Compliance with Safety and Security Rules, Programs, and Policies
Establishing rules, programs, and policies for laboratory safety and security is of no value if organizational leaders do not enforce them and if laboratory managers and workers do not follow them. Incentives are needed to ensure that laboratories operate safely and securely and comply with established organization rules, programs, and policies. In its outreach to top institutional leaders, the U.S. Department of State Chemical Security Engagement Program (CSP) should encourage institutions to develop a system of compliance with safety and security rules, programs, and policies. Organizations also need to identify the barriers to chemical laboratory safety and security in their cultures and find ways to overcome them. This chapter recommends a system for addressing the barriers to and fostering compliance with good laboratory safety and security practices.
COMPONENTS OF A GOOD COMPLIANCE SYSTEM
The major components of a compliance system are regular inspections, reporting, incident investigation, follow-up, enforcement, and recognition and reward. The system should emphasize fact finding, not fault finding. That applies to all the safety and security programs and policies described in Chapter 3. Initiation and maintenance of an effective compliance system are important to:
give organization leaders useful information about the effectiveness of safety and security systems and about needs for improvements;
give designated safety and security personnel authority to collect incident reports and report incidents to higher authorities for action;
discern patterns of unsafe behavior and facilities (based on statistics from reports and inspections), find methods to improve safety and security, and initiates new rules and regulations to protect workers and students;
increase awareness of safety issues in the organization so that a culture of improved safety and security is encouraged;
give current information to safety officers so that training of all laboratory workers can be improved and specific guidance can be given to individual workers; and
give information to laboratory leaders so that they can learn how to use, test, and procure appropriate personal protective equipment (PPE) and other types of equipment to improve safety.
There should be a program for regular inspections of all science and engineering, safety and security practices, and facilities. Conducting an inspection is just the first step; issues found should be resolved to achieve a safer and more secure status. Written communication and documentation of inspections and of resolution issues are essential (see Appendix G for sample inspection checklist).
Conducting inspections also gives chemical safety officers (CSOs) opportunities to notice and reward best practices and to communicate them to the larger scientific community. Leaders of the organization may want to authorize CSOs to recommend individuals or groups for special recognition and even material reward.
A process for incident reporting and investigation should be established, with an emphasis on free exchange of information without penalty to the persons who report an incident (see Appendix G for a sample incident report form). The objectives are to maintain a culture in which people feel comfortable in sharing information about problems they have encountered and promote an understanding that laboratory workers’ personal safety is paramount.
Complex hierarchical systems in developing countries sometimes suppress individual responsibility. An organizational support system and a fundamental change in the behavior of individuals are essential to enable effective reporting of accidents, incidents, and lapses. The greatest challenge is to reduce resistance to reporting problems.
Scientific leaders and administrators should regard the reporting sys-
tem as a method of furthering education and training of valuable skilled workers and students, not as a means of justifying punitive actions. That requires a fundamental cultural change in organizations to conduct bold and open discussion among employees, students, and leaders. Credibility is established by actions. If an organization’s leaders use accident or incident reports as the basis of punitive actions against particular employees, the reporting system will never take root and foster the culture of safety.
Building a culture of safety involves not only increasing recognition of specific potential hazards but also helping workers and students to make better, safer choices in their actions. They should have confidence in the fairness and objectivity of their organization’s leaders.
Both positive and negative feedback is necessary to ensure the proper enforcement of safety and security rules and regulations. The reporting system should delineate consequences of not reporting incidents and not complying with safety and security rules. Establishing rewards for individuals and groups that display consistently safe behavior would reinforce the desired behavior. Workers and students should be encouraged to speak up when they witness incidents, lapses in abiding by safety rules, or outright violations. Such laboratory incidents as sink fires, chemical-hood fires, chemical spills, waste disposal accidents, and safety shower activations need to be reported to a CSO and the laboratory supervisor. They should not be considered trivial even if there is no immediate consequence, such as a call to a fire department or a trip to a hospital emergency room.
Laboratory supervisors are responsible for reporting safety incidents in their laboratories. A form should be filled out that indicates clearly the name of the person involved, the name of the department, the date and time of the incident, and details of the factors that contributed to it. Penalties for not reporting should be severe enough to discourage hiding safety incidents.
