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CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Collaborative Collaborative
Laboratory Laboratory
Inspection Inspection
Program at UNC Program at UNC
Chapel Hill-Ten Chapel Hill-Ten
Years LaterYears LaterJonathan Moore, MS, CHP, Associate RSOJonathan Moore, MS, CHP, Associate RSO
Dept. of Environment, Health & SafetyDept. of Environment, Health & Safety
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Presentation OutlinePresentation Outline
Brief Description of CLIPBrief Description of CLIP Key IndicatorsKey Indicators Standards / RegulationsStandards / Regulations Violations / SeverityViolations / Severity Assessment of Inspection ResultsAssessment of Inspection Results Future EHS Inspection IssuesFuture EHS Inspection Issues
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
What is CLIP?What is CLIP?
CCollaborativeollaborative
LLaboratoryaboratory
IInspectionnspection
PProgramrogram
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Strategic Planning Process-1997Strategic Planning Process-1997
Internal/External Customer SurveyInternal/External Customer Survey EHS RetreatsEHS Retreats Quality TeamsQuality Teams Organizational Changes/ProgramsOrganizational Changes/Programs
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Scope of CLIP ProgramScope of CLIP Program
80-90 inspections per month80-90 inspections per month
Comprehensive environment, health and Comprehensive environment, health and safety inspection done on all laboratories safety inspection done on all laboratories annually (462 total laboratories)annually (462 total laboratories)
Every principal investigator is considered to Every principal investigator is considered to have one laboratory, which may consist of have one laboratory, which may consist of several rooms.several rooms.
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Scope of CLIP ProgramScope of CLIP Program
Radiation laboratories (249 as of Radiation laboratories (249 as of June 2007) quarterly or semiannuallyJune 2007) quarterly or semiannually
Focus on radiation safetyFocus on radiation safety
GM and swipe surveys for removableGM and swipe surveys for removablecontaminationcontamination
Annual physical inventory for Annual physical inventory for radioactive materialradioactive material
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
UNC BENCHMARKSUNC BENCHMARKS
19981998 EHS StaffEHS Staff 38 38 Radioactive Materials UsersRadioactive Materials Users 278 278
Biological Safety CabinetsBiological Safety Cabinets 391 391 Research IncomeResearch Income $290M $290M Michael JordanMichael Jordan $100M $100M
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
What is a What is a CLIPper?CLIPper?
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
EHS Safety Officers (CLIPpers)EHS Safety Officers (CLIPpers)
Four from radiation safety sectionFour from radiation safety section
Two from fire safety and emergency response Two from fire safety and emergency response sectionsection
Two from the industrial hygiene and biological Two from the industrial hygiene and biological safety sectionsafety section
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
CLIP Team Leader DutiesCLIP Team Leader Duties
Assign inspectors by rotation. Assign inspectors by rotation. Each lab is inspected by Each lab is inspected by different inspectors.different inspectors.
Prior to inspection, print Prior to inspection, print contamination survey map contamination survey map and pre-inspection checklistand pre-inspection checklist
After inspection, review checklist and principal investigator After inspection, review checklist and principal investigator letter for accuracy, then forward to front officeletter for accuracy, then forward to front office.
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
CLIP Team Leader DutiesCLIP Team Leader Duties Conduct quarterly CLIP meetingsConduct quarterly CLIP meetings
Handle comments and questionsHandle comments and questions
Track inspection report responses, if requiredTrack inspection report responses, if required
Review written responses for adequacyReview written responses for adequacy
If a required response is not received, suspend privileges If a required response is not received, suspend privileges for ordering radioactive materialsfor ordering radioactive materials
Update survey contamination mapsUpdate survey contamination maps
Close inspection in HASMIS when responses are adequateClose inspection in HASMIS when responses are adequate
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Inspector Cross TrainingInspector Cross Training
All inspectors are required to learn all aspects of the comprehensive EHS inspection through:
Reading policies and proceduresReading policies and procedures
On-the-job training by shadowing inspections with the CLIP On-the-job training by shadowing inspections with the CLIP Team Leader and at least one safety officer from each EHS Team Leader and at least one safety officer from each EHS disciplinediscipline
Learn to use HASMIS database and how to enter data from Learn to use HASMIS database and how to enter data from written procedureswritten procedures
Attend quarterly CLIP meetingsAttend quarterly CLIP meetings
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Strategic Planning Process After 1997Strategic Planning Process After 1997 Utilization of the HASMIS database Utilization of the HASMIS database Continuing Quarterly CLIP meetingsContinuing Quarterly CLIP meetings Performance evaluation of Safety Officer –”Tag-a-Performance evaluation of Safety Officer –”Tag-a-
