Nanoparticles are an area of increasing research interest in many fields. However, the risk data related to the safety, health and environmental impacts is still limited. How should lab researchers approach these uncertainties?
Speakers: Tilak Chandra, University of Wisconsin-Madison / Katie Kruszynski, University of Wisconsin-Madison / Markus Schaufele, Northwestern University
This 4-hour workshop is primarily directed at frontline researchers in academic institutions: graduate students, postdoctoral scholars, and undergraduate students. Faculty and safety staff are also very much encouraged to participate.
Workshop goals are to:
Educate participants about the value of risk assessment
Guide participants towards gaining awareness of safety culture messages from the leadership at their institutions
Empower participants to expand their safety networks and develop laboratory safety teams.
The improvement and enrichment of an organization’s safety culture are common goals throughout both industrial and academic research. As a chemical process development organization that designs and develops safe, efficient, environmentally appropriate and economically viable chemical processes for the manufacture of small molecule drug substances, we continually strive to improve our safety culture. Cultivating and energizing a rich safety culture is critical for an organization whose members are performing a multitude of processes at different scales using a broad spectrum of hazardous chemical reagents as its core activities. While we certainly place an emphasis on utilizing greener materials and safer reagents, the nature of our business requires us to work with all types of hazardous and reactive chemicals and the challenges we face are pertinent to any chemical research organization.
In our organization of approximately 200 organic and analytical chemists[a] and chemical engineers, we have a Safety Culture Team (SCT) [b][c][d][e][f][g]whose mission is to develop programs to enhance the organization’s safety culture. To make this culture visible, the team developed a key concept, Safety is Part of Your Daily Routine, into a brand with its own logo SPYDR. To build on this concept, we designed a program known as the SPYDR Lab Visits shown in Figure 1. The program engages our senior leadership[h][i] by having them interact with our scientists directly at the bench in the laboratory[j][k][l][m] to discuss safety concerns. This program, initiated in 2013, has visibly engaged our senior leaders directly in the organization’s safety culture and brought to our attention a wide range of safety concerns that would not readily appear[n][o][p] in a typical safety inspection. Furthermore, this program provides a mechanism for increased communication between all levels of the organization by arranging meetings between personnel who may not normally interact with one another on a regular basis. The success of this program has led to similar programs across other functional areas in the company.[q]
A key safety objective for all organizations is to ensure that the entire organization can trust that the leadership is engaged in and supportive of the safety culture. [r][s][t][u]Therefore this program was designed to (1) emphasize that safety is a top priority from the top of the organization to the bottom[v][w][x][y][z], (2) engage our senior leadership with a prominent role in the safety conversations in the organization, (3) build a closer relationship between our senior leaders and the laboratory occupants and (4) utilize the feedback obtained from the visits to make the working environment better for our scientists. The program is a supplement to and not a replacement for the long standing laboratory inspection program done by the scientists in the organization.
The program involves assigning the senior leaders to meet with 2–5 scientists in the scientists’ laboratory. There are approximately 40 laboratories in the organization, and over the course of the year, each laboratory will meet with 2–3 senior leaders and each senior leader will visit 4–6 different laboratories. All of this is organized using calendar entries which informs the senior leaders and scientists of where and when to meet, and contains the survey link to collect the feedback.
As a result of this program, our senior leaders engage our bench scientists in conversations that are primarily driven to draw out the safety concerns of our scientists. However, these conversations can run the gamut of anything that is a concern to our team members[aa][ab]. This can range from safety issues, laboratory operations, and current research work to organizational changes and personal concerns. The senior leadership regularly reminds and encourages the scientists to engage on any topic of their choosing; this creates a collegial atmosphere for laboratory occupants to voice their safety concerns and ideas.
The laboratory visit program was modeled around the Safety SPYDR and thus we designed the program to have 8 legs[ac]. The first two legs consist of the program’s goals for the visit. We asked the senior leaders to ensure that they state the purpose of the program, that they are visiting the laboratory to find ways to improve lab safety. The second leg, which is the primary goal, is to ask “what are your safety concerns?”. Often this is met with “we have no safety concerns”, but using techniques common in the interviewing process, the leaders ask deeper probing questions to draw out what the scientists care about and with additional probing[ad][ae][af][ag], root causes of the safety concerns will emerge. Once the scientists start talking about one safety concern, often multiple concerns will then surface, thus giving our safety teams an opportunity to deal with these concerns.
The next two legs of the SPYDR Lab visits consist of observations we ask our senior leaders to make on laboratory clutter and access to emergency equipment[ah]. If the clutter level of a laboratory is deemed unacceptable,[ai][aj][ak][al] the SCT will look to provide support to address root causes of the clutter. Typical solutions have been addition of storage capacity, removal of excess equipment from the work spaces, and alternative workflows. The second observation is to ensure clear paths from the work areas to emergency equipment exist, should an incident occur. We wanted to make sure a direct line existed to the eyewash station/shower such that the occupant would not be tripping over excessive carts, chillers, shelving or miscellaneous equipment. These observations led to active coaching of our laboratory occupants to ensure safe egress existed and modifications to the work environment. For example, the relocation of many chillers to compartments underneath the hood from being on a cart in front of the hood enabled improved egress for a number of laboratories.
For the final four legs of the SPYDR Visit, we ask the senior leaders to probe for understanding on various topics[am] that range from personal protective equipment selection, waste handling, reactor setup and chemical hazards. The visitor is asked to rate these areas from needs improvements, to average, high, or very high. Figure 2 compares these ratings from the first year (2013) with the current year (2018). In the first year of the program, there were a few scattered “needs improvement” rating that resulted in communication with the line management of the laboratory. After the initial year, “needs improvement” ratings became very rare in all cases except clutter. In the current year, we shifted two topics[an] to Laboratory Ergonomics[ao] and Electricity, which uncovered additional opportunities for improvement. We recommend changing the contents of these legs on a regular basis[ap] as it shifts the focus of the discussion and potentially uncovers new safety concerns.
The SPYDR lab visits are built around a feedback loop illustrated in Figure 3 that utilizes an online survey to both track completion of the visits as well as to communicate findings back to the SCT. The order of events around a laboratory visit consist of scheduling a half hour meeting between our senior leaders and the occupants in their laboratories. Once the visit is completed, the visitors will fill out the simple online survey (Figure 4) that details their findings for the visit. The SCT will meet regularly to review the surveys and take actions based on the occupants’ safety concerns. This often involves following up with the team members in the laboratory to ensure they know their safety concerns were heard[aq][ar].
Two potential and significant detractors for this program exist. The first challenge is if the senior visitor does not show up for the visit, this results in a perception that senior management does not embrace safety as a top priority. The second pitfall is if the visitor uncovers a safety concern, but does not fill out the survey to report safety concerns, or if the SCT is unable to address a safety concern. In this case, there would be a perception that a safety concern was reported to a senior leader and “nothing happened”. To minimize these risks, there is significant emphasis for the senior leaders to take ownership of the laboratory visits[as][at] and for the SCT to take ownership of the action items and ensure the team members know their voices have been heard.
DISCUSSION OF SAFETY CONCERNS
A summary of safety concerns is illustrated in Table 1. By a wide margin, clutter was the predominant safety concern in 2013 as it was noted in 50% of the laboratories visited. Three major safety programs within the department were inspired by early visits in order to reduce clutter in the laboratories. This included several rounds of organized general laboratory cleanouts to remove old equipment[au][av]. A second program systematically purged old and/or duplicate chemicals throughout the department.[aw] Most recently, a third program created a systematic long term chemical inventory management system[ax][ay][az] that was designed to reduce clutter caused by the large number of processing samples stored in the department. This program has returned over 900 sq. feet of storage space to our laboratories and has greatly reduced the amount of clutter in the labs. Although clutter remains a common theme in our visits, the focus is now often related to removal of old instruments and equipment [ba][bb][bc][bd]rather than a gross shortage of storage space.
In the first year of the program, one aspect of the laboratory visit was to discuss hazards associated with chemical reactions (feedback rate of 28%) and equipment setup (32%). A common thread in these discussions were expectations of collaboration and behavior from “visiting scientists”. These “visiting scientists” were colleagues[be][bf][bg][bh] and project team members from other laboratories coming to the specific laboratory in order to use its specialized equipment (examples: 20 liter reactors, automated reactor blocks). This caused certain friction between the visiting scientists and their hosts on safety expectations. The SCT addressed this by convening a meeting between hosts and visiting scientists to discuss root causes of friction to produce a list of “best practices” shown in Figure 5 to improve the work experience for both hosts and visitors that is still in use for specialty labs with shared equipment today.[bi][bj]
The next major category of safety concerns for our laboratory visits was associated with facility repairs which was present in 24% of our first year visits. These included items such as leaking roofs, unsafe cabinet doors, or delays in re-energizing hoods after fire drills. These were addressed by connecting our scientists to the appropriate building managers who would be able to evaluate and address these safety concerns. After the initial year, most of the facility related concerns transitioned to the addition/removal of storage solutions within specific laboratories. Currently, when new laboratories are associated with the SPYDR Lab Visit program, major facility concerns will quickly be reported.
These visits also brought to light a common problem occurring in the laboratories, that is, the loss of electrical power associated with circuit breakers being tripped when the electrical outlets associated with a laboratory hood were being used at capacity. This led to the identification of the need to increase the electrical capacity in the fume hoods and this Is now being addressed by an ongoing capital project.
By the third year of the program, the nature of the safety concerns changed as many of the laboratory-based concerns had been addressed[bk]. Concerns raised now included site issues such as traffic patterns, pedestrian safety, walking in parking lots at night, and training. [bl]Among the items addressed for the site include on-site intersections being modified and movement of a fence line to enable safer crosswalks and improvements for the driver’s line-of-sight. A simple question raised about fire extinguisher training and who was permitted to use an AED device led to the expansion of departmental fire extinguisher training to a broader group and the offering of AED/CPR training to the broader organization.
These safety concerns would not be typically detected by a laboratory safety inspection program and are only accessible by directly asking the occupants what their safety concerns are. [bm][bn][bo]Through the SCT, these issues were resolved over time as the team took accountability to move the issue through various channels (facilities, capital projects, ordering of equipment) to develop and implement the solutions.
Since 2013, this novel program[bp] has successfully engaged our leadership with laboratory personnel and has led to hundreds of concerns being addressed[bq]. The concerns have arisen from over 300 laboratory visits, and more than a thousand safety conversations with our scientists. Because this is not a safety inspection program, these visits routinely uncover new safety concerns that would not be expected to surface in our typical laboratory inspection program. The SPYDR visit program is a strong supplement to the laboratory inspection program, and has produced a measurable impact on the safety culture.
A collateral benefit from the program is that it drives social interactions within the department where senior leaders who may not necessarily interact with certain parts of the organization have a chance to visit these team members in their workplace and learn firsthand what they do in the organization[br][bs][bt][bu].
[a]Only a bit bigger than some of the bigger graduate chemistry programs in the US.
[j]Was this a formal thing or out of the blue visits?
[k]initially planned as random, unannounced, we had to revert to scheduled in order to ensure scientists were present and available when leaders stopped in
[l]We had the same thing in academic lab inspections. While unannounced visits seemed more intuitive, the benefit of the visits wasn’t there if the lab workers weren’t available to work with the inspectors. So scheduling visits worked out better in the end
[m]In terms of compliance inspections, I would think that the benefit of scheduled inspections is that it can motivate people to clean their labs before the inspection. While I get that it would be preferable that they clean their labs more regularly, the announced visit seems like it would guarantee that all labs get cleaned up at least once per year. And maybe they’ll see the benefit of the cleaner lab and be more inspired to keep it cleaner generally – but I realize that might just be wishful thinking.
[n]So important. We keep running into the issues of experimental safety getting missed by 1-shot inspections.
[o]Some of that could be addressed with better risk assessment training of research staff.
[p]concerns are generally wide ranging, most started out as lab centric in the early years then expanded beyond the labs
[q]Are these other functional areas related to safety or other issues (e.g. quality control, business processes, etc.)
[r]This seems key but also can be super hard to obtain.
[s]I think that it requires leadership that is familiar with all of the different kinds of expertise in the orgainzation to say that. Higher ed contains so many different types of expertise, it is difficult for leadership to know what this commitment entails
[t]And far too often in my experience in academia those in leadership positions have limited management training, which can inhibit good leadership traits.