All security breaches, small or large, need to be reported in writing, to the concerned authorities. That requires an atmosphere of openness and confidence in the rules and in the leaders. Reporting security breaches helps to improve security systems. People who report security breaches immediately should be rewarded.
All personnel should be trained to look out for suspicious activities or persons. They should learn to report such activities in a timely manner. Persons who do so should receive special recognition from organizational leaders.
The laboratory community should be encouraged to report outcomes of inspections. As mentioned earlier, positive recognition of good practices during an inspection constitutes effective encouragement of a culture of safety.
Protection for Those Who Report Incidents
Clearly written rules should be established to protect those who witness and report a safety or security incident or suspicious activity. Most of the time witnesses do not come forward to make a report because they try to avoid conflict with others. The rules of the organization should provide complete protection from retribution and anonymity to witnesses, if required.
Reporting Methods to Consider
The reporting form should be easy and quick to complete (see Appendix G for a sample incident report form). Taking an hour or two to fill in a tedious form may discourage workers and students from using the reporting system. As part of their basic and continuing safety training, all workers and students need instruction on when and how to fill out the form. The designated safety committee for the organization should establish procedures to receive reports and take appropriate action in a timely fashion. Anonymous filing of incident reports should be considered. There should be a secure place, a designated third party, or a Web site for filing reports of incidents, so that people who are reporting questionable safety actions are assured of confidentiality.
The purpose of filing incident forms is not to attribute blame but to make it possible for the CSO, scientific leaders, and administrators to address basic safety problems and to add to or modify the rules for laboratory safety and security.
An investigation should be used to establish the facts of an incident, determine the cause of a problem, and recommend improvements. All incidents should be investigated, but the depth of each investigation is determined by the seriousness of the incident, according to a process established by the safety committee. For example, a minor incident may require only a call or short interview with an individual or group. The findings of all investigations should be in writing.
APPROACHES TO FOSTERING COMPLIANCE
Changing behaviors and fostering a culture of compliance are challenging. Local social and cultural barriers may inhibit a laboratory manager, laboratory personnel, students, and others from complying with the best safety and security practices. This section discusses approaches that can be implemented to change noncompliant behaviors and improve laboratory safety and security. In addition to what is written here, a laboratory manager will need to utilize educational tools to foster compliance. For example, case studies can be developed and used to train laboratory personnel. An example case study “Ensuring the Use of Safety Measures in the Laboratory” is provided in Appendix G.
Setting Organizational Safety Rules, Policies, and Implementation Strategy
Good compliance requires clear rules, policies, and processes that have been agreed on by organizational leaders, safety and security officers, and laboratory managers. It is also critical for compliance and administration that key stakeholders in the organization also agree to a clear, direct strategy for implementing rules. Rules need to be approved by the highest forums, such as a board of governors or trustees, if they are to have legitimacy and be legally binding. Rules need to be printed and circulated as official organizational documents from the office of the chancellor or president.
Dealing with Limited Financial Resources
Maintaining and improving a system require sustained financial support. However, increasing safety does not have to be expensive. Strong leadership can lead to changes in personal behavior that can result in improved chemical safety and security. Changing personal behavior can be an effective and inexpensive way to improve chemical safety and security.
Addressing Climate Control
In some developing countries, heat and humidity are excessive during most of the year and mechanical ventilation and air conditioning are unavailable. Appropriate actions should be taken to keep people comfortable while they comply with safety practices and rules. For example, one university in the Philippines made it possible to work in humid conditions by purchasing antifog chemical splash goggles for laboratory workers.
Providing Training and Education
People require training to become aware of potential hazards. No one should be allowed to work in chemical laboratories without adequate training in laboratory standard operating procedures. Laboratory personnel should be comfortable asking safety and security officers for expert advice on what to do, before they proceed with risky actions. Safety and security officers should have updated and adequate knowledge to guide others. In developing countries, those officers can be sent to civil defense organizations or other public agencies for training. Scientific leaders, safety and security officers, and others in authority need to be careful when writing directions and instructions they distribute. Material that is distributed should be checked for accuracy and thoroughness. Sloppy, offhand, or ill-informed instructions can be harmful.
