From: 8524828hau**At_Symbol_Here**COMCAST.NET
Subject: Re: [DCHAS-L] UC - LADA Agreement
Date: July 31, 2012 10:45:56 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <003c01cd6da9$0ac0f1d0$2042d570$**At_Symbol_Here**com>


DOE's somewhat dated home page for "Integrated Safety Management" is at http://www.hss.doe.gov/healthsafety/ism/
For a diagrammatic representation click to enlarge the image at http://orise.orau..gov/safety/integrated-safety-management.aspx

The  diagram (center circle) defines seven over arching Guiding Principles for working safely.  The peripheral circles describe five Core Functions for performing work, with initiation being "Define the Scope of Work."    Together, the Principles and Functions define a process defined by the Department of Energy as "Integrated Safety Management" (ISM).

Implementation of ISM is applicable to all work, including bench-scale research with hazardous chemicals and microorganisms.  ISM is the "high bar" that the Department of Energy has established for all of its research laboratories. 

Although with different vocabulary, ISM seems to approximate the "high bar" established by the UC-LADA agreement.  A few examples follow:

The principle "Hazard Controls Tailored to the Work Performed" addresses the questions asked about the differences in the rigor of hazard protection when (for example) working with concentrated nitric acid vs. a dilute solution of 0.1-1N nitric acid.   The principles "Line Management Responsibility" and Roles and Responsibilities" corresponds to the clearly understood roles of the institution, the principal investigator, and the worker.  The core function (outer circle) "Develop and Implement Hazard Controls" corresponds to the preparation and use of an SOP.  The Principle "Competence Commensurate with Responsibilities" corresponds to the training/mentoring and experience level of the person performing the work.  The UC-LADA agreement is an extreme example of the core function "Provide Feedback and Continuous Improvement."

I hope that other similarities between the ISM diagram and the UC-LADA agreement are intuitively obvious.

For those who may wish to delve deeper, see the ongoing refinements and more contemporary ISM documents at:
http://www.hss.doe.gov/healthsafety/ism/
https://www.directives.doe.gov/directives/0450.4-APolicy-a/view
https://www.directives.doe.gov/directives/0450.4-EGuide-1c/view

David Haugen
Retired from a DOE research laboratory


From: "NEAL LANGERMAN" <neal**At_Symbol_Here**CHEMICAL-SAFETY.COM>
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Sent: Sunday, July 29, 2012 11:41:40 AM
Subject: [DCHAS-L] UC - LADA Agreement

The complete Agreement between UC and the LADA related to the Sangji fatality is posted on the CHAS website at:

 

http://tinyurl.com/uc-lada-agreement

 

 

This Agreement has two precedent-setting conditions which will set a new, high bar for academic safety performance.  In Appendix A - Sections 3 and 4, PIs and visiting PIs are not allowed to perform any work or supervise any activity until they receive formal laboratory safety training..

 

This is a powerful requirement which will clearly redefine the position of laboratory safety in the activities of each PI.

 

In Appendix A section 6, the Agreement requires that SOPs for a list of specific chemicals and chemical classes be written by the lab's most experienced person and be signed off by the PI.  CHAS has broken this list of chemicals out of the Agreement and it can be found as a stand-alone document at the URL above. 

 

These powerful requirements apply to the entire UC system.  As such, they will set a performance bar for research institutions across the country.

 

Please read these documents and share your thoughts with the CHAS community.  As time goes on, we will revisit these requirements and learn how their implementation is playing out.

 

Stay safe out there!

 

Neal

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ACSafety has a new address:

NEAL LANGERMAN, Ph.D.

ADVANCED CHEMICAL SAFETY, Inc.

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