Chemistry and research with chemicals in university laboratories have been going on for centuries. Discoveries from chemical research carried out in university laboratories have led to revolutionary developments and advances in all aspects of the human condition. However, the key characteristics of colleges and universities, such as their diversity, “horizontal” decision structures, and tradition of faculty autonomy, present unique challenges for attempts to develop an institutional safety culture. This chapter focuses on the identification and explanation of the current status of issues and conditions associated with chemical safety and chemical safety management in today’s academic research laboratories.
The organizational hierarchy and the responsibility for oversight of safety in university research are crucial elements in the development of a robust safety culture. However, determining who holds responsibility, authority, or accountability for the conduct of safe science in academic research institutions is often much more difficult than in non-academic or industrial settings. To ensure consistent, institutional involvement in establishing and maintaining a strong, positive, laboratory safety culture, participation in promoting safety must be encouraged at all levels, including members of senior university administration, provost and college and school deans, research administrators, environmental health and safety (EHS), department chairs, faculty and principal investigators, and lab researchers. Eliminating this current lack of clarity and consistency about
safety roles and responsibilities across the university, particularly among faculty, researchers, and EHS personnel, is critical.
Variability in the regulatory oversight provided by federal agencies or state agencies, including state public universities, can also be a problem. Students and faculty from schools with little oversight are often caught off guard when moving to another institution where significant controls are in place. This issue is often compounded by a lack of standardized training of new faculty and students arriving at new institutions with varied external and internal oversight of safety.
Other challenges contributing to the existing academic laboratory research safety culture are numerous and include not only issues within the organizational hierarchy, but also physical limitations, such as problems with existing laboratory space and constraints on the design and construction of new research facilities. The increasing emphasis on multidisciplinary and interdepartmental research is a factor that needs to be carefully considered. Differing safety expectations in diverse areas of chemical research can be problematic.
A closer examination of the interface between the research laboratory and its direct leadership and support is a necessary step in promoting cultural change within the academic community. This core element of a strong, positive safety culture has not been developed in depth in other reviews; however, an understanding of the specific interactions, needs, and attributes of entities that are in direct contact with the research bench itself—the faculty/principal investigator, lab researchers, and EHS—is critical to development of sustainable change in academic research safety culture.
An optimal laboratory safety environment would ensure that researchers setting foot in an academic laboratory, from inexperienced students to senior principal investigators, understand that they are entering a research environment that requires special precautions. It requires that researchers are aware of the hazards of the materials and processes that they and others in the lab are working with and are prepared to take rapid and appropriate measures to protect themselves and their co-workers, especially in the case of unexpected events. At a minimum, laboratory safety includes (1) awareness of the physical and chemical properties of laboratory reagents being used and of the safety and health hazards they pose; (2) availability and use of the proper apparatus and control infrastructure to carry out procedures safely; (3) knowledge and application of
any additional special practices necessary to reduce risks; (4) familiarity and skill with emergency procedures including the use of safety showers, fire extinguishers, and eye stations; (5) a well-designed and organized workspace that facilitates safe operation, protects workers from hazardous environments, allows unrestricted movement about the laboratory, and allows for the segregation of hazards; and (6) use of proper personal protective equipment. In an ideal safety culture, all laboratory workers, including their leaders up to the highest levels of the organization, will naturally place highest priority on these practices.
The recent incidents have prompted academic faculty, staff, and administrators to ask two critical questions: What will it take for us to educate ourselves and our students about the risks of our work and about the safety practices that allow each individual to make informed and aware decisions when carrying out research? And, if we are unable or unwilling to commit resources and personnel to provide students and researchers with competencies to handle the risks that accompany their work, should we continue laboratory work that involves the use of potentially hazardous chemicals?
Most academic institutions strive to provide researchers with basic safety training and information, through interactions with the laboratory principal investigator, departmental safety coordinator, and/or university EHS staff. However, existing safety training programs often consist of lists of generic rules and regulatory requirements. Such requirements certainly merit discussion, but training that focuses on rules and regulations may promote a culture of compliance in academia, rather than a more desirable culture of safety. Evidence from other domains reviewed in Chapter 2 suggests that an effective way to promote a culture of safety in academic laboratories is to change the current training paradigm to incorporate not only regulatory awareness, but also in-depth work with safety concepts and practices that are central to research in the individual laboratory. Research practices that incorporate explicit analysis of the hazards and risks of planned work into research proposals and publications may promote better laboratory safety by preparing researchers to plan experiments with a critical assessment of and preparation for unexpected and potentially dangerous situations.
Faculty may not realize how little their students may actually know about the risks of a research laboratory and may simply assume adequate prior training. Both entering and experienced students may not know how to appropriately assess the risks of what they are doing, how to appropriately assess changes in risks if a key experimental parameter is changed, or how to keep a small error from getting out of control. Moreover, they may not realize that a process they used in the past without apparent incident was out of the ordinary, unsafe, or dangerous. Students, postdoctoral researchers, and their principal investigators also may not
appreciate how rivalries, time pressures, and the emphasis on productivity can influence judgment and behavior.
Most, if not all, academic institutions that conduct chemical experiments have resources in place that can improve safety awareness and practices, but presentations to the committee suggested that many do not appear to combine them in ways that teach students core practices of chemical safety or that encourage self-aware behaviors in research laboratories. Some current practices may encourage faculty and students to view safety practices as prescriptive, bureaucratic annoyances that comply with requirements imposed by an external authority, rather than as practices that enhance safety and help ensure the progress of research.