[u]Many academics promoted into chair or dean level get stuck on budgeting arguments rather than more strategic / visionary questions
[v]I’ve found this expectation to be quite challenging at some higher ed institutions.
[w]Everytime I bring it up to upper management in higher ed, they say “of course safety is #1”, but they don’t want to spend their leadership capital on it.
[x]the program was designed to give senior leaders a role specifically designed for them
[z]This approach seems to be a way for leadership to get involved with out spending a lot of leadership capital.
I always had my best luck “inspecting” labs when I could lead with science-related questions rather than compliance issues
[aa]I think it is really cool that this is thought of expansively.
[ab]Nice to not put bounds on safety concerns going into the conversation. Reinforced later in the paper thru the identification and mitigation of hazards well outside the lab
[ac]Are these legs connected to on boarding training for lab employees?
[ad]This skill would be exceptionally important when discussing such issues with graduate students.
[ae]Are scientists trained in this technique? Or does the SCT have individuals selected for that skill set? When I look around campus at TTU I can see lots of opportunity for collaboration by bringing “non-scientists” into the discussion to get new perspectives and possibly see new problems
[af]This definitely takes practice, but it can also be learned in workshops and by observing good mentoring. The observation process requires a conscious commitment by both the mentor and the employee, though
[ag]one thought at least for me, was the interviewing experience senior folks would have and this would be a chance to practice said skill
[ah]Seems like the process could have some standard topics that can be replaced with new focus areas as the program matures or issues are addressed
[ai]Lab clutter is an ongoing stress for me. Is the clutter related to current work or a legacy of previous work that hasn’t been officially decommissioned yet?
Did your organization develop a set of process decommissioning criteria to maintain lab housekeeping?
[aj]Part of me feels that all researchers should at some point visit/tour a trace analytical laboratory. Contamination is always of such concern when looking for things at ppb/ppt/ppq levels, that clutter rarely develops. But outside of trace analysis laboratory its definitely a continuous problem in most research spaces.
[ak]This is a good idea. I wonder if Bristol Myers Squibb has a program to rotate scientists among different lab groups to share “cross-cultural” learning?
[al]@Chris – good point. I started research in a molecular genetics lab. While there were some issues, the benches and hoods were definitely MUCH cleaner and better organized because of concerns over contamination. Also, we have lab colonies of different insects in which things had to be kept very clean in order to keep lab-acquired disease transmission low for the insects. I was FLOORED by what I saw in chemistry labs once I joined my department. We very much had different ideas about what “clean” meant.
[am]I really like this idea as well. Make sure everyone is on the same page.
[an]I like the idea of shifting focus the previous issues have been addressed
[ao]Great to see emphasis on an often overlooked topic
[ap]Would reviewing these legs annually be regular enough? Or too often?
[aq]So important – people are more willing to discuss issues if they feel like someone is really listening and is prepared to actually address the issues.
[ar]And it demonstrates true commitment to the program and improvements. Supports the trust built between the different stakeholders.
[as]Is there some sort of training or prepping down with these senior leaders?
[at]a short training session occurs to introduce leaders to the purpose of the program
[au]Thank you! This is a challenge for all laboratory organizations I have worked for
[av]Agreed! Too often things are kept even when there is no definitive plan for future use.
[aw]What % of the chemical stock did this purge represent?
[ax]I’m always amazed when I learn of a laboratory that attempts to function without a structured chemical management system. The ones without are often those that duplicate chemical purchases, often in quantities of scale (for price savings) that far exceed their consumption need.
[ay]I once asked the chem lab manager about this. He said that 80% of his budget is people and 15% chemicals. He’d rather focus his time on managing the 80% than the 15%.
He had a point, but I think he was passing up an important opportunity with that approach
[az]@Chris – and grad students waste loads of time looking for the reagents and glassware they need for their experiments. And when they find them, sometimes they have been so poorly stored/ignored that they are contaminated or otherwise useless. Welcome to my lab!
[ba]is this more of a challenge in academia vs. industry?
[bb]This is definitely a pretty big issue for us at the university I work at. Constant struggle.
[bc]One of the things I found frustrating while working at a govt lab is that I found out that we legally weren’t allowed to donate old equipment. I was simultaneously attending a tiny PUI nearby who would have LOVED to take the old equipment off their hands. Now working in an academic lab, I have been able to snag some donated equipment from industry labs.
[bd]@Jessica as someone presently in government research I share your frustration! I have to remind myself that the government systems are all too often setup to prevent abuse, rather than be efficient and benevolent.
[be]Are these other laboratories from within your organization or external partners?
[bf]visitors from other labs within the department,
[bg]We had that challenge to some extent, but the bigger issues arose when visitors from other campuses showed up with different safety expectations than we were trying to instill. International visitors were a particularly interesting challenge…
[bh]@Ralph that was often my experience too, dramatically differing safety expectations now being asked to share research space.
[bi]I wish this occurred with greater frequency in academia. Too often folks are too concerned about hurting a colleagues’ feelings or ego than to have a conversation to address safety concerns.
[bj]I like the best practices approach- less prescriptive and allows researchers some latitude in meeting the requirements. Provides an opportunity for someone (who is a subject matter expert in their field) to come up with a better solution
[bk]That’s great, shows a commitment to the program and supports the trust that has been built between the stakeholders.
[bl]These are important issues in setting the tone of a safety culture for an organization
[bq]Since I’m sure these were tracked, this is a nice metric- prevalence of a particular concern over time.
[br]does this go both ways at all? do the research scientists have the chance to ask how their research projects impact the goals of senior leadership/company?
[bs]there is a social interaction aspect here were scientists will get to interact with leaders they normally would not cross paths with, we can take this opportunity for our analytical leaders to visit chemists, chemistry leaders to visit engineers and engineering leads to visit analytical chemists
[bt]Did business leadership (sales, marketing, etc.) have the opportunity to see this kind of interaction? Or do they have separate interactions with lab staff?
[bu]In higher ed, it would be interesting to take admissions staff on lab tours to inform them about what is going on there and potentially give feedback about what students and parents are interested in
As a profession, contemporary scientists enjoy an unusual degree of autonomy and deference. Universities are professional-bureaucracies (Mintzberg 1979). One side of the organization is collegial, collectively governed, participatory, consensual, and democratic. The other side is a Weberian, hierarchical, top-down bureaucracy with descending lines of authority and increasing specialization. These organizational structures may allow for differential interpretations of and responses to legal mandates and differential experiences of regulation and self governance. They often disadvantage regulators and administrative support staff, who occupy lower-status positions with less prestige, in their efforts to monitor, manage, and constrain laboratory hazards (Gray and Silbey 2011). What is regarded as academic freedom by the faculty and university administration looks like mismanagement, if not anarchy, to regulators[a]…[b].Herein lies the gravamen of the risk management problem: the challenge of balancing academic freedom and scientific autonomy with the demand for responsibility and accountability[c][d][e][f][g][h].
We…describe the efforts of one university, Eastern University, to create a system for managing laboratory health, safety, and environmental hazards and to transform established notions that =faculty have little obligation to be aware of administrative and legal procedures.[i][j][k] We describe the setting—Eastern University, an Environmental Protection Agency (EPA) inspection, and a negotiated agreement to design a system for managing laboratory hazards—and our research methods.
We describe efforts, through the design of the management system, to create prescribed consequences for noncompliant practices in laboratories. We show that in an effort to design a management system that communicates regulatory standards, seeks compliance with the requirements[l], and then attempts to respond and correct noncompliant action, Eastern University struggled to balance case-by-case discretion consistent with academic freedom and scientific creativity with the demands for consistent conformity, transparency, and accountability for safe laboratory practices.
Constructing Organizational Consequences at Eastern University: Management System as Solution?
During a routine inspection of Eastern University, a private research university in the eastern United States, federal EPA agents recorded more than three thousand violations of RCRA, CAA, CWA, and their implementing regulations. Despite the large number of discrete violations, both the EPA and the university regarded all but one as minor infractions. The university’s major failure, according to the EPA, was its lack of uniform practices across departments and laboratories on campus.[m][n][o][p] There was no clear, hierarchical organizational infrastructure for compliance with environmental laws, no clear delineation of roles and responsibilities, and, most importantly, no obvious modes of accountability for compliance….Without admitting any violation of law or any liability, the university agreed in a negotiated consent decree to settle the matter without a trial on any issues of fact or law.
At Eastern, the management system reconfigured the work of staff and researchers by moving compliance responsibility away from centralized specialists to researchers working at the laboratory bench. Scientists became responsible for ensuring that their daily research practices complied with city, state, and federal regulations. [q][r]This shift in responsibility was to be facilitated by the creation of operating manuals, inspection checklists, enhanced training, and new administrative support roles.[s][t][u][v][w][x][y][z][aa][ab][ac][ad][ae]
Research Methods: Observing the Design of an Environmental, Health, and Safety (EHS) Management System
From 2001 through 2007, we conducted ethnographic fieldwork at Eastern University to investigate what happens when compliance with legal regulations is pursued through a management system.
The fieldwork included observation, interviewing, and document collection. It was supplemented by data collection with standardized instruments for some observations and via several surveys of lab personnel and environmental management staff. For this article, we draw primarily from notes taken at meetings of the committee designing the system, presenting notes from the discussions concerning a catalog of consequences for poor performance required by the consent decree.
Building Responsiveness and Responsibility into an EHS-MS: Consequences for Departures from Specified Operating Procedures
The final version [of the management system manual] was agreed to only after hundreds of hours of negotiations among four basic constituencies: the academic leadership, the university attorney overseeing the consent decree, the environmental health and safety support staff located within the administration, a nonacademic hierarchy, and the lab managers and faculty within the academic hierarchy.[af][ag][ah]
These descriptions explain that each person, or role incumbent, works with a committee of faculty and staff of safety professionals that provides consultation, monitoring, and recommendations, although legal responsibility for compliance is placed entirely within the academic hierarchy, with ultimate disciplinary responsibility in a university-wide committee.
>What will constitute noncompliance?
Despite the adoption of the original distinctions between minor, moderate, and very serious incidents [described in a section not included in this Table Read], discussions continued about the relationship between these categories and the actual behavior of the scientists. How would the system’s categories of “acceptable” and “unacceptable” actions map onto normal lab behaviors? How much would the lives of the lab workers be constrained by overly restrictive criteria?[ai][aj][ak] As Professor Doty said, no one wanted the system to be like police surveillance. Labs are places where science students live, after all.[al][am] Once a basic list of unacceptable conditions and actions was created and communicated through safety training, the salient issue would be intentionality, as it is in much conventional legal discourse.
>Who will identify noncompliance?
Marsha (attorney for University): I think we’re going to need to be more specific, though, for university-wide committee policy. If the consequence of a particular action is termination from Eastern, then there’s policy in place for that, but what leads up to that? When do you shut down a lab?[an][ao] When do you require faculty to do inspections in departments like XYZ? A lot of people here have partial responsibility for things—the system may work well, but it’s not[ap] always clear who’s responsible. Where we need to end up is to remember this key link to the PI. In order for this to work, I think it really comes down to the PI accepting responsibility[aq], but how they deal with that locally is a very personal thing[ar][as][at][au]. I don’t think we should prescribe action, tell the PI how to keep untrained people out of [the] lab. But we need to convince the faculty of this responsibility.[av]
>How will those formally responsible in this now clearly delineated line of responsibility be informed?
Informing the responsible scientist turns out to be a complex issue at the very heart of the management system design, especially in the specifications about distribution of roles and responsibilities. In the end, Eastern’s EHS-MS named a hierarchy of responsibility, as described above, from the professor, up through the university academic hierarchy, exempting the professional support staff.[be][bf]
Despite the traceable lines of reporting and responsibility on the organizational charts, consultation, advice, and support was widely dispersed so that the enactment of responsibility and holding those responsible to account were constant challenges and remain so to this day. Most importantly, perhaps, because the faculty hold the highest status and yet hold the lowest level of accessibility and accountability, the committee was vexed as to how to get their attention about different types of violations.
Marsha: …So, while you’re defining responsibilities and consequences, make sure you don’t relieve the PI of his duties. You can assign them helpers, but they need to be responsible[bg][bh][bi]. There can be a difference between who actually does everything and who is responsible[bj]. You need to make sure people are clear about that.
