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Health and safety responsibilities for Principal Investigators Dr Emer Bell Integrated Risk Solutions. Session content. Legal duties A framework for managing safety in a research group Risk assessments Training requirements Researcher competency Safety communication Resource implications
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Health and safety responsibilities for Principal Investigators Dr Emer Bell Integrated Risk Solutions
Session content • Legal duties • A framework for managing safety in a research group • Risk assessments • Training requirements • Researcher competency • Safety communication • Resource implications • Records • Information sources
Safety, Health and Welfare at Work Act • You must set out in writing how you manage safety. • You must identify the hazards that members of your research group encounter, assess the risk and set out the controls you have in place to minimise or eliminate the risk.
Safety, Health and Welfare at Work Act • Information & Training • You must ensure your research group has enough information and training to carry out their work safely • That they are competent • That information is delivered in a manner that is understood • That safety information is readily available to your researchers
Safety, Health and Welfare at Work Act • You must have written plans for how you will deal with emergencies such as accidents, fire and chemical and biological spillages
Chemical Agents Regulations & Code of Practice • You must assess the hazards associated with the chemicals used by your group & set out controls • Must consider all the chemicals on a procedure/protocol basis, including products of reactions and waste • Not on an individual chemical basis • Must use the least hazardous chemical available
Carcinogen Regulations • You must assess the hazards associated with carcinogens & minimise exposure to the lowest level possible • Must keep a record of who is exposed
Biological Agents Regulations & Code of Practice • You must assess the hazards associated with biological agents used or encountered by your group and put controls in place based on the Code of Practice
General Application Regulations & Guidance • You must assess the risk & have controls to minimise risk for; • Manual handling • Assessments for tasks carried out by researchers • Electricity • Pregnant employees • Equipment • Inspection and servicing records kept
Safety, Health and Welfare at Work Act 2005 • Section 80 of the Act allows for Seniors Officers such as Principal Investigators to be prosecuted, fined or imprisoned where an offence has been committed as a result of connivance or neglect.
80.—(1) Where an offence under any of the relevant statutory provisions has been committed by an undertaking and the doing of the acts that constituted the offence has been authorised, or consented to by, or is attributable to connivance or neglect on the part of, a person, being a director, manager or other similar officer of the undertaking, or a person who purports to act in any such capacity, that person as well as the undertaking shall be guilty of an offence and shall be liable to be proceeded against and punished as if he or she were guilty of the first-mentioned offence.
Duties as an employee Section 13 • Comply with the relevant statutory provisions, and take reasonable care to protect his or her safety, health and welfare and the safety, health and welfare of any other person who may be affected by the employee’s acts or omissions at work
Co-operate with the employer or any other person to enable the employer or the other person to comply with the relevant statutory provisions • Attend such training and undergo such assessment as may reasonably be required by the employer or as may be prescribed relating to safety, health and welfare at work or relating to the work carried out by the employee,
Report to the employer, (i) any work being carried on, or likely to be carried on, in a manner which may endanger the safety, health or welfare at work of the employee or that of any other person, (ii) any defect in the place of work, the systems of work, any article or substance which might endanger the safety, health or welfare at work of the employee or that of any other person,
Report to the employer; (iii) any contravention of the relevant statutory provisions which may endanger the safety, health and welfare at work of the employee or that of any other person, of which he or she is aware.
Section 14 • A person shall not intentionally, recklessly or without reasonable cause place at risk the safety, health or welfare at work of persons in connection with work activities.
On summary conviction (District court) – fine of up to €3000 and 6 months in prison. • On indictment (Criminal court) – up to €3000,000 and up to 2 years in prison. • NUIG cannot pay the fine on behalf of a Principal Investigator & insurance does not cover it.
NUI Galway Safety Statement “2.2.2.4 Principal Investigators Principal Investigators are responsible to the Governing Authority for theresearch work they undertake and so must take responsibility for the health andsafety management of this work”.