There is wide agreement that protecting students and principal investigators is of primary importance and that, at present the academic community lacks a clear, unified vision about what a culture of safety entails. This stands in contrast to the apparent safety cultures that have developed in industrial research, in which everyone, from the CEO to hourly workers, understands and appreciates the relevance of safety to the mission of the company.
There are many different perceptions of the roles and responsibilities of those in the academic community, depending on where a particular person resides in the hierarchy of the institution. Various parties have often reported confusion or lack of information about the specific roles of other “players” and how these roles are interconnected.
College and university organizations vary in many aspects, but most share some common characteristics that affect the focus, attention, and oversight provided for laboratory safety and the factors that contribute to their safety cultures.
Three key characteristics of colleges and universities are their diversity, horizontal decision structures, and tradition of faculty autonomy. Unlike business, medical, government, or military organizations with defined vertical structures, academic institutions are relatively flat organizations. The leader of an academic institution (often called the president or chancellor), the leader of the academic side of the institution (often called the provost), the deans of the colleges, and the chairs of academic departments or divisions may share more job characteristics with mayors or city managers than with business CEOs or chiefs of hospitals. From this perspective, one useful business analogy for the faculty or principal investigator may be the small business owner. Both are responsible for every function of their business and neither answers directly to their boss
about safety. Just as the small business owner cannot leave hiring to a (nonexistent) human resources office or sweeping to the (also nonexistent) after-hours custodial service, the principal investigator cannot leave lab organization and cleanliness to the campus janitorial service or safety to the EHS staff. Just as the mayor or city manager does not order business owners to adopt fixed safety practices, but rather relies on inspections, fines, or (rarely) closures to provide business owners with incentives to maintain safe workplaces, so too do academic institutions rely on EHS surveys to provide the faculty with information, tools, and facilities to guide their safety practices. These academic incentives may need attention and incorporation of better practices to be more effective and to help promote and advance safety culture in laboratory research.
The tradition of faculty autonomy requires special mention. In U.S. academic institutions, individual colleges within a university, departments within a college, and faculty within a department have substantial autonomy over their research directions and practices. Faculty, working as individuals or groups, must seek and obtain a substantial part of the financial resources necessary to conduct research from sponsors outside the institution. A strong, positive safety culture must become an integral feature of this autonomy in academic chemistry laboratories.
As noted above, a college or university site is more like a small city than a business or governmental operation. Most have large, dependent residential young adult populations living on site. Larger university entities sometimes operate their own power, water, and other utility systems. Some run public transportation systems for the campus and surrounding areas, operate their own police and fire response programs, manage large residential and dining complexes, and host and manage many large fine arts and athletic events on site, some attracting over 100,000 people to such events on the campus. In addition, colleges and universities are often visible political targets for local, regional, or even national issues.
Research colleges and universities often have several diverse laboratory teaching and research facilities. Although there has been a recent increase in the construction of newer research buildings throughout the sector, academic research facilities vary significantly in age and design. Older lab research facilities may lack modern engineering controls appropriate for the advanced research taking place in those facilities. The need for renovation and update of facilities and hazard control equipment to current requirements may be overlooked or considered lower priority by institutions and boards focused on new construction. Moreover, the costs for needed renovation and updating may be underestimated. In the
current funding climate, principal investigators are unlikely to be able to fund the necessary safety-required facility upgrades. In some cases, funding agencies do not typically provide funding for safety upgrades to older facilities and do not allow direct grant funding for such expenses.
Newer research facilities may be designed with better engineering controls, but current designs that focus on efficient and flexible use of research spaces may contribute to overall higher risk to laboratory research occupants. For example, modern open-space laboratories that place the researcher desks and computer workspaces in close proximity to the research activity can be problematic because this approach places individual lab members who might be writing immediately adjacent to areas of chemicals use and storage. These unintended consequences of a well-intentioned design may increase risk to individuals within the laboratory. A safer arrangement provides for an office location outside the research activity environment for non-laboratory-based work. A particularly good arrangement separates desk areas from lab benches by impact- and fire-resistant glass, which protects researchers, but lets them monitor ongoing processes.
Within an academic institution, the research programs themselves are equally diverse. Modern chemical-use research ranges from basic science research in chemistry, physics, and biology, to applied research that crosses disciplines of engineering and medical sciences, to emerging sciences that span energy, nanomaterial, synthetic biology, and advanced materials. The diversity and scope of research conducted at academic institutions require a portfolio of approaches to establish and sustain strong safety cultures.
For example, researchers in engineering likely use different materials and processes than those working in medicine, synthetic organic chemistry, materials sciences, or a broad range of other areas. These differences in materials and processes can be accompanied by differences in hazards and risks, in safety training, and in safety culture. On occasion, these differences may hinder safety practices in collaborations. Indeed, different expectations about safety practices may create challenges for interdisciplinary collaborations not unlike those faced in corporate mergers between companies with distinct business cultures.1,2
1 Weber, R. A., and C. F. Camerer. Cultural conflict and merger failure: An experimental approach. Management Science 2003; 49(4): 400-415.
2 Bouwman, C. H. S. The role of corporate culture in mergers & acquisitions. Mergers and Acquisitions: Practices, Performance and Perspectives, E. Perrault, ed. NOVA Science, Hauppauge, NY, 2013.
Differences in research focus, tools, and chemical use are accompanied by a variety of management structures. Individual schools and departments or research centers may vary in organizational structure, based upon and reflective of the types of research conducted. Higher education organizations are often characterized by a flat structure with local authority and accountability, as opposed to the strong vertical hierarchy with strong authority and accountability within the management ladder, which is prevalent in industry and governmental laboratories where research is centrally funded and managed.
