So, as I've mentioned in the previous post, Occupational Safety and Health (OSHA) can be a useful tool in your toolbox. From my experience, institutions get complacent when it comes to following Standard Operating Procedures (SOPs) and being safe. Generally, doing things the "safe" way adds a minute or two here and there, and that's precious time that labs are not willing to give up, even if it potentially means saving a life. However, there are a couple of things that need to be done in order to get OSHA's attention. You have to submit a complaint, and you have to provide evidence that supports your complaint. If you're going to be a whistleblower, you can't be the boy who cried "wolf".
So, how do you get this evidence? The easiest way to do this is to review your institution's Chemical Hygiene Plan (CHP). Using this as a basis for your checklist, you can then come up with a structured strategy for inspecting your lab spaces and seeing if they are up to snuff with OSHA's safety standards. I am willing to bet you dollars to donuts that your lab has at least a few compliance issues. At the very least, OSHA requires your lab to having guiding documentation, so that the individuals working in the lab know how to conduct lab operations safely and within OSHA compliance.
What does a CHP look like though? Typically, it will stand out on your lab bookshelf as a yellow or red binder, which should clearly state on the front cover "Chemical Hygiene Plan". Additionally, to make this document further accessible to its employees, soft copies should be available on your company's human resources portal. If this is not the case, Environmental Health and Safety is considered a human resources issue. Not having this resource available for employees is a hit in itself, so make sure to take note of that. If for whatever reason, you're not available to find your company's CHP, the leading guidance for the CHP should be the OSHA Laboratory Standard. It is to your benefit to review this official OSHA guidance as soon as possible, if you (like I was) are unaware of its existence. I have provided a link to the OSHA Laboratory Standard below:
Take time to review over this. Take note of everything that is discussed in the guidance --- does anything in your lab or workplace stand out immediately after reading this as being noncompliant? Is your laminar flow hood corroded? Are volatiles being stuffed in the hood carelessly and haphazardly? Take note of these things, and generate a checklist while reading through the material. Print this checklist out and then go through your spaces. Take note of anything that is noncompliant with your checklist. For every hit that you find, take pictures! 1 picture speaks 1000 words, use technology to your advantage!
If your supervisor owns more than one lab or room, you may need to repeat your inspection multiple times, taking note of any and all violations for each room that you inspect. Write the date down, and the room location --- when and where were these mock inspections conducted? Once you complete your inspections, you should be able to revisit those resources I posted in the previous article to submit your formal complaint to OSHA. Provided you do this correctly, you should receive a prompt timely response from your state's regional OSHA office. If anything, you might need to put your pictures into context, and explain the significance of these findings. Why are you showing OSHA these pictures? What is the violation? Is anyone in particular doing these violations? The Five W's are applicable for OSHA complaints as well. Make sure you answer all of the W's. Leave no stone unturned!
In closing, become familiar with your institution's Chemical Hygiene Plan. If your institution either does not have a CHP, or makes it difficult for you to access, refer to The Laboratory Standard. Generate a checklist using either of these two references, and start going through your spaces. If you do not feel comfortable doing this during normal working hours where your lab partners or supervisor may be watching you suspiciously, you might want to stay late one day (if your program is anything like mine, there should be several opportunities to do this), and do your mock inspection then. Take detailed notes, and make sure you answer The Five W's. Then, submit your complaint to OSHA, or your regional office (preferably the latter). With a little luck, you should get OSHA to schedule an inspection for your lab or your entire institution, depending on how serious the violations are.
Good luck, and feel free to ask me any questions if there is anything you don't understand!
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