2.0 Responsiblities

MSDSs

2.0 RESPONSIBILITIES

This section describes and assigns those responsibilities that deal directly with laboratories using chemicals and/or biological materials.

2.1 Vice President for Research
The president of the University has delegated administrative responsibility for the chemical, biological, and radiation safety programs to the vice president for research.

2.2 Associate Vice President for Research Administration
The associate vice president for research administration oversees the activities of ORS.

2.3 Office for Research Safety
The director of the Office for Research Safety reports to the associate vice president for research administration. ORS is responsible for developing and coordinating the chemical, biological, and radiation safety programs.

ORS provides information, training, and technical resources to department heads, center directors, and principal investigators to assist them in implementing the chemical and biological safety program.

ORS responsibilities include:

Maintaining the central repository for Material Safety Data Sheets (MSDSs), which are required by the OSHA Laboratory and Hazard Communication Standards
Compiling chemical inventory information and submitting reports to federal, state, and local agencies
Collecting and disposing of waste and surplus chemicals
Advising with respect to the collection and disposal of biological wastes
Surveying laboratory facilities and offering recommendations for improved practice
Maintaining records for laboratory facilities
Coordinating the ISIS and recombinant DNA registration programs
Providing 24-hour emergency response to spills or other accidents and investigating incidents involving hazardous materials
Training and advising University personnel in safe work practices, personal protective clothing and equipment, engineering controls, and regulatory requirements
Conducting or arranging for environmental monitoring
Inspecting laboratory equipment such as chemical fume hoods
Recommending policies and procedures for the safe conduct of work with chemicals and biological material

ORS representatives are authorized to enter University facilities within their jurisdiction at any time to observe working conditions, monitor equipment, and sample for contaminants. The director and the designated chemical hygiene and biohazards safety officers are authorized to close a facility or stop a process or procedure that poses an imminent danger to life or property.

2.4 Chemical and Biological Safety Committee
The Chemical and Biological Safety Committee oversees the chemical and biological safety programs. Members are drawn from both campuses and a variety of disciplines, including chemistry, engineering, and biomedical sciences. They are appointed by the vice president for research.

The committee's responsibilities do not include research involving ionizing and nonionizing radiation or recombinant DNA molecules. Such activities are under the jurisdictions of the Radiation Safety Committee and the Recombinant DNA Safety Committee. Research involving animals is under the jurisdiction of the Animal Care and Use Committee.

The general purposes of the committee are:

To formulate and recommend to the vice president for research policies governing the use of biological agents, chemical carcinogens, and other chemicals in the laboratory
To monitor the compliance of the University with respect to federal, state, and local regulations pertaining to hazardous materials in the laboratory

The Committee has a number of specific responsibilities, including:

Recommending policies and procedures for a chemical and biological safety program, including, but not limited to, educational programs, laboratory inspections, containment requirements, waste disposal programs, and medical surveillance
Reviewing and approving Laboratory Safety Profiles and Incident Reports

2.5 Recombinant DNA Safety Committee
The Recombinant DNA Safety Committee is responsible for safety oversight of recombinant DNA research, review of recombinant DNA registration documents, and laboratory inspections. The committee recommends policies for implementation of the National Institutes of Health Guidelines for Research Involving Recombinant DNA Molecules. Members are appointed by the president of the University.

Investigators shall file registration documents with ORS for all recombinant DNA research projects. Please refer to the Recombinant DNA Safety Program for more information.

2.6 Department Heads, Center Directors, and Other Facility Directors
The term department head will be used in this text to include center directors and other facility directors.

The senior vice president for business and finance and the vice president for research have assigned direct responsibility for compliance with the University's safety and health programs to department heads. This means that the department head shall provide a safe workplace and shall implement the safety and health programs. This includes ensuring that personnel are adequately trained, developing Safety Desk Books, and overseeing the preparation and submission of Laboratory Safety Profiles and annual chemical inventories. Department heads shall cooperate to develop evacuation plans for buildings, appoint building safety committees, and appoint building safety managers and alternates.

The department head shall maintain discipline, enforce rules and regulations, and take prompt, effective corrective action when necessary. The department head shall also provide assistance to ORS staff when situations arise involving investigators and other personnel in the department.

The department head shall be familiar with and understand the federal, state, and local regulations and University policies applicable to the department's work and shall ensure compliance through principal investigators and other supervisory personnel. Regulatory and policy documents are available from ORS.

The department head may delegate safety and health-related responsibilities to principal investigators or other supervisors, but it is the department head's responsibility to see that the requirements are met.

The department head is responsible for ensuring that biological safety cabinets are certified as required by this document and that safety showers and eyewash stations are available in the department and inspected as required. The department head will require the principal investigator to institute medical surveillance programs for personnel with occupational exposure to certain agents (e.g., OSHA carcinogens, human materials).

When a principal investigator vacates a laboratory, the department head (or appointed designate) is responsible for ensuring that the lab is properly cleaned out and prepared for the next occupant. The principal investigator shall report to the department head that all hazardous chemical and biological materials have been removed and work surfaces (lab furniture, refrigerators, freezers, chemical fume hoods, etc.) decontaminated with an appropriate and ORS-approved method. Should a principal investigator abandon surplus chemicals, the department becomes responsible for arranging disposal, both in terms of inventory and funding. The department head shall also be responsible for providing decontamination of the lab if the principal investigator shirks this duty.