Marsha: We need to convince the faculty of this responsibility….This is what we should be working on this summer. This is unfortunately the labor intensive part—we need to keep “looping back”—going to people’s offices and asking their opinions so they don’t hear things for the first time at [some committee meeting].[bk]
Marsha: We need department heads and the deans to help us with PIs in the coming months…. We need to get PIs—if we don’t get them engaged the system will fail….We will get them by pointing out all the support there is for them, but bottom line is they have to buy into taking responsibility.[bl][bm][bn][bo][bp][bq][br][bs]
In the end, the system built in three formal means to secure the faculty’s attention and acknowledgement of their responsibility for laboratory safety: (1) A registration system was implemented, in which the EHS personnel went from one faculty office to another registering the faculty and his or her lab into the system’s database. The faculty were required to sign a document attesting that they had read the list of their responsibilities and certifying that the information describing the location, hazards, and personnel in their lab was correct for entry into the database. (2) All faculty, as well as students, were required to complete safety training courses. Some are available online, some in regularly scheduled meetings, and others can be arranged for individual research groups in their own lab spaces. The required training modules vary with the hazards and procedures of the different laboratories. (3) Semiannual university inspections and periodic EPA inspections and audits were set up to provide information to faculty, as well as the university administration and staff, about the quality of compliance in the laboratories. Surveys of the faculty, students, and staff, completed during the design process and more recently, repeatedly show that familiarity with the EHS system varies widely.
Although the audit found full compliance in the form of a well-designed system, it also revealed that many of the faculty and some administrators did not have deep knowledge of it,[bt] despite the effort at participatory design.
>What action should be taken?
Consequences vary with the severity of the incident.
It was essential to the design of the system that there be discretionary responses to minor incidents, which are inevitably a part of science.
It was assumed[bu] that regular interaction with the lab safety representative, discussions in group sessions, and regular visits by the EHS coordinator would identify these and correct them on the spot with discussion and additional direction. The feedback would be routine, semiautomatic in terms of the ongoing relationships between relatively intimate colleagues in the labs and departments. No written documents would even record the transaction unless it was an official inspection; weekly self-inspections by the safety reps were not to be fed into the data system.[bv][bw][bx][by][bz][ca][cb][cc][cd][ce]
Consequences for moderately serious incidents include one or more of the following actions: oral or written warning(s) consistent with university human resources policies; a peer review of the event with recommendations for corrective action; a written plan by a supervisor [cf]that may include retraining, new protocols, approval from the department EHS committee, and a follow-up plan and inspection; or suspension of activities until the corrective plan is provided, or completed, as appropriate.
A list of eight possible consequence[cg][ch][ci]s accompanies the definition of a very serious incident. The list begins with peer review and a written plan, as in moderately serious incidents, but then includes new items: appearance before the university’s EHS committee or other relevant presidential committees to explain the situation, to present and get approval of a written plan to correct the situation, and to implement the plan; restriction of the involved person’s authority to purchase or use regulated chemical, biological, radioactive, or other materials/equipment; suspension or revocation of the laboratory facility’s authorization to operate; suspension of research and other funds to the laboratory/facility; closure of a lab or facility; and applicable university personnel actions, which may include a written warning, suspension, termination, or other action against the involved person(s) as appropriate.
These descriptions illustrate the sequential escalation of requirements and consequences and display, rather boldly we think, the effort of the committee to draft a legal code for enforcement of the management system’s requirements.
When the committee completed its work, Marsha, the lead attorney, went to work editing it. When it was returned to the committee, the changes, many of which were grammatical rather than substantive, nonetheless so offended the group that participation in the planning process ceased for a long while.[cj][ck][cl] The associate dean communicated to the EHS leadership that morale among the coordinators and other committee members from the laboratories was low and that their willingness to do their best was being compromised. They believed that the decisions they made collectively in the working meetings were being undermined and changed so that at subsequent meetings, documents did not read as they were drafted; they believed that crucial “subtleties, complexities and nuances to policies and proposals” were being ignored, if not actively erased. If they were to continue working together, they asked for complete minutes and officially recorded votes.
Nonetheless, it was the scientists’ and their representatives’ fear that the system would in fact become what a system is designed to be: self-observant and responsive and, thus, would eventually and automatically escalate what were momentary and minor actions into moderate, if not severe, incidents. This anxiety animated the planning committee’s discussions, feeding the desire to insert qualifications and guidelines to create officially sanctioned room for discretionary interpretation.
>Who will be responsible for taking action to correct the noncompliant incident?
Clearly, most minor incidents are to be handled in situ, when observed, through informal conversation, and the noncompliant action is supposed to be corrected by the observer’s instruction and the lab worker’s revised action. Some noncompliance is discovered through inspections that inform the PI of noncompliant incidents; a follow-up inspection confirms that the PI instructed her students to change their ways. Very few incidents actually move up the pyramid of seriousness.
A significant proportion of the chronically reported incidents are associated with the physical facilities and materials in the laboratories[cm], such as broken sashes on the hoods, eye washes not working or absent, missing signage, inadequate tagging on waste, empty first aid kits, or crowding—simply not enough benches or storage areas for the number of people and materials in the lab…Corrections are not always straightforward or easy to achieve.[cn] Tagging of waste, proper signage, and adequate first aid kits may be fixed within a few minutes by ordering new tags and signs from the EHS office and a first aid kit through the standard purchasing process. While the lab may order its own supplies, it must wait for the EHS office to respond with the tags and signs. The hood sashes and eye wash repairs depend on the university facilities office, which is notoriously behind in its work and thus appears unresponsive. In nearly every conversation about how to respond to failed inspections, discussion turned to the problems with facilities (cf. Lyneis 2012[co])…crowding is often the consequence of more research funding than actual space: the scientist hires more students and technicians than there are lab benches. This has been a chronic issue for many universities, with lab construction lagging behind the expansion of research funding over the last 20 years.
Just as the staff experienced the faculty as uninterested in the management system, the scientists experienced a “Don’t bother me” attitude in the staff, because often the ability to take corrective action does not rest entirely with the persons formally responsible for the lab.[cp][cq][cr][cs][ct] The PI depends on the extended network of roles and responsibilities across the university to sustain a compliant laboratory. This gap between agency (the ability to perform the corrective action) and accountability (being held responsible and liable for action) characterizes the scientists’ experience of what they perceive as the staff’s attitude of “Don’t bother me.” The management system is, after all, a set of documents, not a substitute for human behavior.
Discussion and Conclusion
In this article, we have used the case Eastern University to show how coordination and knowledge problems embedded in complex organizations such as academic research laboratories create intractable regulatory and governance issues and, unfortunately, sometimes lead to serious or even deadly outcomes. Overlaying bureaucratic procedures on spaces and actors lacking a sense of accountability to norms that may in real or perceived terms interfere with their productivity highlights the central challenge in any regulatory system: to balance autonomy and expertise with responsibility and accountability. Under these conditions, accountability may be, in the end, illusory.
…Rather than an automatically self-correcting system of strictly codified practices, Eastern’s EHS-MS relies on case-by-case discretion that values situational variation and accommodation. Compromises between conformity and autonomy produce a system that formally acknowledges large and legitimate spaces for discretionary interpretation while recognizing the importance of relatively consistent case criteria and high environmental, health, and safety standards. [cu][cv][cw][cx]Marsha, Eastern’s principal attorney, noted the difficulties of balancing standardized ways of working in high-autonomy settings, voicing concern about “the exceptions [that] gobble up the rule.” The logic of the common law is reproduced in the EHS-MS because, like our common law, only some cases become known and part of the formal legal record: those that are contested, litigated, and go to appeal. In this way, the formal system creates a case law of only the most unusual incidents while the routine exceptions gobble up the rule.
…safer practices and self-correcting reforms are produced by surrounding the pocket of recalcitrant actors who occupy the ground level of responsibility with layers of supportive agents who monitor, investigate, and respond to noncompliant incidents. In the end, we describe not an automatic feedback loop but a system that depends on the human relationships that constitute the system’s links.[cy][cz][da]
[b]The quote “They spent all this time wondering if they could, that no one thought to think about if they should” is the first thing that comes to mind when I read this sentence.
[c]Why are these viewed as diametrically opposed? They can be complimentary
[d]In practice, have you found this to be the case? I find this perspective interesting, because at least in my experiences and the experiences of those I’ve interacted with, practically, they do often conflict (or, at least are *perceived* as conflicting, which really may be all that matters, culturally)
[e]In many of the issues I have explored as a grad student, I have noticed that this “freedom” often translates into no one actually being responsible for things for which someone really SHOULD be responsible. And if faculty step up to take responsibility, they are often taking on that responsibility alone.
[f]I think it’s strongly dependent on awareness (often via required training) and leadership expectations. In instances where both were sound and established, I’ve seen these elements to be complimentary.
[g]I wonder what this training would look like. In my experience, a lot of training is disregarded as an administrative hoop to jump through every once in a while. I also think it’s wildly dependent on the culture of the university, as it exists. There is often little recourse to leverage over faculty to modify their behavior if it’s not (1) hired in, (2) positively incentivized, or (3) socially demanded by faculty peers. It seems difficult to me to try to newly instill such training requirements, with the goal of making PIs aware of their responsibility for ensuring safety. If there are no consequences (short of a major accident drawing the eye of the law), no social pressure to engage in safe behavior, and no positive incentive structure to award participation, why would faculty change their behavior? Many of them are already aware of the safety requirements—many of them just choose to prefer short term productivity and to prioritize other metrics. In an ideal world, I think I would agree with you that training at the University level would be sufficient, but I think there needs to be a much broader discussion of faculty *motivation*, not just their awareness.
[h]Agreed, the culture/environment aspects are huge in terms of how such awareness training is received. There’s multiple incentive models, and I’d hope that legal liability isn’t the only one that would lead to proactive action.
[i]Sounds like a training deficiency if that’s the perception.
[m]This is a bit vague. Uniform practices? A one size fits all approach?
[n]This caught me out a bit as well. If all they were finding were minor infractions, do we actually have a problem here?
[o]I’m curious what these “minor infractions” were, though. What’s the scale? What’s the difference between a major and minor infraction? 3,000 opportunities for individual chemical exposures or needle pricks may be considered small when it comes to the EPA, but it seems quite substantial when it comes to individual health and safety
[p]In general, minor infractions involve things like labellng of waste containers, storage times in accumulatins areas, etc. without any physical resulting impacts. EPA writes these up and can fine for them, but infractions don’t involve physical damange
[q]Interesting…. this is what caused problems for us at Texas Tech before our accident. Individual oversight often meant no oversight…
[r]Agreed, some form of checks-and-balances should be implemented to verify elements are being completed.
[s]In my experience this is often a techniques employed by higher administration to shift the blame on frontline researchers and their supervisors.
Combine with an underfunded EHS department and this situation results in no oversight or enforcement of these requirements.
[t]But administrators are not experts as the PIs claim they are, If PI’s want freedom and recognition as experts then they do need to be held accountable but EMPOWERED by providing support mechanisms. Responsibility without empowerment is useless.
[u]My eyes immediately went to the “new admin support roles.” If you have someone who understands both the regulations and the relationships in the department, I would think that person would be more effective than someone who shows up from a different department once per year with a checklist.
[v]Agree with Anonymous. If you want the freedom, you take on the responsibility. Don’t want the responsibility, hand over the freedom.
[w]I agree that faculty should be responsible. The common arguments I hear is that faculty aren’t in the lab all the time and can’t always be responsible for what happens day to day. Sort of a cynical view that says that faculty are the idea people and others (students?) should be the implementers…
[x]I don’t think anyone expects them to be responsible for everything every single day though. I think the idea is that they should be responsible for setting the tone in their lab and having standards for the graduate researchers working in their labs – and they should be making an effort to visit their labs in order to walk around and make sure everything is operating as it should.
[y]@Jessica I agree, but if they aren’t overseeing the day-to-day elements, they need to assign that responsibility to someone and make that assignment known to the research group. AND they need to support and empower that individual.
[z]I think I agree with Jessica here. Perhaps, someone with an eye and responsibility for safety NOT being in the lab on the day-to-day is part of the problem. maybe it *should* be a responsibility of PIs to visit their labs, to organize them, to keep up safety standards, inventory, etc. Or, perhaps it is their responsibility to hire someone to do this, specifically. Perhaps these responsibilities should be traded for teaching responsibilities, and thus institutions with high research focus can focus on hiring research teachers and managers (PIs) who are trained as such, and teachers who are actually trained as teachers.
