Culture of Safety & Responsibility

Overview

This culture of safety and responsibility is guided by the following principles:

Leadership and Oversight

• Leadership recognition and support of a culture of safety at every level within the institution.
• Demonstrated commitment and reinforcement on a regular basis through the consideration of safety issues at meetings, in the defining of jobs, and in the evaluation of faculty, staff, and programs across the institution.

Organizational Practices

• Organizational commitment at every level to recognizing that research and other activities present a potential risk, and to ensuring that these operations are conducted safely and in a responsible manner.
• Incorporating safety as an integral aspect of the institution’s operations (e.g., experimental design, facility construction, equipment specifications).
• Creating an environment of collaboration among all stakeholders (i.e., researchers, department safety advisors (DSAs), students, staff, facilities management staff, public safety staff) to identify safety issues and to find solutions.
• Organizational learning is not only expected, but is also embraced.

Institutional Structure

• Creating an environment in which each individual understands their role in the research enterprise or elsewhere in the university and conducts their activities in a responsible manner.
• Creating an environment where individuals are empowered to recognize and to report errors or near misses without fear of reprimand or punishment.
• Continuous review and examination of the infrastructure that provides support for safety practices and procedures.

Shared Core Values and Beliefs

• Empowering all members of the university community to accept their critical role in protecting their own safety as well as that of others.
• Emphasizing personal responsibility to safety and the ethical conduct of research.

Management Systems

• EHS has developed an environmental health and safety management system. These systems are described in the EHS divisional management plans. These plans describe the proactive programs developed by EHS that help provide a safety and healthful environment for patients, students, visitors, and employees. They also describe the programs designed to serve as good stewards and protect the environment.
• Investigating incidents or near misses, identifying “lessons learned,” and modifying programs, as appropriate, to incorporate any enhancements identified during the investigation.
• Committing resources to address safety concerns.

Key Features of the Culture of Safety in the Laboratory

• Active adoption of a culture of safety as a core value at every level.
• Clearly defined roles and responsibilities with each individual recognizing their specific role, as well as those of others, in the continuum of safety.
• Clear indication that while safety is a shared responsibility of each individual working in a laboratory, ultimately principal investigators bear full responsibility for safety in their laboratories.
• Comprehensive training and awareness program for all individuals who work in research laboratories or who provide support (e.g., facilities management, public safety) for research laboratories, with written confirmation by all individuals engaged in research that they have been adequately trained and that they will follow the safety requirements.
• Appointment of a single point of contact, typically an Environmental Health & Safety (EHS) safety specialist, from the Division of Research Safety, referred to as the department safety advisor (DSA).
• Appointment of a laboratory safety coordinator who is specifically responsible for implementing day-to-day safety requirements in the laboratory.
• A comprehensive inspection and oversight program designed to: a) Routinely review all aspects of safety; and b) Provide trending information on the efficacy of the programs.
• Implementation of a comprehensive Research Occupational Health Program to provide both pre-employment health clearances and post-exposure support.
• Inclusion of a commitment to safety as a condition of employment for all those engaged in research and as a key factor in annual performance appraisals.

Training

Importance of Training

Boston University (BU) and Boston Medical Center (BMC) recognize the importance of safety training as a critical element of a comprehensive safety program designed to prevent work-related accidents, injuries, exposures, and near misses. In accordance with regulatory requirements and policies at BU and BMC, faculty, students, staff, and visitors in laboratories must complete a variety of trainings that address hazardous materials in the workplace. These requirements are mandatory for all individuals who work with hazardous materials, including biological, chemical, and radiological materials, as well as those who conduct physically hazardous procedures.
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“Training Mandates

The training mandates include:

• Initial safety training prior to any individual working in or around a research-related facility;
• Hazard-specific training;
• Periodic refresher training; and
• On-the-job mentorship provided by a designated mentor [i.e., principal investigator (PI), laboratory director, laboratory safety coordinator (LSC)].

Reporting Concerns

Reporting Errors or Near Misses
Treatment and Accident Reporting

As stated in the basic principles of the culture of safety, BU encourages an open environment where individuals are empowered to recognize and report errors or near misses without fear of reprimand or punishment. If you have any questions or concerns, you should discuss them with your PI, LSC, or the EHS DSA. Link to Reporting Concerns section.

Training Goals

The fundamental goal of the training program is to ensure that all individuals working in the laboratory have adequate didactic and hands-on training to perform their activities in a manner consistent with the culture of safety established at BU and BMC.

To meet these goals, the training program is designed to meet the following standards of excellence:

• Emphasize the importance of the culture of safety at BU and BMC;
• Robust and comprehensive in nature;
• Logically and modularly designed;
• Based on didactic and hands-on requirements;
• Focused on the functions performed by the individual;
• Compliant with regulatory requirements;
• Provides training for safe routine operations and for unplanned events;
• Is based on a partnership between operations and science programs;
• Fully engages laboratory practitioners throughout development and implementation; and
• Become a model program for other institutions.