Another key characteristic of colleges and universities is the population served by and involved in academic research. Faculty members or principal investigators play a key role in fostering the safety culture and attitudes in laboratories. However, this role is not always emphasized or rewarded within the academic system and is often not modeled during graduate or postgraduate training. Even if such training is available, it is generally not standardized within an individual institution, much less across the research enterprise.
As the leader of the research laboratory, faculty members need to generate the research funding through increasingly competitive grant applications and awards. The faculty member also has to ensure and certify that the grant funding is managed and used properly in the conduct of the research activity and also comply with all the administrative work requirements of the grant agencies and host institution. A 2007 survey completed as part of the Federal Demonstration Project (FDP) Faculty Burden Survey concluded that
[t]he data clearly show that the level of administrative burden is high enough to routinely take our nation’s most qualified scientists away from their research. On average, faculty spent 42 percent of their time ensuring compliance with federal or institutional administrative requirements. Many of the associated processes do not fall within the faculty members’ main areas of expertise, yet they are expected to be experts at managing issues related to affirmative action, accounting, and myriad other tasks. Meanwhile, given that multiple administrative tasks are spread out over each day, faculty members find it increasingly difficult to carve out the blocks of time needed to perform research and write about their results, or collaborate and adequately mentor their research trainees. Each year this problem becomes even more severe. In the FDP report, faculty members observed that the administrative burden has increased in recent years, which is not surprising, given the new regulations related
to homeland security as well as new attention to and requirements for financial accountability.3
The FDP repeated the Faculty Burden Survey in 2012 and found a similar outcome. Funded “researchers still report spending less than 60% of their research time actually engaged in research.” The very nature of academic research—the pursuit of new knowledge—also engenders an entrepreneurial spirit, a part of which can resist central dictates or “one-size-fits-all” mandates.
Research populations in academic research labs involve relatively young individuals with limited experience, which is why such individuals are involved in academic research—to gain research experience. These young learners encompass a wide variety of research positions including research associates, technicians, postdoctoral fellows, graduate and undergraduate students, rotation students, visiting scientists, etc. For many of these individuals, the academic research environment is often their first research “job” in the laboratory, one they enter with little or no independent research experience but with a youthful exuberance. They are concerned about their future and about the impact of their attitudes on their adviser’s opinion of them. With this concern, group members may avoid asking questions or engaging others in discussions about laboratory safety. Because of the nature of academic research laboratories as a training ground for new researchers in academic programs, there is a significant turnover of the laboratory research population. Such a high turnover rate in the core research population can make attempts to sustain a higher-level safety culture especially challenging and difficult.
Graduate students conducting research in U.S. academic research laboratories also increasingly come from diverse cultural backgrounds. In chemistry and engineering disciplines, international graduate and postdoctoral students may comprise 40 to 70 percent of the graduate researcher populations.4 Some international students arrive with limited English skills and safety compliance knowledge, often with attitudes, practices, and values different from those in U.S. laboratories. Visiting scientists from all parts of the world also often carry out research in academic partnerships with U.S. researchers. In addition to different cultural backgrounds, visiting professors also bring their own safety culture and
3 Decker, R. S., L. Wimsatt, A. G. Trice, and J. A. Konstan. A Profile of Federal-Grant Administrative Burden Among Federal Demonstration Partnership Faculty: A Report of the Faculty Standing Committee of the Federal Demonstration Partnership. 2007. Available at http://www.iscintelligence.com/archivos_subidos/usfacultyburden_5.pdf.
4 Faculty Workload Survey (FWS). Preliminary Result Slides. Available at http://sites.nationalacademies.org/PGA/fdp/PGA_055749. Accessed March 12, 2014.
Student Rotations in Academia
In past years, graduate students entering most chemistry departments would participate in office interviews with faculty members during the process of choosing a research laboratory and an initial thesis project. In some departments, these face-to-face meetings were preceded by overview talks given by faculty members to the first-year students as a group. In recent years, this process has changed in a growing number of departments to a “rotation” system whereby each first-year student selects the (usually three) research mentors he or she is interested in working with, and then spends time (anywhere from 3 weeks to 3 months) actually working in each of those laboratories prior to joining one of them as a permanent member. This method of laboratory selection has been driven to a large extent by the fact that NIH training grants now require rotations for the first-year students supported by each grant. The rationale for this requirement may be that a longer-term exposure gives the students, principal investigator, and group members a chance to get to know each other better and thus make a more well-considered decision about which group to join on a permanent basis.
In other parts of this report, we have stated our agreement with departments that require general safety training for all incoming research workers, including first-year students. However, if a department has a rotation requirement for entering students, and these students are expected to carry out experiments during each rotation period, this raises additional safety questions. While there is likely to be overlap between the lab-centric training required to work safely in a particular group, there are also likely to be differences between the labs a particular student rotates through, as well as issues not covered in any general safety training for the entire first-year cohort. Since each student rotates through a different series of laboratories, and each laboratory is likely to encounter several new students doing experiments in their lab space, substantial individualized training is required to operate such a system safely. It is important that departments recognize this challenge and find ways to address it.
practices, for better or for worse, to the group that they are visiting (Box 3-1).
Academic research populations are also characterized by high levels of external and internal stressors. As mentioned above, the degree of intensity and competitiveness of chemistry departments can have a strong effect on a unit’s willingness to embrace a strong positive safety culture. The impact of competition can be amplified by the additional stress created by competing deadlines, funding and publication demands, degree milestones, and personal circumstances. The level of stress faced by principal investigators and researchers can be a serious impediment to the practice of safe discipline in carrying out scientific research and, in some cases, may overwhelm an individual’s capacity to function safely in the
laboratory. In such cases, it may be important for faculty and researchers to make use of campus personnel or mental health resources.