[aa]In the 1970’s and 80’s, externally funded PIs would hire people to do this kind of stuff (often called “lab wives”) but funding for this function was shifted to additional student support
[ab]Blending what Sara and anonymous said while student support has gone up, it has also become more transactional in that it is more linked to teaching duties, while research assistantships tend to be the exception in many “research heavy universities”.
[ac]I think the responsibility of the PI should be first to open the door for safety related discussions amongst the group, and then to make the final decision on acceptable behavior if consensus is not achieved. Following that, they should bare the responsibility of any ramifications of that decision. I think they can achieve awareness of what is happening in their lab without being there every day, but they need to continuously allow the researchers to voice their concerns
[ad]I also think that PI’s might need tools to help them be accountable. Particularly new faculty
[ae]This the unfortunate part of interdepartmental politics, how far is the new faculty wiling to speak up, when in 5 years the same older faculty members will be a part of their tenure decision.
[af]This goes to early commentary on the shifting of regulatory compliance to researchers: were any researchers involved in these discussions or were PIs/lab managers speaking for them in these discussions?
[ag]I’d hope some (if they existed at this institution) laboratory safety officers were participants.
[ah]Lab safety officers were often active participants, but often on a parallel track to the faculty level discussions. I guess which group carried more clout in the system design?
[ai]The wording of this question seems to imply that lab safety impedes on lab productivity
[aj]Building upon this, there is evidence that when safety concerns are not an issue (due to correct practices) productivity is actually better.
[ak]I don’t have evidence for this, but I think it depends on how prevalent compliance is. If everyone is being safe in their labs then I think overall productivity would go up. If some people start cutting corners then while they may get short term improvement in productivity, in the long term everybody suffers (evacuations and accident investigation halting research, bad laboratory practices accumulating, etc.)
[al]Does this imply that “students” are a class of people whose rights and responsibilities are different from other people in the laboratory?
[am]Or to put it another way – why are students living in their labs?
[an]One of the EHS professionals involved in these discussions told me “When you shut down one laboratory you have a mad faculty member; when you shut down a second, you have an environmental management system.”
[ao]Faculty do notice when their colleague’s labs are shut down…
[ap]In what way is the system “working well”? What mission is being served by the way the origional system was structured?
[ar]This seems contradictory to earlier comments that researchers are responsible for their own compliance
[as]The government does not believe this. They believe that the president of the institution is responsible for instituional compliance. The president of the institution may or may not believe that
[at]However, since the presidents turn over much more quickly than faculty, faculty often outwait upper admin interest in this issue
[au]I hear this a lot, but then I have to wonder what the word “responsibility” means in this context. The president of my university has never been to my lab, so how would he be responsible for it?
[av]The subtext I see here is that it would be awfully expensive to have the enough staff to do this
[aw]A ‘dish best served’ by faculty peers rather than university admin staff or legal.
[ax]I don’t believe faculty will have these conversations with each other due to politics. We can have someone they respect make assessments by doing a myriad of approaches including having industry people come visit.
[ay]Or in other words, who is willing to break be the bearer of bad news?
[az]I like this. When I have discussed having issues in my own lab with others outside of my institution, so many respond with “tell the head of the department.” And I’m surprised that they don’t seem to realize that this is fraught with issues – this person’s labs are right across the hall from mine – and this person visits his lab far more often – and this person has seen my lab – he already knows what is going on and has already chosen to “not see it.” Now what?
[ba]Building upon more that “head of department” does not actually mean higher in the hierarchy of authority. These people are still colleagues at the same level of authority most of the time.
[bb]I remember hearing during the research process for the NAS report on Academic Lab Safety, that Stanford Chem had an established structure for true peer inspections of other faculty spaces and in some instances risk assessment of new research efforts. From what I recall that was successful and implemented as that was the expectation. So maybe it just needs to be the expectation, rather than optional. Another alternative is you staff the administrative side with folks that have research experience, then the message may be better received.
[bc]I really like that idea – that faculty would be engaged in the risk assessment of new research efforts. You are right that it would have to be established as a norm at the university – not as optional work – or work that goes to a committee that virtually no one is on.
[bd]The biosafety world is run by a faculty involved oversight committee for grant proposals, for historical funding reasons. My experience is faculty are very reluctant to approach this process critically as peer review, but it does put biosafety issues on the agenda of the PI writing the grant
[be]Interesting that this group is left out. As an EHS employee I see an opportunity to be the consistency and impartiality across departments. Also can disseminate best practices that are implemented in some labs
[bf]Absolutely, and serve as a valuable mechanism for knowledge transfer.
[bg]Yes, delegate task responsibility but not ultimate liability.
[bh]Yes, we have a form we have for the delegation of tasks to the Lab Safety Coordinator (LSC). Ultimate responsibility at PI level, but allow them to delegate tasks using this form.
[bj]Lawyers believe this. Safety professionals not so much.
[bk]Should this responsibility be part of the on boarding process for new laboratory workers in general? I would note that “Eastern U” has had problem with grad student and postdoc misbehavior in the lab, including criminal acts against lab mates. These are handled by police rather than EHS, but EHS is often involved in assessing the degree of the problem.
[bl]Herein lies one of the problems with the unorganized academic hierarchy where PI’s fall into. While systems that improve safety should always attempt to be non-punitive, at the end of the day the repeat offenders still have the freedom to not comply.
This can become problematic if that particular faculty member has a more influential role and position in their department.
[bm]I agree with you that in this case study faculty may have the freedom not to comply until the situation escalates. It is not the case that this is always true. Some universities have the authority to shut down labs. There may be a mad faculty member, but it is a powerful statement to the rest of the faculty to get their acts together.
[bn]The thing about this, thought, is that shutting down a lab is very nearly the “nuclear” option. I would imagine it would be incredibly problematic to determine who deserves to have their lab shut down and who doesn’t. And what has to occur before the lab is allowed to reopen.
[bo]The other problem this presents is the impact of a lab closure on “innocent” grad students in the lab and colloborators with the lab, both on campus and externally. These factors can make for a very confusing conversation with PIs, chairs and deans, which I’ve had more than once
[bp]In my experience, the only time admin and safety committees have even considered lab shutdown is when there’s outright defiance of the expectations and no effort made to resolve identified safety and compliance issues. I’m not sure I’d considered those criteria as being a ‘nuclear’ option, seems more like enforced accountability IMHO.
[bq]I feel like what you just described is what I meant by “nuclear” option. Their doesn’t seem to be anything between “innocuous notice” and “lab shutdown.”
[br]Agree on the point as well about graduate students being the ones who actually “pay” in a lab shutdown. If a faculty member is tenured, then they are getting their paycheck and not losing their job while their lab is shutdown. However, it directly harms the graduate students in no uncertain terms.
[bs]@Jessica Then it sounds like the institution lacks some form of progressive discipline/resolution structure if there’s only one of two options. Sadly some of that (progressive discipline structure) needs to be created with the involvement of HR to ensure labor laws and bargaining unit contracts aren’t violated. But there absolutely needs to be a spectrum of progression of options before lab shutdown is all thats left. And yes, I agree that the graduate student(s) bear a disproportionate penalty at times in the event of a lab shutdown.
[bt]Is this after having the faculty sign on to the program through the registration process?
[bu]I would say “hoped” here rather than “assumed”
[bv]Why no documentation of the informal interactions/feedback? Or was it optional? From a regulators perspective, if it isn’t documented it never happened.
[bw]Good point. The accountability system could take the informality into account but if a lab racks up a bunch of minor, informal infractions it is probably indicative of culture.
[bx]I also worry that not having it documented could lead to the ability for the feedback to be “forgotten” or denied as to having happened in the future if a larger infraction occurs.
[by]This is something that was discussed as problematic in the paper. If it is undocumented, no one knows just how many warnings an individual has had. It is also one of the problems with solely relying on researchers watching out for each other. You don’t know how many times a convo was had and weather the issue was fixed OR the person just got tired of correctly their colleague.
[bz]We are trying a pilot program using this approach. A EH&S building sweep to build a relationships with labs and let them know we don’t just visit to document non-compliance. We are not sure what we’ll document, since these are friendly visits.
[ca]Have you read Rosso’s paper about the SPYDR program they do at BMS? I thought it was a very interesting approach that could be adapted to the academic environment.
[cd]What I particularly like about the feel of this approach is that they are having management intentionally visit labs in order to ASK THE RESEARCHERS what they feel like the problems are. This speaks to me because, as a graduate student, I was frustrated with EHS inspections in which they were focused on their checklist and minor infractions that didn’t matter while they walked right past really problematic things that were not on the checklist – and I would’ve much rather been encouraged to discuss those issues!
[ce]@Jessica Great point about inspectors being too ‘tunnel visioned’ on their compliance checklist and not able to be truly receptive to bigger issues, whether observed or vocalized during (collaborative) discussion with the research group members.
[cf]Is this a supervisor of the lab or to the lab?
[cg]There was a PhD dissertation at “Eastern U” that described how this was negotiated and the impact of those negotiations on the design of the computerized database that was used to implement the system. It’s a fascinating story to read.
[ch]Are you able to quickly find a link to share here?
[cj]This seems very strange to me. Was any additional information provided about the substantive changes that were made that could’ve potentially justified this type of response?
[ck]In working with the EPA, an agreement we were working on was almost scuttled by too many commas in a key sentence. It took 6 months to resolve it because sets of lawyers were convinced that those commas changed the meeting entirely. I couldn’t see the difference myself
[cl]The way through this was for the “clients” (techmical people from the school and the EPA) to get together without the lawyers in the room and come to a mutual understanding and then tell the lawyers to knock it off
[cm]Hardly fair to hold PIs accountable but give the university a pass on providing a safe work place. Although since this is outside the “academic freedom” morass it should be easier to address
[cn]Or are expensive and inappropriate for the PI to do.
[co]I have some of the same problems with facilities
[cp]I am disappointed that this is not a bigger part of this paper. Faculty are often characterized as “not caring” when I think the situation is much more complex than that. As a graduate student trying to get problems fixed, I can certainly attest to how difficult this is – even to know who to go to, who is supposed to be paying for it, who is supposed to be doing the work – and while I am chasing all of that, I am not getting my research done. It can be atrocious to try to get responsiveness within the system – and I can see why it would be viewed as pointless to chase by researchers at least at some institutions.
[cq]As an EHS staff member I can see a cultural rift between the groups. Comes down to good leadership at the top which is in short supply. Faculty and staff all work for the same university…
[cr]@Jessica I agree that getting resolution on infrastructure issues as a graduate student can be a huge time sink and at times even ineffective. That’s where having an ally/collaborator from the professional staff or EHS groups can be invaluable. They often know the structure and can help guide said efforts.
[cs]I would be interested in what percentage of the faculty had this attitude. In my experience, it represents about 20% of an institutional faculty population; 20% of the faculty are proactive in seeking EHS help; and the remaining 60% are willing to go with the departmental flow with regards to safety culture.
[ct]” Faculty and staff all work for the same university…” and work on the same mission, although in very different ways.
Another challenge is that many faculty don’t have a lot of identification with their host institution and often perceinve they need to change their schools in order to improve their lab’s resources or their personal standing in the hierachy
[cu]And if we don’t have experts in actual scientific application looking at the problems or identifying problems then the system is broken. A lab can look “clean and safe” but be filled with hazards due to processes. I believe a two tier audit system needs to be in place: First tier compliance Second tier: Safety in lab processes
[cv]YES! I have often been frustrated when having discussions in the “safety sphere” on these issues. By coming at it from the “processes” perspective, the compliance rules make a lot more sense.
[cw]Reliance on point-in-time inspections can be misleading. My group (EHS) does this for all labs across campus. It is a good start- ensures the lab space is basically safe. But what is missed is what happens when people work in the lab (processes). In a past life, different industry, I worked with a group to develop best practices for oil spill response. If response organizations subscribed to the practices they had guidelines on how to implement response strategies. Not super prescriptive, but set some good guardrails. Might be useful here?
[cx]Experts in process safety are often soaked up by larger industries with much more predictable processes. The common sense questions they ask (what chemicals do you use?, who will be doing the work?) are met with blank stares in academia
[cy]I think this is a profound observation which leads to the success or failure of this kind of approach.
[cz]…this is also foreshadowing for some of her other papers on this case study :).
Diversity and inclusion in the workforce brings significant value to the employer. Diversity in society broadens perspective, improves person to person socializing and creates a culture of openness and growth. ACS has pledged to advance and embrace inclusion in chemistry, which includes promoting our core value of DEIR, identifying and dismantling barriers to success, and creating a welcoming environment so that all ACS members, employees, and volunteers can thrive.