NUI Galway Safety Statement “For research activities, the relevant Principal Investigator will be the person with operational responsibility for health and safety policies and procedures relating to the maintenance, management and use of particular equipment and the PI has the duty to manage the health and safety requirements of their research work.”
Roles & responsibilities • If you are not in the lab with the researchers or you spend periods of time away, appoint a senior post doctoral researcher as the person with day to day operational responsibility for health and safety. • You still retain overall responsibility
Roles and responsibility • This is not a role for a post grad or junior member of the team. • Remember you retain legal responsibility • You must have a mechanism to ensure they are carrying out the role. • See hand out 2 PI safety compliance checklist
Roles & responsibilities • Allocate a person or persons to carry out risk assessments • Risk assessments must be carried out by yourself or senior researchers in association with those involved in the activity • Not a job for junior members
Roles & responsibilities • Other tasks that should be allocated include; • Maintaining the records of inspection and testing of equipment • Reviewing & updating Material Safety Data Sheets on an annual basis • Carrying out safety inspections • Checking first aid and spill kits • Testing emergency showers and eye wash
Roles & responsibilities • Everyone must know their duties and responsibilities • The roles must be documented with names attached.
Responsibility - Sabbatical • Applicants who have been granted approval to take Sabbatical Leave are required to submit, not later than four months prior to the Leave, setting out the substitution arrangements, for the carrying out of supervision and administrative duties. • Includes safety management arrangements • Form APR/LA/2
Setting up a safety management framework for a research group
You must document how you manage safety • Your Unit has a Safety Statement Policy document, your document is a subset of this. • You can use the Unit Safety Statement Policy template See hand out 1 - Sample safety management framework for a Research Group
Risk assessment is about…… • identifying sensible measures to control the risks in your workplace. • Your risk assessment will help you decide whether you have covered all you need to. • That you have done enough.
Definitions • Hazard – any thing, any substance, any activity that could cause harm • Risk assessment – a combination of the likelihood that someone will be hurt and the severity of the injury or ill health
Risk assessment methodology • Set out in section 3.1 of NUI Galway Safety Statement
Risk assessment methodology • Good definitions of likelihood and severity of harm • Provides a matrix for calculating risk • Sets out a sample risk control plan based on various risk categories
Pemac Care • You an use Pemac Care for recording simple room risk assessments • Pull down menu with options for hazards and controls • Calculates risk rating
Risk assessments also required for; • Chemicals including carcinogens and gases • Biological agents • Hazardous equipment, pressure vessels • Radiation • Manual handling • Field work • Driving for work
Risk assessment • They require more detailed documentation. • Risk assessment training is available through HR
Safety Training is a legal requirement • You must carry out a training needs assessment for each type of researcher • Post doc • Post grad • Undergrad • Technical staff • Lab attendant • You must ensure researchers have enough information and training to carry out the work safely. • Failure to train is considered a serious offence.
Safety training is provided in a number of ways • Safety induction training provided within the research group by researcher. • Task specific instruction provided by a supplier of a piece of equipment to researchers.
Safety training is provided in a number of ways • Training provided through Organisation and Staff Development (HR) • Series of safety training sessions that can be booked centrally, e.g. fire safety, manual handling, first aid, evac chair, chemical safety, biological safety, etc. • Training by an external trainer organised by the group for specialised tasks, • e.g. confined space, laser safety.
Training has different forms • 15 minutes up to several days. • Can be provided by a competent person with experience. • Can take the form of an awareness session or practical instruction. • Can be one to one or in groups.
Training records • Outline of training content – bullet points • Who provided it • Date • Who attended – signatures • Send copies to Organisation and Staff Development (HR)
How do you know what or if training is required? • Everyone needs basic safety induction • Good hazard identification and risk assessment will identify other training needs. • Important that activities and use of equipment are assessed.
Safety induction • Appendix 3 of Safety Statement has an outline Safety Induction Checklist • It provides basic safety information for staff • Can be tailored to make it specific to the research group • Provide to all staff and postgraduates