The organizational hierarchy and responsibility for oversight of safety in university research has been identified by other reviews of academic research safety.5,6,7 In general, the descriptions below reflect the organizational structure for management and oversight of safety in academic research.
Responsibility for safety rests with the leadership of the organization. In academia, this leadership is the president or chancellor of the institution,8 with varying input and oversight from a board of regents or board of trustees. Institutional leaders are responsible not only for creating a safe environment, but also for promoting a culture of safety. As noted in the NRC’s Prudent Practices report, “leadership by those in charge ensures that an effective safety program is embraced by all. Even a well-conceived safety program will be treated casually by researchers and others if it is neglected by top management.”9
Common academic administrative structures may dilute the commitment that senior academic leadership makes to laboratory safety. In a common structure, the president or chancellor assigns development and management of safety programs jointly to multiple units, such as schools or colleges, risk management units, and/or EHS units that may have no common reporting line other than the president or chancellor. This can create difficulties in identifying exactly who is vested with the day-to-day management of laboratory safety and hamper clarity about roles, respon-
5 National Research Council. Biosafety in the Laboratory: Prudent Practices for the Handling and Disposal of Infectious Materials. National Academy Press, Washington, DC, 1989.
6 American Chemical Society Committee on Chemical Safety. Creating Safety Cultures in Academic Institutions. American Chemical Society, Washington, DC, 2012.
7 U.S. Chemical Safety and Hazard Investigation Board. Texas Tech University Laboratory Explosion: Case Study. Case No. 2010-05-I-TX. Washington, DC, October 19, 2011.
8 The senior leader at a university can vary depending on the university or university system. For example, the University of California system and University of Texas system use opposite definitions of chancellor and president.
9 National Research Council. Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards, Updated Version. The National Academies Press, Washington, DC, 2011: 2.
sibilities, authorities, and accountability of individuals and organizational units for laboratory safety programs in the institution.
Additionally, the ability of senior university administrative officers to maintain a continued focus on promoting and sustaining a strong, positive safety culture competes with myriad other important issues that institutional leaders must contend with on a daily basis. Rapidly changing priorities and expectations, coupled with the increasing pace of turnover in senior leadership,10 require that leaders in this environment build a management team that shares clear expectations and partnerships across academic and administrative units to foster laboratory safety and an institutional safety culture.
Horizontal academic organizational hierarchies often lead to centralized institutional programs, such as compliance programs and safety programs. This centralization can present a challenge to implementation and management, as these programs rely on flat organizational structures that are also responsible for overseeing other diverse programs and reducing budgets.
At many institutions, a provost (or titular counterpart) is the chief academic officer. This individual reports directly to the president or chancellor and oversees the colleges and schools. She is usually drawn from the academic ranks and increasingly may be hired from another academic institution. She may or may not have experience working in or running an academic research laboratory.
College and school deans are charged with the management of programs for their respective areas. In institutions in which the chemistry department is housed in a multidisciplinary college or school, the dean may be drawn from a discipline quite different from chemistry. As with all senior managers, deans must manage diverse priorities and most must manage with existing limited or diminishing funding. At the same time, deans are often charged with expanding academic programs, and, increasingly, fundraising to support existing and new programs. Reporting to the dean are department chairs, through whom the dean manages the academic programs and processes, including personnel processes such as promotion and tenure, curricular processes, budget and facilities, and any safety and compliance programs housed within the college.
At many institutions, deans and associate deans are unlikely to have detailed knowledge about the research programs in their units or about
10 King, J. American College President 2012. American Council on Education, Washington, DC, 2012.
the facilities and practices needed to conduct specialized laboratory research. They may learn about facilities, infrastructure, and personnel needs primarily as budget requests. They may not have experience working in or running an academic laboratory. Such differences may create challenges as deans seek to identify expectations about laboratory safety in their units.
Deans, along with provosts and faculty governance, often oversee the personnel processes regarding tenure and promotion. College-wide guidelines for tenure and promotion typically describe processes for documentation and evaluation of three areas of faculty performance: teaching, research, and service. It is not clear to what extent, if any, these guidelines incorporate activities in support of laboratory safety, or to what extent such activities are included in materials given to faculty in college-wide “tenure academies” or in guidance for faculty seeking promotion.
Research administration and management in higher education (typically overseen by a vice provost or vice chancellor for research, or comparable title) plays a critical role in supporting and sustaining a safety culture in research. As with senior leadership, safety programs and a strong safety culture compete with many other mandates. Chief among these may be the attraction and maintenance of research funding and creation of facilities for new research opportunities. Research administration offices are often charged with many diverse responsibilities, such as establishing research compliance, various regulatory mandates and programs including conflict of interest, scientific misconduct, export controls, human participants and animal subjects in research, biosafety, responsible conduct of research, and intellectual property rights.11
The contribution of research administration to an institution’s safety culture in academic laboratories is also influenced by a reporting structure that may dilute accountability for safety. In many academic research organizations, the research, development, and compliance programs report to the head of the research organization, while the institutional safety programs, including laboratory safety, report through a different branch of the organization, often through the facilities or financial administration structures. This can lead to a lack of accountability among the safety line management, the facilities management, the academic and research management, and the faculty-led research programs within the laboratories themselves. This bifurcation of organizational reporting can also
11 National Research Council. On Being a Scientist: A Guide to Responsible Conduct in Research. The National Academies Press, Washington, DC, 2009.
affect the promotion and furtherance of a safety culture throughout the whole organization. Organizational structure and reporting of the safety support programs need to be in alignment with academic purposes and objectives to provide the most appropriate organizational alignment for a sustainable laboratory safety culture.
