Research Compliance Summary

1. Research Compliance Summary Research Administrators Council August 7, 2003 Carnegie Mellon University Mark Banister, CIH, CCHO

2. What About This is Important to Me? • Administration is a key component to the compliance of the college/university with EPA, DOT and OSHA requirements • Research grants often request information on regulatory compliance—how do you know you meet these requirements?

3. Subjects you need to address Laboratory safety Chemical/general safety Hazardous waste Respiratory protection Transportation Things you may need to show to others Written programs and procedures Training records Inspection results Performance tests/records Licenses/registrations What We Will Talk About

4. Requirements Training Procedures (esp. PHS) Medical monitoring Labels/ MSDS Air monitoring Written program Chemical Hygiene Officer Documentation Chemical Hygiene Plan Chemical handling procedures Training records and training subjects Lab inspections or air test results Laboratory Safety

5. Requirements Hazard Communication Chemical Inventory Training Labels/MSDS Written program Documentation Training records and topics Inventory Written Program Inspection and air test results General Chemical Safety

6. Requirements Identify employee needs Training Medical evaluations Fit testing Written program Overseeing person Documentation Medical approvals Training records and topics Written program Fit test records Respiratory Protection

7. Requirements Procedures/protocols Waste accumulation Label and seal container Proper storage and removal Training of generators and program operators Requirements EPA Generator Number EPA Generator Status Waste minimization program (if large quantity generator) Biennial reporting Good lawyers Hazardous Waste

8. Documentation Written procedures Training records and topics, including annual refreshers in certain areas Records of identification of waste streams Documentation Inspection results Waste manifests and exception reports Biennial reports Do you include light tubes, computer monitors, mercury items? Hazardous Waste, part deux

9. Transportation/Shipping • Why? • Do your people cross public streets (in a vehicle) with hazardous materials of any kind? • Does anyone prepare packages of hazardous materials for shipment by any carrier? • That’s why!

10. Transportation/Shipping • Requirements • DOT training for all applicable vehicle operators • DOT training for all packers and shippers of hazardous materials • Documentation • Training records and training topics • Transfer manifests

11. Freon control Training Records Reporting TSCA Imported chemicals Developed of synthesized chemicals Asbestos Proper maintenance, removal and disposal Renovation issues Training Lead Proper handling during renovation Miscellaneous Items

12. Environmental Management Systems • A facility-wide comprehensive approach to environmental compliance and responsibility • Currently fairly rare in c/u settings, though more common in industry • An EMS is a lot of work and often a part of a c/u settlement after an EPA inspection, in partial exchange for fines

13. Environmental Management Systems • Requests and demand for this are definitely on the rise among people supporting research • Often centered around the ISO 14000 standard • Official registration of your EMS is possible

14. Isn’t This All Someone Else’s Job? • Yes • However, as administration you need to ensure that certain things really happen! • For regulatory compliance • For research implications • You are often the best contact to indicate new personnel or research activities to EH&S

15. How Do I Know We Are Doing All This Stuff? • Become good friends with your EH&S department, take them to lunch, ask discrete questions to see what they know. . . • They will be probably tickled that you are interested • Consider performing and internal or external audit of these functions

16. What’s Coming Up • Possible “Chemical Security Act” • Bill before Senate, re-introduced in 2003 • Opposed by chemical manufacturers; White House has not taken official position • Tom Ridge thinks is may not be necessary • My guess is that passage is not going to happen real soon. . .

17. Potential Impacts of a Chemical Security Act • Development of “inherently safer technologies” • Use less hazardous materials and smaller amounts • Reduce hazardous temperatures/pressures • Reduce human error and equipment failure

18. Potential Impacts of a Chemical Security Act • Improve inventory control and chemical use efficiency • Reduce or eliminate transportation, handling, disposal and discharge • Enhance security • Increase use of secondary containment

19. Potential Impacts of a Chemical Security Act • Buffer zones between chemical sources and schools, hospitals and population centers • Employee training increase • Personnel background checks • May include all CERCLA materials (i.e., very many common hazardous chemicals)

20. Concerns About the Proposed Acts • The acts are very broad and somewhat vague • Puts industry in the position of fighting terrorism—(and us perhaps, as there is no college and university exemption currently) • May cause the victim of a crime to be a criminal! • Intrusions between conflicting agencies

21. Any Final Questions? • Good luck!