This summary is meant to clarify the responsibilities of Deans, Directors, Department Heads, and Primary investigators for the planning and conduct of research involving physical, chemical or other hazards. Actual cases of damage and injury are outlined and analyzed for root causes.
The examples included in this document demonstrate that planning for safety of experiments is far better than dealing with the employee injury, equipment damage, and work stoppage which results from a lab accident. Primary investigators (P.I.'s) are expected to be fully aware of the risks posed by their research materials/methods, and effectively communicate this awareness to their students. The expected method for instilling this awareness is through written Standard Operating Procedures (SOP's), used to instruct the students and identify necessary precautions to avoid injury and equipment damage. Written records of the instruction must be kept. Equally important to communication is direct involvement of the P.I. in observing the behavior of their students, and enforcing safety procedures. This is sometimes difficult for research directors, so the task may be assigned to a laboratory manager or other designated responsible person. The absence of such a lab manager leaves the research director responsible for the safety of day-to-day activities and resulting accidents. Research equipment safety features, such as exhausted enclosures, sensor/alarm systems, power-interlocked guards and shields, system pressure gauges, and other measures must be installed to reduce exposure risks and monitor system performance.
The University provides safety resources to the research community through the Dept. of Occupational Safety and Environmental Health (OSEH). Technical assistance regarding research material risks, method refinement, equipment specifications and training, hazard containment, protective equipment, and hazardous waste disposal is available from OSEH. The OSEH web page (http://www.oseh.umich.edu/) is a readily available resource for initial query into these areas. Templates for SOP's, safety plans, and recommended methods are all easily accessible from this on-line system. OSEH representatives for the research campuses are a phone call away, and will provide personalized service for specific research challenges.
A graduate student, working alone in a laser lab, was using fluorine gas in a deliver system to fill the laser. The gas bottle and delivery system were not enclosed or vented, and no sensors or alarms were in place to detect leakage. The copper line delivery system was hanging out and unsecured. As the student attempted to fill the laser with 5% fluorine, the delivery system failed at an unexpected location, allowing leakage to the laboratory.
A post-doc researcher was processing several polymer samples, dissolved in ethanol. The process required evaporating the ethanol from open beakers to leave the polymer residue. This was usually done at room temperature in the chemical fume hood. Late in the afternoon, he was in a hurry to have the experiment completed, so he decided to accelerate the ethanol evaporation by using a drying oven. There was no written SOP for the procedure. An hour into the evaporation, and with the lab empty, the ethanol vapors found an ignition source in the thermostatic switch for the oven, creating an explosion and fire. The oven was clearly labeled as not being suitable for use with flammable solvents. This ignited the flammable vapors, and in the enclosed oven, created an explosion and fire. With no SOP, specific instructions on drying were not available from the P.I. - employees were left to their own devices to carry out the experiment. Also, the post-doc was confused about flash points. He claimed that the flash point of his ethanol solution was 70c when in fact it was 70F. Running the oven at 60C equated to 140F, well above the flash point for the solution. Corrective actions have included re-education of the lab staff on flammability risks of solvents and written SOP's for their methods utilizing flammable solvents.
A graduate student, working with a post-doc researcher, was attempting to change the oil in a turbo pump used for a Molecular Beam Epitaxy machine. This research involves solid state electronics production. The hydride gas had not been adequately purged from the system prior to cracking open the pump. Hydride gas escape produced a moderate fire and sensors sent the building into alarm. Students were unable to extinguish the fire for some minutes, facing exposure during that time. This is the second such incident in two years. The gas exhaust system had no reliable gauges to indicate failure, so the researchers had no positive indications that their purge had been unsuccessful. Pump placement, in an awkward position, was another complicating factor. Later, it was found that purge pressure gauges were inadequate to indicate system blockage. SOP's were not in place for most of the lab procedures. An emergency response plan was not in place. Equipment maintenance was non-existent. Two years of continuous use lead to exhaust system blockage. Corrective Actions have been undertaken to relocate pumps to more serviceable positions. Interlocked pressure gauges have been installed for system shutdown in the event of flow failure. SOP's have been developed for all experimental procedures. A mandatory prior approval system is in place for MBE runs. Students have been retrained on all procedures. Equipment maintenance schedules have been developed. Necessary equipment upgrades are on a 6-month plan.