Longs”Longs” Expansion of Biological Safety Lab inspectionsExpansion of Biological Safety Lab inspections
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
UNC BENCHMARKSUNC BENCHMARKS
19981998 20062006 EHS StaffEHS Staff 3838 4242 Radioactive Materials UsersRadioactive Materials Users 278 278 249 249 Biological Safety CabinetsBiological Safety Cabinets 391 391 433 433 Research IncomeResearch Income $290M $290M $593M $593M Michael JordanMichael Jordan $100M $100M $32M $32M
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Standards / Regulations 2007Standards / Regulations 2007Increased focused on the following since 1998Increased focused on the following since 1998
OSHA Bloodborne StandardOSHA Bloodborne Standard
CDC/NIH’s Biosafety in Microbiological and CDC/NIH’s Biosafety in Microbiological and Biomedical Laboratories (4Biomedical Laboratories (4thth Edition) Edition)
New since 1998New since 1998
Export ControlsExport Controls
Enhanced Security Measures for Certain Enhanced Security Measures for Certain Radioactive MaterialsRadioactive Materials
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
UNC LAB ENVIRONMENTUNC LAB ENVIRONMENT
19981998 20062006 Radioactive Materials UsersRadioactive Materials Users 278278 249249 Biological Safety Level 1Biological Safety Level 1 121121 127127 Biological Safety Level 2Biological Safety Level 2 52 52 186186 Biological Safety Level 3Biological Safety Level 3 6 6 13 13 Total # Principal Investigators Total # Principal Investigators 423423 462462 Total # Laboratory WorkersTotal # Laboratory Workers 2, 0772, 077 3,4863,486
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Key IndicatorsKey Indicators RecordsRecords
Personal Protective EquipmentPersonal Protective Equipment
Chemical StorageChemical Storage
Hazardous WasteHazardous Waste
Laboratory FacilitiesLaboratory Facilities
Life / Fire SafetyLife / Fire Safety
General Lab SafetyGeneral Lab Safety
Biological safetyBiological safety
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Laboratory FacilitiesLaboratory Facilities
Chemical HoodsChemical Hoods
Pertinent Information included Pertinent Information included
on pre-inspection info sheeton pre-inspection info sheet
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Fire/Life SafetyFire/Life Safety
Fire Prevention and Fire Prevention and Detection EquipmentDetection Equipment
CLIPpers trained on CLIPpers trained on
annual checks of fire annual checks of fire extinguishersextinguishers
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Biological SafetyBiological Safety Infectious Waste handling/processingInfectious Waste handling/processing Bloodborne Pathogens standard enforcement Bloodborne Pathogens standard enforcement
(training, Hep B vaccination, etc)(training, Hep B vaccination, etc) Recombinant DNA protocol verificationRecombinant DNA protocol verification Sharps precautions/minimizationSharps precautions/minimization Biosafety Level 2 containmentBiosafety Level 2 containment
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Laboratory Safety ViolationsLaboratory Safety ViolationsDe minimisExample: observe lack of personal Example: observe lack of personal protective equipment when it is protective equipment when it is appropriateappropriate
Non-seriousExample: Omitted monthly self-Example: Omitted monthly self-survey for removable contaminationsurvey for removable contamination
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Laboratory Safety ViolationsLaboratory Safety ViolationsSeriousExample: No lid or label on a Example: No lid or label on a hazardous waste containerhazardous waste container
Safety Officers have discretion to judge any violation as serious due to special circumstances.
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Overall CLIP Assessment CriteriaOverall CLIP Assessment CriteriaLab
(Non-Radiation)Lab
With Radiation
Outstanding No violations for two inspections in a row
ExcellentNo violations or1 de minimis violation
No violations or< 5 de minimis violation
Good1 non serious and/or5 or < de minimis
< 5 non serious and/or5 or > de minimis
PoorAny repeat violation and/or5 or > de minimis
Any repeat violation and/or5 or > Non Serious
Unacceptable Any serious violation Loss of radioactive material
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
What has not workedWhat has not worked
Use of tablet PC for data collection during lab Use of tablet PC for data collection during lab inspectionsinspections
Single Assessment of Laboratory SafetySingle Assessment of Laboratory Safety
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Future EHS Inspection IssuesFuture EHS Inspection Issues
Better enforcement of EHS rules in non-Better enforcement of EHS rules in non-radioactive laboratories who do not correct radioactive laboratories who do not correct serious violations or do not respond when serious violations or do not respond when required.required.
CLIPper’s participating in the UNC planned CLIPper’s participating in the UNC planned EPA Self-Audit.EPA Self-Audit.
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
SummarySummary
““Front line” of EHSFront line” of EHS Less distraction in labs by EHSLess distraction in labs by EHS Increase Safety Awareness Increase Safety Awareness All laboratories Inspected at least annuallyAll laboratories Inspected at least annually Optimum Utilization of staffOptimum Utilization of staff
CSHEMA 2007, BOSTON, MA
CLIP AT UNC CHAPEL HILL-TEN YEARS LATER
Questions?Questions?Jonathan Moore
Department of Environment, Health & Safety
University of North Carolina
1120 Estes Drive Extension CB# 1650
Chapel Hill, NC 27517-4440
http://ehs.unc.edu
919-962-5713