EHS programs are an important component of the management of safety in academic research as well and integral to the promotion of the organizational safety culture. EHS programs in higher education also must manage and address a multitude of safety issues and programs that are endemic to higher education organizations and operations, as described previously in the characteristics of academic research institutions.
The organizational placement of EHS programs within the institution is variable.12 As previously discussed, EHS programs in academia often report through the administrative support structures that include direct reporting to facilities, finance, risk management, or business administration lines. Historically, this reporting structure grew from the initial work by small safety programs to focus on those areas of the operations where injuries were, and remain, most prevalent; in facilities, dining hall, residential, and other manual materials handling operations. In others, safety programs were developed as special technical needs were identified. Programs specifically in support of research safety, such as radiation safety and, more recently, biosafety and biosecurity programs, have grown in response to new regulations and mandates. At times, these special laboratory support programs were initially started within the research administration line. Many institutions have coalesced their specialty technical programs into the existing EHS program structure. A small, but growing group of universities are requiring EHS to report through the senior research management programs, typically at the vice provost/vice president or higher level, which better aligns the EHS programs within the academic management system and may allow better access to overall research management. However, this trend is not widespread, and ensuring appropriate organizational reporting of EHS should be included as part of any review of an organization’s overall safety culture to ensure optimal effectiveness and alignment.13
12 Aon Global Risk Consulting. Safety Management Function – Organization and Responsibilities—An Aon Survey. September 2011. Available at http://www.aon.com/riskservices/thought-leadership/survey_safety-management-report.jsp.
13 American Chemical Society Committee on Chemical Safety. Creating Safety Cultures in Academic Institutions. American Chemical Society, Washington, DC, 2012.
There is often confusion over the role of EHS with respect to academic research laboratories. Expectations of this role appear to vary depending upon the view of different responsible parties, especially among faculty and laboratory researchers. Institutional management expects EHS to provide safety, compliance, and risk management oversight of all campus operations, as well as provide assurance that institutional risk is being appropriately identified and managed. In contrast, some faculty members and EHS staff believe that EHS’s role is primarily to serve as a regulatory entity, acting in place of external agency inspectors (e.g., Occupational Safety and Health Administration [OSHA], Environmental Protection Agency, and related state agencies). Others believe that the primary EHS role is to assist the research practitioners themselves in being compliant with external regulations. Indeed, academic administrators often task EHS with the responsibility of campus-wide compliance with all environmental and occupational health and safety regulations. When EHS personnel are not able to provide expert assistance to researchers regarding a safe procedure involving a specific or technical issue, a lack of respect ensues, and a confrontational relationship can develop.
Given this context, it is perhaps not surprising that faculty, postdocs, and graduate students are often confused as to the role of EHS relative to laboratory safety. For example, from the student perspective, EHS staff may be the ones who talk with students about how chemicals are stored or what types of shoes and goggles are needed. If EHS staff are the only, or the primary, people with direct laboratory contact with the students to talk about safety, a reasonable interpretation is that, “the people responsible for safety are the staff from EHS.” Many EHS programs have professional staff able to consult on laboratory safety, but laboratory researchers should understand that EHS does not necessarily have, and in most cases cannot be expected to have, the same level and depth of focused technical skills needed to address the many diverse technical science research projects that take place concurrently in academic research on a campus. This lack of clarity and understanding of the role and authority of EHS can lead to negative attitudes on the part of faculty, graduate students and postdoctoral fellows, as well as cloud the roles, responsibilities, and accountabilities for safety within the academic research laboratory.
Except for individual research faculty, department chairs in academia are closest in academic hierarchy to the actual conduct of research. It appears, however, that the assigned responsibilities of chairs rarely include an explicit mention of safety culture, and departmental processes and practices may not provide clear guidance about the chair’s
role and/or authority relative to laboratory safety. As with college and upper administration, competing priorities and lack of clarity over roles may reduce the likelihood that chairs assume or accept responsibility for safety.14
Departmental chairs in academia are typically interim appointments. They are generally senior faculty who rotate every 3 to 5 years through the administrative role of departmental chair while maintaining their own academic and research programs and interests or individuals who serve as chair and then move to other academic administrative roles. In some institutions, chairs are elected for specific terms (usually 3 to 5 years) by the faculty. As such, some, perhaps most, department chairs will circle back to being research faculty after their tenure as chair, and this places a high priority on maintaining a conflict-averse relationship with their peers. This can create climates in which chairs exert no clear authority to require, either on their own initiative or in accord with compliance or best-practice mandates from other institutional units, actions by other faculty or department members.
Chairs often oversee personnel processes regarding hiring, tenure, promotion, and faculty salary levels within the department. Position announcements for chemistry faculty describe requirements for evidence of promise in research and teaching, often with specific requirements for area of specialization and funding potential. Position postings may include quite specific expectations about publication and funding history but rarely, if ever, include expectations for safety experience or technical safety proficiency. It is not clear whether faculty interview procedures gather information about candidates’ safety background, viewpoint, or abilities or the extent to which such information is considered in hiring decisions. When faculty members arrive in the department, practices associated with rearranging laboratory space and assigning space to the new faculty member vary widely. At some institutions, EHS and other personnel meet with faculty to ensure that the space and facilities are appropriate to the work planned and that the faculty member has the technical expertise to conduct the work and to train others to do so; at others, the new faculty member may only be issued a key and good wishes. A strong safety culture may make limited use of papers and grants as proxies for safety attitudes and actions, but rather be characterized by respectful inquisitiveness, by the chair or other senior faculty and by EHS, about a new faculty colleague’s technical proficiencies and safety practices. Providing effective safety advice at this initial stage of a person’s career has the strongest chance of inculcating strong safety culture in growing research groups.