Training Scope

The training programs are offered in a variety of forms, including online with tests, in-person, and on-the-job training, and cover the entire spectrum of potential hazards that may be present in a workplace.

Examples of training programs include:

• Laboratory Safety Training that must be completed by all personnel (faculty, staff, students, trainees, visitors) who will work in a research laboratory with any chemicals or biological agents.
• Agent-Specific Training that must be completed by all personnel who work with infectious microbiological agents.
• Hazardous Materials Shipping Training that must be completed by all personnel prior to shipping any hazardous materials or dangerous goods.
• BSL-3 Training that must be completed by all personnel (faculty, staff, students, trainees, visitors) who will work with BSL-3 agents.
• Select Agent Training that must be completed by all personnel (faculty, staff, students, trainees, visitors) prior to receiving privileges to order, store, or use select agents.
• Additional Training: special biosafety, species-specific, and technical training for some or all personnel related to your research activities may be required by Environmental Health & Safety, the Research Occupational Health Program, and/or the institutional oversight committees (e.g., Institutional Biosafety Committee, Institutional Animal Care and Use Committee, Radiation Safety Committee, Laboratory Safety Committee). These training requirements are dependent on the experimental methods and conditions described in your protocol.

Training Verification

The trainings are mandated requirements and the oversight committees will not allow for the inclusion of an individual in a research protocol if all appropriate training requirements have not been fulfilled. Additionally, an individual’s privileges to continue to work will be revoked if periodic refresher trainings are not completed in a timely manner.

Environmental Health & Safety reviews training records during its routine and unannounced laboratory inspections.

Culture of Safety and Biosecurity

The following excerpt is from the National Science Advisory Board for Biosecurity (NSABB) report entitled “Guidance for Enhancing Personnel Reliability and Strengthening the Culture of Responsibility”:

“Knowledge is rarely, if ever, neutral. That knowledge can be used for good as well as for evil is one of the recurrent, indeed dominant, themes in the history of humankind. And it is a theme that has been underscored by recent events that have highlighted the potential for misuse of the fruits of scientific progress. Thus today, in the pursuit of knowledge and truth, all scientists—especially those working in the life sciences—are called to cultivate among themselves a culture of responsibility with regard to the conduct and the achievements of their research: Their goal remains that of the generation and advancement of knowledge, but, in some cases, such knowledge may be applied for both beneficial and harmful purposes. Their beliefs, attitudes, and values must reflect a heightened consciousness of the implications of their research, especially of any potential for the deliberate misuse of the information, products, and technologies generated from their research. They must consciously live and demonstrate these beliefs, attitudes, and values through day-to-day practices of mindful research. With transparency, they must examine their own research with consideration of its potential for misuse, and they must conduct and communicate their research in ways that mitigate any risks of misuse.

Finally, in cultivating and sustaining a culture of responsibility, scientists who conduct research must recognize that they engage in a continuous, reciprocal process of promoting and bearing mutual responsibility for their work: They must hold themselves and their peers accountable collegially and with a shared commitment to advancing science and maintaining public trust.”

About BU’s Culture of Safety and Responsibility

2010 TaskForce

Boston University continues to show its commitment to advancing the culture of safety and has worked collaboratively with schools, departments, and other representatives to enhance its safety programs. In March 2010, the associate vice president for research compliance (AVPRC) appointed a Task Force on Biosafety to review the safety program at BU and to make recommendations on how safety in research at BU can be enhanced. The task force, which was composed of representatives from a broad spectrum of BU stakeholders, reviewed various aspects of the programs at BU and issued its final report on July 1, 2010. In formulating its recommendations, the task force reviewed regulatory requirements and practices at other institutions—including those of industry—to identify best practices that could enhance BU’s safety programs.

While the task force report noted that “over the past several years, Boston University and Boston Medical Center have significantly enhanced their safety programs,” it also identified a number of areas in which the modification of existing practices or the introduction of new practices would significantly improve the culture of safety at BU. The task force also recognized the importance of enhancing safety at the National Emerging Infectious Diseases Laboratories (NEIDL) and made additional recommendations in the NEIDL-specific addendum. This addendum includes additional recommendations that establish more stringent criteria at the NEIDL with enhanced monitoring and safety requirements where safety first is the key component of its operations.

The recommendations of the task force were accepted by the AVPRC and were distributed and discussed at various research leadership forums that included the following participants:

• The BUMC and the University provosts;
• BUMC provost’s meeting (deans, associate deans, vice president research, associate provosts, etc.);
• School of Medicine Executive Committee (department chairs, vice deans, etc.);
• Institutional Biosafety Committee;
• Laboratory safety committees at CRC and BUMC;
• NEIDL leadership (director, associate directors, and core directors); and
• Safety program leadership.

