Impacts of UC Regents Agreement with LA District Attorney and Cal OSHA

1. Impacts of UC Regents Agreement with LA District Attorney and Cal OSHA • Settlement only dismisses charges against Regents • Four year Agreement with Annual Reporting/Audit • Identify all UC Chemistry and Biochemistry Labs • Regents acknowledge responsibility for conditions with the laboratory was operated on December 29, 2008. • Establish a “SheharbanoSangji Scholarship at UC Berkeley Law endowed for $500,000. • Pay Cal/OSHA investigation costs not to exceed $50,000 • Hard Deadlines for Chemistry, but requirements are for everyone - and if something happens in another lab…

2. Impacts of UC Regents Agreement with LA District Attorney and Cal OSHA (cont.) • Mandatory Lab Safety Manual • Mandatory Lab Safety Training • Mandatory Written SOPs • Required Procedures/training/PPE for Pyrophorics • Enhanced Reporting Requirements • Increased CalOSHA Scrutiny • UCOP will assist with Centralized Resources (Powers of 10) • Funding solutions and coordinating Campus efforts • UCSD Chemical Hazard Use Authorization (CHUA) • Databanks for SOPs, Training, etc.

3. Laboratory Safety Manual and CHP • Each campus must maintain a formal Laboratory Safety Manual • Chemical Hygiene Plan • Must Include all applicable Title 8 regulations • Manuals must be provided/maintained in each lab within 60 days of agreement • Electronic copies are acceptable • UCSC is Developing an on-line Safety Manual • Will include revised CHP plus expanded information beyond Slug Binder. • EH&S will roll out to labs within the next few months • Some items may be kept in the Lab • SOPs, Inspection, Correction and Training Documentation incorporated as needed by specific lab • Biosafety, Rad Safety, Laser Safety and other existing manuals will be incorporated as needed as well as SOPs

4. Lab Safety Training • Lab Safety Training policy nearing final approval • On-line Training for Everyone to Complete & Pass the Test • Additional Discussion Sections, Refresher and Function-specific Training will be required as needed/determined • PIs will receive additional Roles and Responsibilities Briefing • Robust E-Course Fast-tracked for Development • Upon approval, outline and PowerPoint will be provided to conduct in-person training to commence training within 60 day time period (for Chemistry to meet deadline) • Online version expected to be completed this Fall with soft roll-out • UCSC combo E-Course/ILT starting early 2013 • Test/assessment will be required for completion, whether in-person or online

5. Mandatory Written SOPs • SOP approval required for 10 categories of chemicals totaling ~500 substances (per LADA Agreement Exhibit 1) • SOPs must be reviewed by qualified personnel and lab specific procedures reviewed/authorized by PI • PI and all lab personnel must sign SOP acknowledging the contents, requirements, responsibilities outlined in SOP • SOP amendment subject to PI approval • Electronic copies acceptable if readily accessible to laboratory personnel with documentation of PI authorization and researcher review • (e-commons likely distribution/documentation mechanism)

6. Pyrophorics • All locations must have written procedures, but at a minimum follow UCLA policy • UCSC adopted the UC System guidance document on air sensitive materials as template • Edit with lab’s specific use procedures and PI Authorization • Review and sign Prior to UsingPyrophorics • Ensure proper procedures and PPE are used • Proper PPE includes Nomex lab coat and Nomex pilots’ gloves, plus other means as necessary or appropriate • PPE Assessment must take place prior to use

7. Personal Protective Equipment • PPE policy in Final Approval Process • Many Campus reps put in many hours (including PhD Chemists, ACS/DCHAS Reps, Certified CHO, etc.) • Initial review included UC Faculty Senate • Assessment Procedures to determine level of PPE • Labs and “Technical Areas” where hazardous chemicals are used and stored will require Shoes, Pants, Lab Coat and Eyewear plus gloves as appropriate to material/process • Location specific – not “just when using” specific hazardous chemical • Not popular but the law, UC Policy and PI responsibility

8. Inspections, Corrections and Escalation • System-wide Lab Audit/inspection tool under development • Enhanced documentation accessibility/accountability up through Chancellor • Escalation procedure for non-compliance/failure to correct issues • Compliance status of PI and lab rolls up to Chancellor’s Report Card • External Review/Audit of Compliance and Safe Practices

9. Enhanced Reporting Requirement • PIs required to immediately notify EHS/CalOSHA of “reportable” injuries • Serious injuries: Death, amputation, disfigurement, hospitalization over 24 hours… or if unsure • Immediately contact Campus Dispatch and ask for EH&S – if EH&S is unavailable, then… • PI Must contact CalOSHA Director immediately (within 4 hours) • Call: (510) 286-7013 • E-mail:dgold@dir.ca.gov • Secured incident scene required for 24 hours for Cal/OSHA to respond (Possible inspection by CalOSHA Enforcement and Bureau of Investigation) • Must still report to Local CalOSHA Office within 8 hours

10. More to Come… • As more information is available – PIs and LSRs will receive updates to inform researchers • Info on implementation of Training and PPE Policies • E-Procedures for developing & maintaining SOPs • Info and procedures for accessing mandatory Lab Safety Training and LMS resources • Centralized CHUA and Chemical Inventory systems • Lessons Learned, Research Safety Seminars and Cultural Opportunities via Centers for Excellence