A group met to discuss the DEIR challenges in Chemistry and Environmental Health and Safety in April, 2021. The slides used to lead the discussion are shown here.
The event was co-hosted by:
Division of Chemical Health and Safety (CHAS)
Division of Business Development and Management (BMGT)
The Joint Safety Team (JST) was an initiative started by students from the Departments of Chemistry (CHEM) and Chemical Engineering and Materials Science (CEMS) with the aim of proliferating a culture of laboratory safety from a bottom-up approach via four main areas: compliance, awareness, resources, and education. The idea of the JST germinated from discussions between both departments, in addition to the Department of Environmental Health and Safety (DEHS) at the University of Minnesota with guidance from the Dow Chemical Company in 2012. The departments sought to embrace safety standards prevalent in industry while establishing a culture of safe practices in academic laboratories. Additionally, the JST team was expected to supplement the efforts of the faculty-led safety committees of the two departments to ensure compliance of laboratory practices with government regulations.
Since its initiation in 2012, the JST has taken great strides to be recognized as a leader in student-led safety. The safety endeavor has been well supported by the two departments which have enabled the JST to think of short and long-term safety goals. In 2015, as the initial members who had visited Dow were graduating, both department heads agreed to an ongoing investment in the organization to encourage committee participation and address some concerns from principal investigators about student time being taken away from research[a][b][c][d][e].[f][g][h][i][j][k]¨C11C¨C12C¨C13C¨C14C¨C15C The funding was utilized to provide stipends to JST committee members to ensure prolonged participation in the organization¨C16C¨C17C¨C18C. Furthermore, additional funding from the Dow Chemical Company and the Valspar Corporation (now Sherwin-Williams) was acquired in late 2015, which bolstered JST activities. The financial support from the departments and industrial partners has been critical for the ongoing success of the organization.
The current pyramid structure of the JST (Figure 1) is based on a strong foundation of volunteers[t][u][v][w][x][y] and laboratory safety officers (LSOs) who are responsible for daily implementation of safety practices in their respective research groups. Graduate students and postdoctoral associates assume the role of LSOs of individual laboratories by expressing their interest to the principal investigator of the research group and are assigned by the latter. Typically, laboratories involve two LSOs, a junior (first or second year student) and a senior (student in at least their third year or a postdoctoral associate) member of the group to enable efficient information transfer.
The Administrative Committee (AdCom) was formed as a part of the initial JST and included seven members in 2012. Presently, it is led by the president of the JST and includes the chairs of three subcommittees (E&R, A&C, PR), a Finance Oﬃcer, a Technology Oﬃcer, and representatives from the Department of Environmental Health and Safety (DEHS) at the University of Minnesota. After a collaboration with the Valspar Corporation (now Sherwin-Williams) was established in 2014, monthly AdCom meetings also included a representative from the company. The frequency of the meetings was chosen to ensure that the time committed by graduate students and postdoctoral associates to JST activities was limited and their primary focus lay in research. The member of the DEHS provides expert advice on policy and regulation issues regarding safety while the Sherwin-Williams representatives contribute industrial level expectations to strive toward. [z][aa][ab][ac][ad][ae][af][ag][ah][ai][aj]¨C36C¨C37C¨C38C¨C39C¨C40C¨C41C¨C42C¨C43C¨C44C¨C45C
The AdCom meetings create accountability for ensuring smooth functioning of the subcommittees and aim to provide vision and ideas for future events and activities. The members of the AdCom Committee identify departmental safety weaknesses that need to be addressed in the CEMS and CHEM departments. The president sets and enforces the agenda of all AdCom meetings and is responsible for ﬁlling the open positions in the subcommittees.
The JST website (www. jst.umn.edu) has been instrumental in communicating safety in the two departments, in addition to being the face of the organization as perceived by other research departments. The Technology Oﬃcer, in conjunction with the President, is responsible for website maintenance. The website contains access to the LSO guidebook via a university email address, which includes documentation for LSO training, roles and responsibilities, and transitioning between LSOs in a research group. It also includes “safety moments”, which are publicly available slides discussing speciﬁc aspects for widespread use among all researchers. Academic presentations in the CEMS and CHEM departments are preceded by a safety moment to instill a “safety ﬁrst” attitude across students, postdoctoral associates, and faculty. The website also gives access to the Learning Experience Reports (LER) system. A sister manuscript details how LERs have contributed to improving academic safety in the two departments
The Finance Oﬃcer manages the JST expenses and projected budgets including printing and safety awards and also ensures enough funds are present. Additionally, the oﬃcer is also responsible for preparing the annual budget describing all expenses incurred, which helps the JST obtain future funding. The oﬃcer also contributes to AdCom discussions that are aimed at determining the ﬁnancial feasibility of JST events and prizes. The expenses of the JST have varied through the years around a mean of $1500.[au][av][aw][ax][ay][az][ba][bb][bc][bd]
The Education and Resources Committee: The Education and Resources (E&R) committee oversees the organization of safety events for the LSOs of the CEMS and CHEM departments. The events are held every other month during the academic year and culminate into a grand annual safety event in August, open to all members of both departments[be][bf][bg][bh] (staﬀ, graduate students, postdoctoral associates, and professors). The committee members (one chair, four paid members, and an unlimited number of volunteers) determine the topics of each event and are responsible for the content and the subsequent organization of the events. The E&R committee has evolved from its initial role of solely providing safety information to that of organizing events that train researchers in several practical aspects of safety. The ﬁrst academic meeting held in October typically covers the roles and responsibilities of LSOs as the meeting coincides with the most frequent LSO transition period.
Topics covered at the other meetings change every time and have included round-table discussions and other interactive activities to engage and maintain the interest of the attendees. Often, we ask the participation of professors either for speciﬁc training or for sharing their approach to safety (e.g., evolution of safety over the years since the 1950s by an Emeritus Professor https:// youtu.be/HwXQPdhToec). Additionally, the E&R committee manages and updates the Laboratory Safety Oﬃcers’ guidebook. This document explains the roles and responsibilities of the LSOs in their laboratories and contains hyperlinks in order to eﬀectively provide the LSOs with all the resources necessary to support them in their function. Feedback[bi][bj][bk][bl] from participants is constantly sought to gauge the interest generated by a speciﬁc safety training and its format as well as to determine safety topics of interest ensuring true peer contributions. We found that interactive and entertaining activities help deliver safety messages eﬃciently.
Analysis and Compliance: The Analysis and Compliance (A&C) committee is devoted to preparing methodologies which promote safe behaviors and work environment in individual laboratories. he A&C committee coordinates the biannual peer-to-peer safety walkthroughs of the 53 experimental research laboratories[bm][bn] within the CEMS and CHEM departments aimed at evaluating laboratory safety compliance. The committee also administers the departmental safety surveys to encourage dialogue involving safety within both departments. The safety walkthroughs are peer-to-peer safety inspections organized in October and April every year and conducted by the LSOs. For the fall walkthroughs, LSOs from three to four groups are randomly teamed up, whereas in the spring, teams are selected based on the hazard classiﬁcation. By randomizing the teams, the LSOs are better informed about hazards which they do not commonly encounter. Consequently, they engage in safety discussions and learn how speciﬁc hazards are dealt with (e.g., radiation, large scale reactions, high pressure reactors, biological hazards). The reports are then shared with the respective principal investigators and discussed with researchers within individual research groups. Deﬁciencies are expected to be addressed before the next walkthrough. Even though these walkthroughs[bo][bp][bq][br][bs][bt] do not obligate any safety improvements, we have found that comments and suggestions are generally followed, and overall safety improvement has been observed and noted in the laboratories compared to previous walkthrough assessments. A comparison of the safety areas which “need attention” between 2012 and 2019 show that the number of laboratories showing inadequate levels of safety has drastically reduced (Figure 6).
The A&C committee also conducts anonymous departmental safety surveys every semester including staﬀ and faculty of both departments. The goal of these surveys is to obtain feedback about the general safety climate, speciﬁc aspects of laboratory safety, general suggestions, and for people to raise any other safety concerns. The results of the surveys are summarized and discussed with department heads for further discussion among the departmental faculty-led safety committees. For example, teaching assistants in the CHEM department had raised concerns about lack of adequate training for medical emergencies in a teaching laboratory setting. As a result, a step-by-step procedure highlighting the decisions to make and explaining the steps to take in the case of an emergency has been established and given to teaching assistants. [bu][bv]
Public Relations: The Public Relations (PR) committee was formed in 2013 as an addition to the E&R and A&C committees of the JST. Conforming with the informal JST motto of “making safety cool”, the PR committee functions as a medium of communication to establish safety as a common topic of research conversation. In addition to maintaining an active social media presence on Twitter (@UMNJST), the PR committee has utilized a variety of innovative means to inculcate safety into researchers. In 2016, the PR committee started publishing “stall wall moments”, which are letter-sized safety posters installed in the restrooms of both departments. A repository of all publications from the PR committee can be easily accessed through the JST website. The PR committee has also installed large (3 feet × 2 feet) safety posters across building hallways, stairwells, and common areas describing general safety procedures such as hazard pictograms, glove choices, data management, and building emergency evacuation plans. The committee strives to promote colloquial safety-related readings to encourage daily communication to further strengthen the safety culture. Surveys have consistently shown that “stall wall moments” and posters are eﬃcient means of communication which convey available safety resources and provide commentary on relevant safety incidents to the student body on a daily basis. The PR committee has allowed the JST to become the visible face of safety in the two departments making it easier for all researchers to approach safety, not with apprehension, but with an inherent curiosity to learn and implement self- and community-wide safety improvements
Promotion of the Safety Culture[bw][bx][by]: Academic safety is known to lag behind industrial expectations due to the lack of dedicated resources and enforcement as well as a deﬁciency of a strong safety culture. The JST periodically organizes industrial visits to the DOW campus in Midland, MI and the Valspar Corporation (now Sherwin-Williams) corporation in Minneapolis, MN. The visits bolster the attitudes of the visiting students about safety and provide them with opportunities to gain insights into developing new safety protocols at their home laboratory. Furthermore, this JST peer-to-peer model has inspired departments at other universities to set up analogous organizations to promote safety through a similar model.
Although the JST is a well-established organization in 2020, several challenges inherent to academia remain unaddressed. The high turnover of laboratory members makes it diﬃcult to perpetuate the safety culture and good safety practices. Enhancing participation from LSOs and non-LSOs in safety meetings also proves to be a diﬃcult task. [ch][ci][cj][ck]The JST continuously works toward the development of innovative means to make “safety cool” and hence sustain the safety culture. The “inform and reform” model, i.e., the “Minnesota model” has been well supported by the feedback mechanisms to improve the information that is conveyed to researchers as well as ensure constant improvement in safety standards in the CEMS and CHEM departments. The feedback mechanism itself presents a new set of challenges including excess or lack of speciﬁcity of the questions[cl][cm][cn][co][cp][cq] and encouraging thoughtful feedback from researchers in addition to evaluation[cr]¨C96C¨C97C¨C98C¨C99C¨C100C¨C101C¨C102C of the JST activities provided solely based on a point scale¨C103C¨C104C.
[a]This work will hopefully be considered an added value to a person’s research education.
And again this is another area where I feel that funding mechanism influences the degree of latitude afforded to graduate students in relation to their time allocation. Ones being supported off the research grant are often given less leniency for time spent not solely in pursuit of the grant deliverables.
[d]Agreed. Where you put the money is what gets the attention. Either (a) grant funders need to make safety education part of the grant or (b) the uni admin needs to step up and fund these efforts as part of functioning in the uni.
[e]Absolutely. The fact that we can allocate stipends for volunteers signals to everyone that this taken seriously and being supported by the higher ups
[f]Did anyone feel these concerns were legitimate? i.e. did someone has evidence that time was actually taken from research? Or was this just a general statement?
[g]Safety should be part of the research work. Tilak
[h]@email@example.com. While I wasn’t there at the time, I know of professors who in recent times have been worried about their students participating in student organizations in general. I think this worry comes up when students are involved in one of the JST committee’s rather than when serving as LSOs
[i]Jen Heemstra makes the point that the faculty member’s commitment should be to the student’s professional development, not the amount of lab time the students put in. JST committee work is an important professional asset when it teaches administrative skills (leadership, budgeting, communication)
[j]I know of advisors who don’t support their students taking up leadership positions outside of the lab. I am not surprised some of the faculty members started complaining about the time their students spend out of the lab.
