|University of Arkansas at Little Rock|
|Policy Name: Facility Safety Plan|
|Policy Number: 701.14|
|Effective Date: June 14, 2007|
The following policies, procedures, and standard operating procedures (SOPs) are in place to assure safe and compliant research at the University of Arkansas at Little Rock (UALR) and to protect human health and the environment.
Occupational Safety and Health
Occupational safety and health is the responsibility of each employee at the university. In addition, each person of authority at the university is responsible for those employees under his or her supervision. This responsibility begins with the chancellor and flows down to each person within the structure of the university. The personal and collective safety and health of students and employees are of primary importance. Cooperation among the administration, faculty members, staff members, and student body is necessary for the development and preservation of an enviable safety record. Effective standards, as well as proper attitudes, are required for the maintenance of workplace safety.
The Arkansas Department of Labor regulates the university with regard to occupational safety and health: Act 556 of 1991, Public Employees’ Chemical Right to Know. UALR applies the Occupational Safety and Health Administration (OSHA) standards as found in the Code of Federal Regulations (CFR).
The Department of Facilities Management in cooperation with the Environmental Health and Safety Committee develops guidelines to help departments comply with the occupational safety and health standards. This help is meant to provide to all employees at UALR the proper guidelines to prevent workplace accidents. Under all circumstances, employees must be properly trained to perform their required tasks. These guidelines are to be used as building blocks for individual units to properly provide adequate safety and health protection for their workers. Their purpose is to create an overall awareness of the hazards of the job as well as to offer guidelines for safe work practices. Employees should review, be familiar with, and understand the information set forth in the guidelines.
The following responsibilities are assigned to various university administrators, faculty, and staff:
- The Environmental Health and Safety Committee (EHSC) recommends university policy concerning environmental and safety issues.
- The EHSC is responsible for (1) developing and communicating a clear vision for the university’s/college’s safety program, (2) establishing broad safety goals for departments to attain, and (3) evaluating the university’s/college’s progress toward meeting those goals.
- The Department of Facilities Management and EH&S department enforce compliance with federal, state, local, and university policies concerning occupational safety and health. The Department of Facilities Management and EH&S department are responsible for investigating occupational safety and health concerns and providing consultation to departments for compliance with standards and policies. The Department of Facilities Management and EH&S department report environmental and safety concerns to the Environmental Health and Safety Committee, as well as, federal, state, and local public agencies, as required by law.
- The department head or director of each individual department is responsible for the implementation of safe work practices and adherence to occupational safety and health regulations and policies. The department head or director should communicate with the Department of Facilities Management and EH&S Department and report any occupational safety and health problems. Any work related accidents must be reported to Human Resource Services, who in turn, reports them to the Department of Facilities Management and EH&S department. Near-accidents or near-misses should be reported directly to the Department of Facilities Management and EH&S department.
- Each employee is responsible to know, understand, and follow the guidelines and should be continually on guard to prevent unsafe work practices. The employee should report to the department head or director any work related accidents, near-accidents, or occupational safety and health problems that need to be addressed.
Overall, the university has a responsibility to provide a safe workplace for its employees. Workers also have a responsibility to follow safe practices to protect themselves and others working around them. In all types of labor, there is a certain amount of common sense that must be brought to the job by the worker.
The Department of Facilities Management and EH&S department tries to develop rules or guidelines specific for the University of Arkansas at Little Rock. In other cases, when no additional written rules or guidelines exist, the Department of Facilities Management and EH&S department will rely on OSHA Standards as found in 29 CFR 1910, 1926, 1928. In addition, the Department of Facilities Management and EH&S department will use national standards such as those found in the National Institute of Occupational Safety and Health (NIOSH), the American Conference of Governmental Industrial Hygienists (ACGIH), the American National Standards Institute (ANSI), the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE), the American Industrial Hygiene Association, the National Fire Protection Association, and other organizations.
The following University of Arkansas at Little Rock rules or guidelines exist:
- Chemical Hygiene Program
- Fire and Life Safety Policy
- Hazard Communication Program
- Hazardous Waste Management Program
- Hearing Conservation Program
- Good Laboratory Safety Practices
- Procedures for Handling Asbestos
- Radiation Safety Program
- Respirator Program
- Safety with Chemical Carcinogens in Research and Teaching
- Workplace Precautions for Bloodborne Pathogens
The safety measures and procedures provided by the various rules and guidelines are designed to aid in maintaining a safe and healthful work and study environment on the UALR campus. The Department of Facilities Management and EH&S department can provide assistance in the pursuit of that goal.
