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In catching up with my reading of the Journal of Chemical Health & Safety, I was struck by the paper “Lions, tigers, and bears: Managing research security in academia,” by Maureen Kotlas, director of environmental health and safety at the University of Missouri, Columbia. I was particularly interested in the various regulatory requirements for development of security plans for laboratories, and it occurred to me that most of these requirements don’t actually apply, in particular, to smaller academic facilities.
Maureen lists DHS, DOT, NRC, USDA, HHS/NIH, CDC, and AAALAC as all having requirements to assess security measures in labs (please forgive the abbreviations – just spelling those out would take half a page!). Most of those requirements apply only to certain types of labs, particularly those with animals or doing clinical work. In fact, most academic laboratories would only have to deal with the DHS requirements, and then only if they have threshold quantities of the Chemical Facility Anti-Terrorism Standards.
So, what are the real drivers for chemical security in academic labs, and how secure are chemicals in academia? Having traveled abroad and visited chemistry departments in other countries, I don’t see any consistency in chemical security. Some labs have chemicals kept so secure there would appear to be no chance of theft, deliberate misuse, or vandalism. Others present almost an open invitation to anyone with a desire to blow up things, outfit an illegal drug lab, or poison someone.
The Kotlas article touts security devices such as key-card entry, pan-tilt cameras, and vehicle access control. All of those can be effective parts of a security plan, but most are likely too expensive for smaller institutions to implement. I see two general problems in the area of lab security. One is a lack of resources for many smaller colleges and universities. The second is a laissez-faire attitude that many facilities need to work to overcome. Security risk and vulnerability assessments are not difficult or necessarily expensive. A simple walk-through of facilities by someone who doesn’t work there but knows what to look for is a good start; I’d recommend the ACS Committee on Chemical Safety’s security vulnerability checklist for anyone who isn’t sure how to proceed or what to look for.
There’s been a whirlwind of safety activity at the ACS meeting this week! The safety culture symposium was very well attended, and the speakers continually came up with new and effective approaches for the attendees to consider.
For my part, I realized that I need to change one aspect of my chemical hygiene officer training. I’ve regularly used the combination of engineering controls, administrative controls, and personal protective equipment (PPE) as the triangle of safe practice in the laboratory. It’s clear that I need to add a fourth corner: safety culture. The proper use of engineering controls (hoods, eliminating processes, isolating equipment, etc.), administrative controls (rules, policies, procedures), and certainly PPE is not enough without safe behavior in the use of those controls. Also, the paradigm we use in keeping laboratories safe has an economic component. Laboratories should be putting more emphasis on the operational costs of the laboratory, particularly energy. Looking at each aspect of laboratory operation from a “green” perspective has real value, since reducing costs can often result in the ability to increase budgets elsewhere.
We’ve also heard some news relating to the University of California system’s agreement with the Los Angeles County District Attorney’s office to follow the terms of a specified lab safety program at all of its campuses. The UC campuses are beginning to work together to develop consistent training programs to address the requirements, and UC has asked ACS to validate the program once it has been finalized. This peer review, which would most likely be performed by come combination of Division of Chemical Health & Safety and Committee on Chemical Safety members, could help the UC system substantiate compliance. Pending legal review and agreement between ACS and the UC Board of Regents, it appears this will move forward, since both CHAS and CCS agreed unanimously to support the project.
The weather in Philadelphia has been great, the sessions well attended, and the lab safety community has had plenty to talk about. All in all, it’s been an excellent meeting! Thanks to all who participated, and if you couldn’t make it, we hope to see you in New Orleans in 2013.
How would you have handled this situation?
Three chemists in a small laboratory were moving some old chemicals to a staging area prior to disposal. Many of the chemicals were simply unopened expired reagents, while others had been previously opened and used. After perhaps a half hour of moving chemicals, one of the workers complained of a severe burning sensation on the palm of his hand. When he removed his latex glove, his hand had some minor swelling and redness but no outward sign of burning. His pain quickly became worse.
