspections and corrections, as required, and ensuring all corrective actions are completed and that annual EH&S audit findings are addressed, documented and forms returned to EH&S;
- Prompt reporting of laboratory accidents and injuries to Risk Management and EH&S. Serious injuries MUST be reported to EH&S within 8 hours of the incident;
- Providing funding for medical surveillance and/or medical consultation/examination for laboratory personnel, as required; and
- Informing facilities personnel, other non-laboratory personnel, and any outside contractors of potential lab-related hazards and how to mitigate these hazards when they are required to work in the laboratory environment.
Laboratory PersonnelAll laboratory personnel in research operations are responsible for:
- Reviewing and following relevant laboratory safety manual(s) (e.g., online Laboratory Safety Manual, Standard Operating Procedures, Biosafety, Radiation Safety, etc);
- Following oral and written laboratory safety rules, regulations, and standard operating procedures required for the tasks assigned;
- Keeping work areas safe and uncluttered;
- Reviewing and understanding the hazards of materials and processes in their research operations prior to conducting work;
- Using appropriate measures to control identified hazards, including consistent and proper use of engineering controls, personal protective equipment, and administrative controls;
- Understanding the capabilities and limitations of PPE issued to them;
- Obtaining prior approval from the PI/Laboratory Supervisor for the use of particularly hazardous chemicals, biological agents, or radioactive materials;
- Consulting with the PI/Laboratory Supervisor before using highly hazardous materials or conducting certain higher risk experimental procedures;
- Prompt reporting of accidents and unsafe conditions to the PI/Laboratory Supervisor, as well as EH&S (Hazard Alert form);
- Completing all required health, safety and environmental training and providing written documentation to their supervisor;
- Participating in the medical surveillance program, when required;
- Informing the PI/ Laboratory Supervisor of any work modifications ordered by a physician as a result of medical surveillance, occupational injury or exposure; and
- Laboratory personnel working autonomously or performing independent research are responsible for:
- Reviewing the plan or scope of work for their proposed research with the PI/Laboratory Supervisor;
- Notifying in writing and consulting with the PI/Laboratory Supervisor, in advance, if they intend to deviate from their scope or scale of work;
- Preparing SOPs and performing literature searches relevant to safety and health that are appropriate for their work; and
- Providing appropriate oversight, training and safety information to laboratory personnel they supervise or direct.
Environmental Health and Safety (EH&S) and Chemical Hygiene Officer (CHO)
EH&S has responsibility for administering and overseeing institutional implementation of the Laboratory Safety Program. EH&S ensures that the online Laboratory Safety Manual meets relevant Cal/OSHA regulatory requirements, including the Chemical Hygiene Plan requirements under 8 CCR 5191, and that the Manual presents information to prevent or minimize lab-related injuries and illnesses, to protect the quality of the workplace, and to protect the surrounding environment. EH&S advises the research community of its responsibilities with respect to laboratory health and safety issues, recommends appropriate corrective actions and programs, implements new health and safety programs, and serves as the liaison between UCSC and various external agencies and regulatory bodies.
The Chemical Hygiene Officer (CHO) has primary responsibility for ensuring the implementation of 8 CCR 5191, "Occupational Exposure to Hazardous Chemicals in Laboratories." The CHO is a member of EH&S and, with support from other EH&S personnel, is responsible for:
- Informing PIs/Laboratory Supervisors of chemical-related health and safety requirements and assisting with the selection of appropriate safety controls, including engineering controls, laboratory and other workplace practices and procedures, training, and personal protective equipment;
- Helping to develop and implement appropriate chemical hygiene policies and practices;
- Working with Departments and lab groups to develop and review SOPs for processes using hazardous chemicals;
- Conducting periodic inspections and immediately taking steps to abate hazards that may pose a risk to life or safety upon discovery of such hazards;
- Performing hazard assessments, upon request; and
- At least annually, reviewing and evaluating the effectiveness of the Laboratory Safety Manual and making updates as appropriate.