Central to the management of hazardous chemicals in the research laboratory is the university’s Hazard Communications Program and the Chemical Hygiene Program compliant with CFR 29 1910.1200 and 1910.1450. These are performance based programs which requires:
- The maintenance of MSDS’s throughout the colleges.
- Chemical bottles and containers are appropriately labeled.
- Written Standard Operating Procedures are maintained in each laboratory.
- A Chemical Hygiene Plan is maintained in each department.
These requirements ensure that faculty and staff are aware of the protective measures and procedures in place to protect employees and students from the hazards of working with chemicals, biological material, and animal carcasses.
The university has access to trained personnel to provide fire protection and additional hazardous materials protection via the Little Rock Fire Department. In addition, buildings are protected by smoke detection and fire alarms, fire extinguishers, and in some cases, sprinkler systems. Fire safety training and the use of fire extinguishers training is conducted by the EH&S supervisor and offered to all university personnel.
The Department of Public Safety (DPS) also operates a 911 emergency dispatch station. First response to an accident or injury is normally provided by the EH&S department who have trained and certified first responders. These, and other appropriate staff, have bloodborne pathogen training. Post incident clean up or routine attention to pathogenic waste is managed by Facilities Management custodial staff who maintain a core of specifically trained staff for this purpose.
Environmental concerns are addressed by the Department of Facilities Management and EH&S department which oversees programs required under the Clean Water Act, the Clean Air Act, the Resource Conservation and Recovery Act, the Comprehensive Environmental Response, Compensation, and Liability Act, the Superfund Amendments and Reauthorization Act, and the Toxic Substances Control Act. The departments also maintain the proper permits as may be required under these acts.
Use of Animals in Research
The use of laboratory animals carries with it unique professional, ethical, and moral obligations. UALR is committed to ensuring that all institutional animal use is responsible, judicious, and humane. The UALR animal care and use program is in full compliance with the Animal Welfare Act (and its subsequent amendments) and the Health Research Extension Act of 1985. Standards for housing and care of research animals at UALR meet or exceed these federal laws and guidelines. The UALR Basic Animal Services Unit is accredited by the Association for the Assessment and Accreditation of Laboratory Animal Care, International (AAALAC).
UALR utilizes the United States Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research, and Training Guidelines for appropriate animal use in a research and teaching setting. UALR files an Assurance Statement with the National Institute of Health (NIH) Office of Laboratory Animal Welfare (OLAW) which assures our adherence to quality care and use principles in animal facilitated research and teaching. This document further demonstrates UALR’s commitment to regulatory compliance in its animal care and use program. UALR’s Animal Welfare Assurance Number is A-3313-01. UALR is registered with the United States Department of Agriculture (USDA), Animal & Plant Inspection Service (APHIS) as an approved research facility. UALR’s USDA Certificate Number is 71-R-0012.
Animal care and use is heavily regulated by the federal government, and requires targeted, documented training for personnel involved in those activities. It is the responsibility of the institution and the Institutional Animal Care and Use Committee (IACUC) to ensure adequate training for personnel in topics pertinent to ongoing animal care and use programs. The UALR animal care and use program training and education modules provide a significant part of that material. These training modules are mandatory for anyone working with animals in the research, training, or teaching. The USDA and the NIH’s OLAW have ruled that training be “ongoing.” Consequently, evidence of formal training in pertinent animal care and use will be required at a minimum of every 3 years.
UALR is committed to performing animal facilitated research in a humane and compliant manner. The UALR Institutional Animal Care and Use Committee (IACUC) are empowered by the federal government to “review and if warranted, investigate concerns involving animal care and use resulting from public complaints, or reports of noncompliance from laboratory or research facility employees or personnel.”
Research with Microbiological Agents, Recombinant DNA, or Biological Toxins. University research is permitted using microbiological agents, recombinant DNA, or biological toxins. Guidelines for this research are found in Biosafety in Microbiological and Biomedical Laboratories as published by the Center for Disease Control (CDC)/NIH. All of the research falls under the requirements of Biosafety Level (BSL) 1. There are no research projects which fall under BSL2, BSL3, or BSL 4. The university currently has status with the CDC as having the potential for research using select agents. The CDC routinely inspects the university for compliance with the Public Health Security and Bioterrorism Preparedness Act and the Agricultural Bioterrorism Protection Act.