As is the case for college-wide guidelines discussed above, department-level guidelines for tenure and promotion usually describe processes for documentation and evaluation of three areas of faculty performance: teaching, research, and service. It is not clear to what extent, if any, these guidelines incorporate activities in support of laboratory safety, or to what extent such activities are included in materials given to faculty by departments or by their faculty mentors.
Principal investigators (academic research faculty members) play crucial and primary roles in laboratory safety and in development and maintenance of an effective safety culture within their research groups and within their departments. It is not clear, however, that the scope and importance of the faculty’s roles are recognized and supported by all faculty members, or by their institutions. Academic research laboratories are operated quite independently from researcher to researcher. Principal investigators are expected to raise their own research funding through competitive grant processes, manage and oversee their awarded project grant portfolios, and perform other administrative duties that cannot be delegated to others. They are often not provided with management or mentorship training that is needed for the effective management of people.
Because of the need to regularly pursue grant funding and the administrative details related to managing funding, research faculty have less time to actually be present within their research laboratories on a regular basis. This may mean that they are unable to provide the necessary mentoring and direct management oversight, including safety oversight, to the research being conducted. This necessitates significant delegation from research faculty to postdocs and graduate students for the regular laboratory oversight and management responsibilities, including for safety within the laboratory, often without proper instruction, training, or authority. In some laboratories, the faculty principal investigator may no longer have the technical knowledge to set up or perform some newer procedures—especially if those procedures were developed after she or he completed training or, as often occurs in interdisciplinary research and emerging fields, has come from a different research discipline. In such cases, delegation is accompanied by the need to manage a process in which one is not always the expert.
Specialized safety training, specifically for faculty, is very limited and variable in content. Faculty are sometimes unclear about, or unaware of, the safety hierarchy and their individual responsibilities relative to laboratory safety, pointing to the graduate students, postdoctoral fellows, or
the institutional EHS program as the personnel responsible for safety in their research programs. A university’s expectation of the responsibility of faculty members for safety in their own laboratory research programs is often not made clear. The role that the faculty member has in providing leadership and setting the stage for promoting and advancing the laboratory research safety culture is often absent from many research groups.
Studies of safety cultures in other types of organizations suggest that perceptions about institutional commitment to safety play a significant role in faculty actions. For example, if the faculty perceive that colleagues do not discuss safety with their students or support consequences in the event of unsafe actions, they are less likely to engage in such discussions themselves. If they perceive that chairs, deans, or other university administrators will not cover the costs of mandated or recommended facility safety or environmental activities, requiring instead that funds come from direct grant dollars, which are not allowable under many awards, they may disregard the same administrators’ safety exhortations. If faculty perceive that deans, chairs, and colleagues value grant income above all else when deciding raises, tenure and promotion, and award nominations, they will set their own priorities accordingly. Processes for annual faculty evaluations and tenure and promotion decisions provide perhaps the most visible criteria that faculty can use to judge their own efforts, and it appears that few faculty evaluation processes include opportunities and requirements for faculty to document their work to establish a robust safety culture in their laboratories.
Academic research program staff typically includes the following categories of personnel: research associates, postdoctoral fellows, doctoral students, master’s students, undergraduate students, and from time to time, high school students and visiting scientists working on collaborative research. The majority of researchers in academic research laboratories are graduate students working in their first full-time research laboratory (perhaps after a modest amount of undergraduate research), along with postdoctoral fellows conducting independent research under the general direction of the faculty member with whom they are associated.
Several characteristics of these researchers may be critical to identifying the current level of safety culture in academic laboratories and to designing strategies to strengthen safety culture. First, most academic researchers are trainees. They are not permanent, long-term members of the laboratory, and their numbers and experience vary from person to person and fluctuate over time within a lab. They are at different stages of their educational and research training and may have different forms
of financial support, or may even be paying for their graduate training. In a single laboratory, different trainees may work on quite different projects. They may have research deadlines that conflict with deadlines for academic courses or exams. They are often young, may or may not have support systems outside the laboratory, and are often encountering the complexities and pressures of academic research for the first time.
Entering laboratory research trainees differ in their experiences and expectations about laboratory work and in their knowledge about what it takes to conduct such work safely. Their college, or even pre-college, experiences may affect their expectations. In some school districts, hands-on high school laboratories, particularly in non-AP courses, have been replaced by demonstrations or online activities. Whether the changes in educational technology result from financial or personnel challenges, the disappearance of hands-on laboratories in science, technology, engineering, and mathematics disciplines has an influence on student skills and expectations. Students may arrive at their undergraduate chemistry labs with no experience in the special requirements of laboratory work and they may arrive with little awareness of the integral and important position of safety in laboratory research. Lack of awareness about safety and risk may also arise as an unintended consequence of changes in undergraduate chemistry laboratories. At some institutions, the undergraduate laboratories have been revised to focus on simplified, minimal-risk microscale experiments, limiting the numbers, types, concentrations, and amounts of chemicals used, the complexity of apparatus, and the variety of reactions. Such changes, pursued with valuable goals such as decreasing chemical waste, minimizing environmental impact, and reducing danger in laboratories containing large groups of beginning students, may decrease trainees’ awareness, experimental experience (especially with larger-scale reactions), and understanding of and attention to questions of risk assessment and safety—and challenge faculty as they work to establish their research lab’s safety culture.