Task Force Report

Culture of Safety Task Force Findings

Current Safety Alerts

Laboratory dry heat ovens caused fire

_{Photo courtesy of Sonya Butler, BU EHSEnvironmental Health & Safety}

If not operated properly, the use of a drying oven can potentially cause a fire in the laboratory. Such was the case on November 24, 2012 and January 10, 2013, when the plastic materials being dried along with glassware in the ovens overheated and melted, creating smoke and setting off the fire alarm and fire suppression system.

In one of the incidents, smoke and fire from the melted plastic materials triggered the building’s sprinkler system and drenched the entire area with water. In the second incident, overheated plastic bottle caps produced smoke and responders used a fire extinguisher.

Personnel who use laboratory equipment such as drying ovens must follow appropriate and safe operating procedures. Here are a few guidelines to follow:

• • Ensure that new users are initially trained on the proper and safe operation of the equipment.
  • Refer to the manufacturer’s manual to determine operating limitations of the oven and have full, clear written instructions on the equipment or nearby.
  • Use appropriate personal protective equipment such as heat-resistant gloves, eye and face protection, and lab coats when retrieving or handling hot materials from the oven. When feasible, hot items should be given proper time to cool and tongs or other tools should be used to handle hot items.
  • Check the thermostat during operation to ensure that is at the right temperature setting programmed by the operator.
  • DO NOT use plastic, rubber, or paper materials in high-temperature environments. If plastic or rubber material is used, assure that the temperature of the oven will not cause the materials to melt and potentially cause a fire.
  • DO NOT use glassware soaked or rinsed in organic solvents as it poses a danger of explosion.
  • DO NOT exceed the recommended temperature.
  • DO NOT dry chemicals that are volatile or sensitive to heat.
  • DO NOT use chemicals that might pose a hazard because of acute or chronic toxicity. Continuous venting to the outside atmosphere is required in these conditions and by the process reviewed by EHS in consultation with the Laboratory Safety Committee.
  • DO NOT use mercury thermometers to monitor the temperature of the oven. Accidental breakage and spills can cause the potential release of, and exposure to, mercury. Use a non-mercury substitute thermometer.
  • DO NOT over-stack loads in the oven.
  • DO NOT plug in via an extension cord.
  • If you have a model that has an exposed heating element below the drying area, DO NOT place objects that can fall through the shelf directly onto the heating element below.
  • Ensure the equipment is properly maintained and report any faults to your supervisor immediately so they can be rectified.
  • For safety-related concerns, call EHS at 617-353-4094 on the Charles River Campus or 617-638-8830 on the Medical Campus.
  • In the event of a fire, call BU Police at 617-353-2121 on the Charles River Campus or the Control Center at 617-414-6666 on the Medical Campus. Pull the fire alarm if you notice fire or smoke coming from an oven or other piece of equipment.

You can get more information at:
BU Laboratory Safety Toolkit Resource Page
NCBI: Working with Laboratory Equipment

Lab Safety and Inspection

Lab Safety Coordinators

The LSC toolkit on the EHS site provides quick access to information, guidance, and helpful tips for LSCs.

Comprehensive Laboratory Inspection Program (CLIP)

Research laboratories use a variety of hazardous materials (e.g., chemical, biological, radiological), and potentially hazardous procedures and equipment (e.g., centrifuges, x-rays, lasers) that carry the potential for causing physical injuries (e.g., via pressurized vessels, vacuum systems) or general fire or life safety hazards (e.g., via flammable materials, electrical/electronic equipment).

All of these substances, equipment, and activities are governed by myriad regulations that have been promulgated by local, state, and/or federal agencies. Many of these regulations require oversight provisions that mandate:
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• The submission of an application for review and approval (e.g., biological materials use);
• The tracking of activities post-approval (e.g., environmental health and safety surveillance) and periodic reviews, audits, and inspections;
• Maintaining detailed inventories of hazardous materials (e.g., chemical or radiological), animals, and controlled substances;
• Training programs for individuals engaged in research activities; and
• Unannounced inspections by the regulatory agencies.

Principle of Safety Program

Boston University (BU) and Boston Medical Center (BMC) safety program adopts the quality control approach, continuous review and improvement, and the core principles of Plan-Do-Check-Act:

The Comprehensive Laboratory Inspection Program (CLIP) has been developed to meet the post-approval verification and monitoring* requirements as a mechanism to:

• Monitor compliance of applicable regulations, standards, and policies;
• Evaluate the efficacy of the safety program;
• Allow for early identification of potential problems and corrective actions;
• Determine the level of adherence by users to ensure safe operating procedures;
• Provide an interface between Environmental Health & Safety (EHS) and research staff;
• Allow for the timely identification of problems or potential problems and the remediation of programmatic areas in need of improvement; and
• Develop new or enhance existing training programs to support the culture of safety.