[k]Agree with Monica. This varies quite widely. In terms of Ralph’s comment, it does come back to questions around the purpose of the institution: As a PI, are you primarily there to deliver students or primarily there to deliver data?
[l]I think many would default to the later response, as it influences future funding.
[m]I think that is the sad reality. Grad school on paper is about getting a degree and growing as an individual, but not every PI sees it that way
[n]I think it depends on how broadly you are considering the picture. This is constantly talked about in organizational literature. If you focus on product, you will make money in the short-term. If you focus on supporting your employees, you will typically make more money in the long-term. Better environment = more productivity if you are looking at the long game.
[o]The ACS did a study in 2014 of graduate education that is very interesting to read in light of this issue. The study was led by corporate science leaders and voted strongly for broader education rather than data-oriented training
[p]That is really interesting Ralph. Do you have a link to that study?
[q]What is the value of these stipends? For example, do the members do the JST activities INSTEAD OF teaching? Or are they additional supplements to standard funding mechanisms?
[r]Also, is there a means of judging whether or not paid JST members have “earned their pay” so to speak?
[s]The stipends are $200 per semester, so they do not replace teaching. The committee chair keeps track of attendance to committee meetings, of which there are usually five each semester. The member loses $40 for every meeting missed
[t]Are these solely researchers, or have there been other univ admin staff joining too?
[u]They have been solely researchers. We have tried to ensure that we stay student led so far. We do have a DEHS personal and department staff who support us, but at the end of the day the team is researcher led
[v]We have found that participation of and leadership from more permanent staff is quite useful.
[w]While it is important to have more permanent members stay up-to-date and interested in the LSTs, the thing that sets the LSTs apart from other types of committees is that it is graduate student and postdoc led. This has been incredibly important in order to encourage honest conversation and evaluation from those on the frontline in these labs.
[x]I agree with Anthony in that I’ve found substantial value in engagement and involvement with more permanent staff.
I’m not recommending a change in structure from a leadership and organizational perspective. But I do feel that having engagement and participation from career staff is value-added and can serve in areas of continuity and knowledge transfer.
[y]Our old DEHS staff representative was very essential to our success as well, and we felt a big hit when she left the university. Having that reperseenitve be present at our meetings and advocate for us was extremely helpful. The most important distinction is that they serve in a supportive role, but the organization as a whole is still researcher led
[z]Who does this representative tend to be? A scientist? Administrative staff person?
[aa]It is a DEHS administrative stuff. They usually have some background in science however
[ab]Additionally, do you have any sense what is “in it” for the company to be this involved? I have found that we struggle to get much traction in building relationships with local companies – beyond giving us tours of the facility (which is usually thought of as a recruitment opportunity to them so is typically run through HR).
[ac]I think it is more or less PR for them too. They employ a lot of grad students, so it does help them to have their future employees trained in proper safety practices
[ad]I suppose it may depend on how heavily they anticipate recruiting for 1 particular program at 1 particular school…?
[ae]Yeah they are very involved in the two department where we operate. They have recruitment events and even collaborations with some of our faculty
[af]At Cornell, I was able to arrange a safety-oriented tour of Corning labs for chem engineering students. They were disappointed that they didn’t get to hear about cutting edge research (aka trade secrets) as well as working expectations…
[ag]Well – if they thought they were going to hear trade secrets, they may need a bit more education on how companies run :). I have been on tours in which they were essentially led by HR & we didn’t get to see anything cool which were terrible. I have been on other tours that have involved researchers and we got to actually go around the facility and discuss details of the work. If our questions go to something proprietary, they would say essentially, “can’t answer that – but here’s what I can say.” Those were extremely valuable tours in terms of thinking about how companies operate and what possibilities existed for career options for researchers.
[ah]I have found that it takes an entirely different vocabulary to say what you are interested in doing in academia versus what you are interested in doing in industry.
[ai]Yes, the grad students were disappointed that they were being educated about safety vocabulary rather than technical fields where their strengths already were. With this in mind, I could have done a better job in setting expectations for the visit.
[aj]The unhappy response was “well, I missed a day in the lab for this”
[ak]I have found that our lab tours attract far more international students than domestic students. Everyone has expressed appreciation for the tours and the ability to connect – I definitely do realize that the students are going on the tours to make connections in companies (not for the love of learning about safety), however, I also think it is good that the two (safety + employability) are being shown together and necessarily connected to each other.
[al]We usually organize tours to Sherwin Williams that along the same lines. It about highlighting the safety practices there and also a recruitment event for the the company. We have gotten mixed responses are well in the past
[am]Employability = meeting industrial level expectation = part of a person’s research education?
[an]I think in an ideal world it would be, but safely safety adherence gets often overlooked in academic settings
[ao]There are also quite a few PIs who do not think of it as their job to prepare their students for work in industry.
[ap]There are quite a few PIs who wouldn’t know what industry needs. My master’s adviser went on sabbatical year to an industrial position and came back 6 months early because he and the corporate world didn’t get along
[aq]Do we even have a “definable” idea of what industry is looking for? Safety is too broad for those academics who have never worked in industry.
[ar]While I think that it is a good idea to get a feel for the “definables”, I also think a lot of the problem is actually centered around the basics: wear your freakin’ PPE; don’t do stuff in the lab without telling other people what you will be doing.
[as]Yeah I think the main thing that we got from DOW and Sherwin Williams was to have researchers go with a safety oriented mindset, and being willing to adhere to safe practices outlined by the companies. That is why the core of what we advocate is the safety culture above everything else
[at]Personally, it was weird for me to go from undergrad where you are constantly watched to grad where you are NEVER watched. The companies I have worked with, there was an expectation that people were going to be around sort of keeping an eye on you, but it was also your job to be an adult and communicate with others. Personally, I found this REALLY GREAT because I learned so much more from the people around me.
[au]This seems like a very doable, yearly investment. Any idea on ROI?
[av]Are there any critical “donations” of space, resources, etc?
[aw]I am assuming that this amount does not include the stipends. 🙂
[ax]What do you mean with ROI? In terms of space, we have not needed any dedicated space so far. Any supplies that we have needed to keep we have kept in a box that one of the committee members keeps in one of their offices.
[ba]I would imagine that all of the press and attention UMN gets for this work is likely the ROI to be expected – and all of this attention resulting from a few thousand dollars is likely viewed as remarkably good ROI.
[bb]I agree with Jessica. I think the department is very happy with the exposure that we get and uses us a recruitment device. I also think the simple fact that people generally feel safer in their lab spaces is well worth it
[bc]Are these costs solely operational/administrative, and not reflective of any other incentive expenditures (e.g. monetary awards)?
[bd]The costs are split between posters, awards, and food. There is a figure in the paper that breaks these down in more detail
[be]Is space limited? If not, is there interest for participation from other departments/organized research units?
[bf]The space is not at all limited. We have currently started a new committee dedicated to outreach, and we plan to start inviting students from local PUIs
[bg]Excellent, I hope that others find value and choose to participate.
[bi]It would be interesting to see the list of topics covered where student interest was the greatest. Also, are these meetings mandatory or optional for students in these departments?
[bj]We do send out surveys after these events to gauge interest, but we do not get a lot of response. These events are mandatory for LSOs, but open to all researchers
[bk]While I know it doesn’t “feel” like data gathering, I have found it far more useful to have our JST members (and EHS staff) floating around during events eavesdropping on conversations and explicitly asking for people’s feedback rather than handing out surveys. Not only do we get more response, the responses are actually much more useful and informative – especially when I engage people who have been “voluntold” to be there but are clearly not enjoying it. You gotta be ready for the real criticism with that approach though :).
[bl]Yeah I try to do this during our events where we have group discussions. I participate as a researcher and not as the president of the JST, and I think that helps me gauge people’s attitudes a little bit. This was easier when everything was in person though
[bm]Is this lab spaces or lab groups? (i.e. my 1 lab group has 3 separate lab spaces that are all situated next to one another – the 3 spaces are inspected separately by EHS).
[bn]We do it by groups. The idea is that each group gets a review of how safe they are that they can discuss together afterwards
[bo]Is there is any checklist for the walkthrough, how do you gauge the safety improvements
[bp]Yes. We have a sample sheet in the SI. It is constantly being revised and each category has a detailed rubric. The A&C committee also analyze the results each year and reports that information to the heads of the two departments
[bq]Have these results been used to identify department-wide pain points or issues that are more appropriately addressed on a department level or university level – rather than just individual lab issues?
[br]We have identified issues on the department level that we have addressed or are currently addressing. One big issue in the past was cluttered which we did an event targeting in the past and did a good job of minimizing. We have also had issues come up with electronics and old waste, and so we have brought up those issues in our events. We are currently working on creating hazard specific walkthrough rubrics
[bu]It is really good to see that this produced an effective feedback loop.
[bv]Yes we are very lucky in that we have a lot of support from the departments, and that they are willing to listen to the issues that we bring up and try to address them
[bw]Have there been or are there plans to expand to other departments?
[bx]We are currently working in talks with the college of pharmacy to try to implement a safety team there. There are the closes to us in terms of research, but they have their own set of challenges such as being spread out all over campus
[by]This is an interesting example, in that pharmacy’s have product safety certification requirements as well as lab safety concerns. This might provide another angle to foster in that department
[bz]The ultimate purpose of a JST is to inculcate safety into the students as they progress in their careers. With about 8-9 years history in this project, is there any follow-up of graduates who are now a few years into their post-graduate career?
[cb]I don’t know a lot of the original organizers, but I do know of a few. One of the DEHS positions have been field with a previous member of the JST, and there is actually another DEHS position that I know a graduating member of the JST is seeking. I also know that several members ended up in different industries where they continue to advocate for safety in their new roles. Good point though, I will try to reach out to some of the past members though and compile a list of stories
[cc]This is a really good idea. While it is neat to see some of these folks become safety professionals, I think it would be really important to see some of them go into more traditional roles but have their JST experience influence how they act in that role.
[cd]Are the opportunities associated with JST involvement discussed with potential students? Or when recruiting new faculty?
[ce]I hope, and the reason I strongly support JSTs, that the next generation of PIs and lead scientists include safety in their science view. Measuring that will have a strong indication of the success of the JST endeavor.
[cf]@Ralp Stuart, One of our biggest recruitment tactics is to say that involvement in the JST looks great on a resume and allows you to network with safety professionals.
[cg]@Neal I completely agree. We have gotten to the point where the JST is embedded into the fabric of the two departments and taken for granted. Our biggest measure of success has been the surveys that we send out, and how people feel about the safety conditions of their work environments
[ci]More interactive activities such as safety demos was a big hit. We have also tried to do hazard specific panels as well as invite outside speakers. According to our rules we are supposed to penalize LSOs who do not attend, but we have not implemented that because we didn’t want to add another source of stress to our LSOs during a pandemic
[cj]I would think it wouldn’t make sense to have penalties for non-attendance – goes against the spirit of the whole thing! I recall Texas A&M’s team used “Safety Moments” to start meetings that were focused on a particular technique or piece of equipment – for example, they started with glovebox safety. After kicking off with the Safety Moment, they would open it up for everyone to share questions, ways they had dealt with different challenges, etc. I really liked this idea because it was more specific for people who had those particular challenges so I would think they would get more from it as opposed to always focusing on the safety stuff that all of us share.
[ck]That’s an interesting idea. We try to start our events with safety moments, and all of our departmental seminars also begin with safety moments, but we do not open the floor for discussion afterwards. In the past we have had specific topic events such as Schlenk lines, glove boxes, vacuum pumps, etc, and those we do get good attendance for
[cl]This is a core skill for professionals in general and safety professionals in particular to develop. It is not easy and is done by trial and error. So it is good to hear that this is being experienced at the grad student level
[cm]Yes we are constantly improving our skill level. The big issue is that a lot of the lessons that we learn get lost due to the high turnover rate that we hava
[cn]There are commercial half day and full professional development courses around these issues available that can be useful in the early stages of ones career. Perhaps the departments could support scholarships to them.
[co]That would be an awesome way to bolster the “value” of high participation in the JST as well.
