From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Roger McClellan
Sent: Thursday, May 17, 2018 3:19 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] 20L Drums of Flammables

To all:

   I am pleased to note so many individuals have offered advice to Monique Wilhelm on  the issue of purchasing, storage and use of organic solvents and re-sue of metal containers.

 However, I am disappointed at the lack of comment on the much bigger issue of the lack of authority of a safety officer and faculty IGNORING ALL SAFETY REGULATIONS. This apparently applies to the Head of the Department who is clearly lacking in understanding of their legal responsibilities to provide support for the Department's designated safety officer. I am offering this comment now because I have noted many similar situations on this web site over the past decade. Why are senior individuals in this Division unwilling to confront the apparent "status quo" that gives lip status to the role of safety officers in academic departments?

I offer my comments having served as the senior individual responsible for the overall operations, including health, safety and environmental issues, for two major laboratories. One was the Lovelace Inhalation Toxicology Research Institute  (ITRI) with over 200 staff that was Government Owned , Contractor Operated facility for the Department of Energy. We conducted research on numerous radionuclides including Pu-239 and many potentially hazardous chemicals. We had a full time HSE staff of 5 or more individuals and a full-time on site nurse .  The other organization I served as President, CEO and Chief Scientific Officer was the Chemical Industry Institute of Toxicology (CIIT) in Research Triangle Park, NC with a staff of over 150 individuals supported by private sector companies. At CIIT, we studied a wide range of potentially hazardous chemicals. We had a full time HSE staff of at least 4 individuals.

At both institutions the HSE operations reported directly to me as the Laboratory Director.  These were well trained and certified individuals , and appropriately compensated individuals that other organizations routinely attempted to hire way. The Head of HSE in both cases was delegated full responsibility and authority for maintaining a safe work environment for all employees.. This included full authority to see that ALL HSE procedures were followed including the authority to shut down any unsafe operation and "lock out" the laboratory. This extended to oversight of every laboratory employee irrespective of their "rank or status". One of most useful approaches used was a cross laboratory advisory committee of professionals and technicians that conducted regular inspections of every laboratory and operating facility. No one wanted their laboratory to be tagged and shut down as unsafe. We had regular inspections by government authorities. The outcomes were usually positive and helpful. They routinely commented on the unusual situation in which the HSE unit had so much authority and reported to the Laboratory Director. I routinely reported on the status of our HSE operations to the Chair of the Board of Directors, my annual evaluation  by the Board included HSE operations

I suspect at this point many of you are thinking -- well, McClellan was not in an academic institution and does not know what he is talking about. I am sorry, if that is your view. The world is changing and academic officials have to begin recognizing they have really responsibilities for all aspects of an Institution's operation including ethical behavior and HSE operations. If in doubt, check the media reports on an Institution in search of $ 500 million to settle law suits for unethical and inappropriate behavior and lack of institutional oversight.

I feel sorry for  many "safety officers" in many academic departments, colleges and universities that are given limited authority by "higher ups" and looked down on by faculty members as a nuisance. Why does the profession tolerate this situation? These individuals serve a valuable role as team members to ensure the health and safety of all employees. I suggest the time  is over due for the DCHAS and the ACS Board to indicate they are really serious about Health and Safety and willing to offer meaningful guidance for the responsibility of faculty and staff and, most importantly, the role of safety officers. The lip service approaches of the past are no longer acceptable.

I welcome your responses and , most of all, your  actions. It is important to maintain dialogue on day to day operational issues, but , the elephant in the room can not be ignored any longer!

For improved health and safety operations.

Roger O. McClellan, DVM, MMS, DSc (Honorary)

Long time ACS and DCHAS Member

Diplomate - ABVT and ABT

Fellow - ATS, SRA, HPS, AAAR, IARA, ATS and AAAR

Member - National Academy of Medicine

Advisor, Toxicology and Human Health Risk Analysis

Albuquerque, NM 87111