A student, working alone with a Class 4 laser, wished to align the laser but chose not to use their eye protection. The student removed a shield, meant to guard against accidental eye exposure and injury, and received a flash exposure from a laser flash of the edge of the optical lens. The laser guard was not interlocked with the power, which would have prevented laser operation when the guard was removed. Corrective actions have included retraining of the research lab staff on SOP's for safe laser use, and interlocking laser power to the guard mechanism.
You wish for your experimental design to deliver useful data in an efficient and timely manner, without delays or incident. Some of the first considerations for an experiment design or method change are the hazardous chemicals to be used, dangerous equipment to be purchased, and the potential injury they may cause. One rule-of-thumb is to assume that accidents will happen (chemical spills, fire) and plan accordingly. This will drive decisions to: minimize experimental quantities; mandate protective equipment; enclose processes in fume hoods or other ventilation; place guards, screens, or barriers between the hazard and the researcher; and other prudent practices. UM-OSEH is a resource for this planning process and can help identify points of consideration.
You wish to have a good working knowledge about the hazards of the chemicals you plan to use and the potential dangers of the equipment you have purchased. Read and understand the product safety warnings on research equipment and hazardous chemical labels. Thoroughly review material safety data sheets for the chemicals you expect your staff to use, so you can brief them on specific hazards. Consider how you will train your staff to assure they retain the knowledge. Think about the response and performance you expect from your staff if a spill occurs.
You wish for your staff and students to be knowledgeable about the hazards of their work and what action to take in the event something goes wrong. Make absolutely sure that students and staff who are working with hazardous materials and equipment have been fully briefed on the risks they are exposed to and what to do when things go wrong (assume they will). Provide them with written emergency procedures and training to handle chemical release emergencies and personal injuries.
Your wish for your experimental protocol to be followed closely and without incident. When you write your materials and methods, include precautions and warnings that address protective equipment, chemical storage, fume hood use, and chemical waste disposal. Write these precautionary instructions into the protocol at points where the risks appear.
You wish for your staff and students to be familiar with and follow the SOP you have prepared and approved. Use the SOP to instruct the researchers in your lab about your expectations for performance and safety. Written SOP's lend an element of consistency to instruction, so you don't over-train one person and under-train another. Continuity is also a factor, so the instructions are not distorted or weakened over time and by staff turn-overs.
You wish to know that your instructions are being followed in practice, on a daily basis. As laboratory director, you are responsible for personally verifying that the methods and precautions you have approved are being followed. Your regular presence in the research lab, observing the experimental methods, shows that you care and are serious about safety.
You wish to know about and correct those who do not follow your instructions. In the event you find employees not following standard safety precautions, or flagrantly ignoring good lab practices, you should take firm action to clarify your expectations to the employee and others in the lab.
You wish to have a management structure in place to maintain the quality of your operations when you are away. Long-term management of a research project is best accomplished with the aid of laboratory supervisors with seniority and a measure of authority. Such lab managers can efficiently instruct new staff, maintain the quality of practices, and offer ideas for improvements.
You wish for your hazardous equipment to have features that prevent injury to the user, even if they intentionally try to defeat the guards and shields. Many modern scientific instruments contain features that reduce or eliminate the potential for accidental exposure and injury to the user. These features are present to reduce product liability, based on past injury experience. For thousands of older instruments that contain few or no safety features, the laboratory director is responsible for identifying critical hazard points and guarding them with shields or power interlocks.
You wish for your scientific equipment (or sophisticated facility) to function safely for a long period of time. Nothing man-made lasts forever, and most equipment requires expensive maintenance to operate past 5 years. At 10 years, most equipment is obsolete and parts are hard to find. At this point the equipment may become unsafe. Planning for maintenance costs and eventual replacement costs for critical equipment and specialty facility infrastructure should be undertaken as a lab management function. Too often, the day comes for replacement and no funding is available.
UM-OSEH provides consultation and technical support for all of the above responsibility areas. Please contact us with your questions at 7-1142.