[cp]That is a good idea. I think the department is not willing to pay any extra money right now due to budget cuts and COVID, but potentially when the pandemic is over we could pursue that route
[cq]There is also the possibility of seeking out what is already happening and then inviting/incentivizing your LSO folks to go. So many of the issues that come up for JSTs have to do with communication, handling difficult conversations, managing up, etc – and I certainly know there are other departments at UConn who do a much better job of creating these events than my department does. The events are typically open to all departments – although I have been at PLENTY of these types of events/trainings in which I am the sole Chem person (even though we are one of the largest departments on campus) and sometimes even the sole STEM person. If my Chair actually valued this type of training, even light encouragement from him could increase those numbers.
[cr]How did the recent incident impact the JST? Was there a sense of failure?
[cu]Yeah there was definitely a sense of failure as a result of that incident. One the biggest one was that it took a lot of time for anyone to communicate what happened with us, and so it was months after before we could say something to the LSOs about it, which angered a lot of people
[cv]What was the cause of this incident, can you briefly explain
[cw]The fact that this delay in communication angered a lot of people is in itself progress! Stuff happens in our department all the time that doesn’t get discussed or shared in an official capacity – and no one is angry about it because it is just so normalized for us to not be in that conversation.
[cx]The researcher ran a Fischer esterification with two new substrates on a 35g scale. They felt safe because they had runt he reaction with different substrates on a similar scale in the past. The reaction involved adding propargyl alcohol to a sulfuric acid mixture and heating to 70C. after 30 minutes the reaction detonated. The researcher did not have a lab coat on and had several cuts and burns. Luckily there were other group members there who helped the researcher use the safety shower and then seek emergency help
[cy]I agree Jessica. It definitely is a step in the right direction. There is still room for improvement though!
[cz]Have you made any efforts to encourage feedback by a mechanism other than surveys?
[da]We have recently started doing a semesterly LSO forum. This in an event where all LSOs are invited to come together and share any issues that they are encountering
On WEDNESDAY, March 24 the CHAS Art and State of Safety Journal Club discussed the paper “Anaphylaxis induced by peptide coupling agents: Lessons learned from repeated exposure to HATU, HBTU, and HCTU.” 1st author Kate McKnelly led this discussion on this paper.The full paper can be found at this link: https://pubs.acs.org/doi/10.1021/acs.joc.9b03280. Comments on the table read are found below.
INTRODUCTION After working for years with peptide coupling agents HATU, HBTU, and HCTU[a][b],[c][d] a twenty-seven-year old female researcher (K.J.M.) developed life-threatening anaphylaxis. She began working with the aforementioned peptide coupling agents in May 2015. During the next few years, she worked heavily with these uroniumpeptide coupling agents. In March 2016, she began developing allergy symptoms of sneezing, coughing, and a runny nose. During the next couple of years, her symptoms progressed[e] to the point of anaphylaxis. These coupling agents are especially insidious because a severe allergy developed slowly over the course of three and a half years of exposure to the point of a life-threatening incident.
About one and a half years after beginning to work with these coupling agents, she noticed she had allergy symptoms when she weighed out coupling agents and Fmoc-protected amino acids for use in solid-phase peptide synthesis. In July[f][g] 2018, she began suspecting she was becoming allergic to coupling agents because she experienced sneezing and a runny nose immediately after spilling HCTU onto her glove. It was not until September 2018 that she experienced her first brush with allergy-induced anaphylaxis. She was at the weekly research group meeting in a seminar room down the corridor from the laboratory, and she began wheezing slightly. The wheezing was fleeting and went away after the group meeting when she left the building. A couple of weeks later, she started wheezing as she drove two labmates home. This time, the wheezing was louder—her labmates could also hear it—so she took the antihistamine diphenhydramine (generic Benadryl) to stop the reaction. Within 20 min, she could no longer hear wheezing.
Finally, in late October 2018, the researcher sat down at her desk in the lab and almost immediately began coughing, sneezing, feeling tightness in her throat, and subsequently wheezing. She attempted to remove herself from whatever she was exposed to in the lab and moved down the hallway to an office outside the lab. Once there, she continued reacting, and the wheezing progressed until she could hear a rattling wheezing sound when breathing through her nose. She immediately left the lab to obtain diphenhydramine. As[h] she exited the building, her symptoms stopped progressing. An hour after taking diphenhydramine, the wheezing subsided completely. In hindsight,[i][j][k] she should have called 911 for emergency medical help, because a throat-closing anaphylactic reaction can occur quickly, sometimes so quickly that there is barely enough time to avoid fatality.
How did this happen? How could this have been prevented?[l][m][n][o][p][q][r] We have been tackling these questions since the incident occurred. We provide this case study as a cautionary note about the potential hazards from chemical exposure that can develop over time and sneak up on a researcher. We first sought to determine what caused this anaphylactic reaction to occur. We then adjusted how peptide coupling agents were handled in the lab to minimize exposure and attempt to prevent other researchers from becoming sensitized as well. In sharing our experience here, we hope to contribute to the widespread implementation of standard operating procedures for peptide coupling agents and protect others who work with them.
We first scoured the literature for information on sensitization by peptide coupling agents HATU, HBTU, and HCTU and Fmoc-protected amino acids. Information regarding sensitization varied among chemical supplier material safety data sheets (MSDSs). HATU is reported to cause skin, eye, and respiratory irritation and is denoted by an exclamation mark hazard symbol. HBTU is reported to cause respiratory sensitization. HCTU is not reported to have known toxic effects. [s][t][u][v][w][x][y]We found only nine published cases of sensitization by the uronium coupling agents HATU and HBTU and none by HCTU or by Fmoc-protected amino acids. The first reported case implicating uronium coupling agents as chemical sensitizers came in 2003. Yung et al. described a researcher at a university that first developed eye irritation, a runny nose, and coughing (rhinitis) after weighing HBTU. Her symptoms progressed over the course of 2 weeks, developing into chest tightness, a cough, and skin rashes (urticaria) and culminating in sore, red itchy eyes, coughing, sneezing, and urticaria within 1 h of being in the laboratory. The researcher was tested with skin prick tests for allergies to HATU, HBTU, and HCTU because all chemicals were present in the lab. She tested positive for sensitivity to HATU and HBTU but negative for HCTU and various Fmoc-protected amino acids[z][aa]. Because the researcher did not exhibit sensitivity to HCTU, the authors suggested that this uronium coupling agent may be a safer alternative for widespread use.Other publications report that HCTU is nontoxic and nonirritating.
The other published instances of chemical sensitization to uronium coupling agents have involved HBTU exclusively. In 2003, another researcher, this time in a pharmaceutical plant, developed occupational rhinitis and bronchial asthma from HBTU and TBTU, which is identical to HBTU except for the counterion. The allergies were confirmed by positive skin prick and nasal challenge tests.In 2005, Bousquet et al. reported a chemistry researcher who developed allergic rhinitis and dermatitis on the hands and fingers which then progressed over the course of a year to include his face, upper back, neck, elbows, and ankles. The authors confirmed the researchers’ sensitivity to HBTU through patch testing and found he was not allergic to dimethylformamide, dichloromethane, acetonitrile, triisopropylsilane, HATU, or BOP. From 2006 to 2010, six more instances of chemical sensitization from HBTU were reported with similar respiratory and skin reactions.One example, in 2006, involved a university researcher developing an anaphylactic response to HBTU over the course of three years, similar to the case reported in this paper. All of these examples were published in allergy and other medical journals, which are not generally read by researchers who use peptide coupling agents.[ab][ac][ad][ae][af][ag]
We suspected that peptide coupling agents caused K.J.M.’s allergic reactions. An allergist and clinical immunologist (W.S.) tested the researcher for allergies to a panel of over 60 allergens by skin prick tests to determine if common environmental allergens accounted for her anaphylaxis. She was only slightly allergic to two environmental allergens, but not so allergic that they would cause anaphylaxis. Skin prick tests were then performed to determine if she was allergic to HATU, HBTU, HCTU, DCC, Fmoc-leucine–OH, Fmoc-phenylalanine–OH, and Fmoc-asparagine(Trt)–OH. The researcher worked with most of the canonical amino acids in their Fmoc-protected forms, so three were chosen as representative amino acids. DCC was included as a control because it is a notorious sensitizer that the researcher had never previously worked with.
As hypothesized, the researcher had severe positive allergic reactions to uronium peptide coupling agents but only mild responses to Fmoc-protected amino acids. The coupling agents HATU, HBTU, and HCTU all caused the formation of large hives, comparable in size to those formed by the histamine positive control. DCC did not cause any reaction, which is not surprising as the researcher was never previously exposed to DCC. Fmoc-leucine–OH, Fmoc-phenylalanine–OH, and Fmoc-asparagine(Trt)–OH all elicited minor reactions and produced hives much smaller in size than the histamine positive control. The lack of a strong reaction to the Fmoc-protected amino acids is not surprising, as they are not known chemical sensitizers.
This paper serves as the first reported case of chemical sensitization resulting in anaphylaxis from three common uronium coupling agents: HATU, HBTU, and HCTU. The sensitized researcher (K.J.M.) can no longer work in her research lab.She cannot go into the building where the lab exists; the hallways, rooms, and common spaces all cause her to react, first with a runny nose and throat tightness and then with wheezing.[ah][ai][aj][ak][al][am] Her allergic response is so severe that she risks anaphylaxis whenever exposed to these coupling agents, and she now must carry an epinephrine autoinjector (generic EpiPen) as a safety precaution whenever she is near researchers actively working with peptide coupling agents. She has become sensitive to colleagues who have been in her research laboratory and must be careful to ask them to change their clothes and in some cases wash or cover their hair to prevent her exposure to the pervasive coupling agents. These events prompted the research group as a whole to re-evaluate how the group handles peptide coupling agents and to change their standard operating procedures to prevent group members from becoming sensitized to coupling agents.
Chemical sensitization causes an immune response in the form of reactions as mild as seasonal allergy symptoms, like rhinitis, and as severe as dermatitis and anaphylaxis. Many[an][ao][ap][aq][ar] chemical sensitizers are chemicals that can modify human proteins. All reactive compounds that can modify proteins should be treated as potential sensitizers unless they are known with certainty to be safe. In spite of this hazard, most researchers do not treat compounds that can react with proteins with proper precautions. Peptide coupling agents are prime examples.
Peptide coupling agents induce the formation of an amide bond from the reaction of a carboxylic acid group with an amine group. The coupling agents react with the carboxylic acid and activate it for subsequent attack by a nucleophilic amine. After the amine reacts with the activated carboxylic acid, an amide bond forms. Human proteins display multiple carboxylic acid groups (e.g., glutamic acid and aspartic acid) and amine-containing groups (e.g., lysine) in the form of amino acid residues at protein surfaces. The reactivity of coupling agents toward amino acid residues primes them to cause sensitization by modifying proteins in the human body.
The carbodiimide coupling agent DCC (dicyclohexylcarbodiimide) is a notorious chemical sensitizer with a long history of causing sensitization. DCC was first reported as a peptide coupling agent by Sheehan and Hess in 1955. It quickly grew in popularity due to the ease with which it induced the formation of peptide bonds. Soon after its introduction, a publication reported that DCC caused three cases of allergy-induced skin rashes (contact dermatitis) in 1959. Zschunke and Folesky subsequently reported seven cases of DCC-induced contact dermatitis in a pharmaceutical plant in 1975. In 1979, two independent cases of DCC sensitivities were published in the journal Contact Dermatitis. In one case, a lab worker developed a blistering eruption rash on his hands and forearms, and in the second case, a research chemist developed a rash over nearly his entire body that persisted for five days before he was hospitalized.Since 1979, 11 more cases were reported of DCC causing similar skin contact allergic reactions. In one of these cases, the researcher also developed sensitivity to diisopropylcarbodiimide (DIC) and suffered a vesiculopapular rash on his cheeks and the backs of his hands from both DCC and DIC. The authors of each of these reported cases confirmed sensitization with skin patch tests.
The many reports of DCC sensitization lead to toxicology testing to confirm the hazard it poses to human health. DCC and DIC were nominated for testing by the National Toxicology Program in 1993. Hayes et al. then tested DCC and DIC on the skin of mice for their potential as sensitizers and in 1998 reported sensitization at concentrations as low as 0.006% (w/v) for DCC and 0.3% (w/v) for DIC. Another report in 2002 confirmed DCC and DIC as sensitizers to mice when examining the mechanism of DCC- and DIC-induced chemical sensitization. In 2011,[as][at][au] Surh et al. further characterized DCC and DIC for toxicity and carcinogenicity and determined that both DCC and DIC caused skin sensitivity in rats and mice, but only DCC exhibited carcinogenicity. The detrimental health effects of the peptide coupling agents DCC and DIC are worrisome for anyone who handles them.