The EH&S Committee provides a comprehensive and compliant biosafety program for researchers, students, and potential human subjects. The EH&S Committee (EHSC) is mandated by federal laws and regulations, and is responsible for oversight of all activities involving research with microbiological agents, recombinant DNA, or toxins of biological origin.
The university provides adequate training and oversight for researchers who use infectious agents and/or rDNA. The (EHSC) performs the oversight function by reviewing proposed activities, and approving registration documents for using infectious agents and/or DNA. All personnel listed in the EHSC registration document as proposing to work with infectious agents and/or rDNA at UALR must complete the applicable training modules prior to final EHSC approval of the project. The Department of Facilities Management and EH&S department issues a Certificate of Completion of Training, and maintains a permanent record of training in a database. The training is largely based on information found in the Biosafety in Microbiological and Biomedical Laboratories (BMBL), and the NIH Guidelines for Research Involving Recombinant DNA Molecules.
The principle investigator (PI) or laboratory director is responsible for providing technical and agent specific training for all personnel using infectious agents or rDNA in their activity. It is also the responsibility of the PI or laboratory director to ensure that all new collaborators or employees that participate in a project using infectious or recombinant DNA agents, complete the applicable EH&S department training modules. The training is in addition to any agent and/or technique/procedure specific training required from the P.I. or laboratory director.
In addition, UALR’s Department of Public Safety follows procedures/policies set forth in the Emergency Action Plan to reduce a terroristic threat.
The university has committees in place to provide oversight and compliance for:
- The Environmental Health & Safety Committee (EHSC) acts as an umbrella committee to other safety committees to coordinate safety-related activities on campus. The committee serves to promote, create, and maintain a safe and healthful environment by conducting inspections for fire safety, industrial safety, and chemical safety in campus buildings. The committee makes policy as is appropriate. In addition to acting as an umbrella committee, the EHSC’s responsibilities include:
- Insuring that necessary educational programs on AIDS, ARC, and other communicable diseases are implemented, that these programs are up-to-date on current scientific information about the diseases, and that the university guidelines are carefully followed. This committee may recommend changes in the guidelines, policies, or procedures as medical, scientific, or legal changes take place in the future.
- Formulating and implementing university policies regarding the use of biohazardous materials including the practices for constructing and handling of recombinant DNA molecules as well as organisms and viruses containing recombinant DNA molecules, according to the U.S. Department of Health and Human Services. The committee also has the responsibility for oversight into the proposed use of infectious agents.
- Formulating and implementing university policies regarding the use of human subjects in any research project performed by either university employees or students. Responsibilities include reviewing all protocols involving use of human subjects, independent of whether such project is funded, either by an internal or an external sponsor. The committee also serves as the Institutional Review Board established in compliance with federal regulations.
- The Institutional Animal Care and Use Committee formulates policies governing laboratory animal care, advises on animal housing requirements, inspects animal care practices, and reviews all protocols involving the use of animals at the university. The committee also has responsibility for providing assurances to external agencies of compliance with federal regulations.
- The University Radiation Safety Committee formulates university policies and regulations concerning the acquisition, use, and disposal of radioactive materials as in accordance with the Arkansas Department of Health, License # ARK-421-BP-02-10. Responsible for radiation safety aspects of activities conducted under the university’s Radioactive Materials License.
Facility Hazard Mitigation Equipment
Each laboratory is equipped as necessary with fumes hood(s), biological safety cabinets, emergency showers and eye wash stations, fire extinguishers, emergency respirators, autoclaves, flammable storage cabinets, corrosive storage cabinets, gas storage safety cabinet, flammable storage and explosion proof refrigerators/freezers, radiation detectors and chemical detectors, and personal protective equipment including laboratory coats, aprons, eye glasses or goggles, face shield, and chemical resistant gloves. Training for all equipment is the responsibility of the research department with assistance from the Department of Facilities Management and EH&S department.
Hazard analysis is performed on a case by case basis by the researcher. The properties of the materials and reagents to be utilized are reviewed. Accordingly, appropriate local measures and procedures are enacted to minimize risks to safe levels. Investigators are responsible to provide all necessary personal protective equipment.
A current copy of UALR’s State of Arkansas issued license is kept on file with the Dr. Keith Hudson, Director, Graduate Institute of Technology, and is available upon request.
Source: Environmental Health and Safety
Approved By: Environmental Health and Safety Committee, June 14, 2007
Custodian: EHS Committee