Studies of safety cultures in other types of organizations suggest that perceptions about laboratory life might play a large role in trainees’ actions. Trainees’ perceptions of reward structures and expectations may contribute to a view that “time spent on safety is time not spent on my dissertation research.” The committee heard experienced postdoctoral researchers and graduate students indicate that they feel disconnected from safety in their own laboratory. Although they may take online safety training, complete safety training quizzes, and so forth, safety practices are not consistent within or across research laboratories in a division, department, or institution. Moreover, trainees indicate that they do not feel empowered to address their concerns with others within the lab or with the faculty adviser. They also do not believe that they can move
forward to effect positive safety changes without negative or punitive consequences to themselves. Students can feel uncomfortable confronting labmates and can feel that they do not have the power or authority to effect any changes without adverse negative consequences. Students also reported that the attitudes of principal investigators vary substantially among laboratories, and that this can affect how students approach safety in their own research. In addition, some have encountered students who do not follow the rules no matter how good the leader, and who may do so without consequences from their adviser or other leaders in the laboratory. These experiences lead to diminished value toward safety by the trainee.
In many laboratories, it is not clear whether hazard analyses of experimental procedures are being undertaken in any standardized form. Principal investigators focus on the science and research to be conducted, but it appears that not all investigators model or put priority on the need for a formalized identification of hazards inherent in materials and processes, or emphasize the need for a systematic and recorded risk assessment and safety plan (Figure 3-1). There appears to be a need for a more formalized approach to inclusion of hazard analysis, risk assessment, and safety as an integral part of the academic research process.
Additionally, it appears that for many laboratory researchers, formal safety education begins and ends with generic, and often online, safety training. While online materials or face-to-face lectures, and their associated assessments, can be effective ways to impart basic information about regulatory requirements and safe practices for laboratory work, they cannot substitute for engaging in the actions themselves. It appears that many current assessments of what researchers learn in safety training consists of written or online tests, rather than actions in a scenario in which the EHS professional and principal investigator set up a mock situation and say, “put these chemicals in storage,” “clean up the spill,” “is this apparatus ready to go?”
As stated in On Being a Scientist, “all researchers have had advisors; many are fortunate to have acquired mentors as well. An advisor oversees the conduct of research, offering guidance and advice on matters connected to research. A mentor—who may also be an advisor—takes a personal as well as a professional interest in the development of a researcher.”15 Appropriate mentoring by faculty, including a focus on safety in the conduct of science research, is a critical and primary element of promoting a safety culture in academic research.
15 National Research Council. On Being a Scientist: A Guide to Responsible Conduct in Research. The National Academies Press, Washington, DC, 2009.
FIGURE 3-1 Complexities of student perceptions of where lab safety ranks. http://www.phdcomics.com/comics/archive.php?comicid=1613. Accessed November 6, 2013. Used with permission from “Piled Higher and Deeper” by Jorge Cham www.phdcomics.com.
There are numerous units that regularly inspect, evaluate, and advise on academic and management programs. Externally, these include regulatory programs such as federal or state OSHAs, granting agencies such as the National Science Foundation and the National Institutes of Health, and accreditation programs such as Association for Assessment and Accreditation for Laboratory Animal Care, that certify programs for adherence to professional standard of practice norms. Other accreditation bodies, such as the Association for the Accreditation of Human Research Protection Programs (AAHRPP), may also be used as an example.
Regulatory agencies vary from state to state in terms of what is expected and enforced. However, there are differences in whether regulatory agencies are effective or even have jurisdiction over some academic centers, depending on the type and location of the university or college. In some instances, federal agencies do not provide regulatory oversight for state agencies, including state public universities, while in others, such oversight by state and/or federal agencies is common. Students and faculty from schools with little oversight can be caught unaware when moving to another institution where such external oversight and internal controls are in place.
Most granting agencies do require that institutions receiving funding provide evidence of an active safety program, but do not require detailed
information about the potential risks to researchers or safety of the specific proposed research as part of the individual grant application process. These agencies also do not necessarily provide oversight of laboratory chemical safety for grantees.
Professional associations such as the American Chemical Society (ACS) have been and are continuing to develop programs directed toward laboratory chemical safety. Still, the challenge is how to get this information disseminated to the appropriate parties and how to get people to use this information more effectively. These same ACS safety programs and guidelines have yet to be included in academic accreditation programs and thus are often not included in the academic training and instruction programs of the accredited institutions.
There are many accreditation programs for teaching and for research management, but these programs do not typically touch on issues of overall safety culture development in laboratories. By emphasizing a robust laboratory safety culture as critical for accreditation, the programs could provide additional support and incentive for enhancing and advancing safety culture at academic institutions.
Role of Funding Agencies
To date, funding agencies have relied on the institutions receiving grants to provide oversight. Those reviewing the scientific value of the proposed grant might be in a position to evaluate whether significant safety risks exist in conducting such research. Such review, however, does not currently include an assessment of whether the proposed grantee has the requisite knowledge of or understands the risks inherent in the proposed research. Identification or acknowledgment of the risk of such research is not typically part of either the grant proposal or the fund source evaluation process.
Some funding agencies may limit the use of direct grant funds and do not allow use of such funds for management of the safety risks of the proposed research. This is different for each granting agency and a policy that grant agencies should review and perhaps adjust to ensure better management within the laboratory of major grantees.
Role of Professional Associations and Publications
Graduate students, postdocs, and faculty should be more involved in setting safety rules and guidelines. EHS also plays a role, but one that may be more appropriate as advisory, as the primary responsibility for safety is with the researcher and faculty member. Principal investigators and researchers get their technical information primarily from peer-reviewed
journals and other scientific association interactions. Journals and associations currently do not necessarily integrate science with the safety practices involved in the conduct of science to any great extent. When research is reported, there is seldom any remark about the safety precautions involved in carrying out the research activity that led to the desired outcome of good scientific data. There is a need for better integration of laboratory safety in the conduct of science, and journals and associations can play more of a role with such linkage of higher-risk research.