These audits are conducted by EHS staff and include a thorough review of the administrative requirements of the programs, training records, usage and storage procedures, protective personnel equipment, and surveys and wipe tests of the laboratories.

*Post-approval verification and monitoring is the term used to describe the programmatic approach an institution implements to ensure that the approved research activities are conducted in accordance with the regulations that govern such activities.

Purpose of CLIP

CLIP is designed to meet a number of goals:

• Provide a comprehensive evaluation of the institutional safety programs in a laboratory or facility;
• Address issues of health and safety in an integrated and holistic manner in order to improve overall safety;
• Improve the overall efficiency of safety programs by reducing the need for repeated visits for each category of inspection;
• Reduce burdens on the laboratories by providing an integrated safety program; and
• Allow for the identification of trends in individual or institutional safety programs.

The philosophy of CLIP is to educate and support the research community’s awareness of safe laboratory practices and regulatory obligations, and to minimize workplace hazards. It is not the program’s goal to discipline or penalize researchers, but to assist in correcting any hazards that are identified.

Scope of CLIP

CLIP covers all hazardous materials and physical hazards (e.g., radioactive, biological, chemical, fire and life safety, etc.) and is intended to provide two levels of information:

• Routine updates on hazardous materials, including a description of the materials used, users, use locations, equipment, etc.
• Review of safe procedures and practices for handling hazardous materials used at BU and BMC.

CLIP continued

Criteria for CLIP

CLIP groups all elements of a comprehensive safety program into one of two unique categories:

• Category A: Includes general information that is common to all subject-specific inspections and audits (e.g., training, postings, and signage); are time-sensitive items (e.g., fume hood or biological safety cabinet certifications); have a regulatory inventory requirement (e.g., radioisotope or controlled substances); or are items identified by EHS or an oversight committee as important during the risk assessment and review of application for use of hazardous materials.
• Category B: This includes in-depth, subject-specific inspections and audits and includes all subject-specific elements.

Frequency of CLIP

Many of the oversight agencies have requirements that inspections be performed routinely and at the least, annually. The major categories of inspections are: biological safety, chemical safety, fire and life safety, radiation safety, and controlled substances. Therefore, at BU and BMC, the program is designed to perform inspections based on risks identified with materials being used, space, equipment, and performance of those working in the area. The frequency and intensity of inspections will be adjusted based on changes in conditions through risk assessment and/or as mandated by the oversight committees.[/collapsible]

Implementation of CLIP

For both categories, EHS staff members are assigned to specific schools, departments, and/or principal investigators (PIs). These assignments encompass all PIs, administrators, and other groups (e.g., life safety in office areas); however, this procedure primarily focuses on the PIs who are actively performing research and/or teaching, as well as the laboratories in which these activities are ongoing.

CLIP Reports

At the conclusion of each inspection, a report is issued to the individual responsible (i.e., the PI, laboratory safety coordinator, etc.) outlining any findings, along with recommendations for corrective actions, if necessary. The responsible individual is required to provide a response outlining the actions taken to remedy the findings and to prevent their reoccurrence.

Depending on the nature of the findings, EHS may revisit the laboratory to confirm that any corrective actions have been implemented, or follow up on specific issues at the time of the next scheduled meeting with the laboratory safety coordinator.

CLIP Checklists and Definitions

Detailed checklists and definitions are used for each category of inspection. These are intended to serve as a quick reference. The details of each requirement are described in various institutional safety manuals.

All checklists are grouped into nine major categories, as listed below:

• Administrative: general items related to documentation, record keeping, presence of safety manuals, etc.
• Labeling: includes all required postings and labeling [e.g., National Fire Protection Association (NFPA) signs, hazard warning labels, etc.].
• Personnel/Safety: ensuring that all personnel training is complete and current, including knowledge of safety requirements, agent-specific training, etc.
• Use areas: appropriateness of the area for intended use, area security, lack of clutter, etc.
• Contamination control: area decontamination, adequacy of hazardous storage, proper procedures to prevent potential contamination, etc.
• Personnel exposure control: participation in the medical surveillance program administered by the Research Occupational Health Program (ROHP), appropriate vaccinations, exposure control equipment, etc.
• Equipment: appropriateness of safety equipment (e.g., biosafety cabinets, fume hoods), verification that the certifications are current, proper waste disposal containers, fire extinguishers, etc.
• Inventory control: verification of appropriate inventory records (e.g., receipts, usage, storage, disposal), shipping records, etc.
• Emergency action plans: presence of emergency action plans appropriate for the facility.

These groupings allow for trending of the findings and assist with the programmatic reviews to determine whether changes to safety or training programs are required.