Chapter 4 - Safety Training Requirements

[Safety training is a fundamental responsibility of all supervisors, including principal investigators, lab directors, class instructors, and shop supervisors for which EH&S continues to provide responsive assistance]

Stanford's policy on training states that all faculty and staff supervisors including those in labs, shops, kitchens, and offices are responsible for training all employees (including permanent, part-time, and temporary) and students under their direction about hazards-- including hazardous substances--in their work areas. This information and training must be provided to employees at the time of their initial assignment to the work area, and to students within a reasonable period after enrollment in a course or lab involving the use of chemicals.

Additional instruction must also be provided whenever a new hazard is introduced in the work area or laboratory. Contact your University Safety Partner, or EH&S, with any questions about your department's safety training procedures that are not answered in this manual or by your building/department safety coordinator.

Supervisors are also responsible for communicating specific information to their staffs and/or students concerning safety procedures to be followed for all routine and non-routine laboratory or maintenance tasks involving hazardous materials. Employees and students are to be informed of any new information concerning potential hazards as it becomes available. If laboratory work involving chemicals is part of an academic course, it is the instructor's responsibility to include safety training on the course's specific chemical hazards as part of the curriculum.

EH&S and the University Safety Partners have adopted the following guidelines (see boxes at right and on the following two pages) delineating safety training responsibilities among EH&S, Schools/Departments, and individual supervisors.

[The three tiers of training at Stanford--a delineation of training responsibilities among key players]

Stanford can be described in terms of three tiers. The intent of this approach is to provide a manageable means for the responsible administrator, principal investigator, laboratory director, or shop supervisor to carry out their obligations under the state and federal Hazard Communication Standards and the University's Hazard Communication Policy and IIPP.

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TIER 1: GENERAL UNIVERSITY ORIENTATION

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Trainees: All new University employees Training provided by: Personnel Services staff This tier includes a statement from the Director of EH&S, a brief message on safety attitude, and a brief message about hazard communication. This information is distributed by the University Personnel Office during the employee orientation workshop and consists of:

* Stanford's health and safety policies and practices

* Employee health and safety rights and responsibilities

* Health and safety services at Stanford

Supervisors and Managers
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Supervisors and managers will receive a 2-hour module on safety in the workplace and their responsibilities during Personnel Service's "Stanford Supervision and You" (SSY) Training Program. This module is also offered through EH&S. Please call 725-1470 for more information.

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TIER 2: SCHOOLS/DEPARTMENTS/OFFICES

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Trainees: All employees and students in labs, shops, kitchens, offices or other workplaces where special hazards may be encountered Training provided by: School/department/building safety representatives and EH&S Tier 2 includes general information applicable to the school, department, building, service shop/kitchen, or office about safety administration, programs, and procedures. Each school, department, building, or service administration should develop a training plan with the guidance of its University Safety Partner and EH&S to address Tiers 2 and 3. Tier 2 may be delivered within the cultural context of the unit (i.e., as part of an existing event). The following topics for Tier 2 should be covered.

School/Department:
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* Health and safety organization within the school/department

* Health and safety program, plans, and procedures within the school/department

* Emergency Response Plan/Evacuation Procedures/Drills

* Basic hazardous materials safety procedures (e.g., asbestos, chemical, biological, radiological, electrical, tools, machinery, confined space, etc.)

* Fire and earthquake safety

* Life Safety Box System and MSDSs

* Accident Reporting

* Safety equipment and supplies

* Local training materials and resources

* Hazard reporting and record-keeping responsibilities

* Student/employee rights and responsibilities

* Supervisory responsibilities

* Other school- or department-specific issues, requirements

Offices
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* Health and safety organization within the office (e.g., people trained in CPR and/or First Aid)

* Emergency response procedures (e.g., in the event of fire or earthquake)

* Office-hazards safety (e.g., lifting, electrical, ergonomics, VDTs, etc.)

* Safe operation of office equipment and machinery

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TIER 3: RESEARCH GROUP/LAB CLASSES/SPECIFIC SHOPS

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Trainees: Laboratory researchers and assistants, lab class students, shop and food service workers, and other employees. Training provided by: Principal investigators, lab directors, shop/kitchen supervisors, class instructors, and administrators

This Tier is where the true intent of the Hazard Communication Standard is addressed: to train individuals on the specific hazards associated with the materials and equipment they use and how to protect themselves.

This Tier consists of information specific to labs, offices, research groups, and shops regarding the special hazards of their work and the specific protocols and procedures to be performed by the individual (see box at right). This Tier should be delivered through a written method established by the school or department. Associated administrative and engineering safety systems and responsibilities within the group should also be discussed. The above should be presented within the cultural context of the research group, lab class, or shop worker group.

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SPECIFIC TRAINING RESPONSIBILITIES OF PI'S,

SUPERVISORS, AND INSTRUCTORS

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* Written statement of commitment from the PI, Supervisor, or Instructor

* Laboratory/shop safety tour

* Fire and electrical safety

* Safety equipment, shower, eyewash, chemical storage, building alarms, exits

* Personal protective equipment

* Literature resources specific to the hazards of the work area

* Supervised instruction on handling of specific hazardous equipment or materials

* Methods for detecting releases of hazardous chemicals in work areas

* Laboratory/shop specific policies and practices:

Safety signing, warning, and labeling systems used in the lab Chemical procurement, containment and storage, and inventorying

Waste labeling, storage, and disposal practices

Safety equipment and supplies purchasing

Pursuing safety inquiries within the group or class

Emergency Response plan within lab

Equipment shutdown procedures

* Effluent management and waste minimization practices

* Consequences of unsafe practice-personal, collegial, institutional

* Safe lifting

* Inspections: external and internal

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DOCUMENTATION

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[Documenting training sessions is required by policy to meet regulatory requirements]

Documentation at all levels of training is critical to maintaining the maximum return on the training investment by providing a legal record that reasonable care has been exercised by the responsible party. EH&S is developing a unified training evaluation and documentation form that can help Schools and departments meet regulatory requirements. Other documentation schemes can be used including meeting minutes, training evaluations, certification sheets, memoranda, and sign-in sheets.

Instruments (e.g., tests, quizzes) to measure learning can be implemented at any level to provide some added assurance that information that has been delivered has also been learned. Compliance with the Hazard Communication Standard will be determined by an OSHA inspector through auditing of records and random interviews with individuals in their work environment whenever OSHA decides to audit the program.

--VIDEOS, PUBLICATIONS, AND EH&S ASSISTANCE

EH&S has a safety video library and a collection of safety publications to assist you and your department in implementing your training programs. EH&S also assists Schools and departments, in collaboration with your University Safety Partner, in providing general laboratory safety training to students, staff, and faculty. Call EH&S' Communications Office (725-1470) with any questions about training or training materials.

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QUESTIONS REGARDING THE HAZARD COMMUNICATION PROGRAM

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Questions and concerns of employees or students about safety in general and the chemical hazard communication program in particular should first be addressed to your principal investigator, supervisor, or building/department safety coordinator (Health and Safety Manager in the School of Medicine). In addition, your School or department's University Safety Partner and EH&S (723-0448) are available as resources. Use them!