There are also a variety of internal institutional groups that provide review and audit research-related programs. Most relevant to the advancement of safety culture are the programs and oversight provided by the institution’s EHS program.
However, EHS is not the only institutional oversight and auditing program available to review laboratory research. An organization’s internal audit program periodically conducts management audits of various academic programs, primarily focused on financial and management systems auditing for compliance with myriad external requirements in those arenas. Internal audits seldom review management systems for the school or college’s laboratory safety programs. However, some institutions have begun to include school and department management systems for safety and safety culture within the internal audit purview and review process. Some institutions have incorporated safety culture language into job descriptions and performance evaluations for all employees. These internal organizational approaches help to promote safety culture as a priority and serve as additional means to identify and support an awareness of safety as a core value for the institution, a key element for a strong safety culture.
Most universities carry out periodic audits of their various units, both academic and non-academic. A review typically involves the appointment of an external review committee composed of well-established and active research and teaching practitioners in the department’s discipline from other universities, and sometimes includes individuals from nonacademic institutions such as corporations. Typically, the department will draft a self-study document with contributions from various individuals, such as faculty, students, and staff. This is followed by an onsite visit by the review committee, during which an overall evaluation of the department’s teaching and research is carried out. It is our perception, based primarily on reviews in which committee members have participated, that these exercises seldom involve analysis of safety culture and practices within the department.
Laboratory space is among the most expensive to construct on a university campus; thus, it is understandable that experimental chemistry units and researchers try to maximize the amount of available hood and bench space. Unfortunately, cost restrictions often result in poor lab design from a safety point of view. For example, issues with desk space located in close proximity to working lab space is of concern for several reasons: First, for researchers to reach their desks, they have to pass through laboratory space requiring personal protective equipment, which is inconvenient at best and hazardous at worst. Second, individuals are concerned about their personal safety while working at their desks, particularly in cases where those desks are located close to another researcher’s experimental work area as incidents occurring within other students’ work areas could affect them. Finally, the lack of designated areas for students to eat, clearly situated away from chemically contaminated areas, is of concern. While National Fire Protection Association standards discourage this practice and sometimes require segmentation between hazardous and non-hazardous activities, the decision to segment is based on relative risk and is often complex. It would be helpful, perhaps, to have a national resource available that could provide reliable assessments, at the design stage, of the safety of new laboratories whose construction universities are considering.
Part of the job of educators is to train their students to do science in the “real world.” That job is made even more difficult if laboratory space is not properly designed to ensure attention to safety. It is not surprising that industry recruiters often express concern at the lack of safety consciousness on the part of many newly minted Ph.D. graduates.
Multidisciplinary and interdepartmental research is a significant area of growth in academic research. While this has led to exceptional advances, there is a risk that the increasingly interdisciplinary nature of research may lead non-chemists to undertake experiments involving chemicals without proper understanding of and training in the hazards involved.
It is not unusual to find projects that involve chemists working together with biochemists, cell biologists, engineers, and materials scientists, among others. Safety practices can vary widely from discipline to discipline. For example, researchers in biologically oriented labora-
tories that utilize chemicals do not always fully recognize the hazards of the materials they are working with. Although much of the discussion thus far has been focused around chemists working in chemistry laboratories, there are chemical hazards found in many other places on university campuses. Universities need to be cognizant that researchers in non-chemistry departments typically have less experience in the use of chemicals than many people working directly in chemistry labs. The lack of cross talk between disciplines concerning safety practices can lead to students undertaking experiments with no conception or little awareness of the risks and hazards involved.
As identified previously, a number of other reviews have focused on the academic research hierarchical systems and provided detailed recommendations for responsible parties outside the lab where the research takes place. These recommendations include a strong commitment from university leadership, including assurance of appropriate support resources, to sustaining a safety culture.
These recommendations are also very much aligned with this report’s identification of the need for strong institutional support throughout the organizational structure and are reinforced in this document. The following list addresses some of the items identified as necessary to ensure a viable research safety culture:
- Demonstration of safety as a core institutional value for the entire institution. This requires more than statements from leadership. It requires concrete demonstrations of how this value is prioritized and implemented throughout the organization.
- Articulation of clear roles, responsibilities, authorities, and accountabilities for those directly involved in research safety within the laboratory, namely the faculty/principal investigator, laboratory researchers, and EHS staff that support lab safety.
- Support for a strong, competent EHS program that is able to provide the technical support expertise necessary to maintain strong safety programs in research.
The existing hierarchical structure creates power differentials, impacts communication, limits upward feedback, and inhibits creativity and change. The current focus is on punitive outcomes or admonitions for focus on areas other than active research. There is a need for more focus
and understanding regarding the elements at the research laboratory interface.
A core element of a successful safety culture rests with the basic working group affected; for academic lab safety culture, this is the bench research group and its direct leadership and support. Understanding the specific interactions, needs, and attributes within entities that are directly in contact with the research bench itself is important.
The Venn diagram in Figure 3-2 illustrates three critical components of safety and safety culture within the research laboratories and the interdependence of these components in developing and advancing safety culture in academic research. What is needed is a better understanding of how these three major players can most effectively work together to advance the safety culture. Identifying the key attributes of advanced safety cultures in academic research labs and how each of the major players supports such advanced cultures will allow individual programs to better assess their existing programs and assign the roles, responsibilities, authorities, and accountabilities for laboratory safety culture advancement in academic research. The bottom line is that good science integrates safety directly within the research process and is valued by all direct and indirect participants.
FIGURE 3-2 Lab safety culture at the bench top: Critical players and roles.
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