A quick examination of the chemicals he had been handling showed that most were fairly innocuous, but one was a gallon container of waste labeled “HNO3, H2SO4, and HF.” The immediate suspicion was that some of the hydrofluoric acid had somehow leached out of the bottle or been spilled, depositing residues on the outside. The waste container was a glass bottle, and no HF has been used in this particular laboratory for approximately 20 years. Of the other chemicals the worker handled, the only one with known skin irritant properties was osmium tetroxide. There was no evidence to suggest significant exposure, since the OsO4 bottles were all contained in a box and had not been handled directly.
So what to do? The decision was made to take a conservative approach and treat the hand with calcium gluconate. A tube of 2.5% gel was located fairly quickly. The gel was dated “1993” and had partially separated but appeared to still be viable. The hand was treated heavily with the gel, and a latex glove was then placed over the entire hand. This is all consistent with recommended practice for treating HF burns.
The chemist’s pain persisted after treatment, so as a precaution he was taken to an emergency room about five minutes away. The first two medical professionals attending in the emergency room, a registered nurse and a physician’s assistant, were unfamiliar with HF. The workers didn’t bring a material safety data sheet because there was no way to to be sure of the source of the problem, since the suspect container was a mixture of acids. The physician who eventually arrived was well familiar with HF and the appropriate treatment. Since the hand had already been treated appropriately, she prescribed Benadryl (diphenhydramine) to treat possible allergic or sensitivity symptoms and sent the patient on his way. Later in the day, the chemist reported that the pain had subsided and he had no apparent ongoing effects.
So… what might we have done differently?
Osmium is the densest of all natural elements and certainly one of the rarest, with worldwide production of about 545 kilograms annually. It’s incredibly expensive stuff, and yet, look at all the varied uses! Osmium is used by itself or as an alloy for fingerprint detection and in fountain pen tips, pacemakers, light filaments, and jewelry. And it’s reacted with oxygen to form osmium tetroxide.
The word osmium actually comes from the Greek word “osme,” or odor, for the unique acrid odor given off by OsO4. Osmium tetroxide is incredibly toxic and has an OSHA permissible exposure limit (PEL) of 0.002 mg/m3. For comparison, elemental mercury vapor has a PEL of 0.1 mg/m3. Osmium tetroxide might even be considered a perfect component of a terrorist “dirty bomb,” but it’s simply too expensive to buy enough to make that practical.
A primary use for OsO4 is for tissue fixation in electron microscopy. Hundreds of hospitals use it in their clinical labs, and when the solution is spent, it needs to be disposed safely. My experience with OsO4 stems primarily from efforts to recycle the spent compound. Ironically, despite its obvious toxicity, OsO4 isn’t regulated as hazardous waste. While it is certainly toxic to humans, it breaks down fairly readily in the environment, (apparently) isn’t toxic to aquatic or marine life, and isn’t mobile enough to be considered a threat to drinking water. That means that theoretically one could take this non-regulated waste and sell it for a handsome sum to a refiner who could recover and resell the metal.
However, here is a lesson in making sure you know the hazardous waste regulations thoroughly! It turns out that one of the several buffers that labs use with OsO4 is cacodylic acid, which has the formula (CH3)2As(O)OH. Therein lies the rub. While EPA decided that osmium isn’t hazardous to the environment, arsenic is. So, any refiner recovering osmium from the spent solution also containing that particular buffer must have a full-blown EPA hazardous waste treatment, storage, and disposal facility permit! Use a different buffer and you’re fine.
It only took me stops at five hospitals to find out the popularity of the cacodylic acid buffer, thus ruining my plans for an early retirement.
For more on osmium, check out this essay on the metal from C&EN’s 80th anniversary special issue on the periodic table and this video from the Periodic Table of Videos:
With the news last month that the Los Angeles County Superior Court has once again delayed the arraignment of the University of California, Los Angeles, and chemistry professor Patrick Harran on felony charges for labor code violations, it seemed appropriate to take a closer look at what the university is doing to move forward.
In response to the death of UCLA laboratory researcher Sheharbano (Sheri) Sangji, the university instituted a number of safety improvements, including more thorough lab inspections, more flame-resistant lab coats, and additional special training in the use of safety gear and the handling of air-sensitive chemicals. UCLA also established a Center for Laboratory Safety (CLS). According to the CLS website, the center was created to “improve the practice of laboratory safety through the performance of scientific research and implementation of best safety practices in the laboratory.” The Center operates under the oversight of an advisory board, with technical support from the UCLA Office of Environment, Health & Safety (EH&S) and the UCLA School of Public Health’s Department of Environmental Health Sciences.
