Over the last few years, high-profile laboratory incidents at major institutions have made front-page headlines. The latest resulting in the death of a graduate student at UCLA, and the Occupational Safety and Health Administration (OSHA) and Department of Justice’s (DOJ’s) decision to pursue criminal charges against both UCLA and the individual principal investigator (PI) in charge of the lab. The UCLA tragedy and another high profile accident at Texas Tech University (which also resulted in casualties) have altered the way OSHA is approaching enforcement in research lab settings. Specifically, OSHA has dramatically heightened the level of scrutiny on the university research sector, and has indicated its willingness to pursue criminal charges against individuals and institutions if and when it deems either to be criminally culpable. This heightened scrutiny coupled with the potential of personal criminal liability has sent shock waves through the university community, which by and large has been more focused on environmental rather than safety issues for the last decade.
While universities are putting increased emphasis on their lab safety programs, they also continue to strive to reduce their carbon footprint and the high energy costs associated with laboratories, which can use up to five times more energy than non-lab spaces of similar size, construction, and age. These seemingly conflicting interests have often lead to friction between the Environmental, Health, & Safety (EH&S) Departments, which need to provide the safest possible laboratory environment through conditioned and constantly changing air, and the Facilities Department’s desire to provide adequate conditioned environments while minimizing energy usage and reducing costs. Those institutions that are looking at lab safety and reducing energy usage in a comprehensive and collaborative manner are finding that the two goals are not necessarily mutually exclusive.
What Makes a Strong Lab Safety Program?
The starting point of any lab safety program is identifying risks and hazards. This requires an assessment of the chemical, physical, and health hazards present in a lab. While OSHA requires institutions with employees that are potentially exposed to health or physical hazards to perform hazard assessments, many institutions have never done this or have not done it in a disciplined, comprehensive and consistent manner with respect to laboratories. The level of detail put into the assessment should be commensurate with the risks present, with higher risk labs getting more intensive and specific evaluations. The process can be streamlined, automated, and institutionalized in ways that lead to efficient, effective, and consistent information gathering. Accurate information is the key to doing a competent risk assessment and developing effective safety mitigation measures that can be implemented. In most cases, to ensure accurate information is gathered, institution leadership has to set lab safety as a priority, the PIs and lab managers must buy in to providing the information to EH&S who can work with them to perform the hazard assessment and develop appropriate protocols to mitigate the hazards and risks.
There are several hazard assessment methods, but each requires getting accurate information regarding chemical use, waste generation, research protocols, equipment and lab usage. Information gathering can be automated at institutions with large numbers of labs, or it can be done lab-by-lab. Once the hazards are identified, they can be eliminated, engineering controls can be implemented, necessary training (hazard communication, hazardous waste, etc.) can be provided, personal usage (fume hood practices and operations, respirators, waste handling) practices can be demonstrated, and appropriate personal protective equipment (PPE) for lab practices can be assigned to minimize risk. Once hazard assessments are complete and lab safety programs are in place, routine internal and/or external audits should be performed to ensure that the programs are well implemented. Audits should:
*Review policies and practices, looking at the written policies, training requirements and programs, standard operating procedures and other documentation to make sure they will result in a safe working environment and can realistically be implemented. These policies should include a ventilation evaluation (how many air changes per hour are safe based on the hazards in occupied and unoccupied spaces, sash settings, face velocity). *Analyze program implementation and management systems. Strong written programs are important, but ensuring the programs are implemented as written, inspected on a regular basis, and backed with the full support of the PI, lab manager and institution is critical. *Help embed safety into the organizational culture. The best written program in the world will not result in a safe lab if the culture does not support a safety first mentality. Accordingly, universities must make the practice of safety a daily priority by building safety-related routines into all aspects of operations. This can include integrating a safety discussion into department meetings and creating a system to reward adherence to safety procedures; or penalize disregard or failure to enforce safe practices. You can have state-of-the-art fume hoods installed, but if the sash is not set appropriately, the ventilation is blocked by waste and an overcrowded hood, the face velocity is off, or it is not used effectively, it may not be providing the necessary amount of protection. *Make sure departments work directly with EH&S. Safety experts can help faculty, staff, and students understand risk and hazard assessment, and come up with practical ways to integrate safety practices into the work of the lab without compromising research or safety. An effective safety program is one that sets high standards, and creates a long-term sustainable system. With OSHA and DOJ now potentially holding individuals and institutions criminally responsible for accidents in their labs, poorly implemented safety programs pose a host of unacceptable risks.
Maintaining Safe Labs While Managing Energy Use
As noted earlier, lab buildings can use up to five times more energy than comparable buildings. Reasons for this include fume hoods that are designed to change the air anywhere from two to 12 times per hour, energy-intensive equipment, active use of the labs 16 plus hours a day, and older buildings not performing as originally designed. All of these activities increase energy demands and also represent potential health and safety risks. So if the primary goal is safety, what can be done to reduce usage and costs?
The first step in reducing energy costs in labs is understanding the buildings and individual lab’s ventilation system, equipment, and usage. The hazard assessment discussed above helps to define risks and will determine, in part, what is needed from the ventilation system in terms of minimum air flow changes per hour. A valid risk assessment that has buy-in at the lab and EH&S levels should result in agreement on this question, and the consequences are significant. For example, a 200 sq. ft. lab with minor inhalation hazards with a fume hood set at six air changes per hour, rather than four air changes per hour during occupied times and two during non-occupied times, can use dramatically more energy and may not provide a safer environment for its occupants. Similarly, the safest most efficient hood in the world will not perform as advertised with respect to safety or energy consumption if it is not being used correctly.
Assuming collaboration between facilities, EH&S, lab PIs and staff with support from institution leadership, the following steps can be taken to ensure lab safety while dramatically reducing energy costs and climate impact:
- Perform an energy conservation/optimization audit that evaluates building ventilation systems equipment, design, and operation and examines users’ behaviors to create a prioritized list of energy conservation measures.
- Modify lab design, operation, and equipment where it makes financial sense to do so and will not adversely impact safety.
- Have facilities and users work together to understand how behavior positively and negatively affects energy use.
- Develop a comprehensive ventilation management plan that will support consistent implementation.
- While these steps cost money, they often result in savings of up to 30 percent annually, making the return on investment attractive. They also serve to reduce the institution’s carbon footprint.
As a result of catastrophic events at major institutions and regulatory reactions to these events, iLab safety has never been more important. Because of the rising costs of energy, which have made it the second highest expense at most institutions behind only labor, and the effects of climate change, reducing energy usage has never been more important. While these seemingly conflicting pressures exist at virtually every college and university in the country, by employing a systematic hazard/lab safety assessment and program implementation, conducting a ventilation assessment and energy audit process, implementing the resulting recommendations and behavioral changes, and gaining buy-in and collaboration from stakeholders throughout the institution, both goals can be met.