2.7 Principal Investigators and Supervisors
The term principal investigator as used in this document shall include laboratory and other supervisors (such as managers or directors of common facilities). A principal investigator is defined as any faculty member who has been granted permission by the Office for Research and Sponsored Programs (ORSP) to serve as a principal investigator on a project or to submit a proposal. All persons granted faculty-level research appointments are eligible to be principal investigators. The vice president for research may authorize others to be principal investigators.

The principal investigator is responsible to the department head for the safe and legal conduct of research under his or her purview. This responsibility shall not be delegated. The principal investigator shall be aware of the physical and health hazards associated with all materials present in the laboratory. In the event of an accident, the principal investigator shall initiate appropriate emergency procedures. Written Incident Reports shall be provided to ORS.

The principal investigator shall prepare a Laboratory Safety Profile within ISIS, make all laboratory personnel aware of the profile, and enforce the safety rules and procedures described therein. See Section 3.0 for information about the Laboratory Safety Profile. The principal investigator shall be familiar with and understand the rules, regulations, and University policies pertaining to the workplace. These encompass but are not limited to the following items: training, record keeping, maintaining and providing easy access to MSDSs, labeling chemicals, labeling and proper disposal of surplus and waste chemicals and biological materials, posting warnings, medical surveillance, inventory reporting, engineering controls, safe work practices, providing personal protective clothing and equipment, and access restrictions.

The Occupational Safety and Health Administration (OSHA) states that it is "clear that it is the employer's responsibility to compel compliance. it is the employer, and not the employee, who controls the conditions of work at a given workplace." According to University interpretation, the principal investigator or lab supervisor is defined as the employer responsible for ensuring adherence to safety regulations and proper use of safety equipment in the lab. The principal investigator shall correct any deficiencies that could lead to health and safety repercussions for lab personnel.

2.8 The Individual
Each individual working in a laboratory or other worksite where hazardous materials are used shall know and comply with the University's safety policies and rules and shall follow both oral and written instructions from the principal investigator or supervisor. The individual shall report to the principal investigator any unsafe conditions and any accident or exposure to chemicals or biological agents. If the individual receives no response or an unsatisfactory response, (s)he shall contact the department head or ORS. The department head or ORS shall ensure confidentiality for the individual reporting a safety concern.

The individual shall know the hazards of the chemical and biological agents in the workplace as well as proper handling and disposal procedures. Training shall be provided or arranged by the principal investigator.

2.9 Laws and Regulations
Numerous laws and regulations govern work with chemicals and biological materials and the responsibilities of employers and employees. A list of the major regulations follows.

FEDERAL LAWS

Occupational Safety and Health Act of 1970 (OSH Act). Contains the general industry regulations.
OSHA Hazard Communication Standard. Governs the use of hazardous chemicals in nonlaboratory locations.
OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard. Governs the use of chemicals in laboratories. In general, the Laboratory Standard adopts the guidelines found in Prudent Practices in the Laboratory, Handling and Disposal of Chemicals (published by the National Research Council) and incorporates some elements of the Hazard Communication Standard.
OSHA Occupational Exposure to Bloodborne Pathogens Standard. Governs workplace exposure to human blood, blood products, and other potentially infectious material in any occupational setting.
National Institutes of Health Guidelines for Research Involving Recombinant DNA Molecules.
EPA Superfund Amendments and Reauthorization Act (SARA), Title III: Emergency Preparedness and Community Right-to-Know Act. Establishes responsibilities for chemical reporting to the community.
Resource Conservation and Recovery Act of 1976. Governs hazardous waste disposal.
Other regulations of the U.S. Environmental Protection Agency.
Regulations of the U.S. Department of Transportation.
Regulations of the U.S. Department of Agriculture.

STATE LAW

Illinois Toxic Substances Disclosure to Employees Act. A "worker's right-to-know" law.

LOCAL LAWS

City of Evanston Recovery of Hazardous Substance Removal and Abatement Costs Ordinance. Provides for recovery of emergency response costs.
City of Chicago Liability for Fire Suppression and Other Emergency Costs Ordinance. Provides for recovery of emergency response costs.
The Metropolitan Water Reclamation District of Greater Chicago Sewage and Waste Control Ordinance.
The BOCA National Building Code as adopted by the City of Evanston. Requires inventory of and quantity limits on storage of chemicals in renovated and newly constructed spaces.

2.10 Students
Although the OSHA and Illinois laws apply only to employees (including student employees), it is the policy of Northwestern University to ensure that all students who might be exposed to hazardous materials in the course of their activities at the University are also adequately protected and trained. Therefore, Laboratory Safety Profiles shall also be prepared for teaching laboratories. Students shall receive instruction in the appropriate safety precautions for their specific teaching lab and will be expected to follow the given rules, as shall the lab supervisors.

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Last Revision 05/16/2007
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