HATU, HBTU, and HCTU were developed between the late 1970s and the early 2000s and are now widely used as coupling agents in peptide synthesis. Despite being implicated as sensitizers in at least ten reported cases, including the current one, they have not been rigorously tested for their immunogenic and toxicological properties.
LABORATORY ACTION PLAN
In response to the sensitization of K.J.M., we developed standard operating procedures to handle HATU, HBTU, and HCTU more safely. We found guidelines for handling sensitizers, which recommended never opening sensitizers outside of a fume hood and minimizing exposure if handling them outside of a fume hood. Our lab dedicated a portion of a fume hood to weighing out coupling agents and amino acids and placed a balance in the hood[av].[aw][ax][ay] A waste container was placed in this fume hood as a receptacle for weighing paper and other materials contaminated by coupling agents or Fmoc-protected amino acids. Coupling agents and amino acids are transferred into sealable containers before removal to individual researchers’ fume hoods. As with other standard operating procedures for handling hazardous chemicals, personal protective equipment (PPE) in the form of a lab coat, eye protection, and disposable gloves [az][ba][bb][bc][bd]should be worn at all times when handling coupling agents. We anticipate that these procedures will reduce the risk of other researchers becoming sensitized in the future.[be][bf][bg][bh][bi][bj][bk][bl][bm][bn][bo]
Any research lab that performs peptide synthesis should take extra precautions to avoid exposing researchers to coupling agents. The Supporting Information provides a standard operating procedure to handle peptide coupling agents more safely in the research laboratory by minimizing exposure[bp].
Peptide coupling agents, regardless of whether they are carbodiimide reagents, uronium reagents, phosphonium reagents, etc., all perform the same chemical function of facilitating amide bond formation and therefore can all covalently modify human proteins. If a chemical can modify human proteins, it is a prime candidate as an immune sensitizer, even if it is not a known sensitizer. We hope that our laboratory’s experience of the hazards of HATU, HBTU, and HCTU will serve as a cautionary note to those working with any peptide coupling agents.
[a]I see that PF6- is frequently the counter ion. Was this tested as an allergen?
[b]In second paragraph of the literature search part they mention a researcher who became sensitized to both HBRU and TBTU, which has a different counter ions, so while it sounds like the counter ion wasn’t tested for specifically, it doesn’t seem to be the culprit here. This makes sense since the counter ions do not partake in the coupling reaction and only has a slight influence on coupling efficiency
[c]What is the best practices to handle these coupling agents? Tilak
[d]This is discussed towards the end – also if you are interested in the protocol they shared, that is in the SI if you follow the link to the paper.
[e]Why it is important to pay special attention to unusual symptoms.
[g]Reporting symptoms early is also important for legal (i.e. Workers Comp) reasons
[h]Another scenario I have seen a lab worker suffer was a techinician in a electron microscopy lab. She accidently brushed her hand against a container of an epoxy they used to set up samples for the microscope and didn’t think anything of it. The next day when she can to work, her fingers started itching and keep getting worse for a week. She eventually had to leave that job.
The difference from this report is that it was a single exposure that led to the sensitization rather than repeated exposure over time.
[i]Why it is important to keep an eye on our colleagues as well and ask questions. As wild as this sounds, it is so easy for us to dismiss our own symptoms as minor even if we would be incredibly concerned about those same symptoms if we observed them in another person!
[j]A lab tech reported to me a situation in which she and a colleague were transferring insect samples between killing jars which contained 70% ethanol in the open lab. After about half an hour, she noticed that her partner was getting goofy. She then realized that they were both getting drunk from breathing the ethanol that was evaporating as they did the transfers. It’s not likely that she would have noticed this without seeing that her partner was being affected.
[k]Really good point. Also, would she have noticed her own symptoms if she had been working alone? Could’ve just interpreted this as tiredness.
[l]Would a system where researchers can report any symptoms as soon as they occur would have prevented it from getting worse?
[m]I suppose it depends on whether or not people use the system, how easy it is to use, who they are reporting to – as well as how seriously the person themselves takes their own symptoms.
[n]There are many places the someone can be exposed to allergens and the pattern they describe in the paper is more evident in retrospect than as it occurs. Animal care workers have prospective monitoring for allergies to the mice, etc. they work with, but that doesn’t prevent many from having to retire from this profession due to allergies acquired over time
[o]When I was working at the USDA, I learned of multiple people who developed allergies to moth scales over time due to a protocol in regular use that essentially required them to gently suck moths into the tip of a tube in order to move them. Gross to think about now (I never did this), but it was standard practice for a long time and many still do it this way.
[p]I have seen similar techniques outside of the chemistry lab setting. I haven’t had any lab person defend mouth-pipetting of chemicals to me since about 2005; perhaps it is a past practice, at least in academia? I’d like to think so.
[q]I knew people doing this when I was working there up through 2016!
[r]I’ve never actually seen anyone mouth pipette chemicals, so I believe the campaign against that has been a bit more effective.
[s]So “looking up the SDS” provided no information in this case.
[t]GHS SDSs should include information about sensitization, but I suspect that a chemical supplier wouldn’t add that content to a SDS based on “anecdotal evidence”. I suspect that there would need to be a published peer review study before the information was added to a SDS.
[u]Well – that is my point. We are here working on the cutting edge, but official documentation like SDSs will be necessarily behind. I cringe every time a grad student tells me “well I just looked up the SDSs and carried on” w/o having talked to ANYONE ELSE about their projects.
[v]Toxicology studies will always lag behind the introduction of new reagents. Maybe it would help to have a recognition of what classes of chemicals could be potent sensitizers and apply the precautionary principle to those. Here’s an example: “First, a chemical with dermal sensitization potential has to be able to penetrate into the skin—meaning it must have a low molecular weight, usually less than one kilodalton—and induce or elicit an immune response by being chemically reactive and electrophilic with skin proteins.” (from: https://synergist.aiha.org/201911-dermal-sensitizers) I understand that the above is broad, but it’s a start. Peptide coupling agents certainly fit the bill.
[w]It is interesting that in most cases there was little allergic reaction to HCTU, but much more severe reactions to HATU and HBTU. I wonder if once one is sensitized to the latter there is an allergic reaction to HCTU? This was the case in this study.
[x]It is also so hard to know how many people experienced these symptoms and did not connect them to exposure to these agents – so they have effectively gone unreported.
[y]I think form a chemical standpoint that would make sense. HCTU is essentially HBTU with an added chlorine, so it’s not a stretch to believe that the immune system recognizes both of these reagents in the same manner
[z]Anyone doing work with coupling reactions for peptide. peptide-mimics ought to have training on sensitizers since most of these are amines which cause sensitization
[aa]Who determines this? When I sent this article to our chemical safety specialists, they were surprised to see it! As were the members of the 1 lab I know in our building that works with these.
[ab]Another frustration with “the literature.” Safety information about chemicals doesn’t seem to have a home – it is scattered throughout so many different places that it can be easily missed by the people who need to know the information. Case in point: This case study was published in the Journal of Organic Chemistry!
[ac]These should have been posted in C&EN. That was often done during that time period as a way to alert the general chemical community. Part of the other problem is that many biochemists don’t read ACS publications.
[ag]While it made the rounds at the time, there are plenty of undergrads and grads working in labs who aren’t reading C&EN. C&EN is a pretty specialized resource. When I was working in a molecular genetics lab, I hadn’t even heard of C&EN.
[ah]Is there that much of the sensitizer floating around the building? Why weren’t they working with this in the hood???
[ai]Hoods are not black holes. For example, when it comes to powders they can disrupt use of the material because of the air movement in the work area
[aj]We have seen similar reports in other settings. Usually anecdotal and not as clearly documented as this. Review the literature on “multiple chemical sensitivities”. I frequently have trouble with these reports as the claims seem very wild. However, we know that sub-picomol levels of agents such as we are discussing here can induce an allergic Rx in hyper-sensitive people.
[ak]Taysir shared a comment below on why these are difficult to work with in hoods.
[al]Agree with Ralph. The appropriate engineering control for working with or weighing powders are enclosures with HEPA filtration design for that purpose, not fume hoods.
[am]Like Neal, I remember the emergence of the idea of Multiple Chemical Sensitivies and how much this confused the EHS world. There was a weird mix of science and pseudo-science that we were required to react to in addressing situations both in the lab and outside it
[an]A question this paragraph raises for me as a trainer is whether I should call attention to the chemical properties of the material the way this article does or whether I should alert people to the symptoms that they should be alert to as warning signs. The OSHA lab standard suggests training peiople on “signs and symptoms” rather than focusing on chemcials
[ao]Would it be better to do both? If one knows the symptoms but not the agent, then there could a wide range of things that could lead to these symptoms, even some not in the lab. It seems like there really needs to be causality established.
[ap]I would also think that this would be considered when discussing the design of experiments and lab protocols. You don’t want to wait until someone is having symptoms to do something about it.
[aq]I feel like the safety aspects of the research carried out in the lab doesn’t get discussed enough , even in group meetings. It’s only after something terrible has happened. I’m wondering how this culture can be affected.
[ar]Monica – that is a fundamental point of the increased interest among grad students in safety. As they move on to their careers they will become the safety leaders.
[as]1955 to 2011 – it is pretty wild to see how long it can take for a regularly used chemical to be recognized for the harm it can cause. This is important to keep in mind as we work on the cutting edge of scientific experimentation!
[at]Part of the problem, again, may be in the communication forums used during that time. I wonder if some of the more common social media will make this easier now…
[au]I may not be following the correct social media, I don’t see a lot of lab procedure information there. Where would one look for these stories?
[av]The measures taken are pretty basic – and involve things that are now available in virtually ALL labs. This is another important consideration.
[aw]Is there a process for decontaminating the balance and hoods in place? Can the agents be deactivated by other chemicals?
[ax]I believe bleach will not work with these chemicals, may be cleaning by ethanol is the best solution
[bc]Yup, DEHS at my institution provides that testing
[bd]I suspect that the allergeric reactions could be triggered by skin exposure and other environmental contamination as much as respiratory exposure. The NP95 masks will help by avoiding cross contamination from your hands to your face, which may be helpful
[be]As a result of this paper, I convinced my group to buy a new balance to keep in the hood for weighing out HCTU and to follow the suggested protocol. The issue we ran into is that due to the hood flood it takes a very long time for the balance to tare. Since our peptide synthesizer is cartridge based we have to weigh the coupling reagent individually for each amino acid. As a result, it now takes days instead of hours to finish weighing all the amino acids. Many researchers in our lab have instead elected to wear N95 masks when weighing the coupling reagent instead of using the hood balance
[bf]That is interesting. We didn’t have any hoods in my lab with balances in them, but I have used them in other labs and had no issues with them taring. I’m wondering now what made the difference.
[bg]Probably due to our hoods being ancient to be honest. I am not happy about this solution, but I understand why people go for it
[bh]generally it is difficult to weigh powders inside the chemical fume hood due to air flow, however, crystalline material is ok
[bi]Housekeeping is very important to handle such chemicals in the lab
[bj]It also takes some time and practice to get used to working with powders and crystalline materials that I don’t think most students really get until they are working in a research lab. Working a hood does add to the complexity of this.
[bk]The lab I worked in in the 80’s had ventilation weighing station for working with silca and asbestos dusts. It takes a very careful ventilation design for sensitive balances to be able to operate in a wind current. We also had a special table which was very heavy to provide a steady surface for the balance.
[bl]A weighing enclosure will also work for this purpose
[bm]I agree with Jessica about the practice/ or hands-on on weighing
[bn]We just use a three side piece of acrylic around the scale and have no problems. As an alternative, you could teach people in the lab to weigh out chemicals using analytical subtractive techniques. This is the fastest method by far. (weigh out your vial, add some chemical to the vial in the hood, put the lid on and weigh again, add solvent to desired concentration)
[bo]Was working only with solutions considered? I.e., upon receipt of a new bottle of coupling agent, dissolve it in a solvent to a known concentration, then for each use, volumetrically measure what’s needed and then dilute? Wet methods are excellent for controlling exposures to dusts/particulate. Look at construction sites during large-scale demo…you usually see a big hose running to minimize dust.
[bp]We use a synthesizer often. All chemicals are weighed out and diluted in the hood. The sealed bottles are then transferred to the synthesizer. A tube is then use to carry any escaping vapors back to the fume hood.
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