James Gibson, UCLA’s director of EH&S and the executive director of the CLS, has been on the road constantly promoting the center as well as UCLA’s overall response to the Sangji incident. Also promoting the center everywhere has been Erike Young, the EH&S director for UC’s Office of the President. Young is charged with seeing that all of the UC campuses improve their safety culture. He pointed out during his 2010 talk at the National Research Council’s Safety Summit that most UC campuses do not perform “lab safety inspections”, although they may be inspected by individual programs for fire safety, biological safety, radiation safety, etc. Audits commonly find lack of safety training by PIs and research teams, lack of enforcement on PPE requirements, insufficient or improper safety equipment, and lack of follow-up on inspections.
Young said that UC’s challenge is to integrate safety management into the basic operation of research laboratories, a concept also championed by the ACS Safety Culture Task Force (pdf). If structure drives behavior, then it stands to reason that laboratory safety issues will more frequently be apparent at facilities without a strong safety culture. Unfortunately, Young noted that university EH&S lab safety is largely regulatory driven, not risk based. This is something the CLS is trying to change.
So what has UCLA done to fundamentally change its safety culture? Among other things, the University has appointed a new chemical hygiene officer (CHO), Petros Yiannikouros.
I had the pleasure of spending a number of hours with Yiannikouros during the recent ACS meeting in San Diego. I found him engaging, communicative, and fun to talk with (which makes him one of my new best friends). A native of the island of Cyprus, Yiannikouros is at UCLA at least partly because of its proximity to the ocean – he told me it is impossible for him to live more than an hour from water and an opportunity to fish. Upon a little research, I find that his background also includes serving as the Head Scientist in charge of Quality Control for the Carlsberg Brewery in Cyprus!
While he was unable to speak to the Sangji incident (it precedes his time at UCLA), Yiannikouros outlined some of the challenges he faces. When asked what he believes makes a successful CHO, he stressed experience in the laboratory. Yiannikouros feels it is difficult, if not impossible, for a CHO to adequately manage safety in a research environment without clearly understanding the processes and procedures. With the emphasis at UCLA on the handling of reactive chemicals, Petros finds his experience in organic research to be invaluable, particularly in respect to the handling and use of organometallics.
The California Division of Occupational Safety & Health (Cal/OSHA) agrees with Yiannikouros. “A CHO should be able to interact with investigators as a peer and be able to understand what it is they’re talking about,” as well as know the various regulations involved, Cal/OSHA senior safety engineer Deborah Gold told my co-blogger Jyllian in 2010, when discussing why the agency felt a previous UCLA CHO was unqualified.
I certainly wish Yiannikouros luck at UCLA as he continues to help change the safety environment. It is clearly a challenge to get principal investigators to “buy in” to structured safety behavior, but it looks like Yiannikouros has the tools to do that at UCLA.
I may have ranted about this a few times in the past 25 years or so… but why give up now? It is time to get rid of the Land Disposal Restriction (LDR) form.
A little history: Back in 1984, when the Resource Conservation and Recovery Act (RCRA) was reauthorized, the Environmental Protection Agency (EPA) banned the land disposal of hazardous waste and created one of the most useless government-bureaucracy-wasteful forms ever in the process. Generators of hazardous waste, including laboratories, were required to complete a “notification” to their disposal facility telling them what kinds of waste they were providing and what could be done with it according to RCRA. A “one time only” notification is required for each waste stream; but for laboratories that means that each and every lab pack–a drum packed with smaller containers of chemicals–offered for disposal requires the completion of a non-standardized form which runs about 3 to 5 pages in length. Although the disposal facility’s permit already specifies what it is allowed to do, a waste generator still has to tell the facility how to handle the waste. Okay, maybe this form was useful for a year or two… I’ll give EPA 1984 and 1985.
