When it comes to environmental health and safety management systems, larger organizations have a definite advantage in budget and manpower. But sometimes, you need an EHS management system that works on a somewhat smaller scale. Laboratories, for example, might need a “laboratory scaled” system.
The National Research Council (U.S.) Committee on Prudent Practices in the Laboratory publication, “Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards” includes a chapter on environmental management systems for labs that was heavily revised for the most recent (2011) edition. According to the Council, the most common problem with laboratory EHS management programs is that they tend to be incomplete—some parts, like risk assessment or policy documents, will be fully developed, while other aspects of the program don’t even exist.
Here’s some guidance from the Council on how to develop a laboratory-scaled EHS management system—whether your lab is large or small.
Create a Policy
The first step to creating a program is to create a policy that defines the roles and expectations of each individual in the lab, including faculty, other employees, and students. Input should be solicited from all laboratory personnel, both so that they will feel some ownership of the program and so that the major concerns of all parties are identified and addressed.
Make sure that your EMS policy covers:
- The prevention of laboratory accidents, occupational exposures, and environmental events
- The inclusion of environmental health and safety in all laboratory discovery and development environments
- Regulatory compliance
- Continuous improvement
Remember, at this point, that a management system should involve management in order to be successful. Make management’s commitment explicit by incorporating a formal statement of intent into the policy.
Plan Your Program
Once your policy is in place—that is, once everyone knows what his or her role is, and once management has expressly committed itself to supporting the program –it’s time to plan. During the planning stage, make sure that you:
- Identify all EHS concerns, including concerns about health effects with long latency periods by conducting a thorough risk assessment.
- Assess your risk and control capacity, including whether additional risk controls may be necessary and how they should be prioritized.
- Identify the legal requirements that apply to your lab, including state and federal environment, health, and safety rules; fire and building codes; and permitting requirements.
- Create an ongoing process for tracking both changes in applicable regulations and in the work done in the laboratory.
- Define the goals and objectives of your program, as well as how they will be measured.
Both your policy and your planning documentation can be incorporated into that laboratory safety bible, your Chemical Hygiene Plan.
Tomorrow we’ll look at strategies for the implementation and ongoing assessment of laboratory EHS management programs.