Encouraging Rest and Well-being
Working while physically or mentally tired is one of the most common causes of laboratory accidents, near-miss incidents, and lapses of security. Workers and students need to look out for each other and encourage ill or exhausted coworkers to leave the laboratory and get rest or sleep so that they will be able to meet the stress and effort of work. The organization should support workers and students in participating in interesting, extracurricular activities on a regular basis to reduce mental stress and achieve a more balanced life. Happy, rested workers make an organization productive and safe.
Enforcing Consequences of Risky Behavior
Rules for safe behavior and penalties for their violation should be widely publicized, in advance, to make everyone aware of them. If people know that negligent or deliberately risky behavior in laboratories or breaches in security will have no consequences, they will have little incentive to change their habits. Consequences of safety or security violations could include publicity of the violations, restrictions on use of laboratory facilities and
equipment, monetary fines, withdrawal of financial support, or job termination. Consequences should be proportional to the severity of the violations. To promote compliance with rules, leaders also need to reward people who have consistently taken safe actions and behaved responsibly. A reward might be monetary or simply favorable recognition.
Relieving Time Pressures and Avoiding Shortcuts
Trying to do laboratory or experimental processes too fast can lead to mistakes and accidents or incidents. Shortcuts in standard operating procedures can compromise safety. Supervisors and laboratory leaders need to be mindful of the time required to complete assigned work and of the risks and consequences that can ensue if they reduce time without adding workers. In designing experiments, supervisors should consult with workers to validate the proper allocation of time required for every step of an experiment. Adequate time is needed to do things the right way. Additional education and training may be required to give people incentives to avoid dangerous shortcuts. Every person in a laboratory should learn about the consequences of shortcuts and be made aware of the penalties for taking them. Coworkers should learn to encourage one another to work safely.
Taking Special Safety Precautions for Women
Women require additional safety measures to protect their reproductive health. For example, certain chemicals are reproductive toxins that women should not handle. Organizational leaders should ensure that female laboratory personnel are provided with the appropriate guidelines, training, and equipment needed for their safety and security.
In addition, cultural or religious traditions could keep men from giving women physical assistance that they need in emergencies. In case of such situations, laboratory safety offices and security offices should hire women.
Accommodating Social, Ethnic, and Religious Differences
Discrimination against groups and against persons of low social status happens globally. Institutions should have clearly defined policies with regard to fair treatment of all workers. Lower-status workers in particular are often involved in cleaning and other potentially hazardous jobs, but have little or no education in chemistry. They should be provided with adequate PPE and training to avoid harm to their health in the line of duty. Scientific leaders and administrators need to become role models for equitable, objective, and humane treatment of all workers and students. In some cases, leaders may be legally obligated to take such measures. Large personal fines
or even prison sentences may be implemented if leaders do not provide a safe and secure working environment for students and staff.
Accommodating Propriety in Dress and Behavior
All laboratory members should be educated about and kept aware of the need to wear proper clothing and protective equipment. They should have ready access to proper clothing for the laboratory such as lab coats and gloves even if they prefer to wear traditional clothing outside. Feelings and traditional standards of propriety may discourage persons, particularly women, who have been splashed with caustic chemicals or other hazardous materials in the laboratory from immediately removing contaminated clothing to reduce chemical burns and from going to and using emergency safety showers properly. It may be necessary for educational institutions to provide laboratory sessions for female students that are separated in time and possibly location from those for male students, or to specially design personal protective clothing and equipment that can accommodate fitting under or over traditional attire.
Confronting Coworkers or Superiors
Laboratory workers may witness safety or security breaches but be fearful of or apprehensive about confronting coworkers and authorities. These are normal feelings and reactions that should be countered by providing anonymity for informants, if possible, by protecting informants and by preventing reprisals.
Proper handling of such a situation depends heavily on having clear, agreed rules and an objective, fair, well-publicized, and understood strategy for investigating incidents and administering the consequences of breaking or disregarding the rules. The messenger should not be blamed but rather thanked for rendering a valuable service. Please refer to earlier section on protection for those who report incidents.
Looking Out for Coworkers
A person’s sense of survival or concern for the well-being of others can be complicated. Specific rules or strong guidance may be needed for training workers on when and how to help others and one’s self in emergencies, and even more importantly, on when to cooperate with others to prevent accidents and emergencies. All laboratory workers and students should also receive adequate education on the importance of both wearing PPE and training in its proper use; these are critical for compliance with laboratory safety rules.