Now all the LDR notification does is waste money. Lots of it. If you assume, conservatively, that one million lab packs are shipped in the U.S. annually (the laboratory I handle has 25 employees and generates about 50 lab packs each year), and the completion of the form for each takes 5 minutes, that’s more than 83,000 manhours a year. With an average billing of a lab pack team (all sitting there either completing the forms or waiting for someone doing it) at about $100/hour, that’s more than $8 million annually that U.S. labs are spending to comply with LDR.
I’ve been trying to get rid of this requirement since 1990, 22 years ago. To take my math a step further, it’s quite likely that U.S. labs have spent well over $100 million complying with this law since 1990. Efforts (not just my own) to implore EPA to get rid of LDR have included repeated petitioning, complaints at EPA public hearings, and meetings with EPA and congressional staff.
So why doesn’t EPA get rid of the forms? Probably because EPA thinks it has bigger fish to fry. EPA estimated in the early 1990s that laboratory waste represents less than 1 tenth of 1 percent of all hazardous waste, so pretty much any regulatory effort that comes along is going to be aimed at the other 99.9%.
If you agree with me, say so. If you can find any reasonable justification for keeping LDR, I’d love to hear from you.
Responding to a request from several former ACS presidents, the ACS Division of Chemical Health & Safety is attempting to develop an online laboratory safety certification program aimed at chemistry graduate students. The program ideally would address longstanding complaints from industry that Ph.D. programs do not adequately educate students to work safely in industrial research and development laboratories. A well-planned and peer-reviewed online certification program could be part of the solution to this training gap.
The development cost for online training programs, according to an informal survey of commercial online training providers, is approximately $20,000 for each presentation hour of this type of safety course. This means that developing an 8- to 10-hour course with about a dozen training modules would cost $160,000 to $200,000.
The division is now facing the following questions and would welcome input from Safety Zone readers:
- How might costs be lowered? What work could be done by volunteers rather than paid consultants?
- Does ACS have the resources to develop the program without using a training provider?
- Several organizations are willing to support program development: the ACS Corporate Associates, National Academy of Sciences, National Research Council, and Council for Chemical Research. Are there others that might be interested?
- Is there sufficient demand to warrant developing the program? Can it meet industry’s needs?
- What topics should be covered, and what is a realistic amount of time to commit for effective training?
- Is taking an online course and passing tests sufficient for certification or should there be other components?
Related post: Teaching safety to chemical engineers
The ACS Southwest Regional Meeting in Austin last week featured a wide-ranging program that included a strong focus on chemical safety. I presented two workshops on “Laboratory Waste Management” and “How to be an effective chemical hygiene officer,” and there was also a half-day session on “Recent Advances in Chemical Safety” that was well attended.
Of particular interest in the symposium was a talk by Ephraim Massawe, a professor of computer science and industrial technology at Southestern Louisiana University, on a subject I had never really thought about but has wide-ranging implications: “Nanoinformatics for nanoscale chemistry and nanotechnology: Opportunities for preventing occupational exposures in nanoenabled remediation.” While most discussion of nanomaterial safety focuses on air exposures, Massawe pointed out that there are safety considerations for environmental remediation of Superfund and other abandoned waste sites using slurries containing iron, silver, and other metal-based nanomaterials. Obviously, the surface area advantages of nanomaterials present many opportunities in the remedial field, and evidence suggests there have been a number of successful applications. The costs, according to data Massawe presented, are significantly lower than traditional pump and treat and other common technologies. Since there is so little real toxicological data available for nanomaterials in general, and most of what is available is focused on air exposure, what are the implications of application to injection wells? Is there potential for adverse impact on groundwater supplies? Are aquifers at risk or is the earth capable of filtering these materials when in liquid form as a slurry? It was an interesting talk and clearly there are challenges for those keeping an eye on the safety of nanomaterials.
A big Texas shout-out should go to Texas State University, San Marcos, chemistry professor Linette Watkins and Applied Nanotech safety officer Betsy Shelton for a very successful regional meeting that attracted over 1100 registrants. A special treat was hearing Nobel Laureate Robert Curl from Rice University tell the story behind the discovery of fullerenes, aka “Bucky balls” (and why that’s the common name for C<sub>60</sub> instead of soccerenes or footballenes!).