Review the training programs offered by EHRS and ensure that lab staff attend all required safety training.
Ensure that you and your lab staff attend Introduction to Laboratory & Biological Safety Training at the start of employment, and complete Online Annual Update Training annually thereafter. Determine if you and your staff needs Occupational Exposure to Bloodborne Pathogens Training, Radiation Safety Training, or Training for Shippers of Hazardous Materials/Dangerous Goods.
Know what to do in the event of a
Develop written Standard Operating Procedures to handle emergencies such as spills in your laboratory. Identify the location of emergency eyewash and showers in the laboratory and inform staff of these locations. Keep eyewash stations and safety showers free from obstruction at all times. Notify EHRS if your lab does not have a shower or eyewash. Test your eyewash weekly if it is connected to a drain.
All human and animal research must be reviewed and approved by the appropriate Penn Regulatory Offices.
If you plan to generate recombinant DNA or transgenic animals, you must read the NIH guidelines. You must register non-exempt generation of recombinant DNA with Penn’s Institutional Biosafety Committee and the IACUC.
If you plan to use radioactive materials, irradiators or X-ray machines, the protocol must be approved by the Radiation Safety Committee.
The possession, use and transfer of Select Agents must be registered with the University and with the CDC and/ or APHIS prior to bringing these agents to Penn's campus. Contact an EHRS biosafety officer for assistance.
The Penn policy on the use of vaccinia virus in research follows national guidelines issued by the Centers for Disease Control and Prevention (CDC). All lab personnel who work with vaccinia virus that is infectious to humans must be provided mandatory counseling by Occupational Medicine and the opportunity to obtain smallpox vaccine. Principal Investigators must obtain written approval to use vaccinia virus from EHRS. For more information consult the Protocol for Approval to Use Vaccinia Virus in Research.
Familiarize yourself with Penn's Laboratory Safety Manual (Chemical Hygiene Plan, CHP) and review the CHP with your lab staff. Complete, sign and post a Chemical Hygiene Work Plan and update this Chemical Hygiene Work Plan annually.
Obtain Material Safety Data Sheets (MSDS's) for hazardous chemicals and make them available to your lab staff.
Review Penn’s Chemical Storage Guidelines before setting up your laboratory.
Evaluate the risks to your lab staff by performing an exposure assessment. Inform employees of the physical, chemical and biological hazards of the research. Assess the need for personal protective equipment and review with staff.
Inform staff of the need to wear lab coats and eye protection at all times while in the laboratory. Lab workers must wear lab coats where chemicals are being handled. Lab coats should not be worn outside of the lab. The principal investigator must provide lab coats and lab coat laundering services at no cost to all employees who work in the lab. Shorts and sandals should not be worn in the lab.
Identify your laboratory with appropriate room signs. Complete a Room Sign Request Form for each of your labs.
Check that fume hoods in the lab are working properly (e.g. the hood alarm (if present) is working, the sash operates). If the hood(s) is not working properly, contact Facilities.
Penn’s goal is to manage chemical wastes in a safe and environmentally sound manner that complies with all applicable federal, state and local regulations. There is no charge to university laboratories for chemical waste disposal.
Make certain lab staff know how to collect, package, and label the chemical wastes generated in your lab. Contact EHRS for waste collection as needed. Allow 10 working days for collection.
Department of
Homeland Security's Chemical Facilities Anti-Terrorism Standards
The U.S. Department of Homeland Security (DHS)
recently promulgated an interim final rule that imposes comprehensive federal
security regulations for high-risk chemical facilities; the Chemical Facilities
Anti-Terrorism Standards require Penn to report possession of over 300 Chemicals
of Interest (COI) if any of the listed chemicals are possessed at or above a
specific regulatory limit called the Screening Threshold Quantity (STQ).
Penalties of up to $25,000/day are possible for violations of the rule. Because
of the very short timeline for compliance with the DHS mandate, February 29,
2008 is the deadline for reporting possession of any DHS listed chemicals to
Environmental Health and Radiation Safety (EHRS). The timely cooperation of
those who use or store chemicals is vital to achieving compliance with this
rule.
Process for
Compliance
In order to comply with the rule, a careful
review of chemicals used or stored throughout the university must be conducted,
except for School of Medicine
and School of Veterinary Medicine
buildings in Philadelphia. Faculty and other managers are
responsible for inventorying their labs/areas and reporting, to Environmental
Health and Radiation Safety (EHRS), the possession of DHS listed COIs in any
room or area for which they are responsible. To assure complete
inventories, rooms that do not have COIs must also be reported.
A two phase process was developed to gather and aggregate the information.
Phase I -
Inventory
EHRS provides a list of COIs on its website for
Principal Investigators and others to use in conducting the inventory of COIs in
each space, lab or room, where chemicals are used or stored.
Use the CFATS Inventory Form to inventory rooms prior to
completing Phase II. Please keep your copies of the inventory for reference if
EHRS has questions.
CFATS Inventory Form: List of Chemicals of Interest (COI) [PDF]
Use one form for each building in which you use or store chemicals.)
Phase II -
Reporting
EHRS developed a website for entering COI
information for aggregation. This website must be used to report quantities, by
building and room(s), of any amount of COI’s. EHRS will aggregate the data and
submit any required reports to DHS.
Online submission website
[PennKey required]
Familiarize yourself with Penn’s Biosafety Manual and review the manual with your lab staff.
Perform a biohazard risk assessment.
If you or your staff work with human source material, bloodborne pathogens, or any other potentially infectious materials:
Provide medical surveillance for personnel who have the potential for occupational exposure to:
Register your use of biohazardous materials by completing the University of Pennsylvania's Biological Agent Registration Form (available shortly).
Biological Safety Cabinets (BSCs)
Understand and implement the University’s Guidelines for the Management of Infectious Waste.
Principal Investigators must apply for a License to use radioactive materials.
Radiation Safety Training must be taken for any user of radioactive materials or radiation-producing equipment.
Familiarize yourself with the appropriate Radiation Safety User's Guide and review it with your lab staff.
If you use lasers, obtain a copy of the University’s Laser Safety Manual. Complete a Laser Registry Form and have a Laser Warning Sign made for your laboratory. All persons who work with lasers must receive laser safety training.
Have additional questions? Contact Laura Peller at lpeller@ehrs.upenn.edu