Research Safety Policies and Updates

Incident Review Protocol

The incident review protocol sets expectations for incidents that occur on campus and is intended to be a reference tool for the unit-level safety committees. The protocol covers all types of safety incidents that occur in research areas, but there are additional expectations for issues that reach the threshold of “significant” as defined in the protocol.  

In the event of an incident that reaches this level, it is important to understand everyone’s role and expected communication in advance to minimize additional stress and confusion. The RASC may want to be apprised of the status of the work as well as the actions planned but understands that the unit safety committee also needs time to investigate and meet to discuss the incident.  

Please review the incident protocol, and if you have any questions, please email us at [email protected]. 

In an effort to strengthen research and academic safety across the University of Michigan, beginning this month, laboratory inspection reports generated by the Department of Environment, Health and Safety (EHS) will now identify repeat deficiencies. A “repeat deficiency” is defined as a deficiency that is cited in two consecutive laboratory inspections

As EHS works diligently to enhance a universitywide culture of safety, its team remains committed to correcting identified issues in a timely and sustainable manner. The addition of a “repeat” metric will provide EHS with important insight into whether the corrections made were indeed sustainable.

The expectation for timely correction is currently the same as other deficiencies – 30 days. This data will be reviewed collectively by the Research and Academic Safety Committee to determine next steps, and it will be included as part of the committee dashboard reporting to the respective units.

The EHS team is available to support research staff members so that, together, we can prioritize the elimination of repeat safety deficiencies by identifying issues and implementing strategies to prevent them from recurring.

Please contact your EHS representative if you have any questions or concerns. Thank you for your part in U-M’s effort to ensure safety first, safety every day.

Research and Academic Safety Policy

The Research and Academic Safety Policy sets the expectations that drive the university’s safety culture in academic and research activities on the Ann Arbor campus. The policy is issued by the Department of Environment, Health & Safety in collaboration with the Research and Academic Safety Committee’s Executive Leadership Team: the Provost and Executive Vice President for Academic Affairs, the Executive Vice President and CFO, the Vice President for Research and Innovation and the Executive Vice President for Medical Affairs.

The Department of Environment, Health and Safety (EHS), working closely with the Research and Academic Safety Committee, develops innovative and responsive programs to enhance university safety.

We would like to highlight several new and upcoming changes that are intended to further improve safety performance and strengthen the culture of safety across the research and academic enterprise. Many of these changes were initiated based on feedback from lab directors, unit safety committees, and others:

• Monthly Laboratory Self-Inspections
• New Reporting Option for Facility Issues
• New PPE Risk Assessment to Designate Areas Where PPE is Not Required
• 30 Day Completion Date for Corrected Deficiencies

Laboratory Self-Inspections
In an attempt to reduce burden, EHS has developed a new process for labs to conduct their laboratory self-inspection. Rather than completing a long checklist once a year, EHS has created short monthly checklists significantly reducing the time to complete this task while highlighting lab safety and recognition of potential safety concerns more frequently.

These proactive monthly checks will serve as a non-punitive way for researchers to audit and track specific safety proficiencies in their laboratory, thereby being more aware of factors that compromise safe working conditions. The monthly self-inspections are available in the MISP Portal as a complement to regularly scheduled EHS safety inspections.

Development of a Separate Report for Facility Issues
EHS is developing a new process for the remediation of hazards that are beyond the authority or ability of the lab director to correct (e.g., provision of safety showers, repair of building infrastructure). Once this process is complete, the EHS safety inspector will notify the appropriate group of the facility issue(s).

Each school or unit should designate the individual to be responsible for receiving these reports and ensuring the issue has been corrected and entering the correction in the MISP portal. Training for facility contacts will be provided prior to implementation. Facility issues identified will be included in the report to the lab director as a point of information.

Personal Protective Equipment (PPE) Risk Assessment Template
In response to faculty requests and in keeping with safe lab practices, EHS has recently developed a PPE Risk Assessment template to designate areas within a lab space where PPE is not required. This newly formalized process is best conducted collaboratively with the lab’s EHS research safety specialist.

The process involves briefly documenting the rationale for reduction in the level of PPE keeping in mind that the level of protection chosen should take into account hazards from work being carried out in the vicinity that could affect the worker. Examples where such an assessment may be useful include areas where hazardous materials are not present, areas protected by adequate distance (note – some desk locations are problematic), or areas protected by adequate physical shielding. The Risk Assessment template is available electronically in Section 6 of the EHS Document Binder. These documented assessments also serve as a training tool for the staff.

Change to the Completion Date for Corrected Deficiencies
All deficiencies identified as part of the EHS inspection are important to correct. Work to abate the deficiencies should begin as soon as feasible. Beginning September 1, 2021, items identified during EHS inspections must be corrected within 30 days of receipt of the laboratory inspection report. This is a change from the previously prescribed time of 60 days.

If corrective actions cannot be completed within the 30-day timeframe, labs must indicate the anticipated completion date in MISP. Once the correction is completed, faculty must provide the update through MISP. For instance, if a piece of equipment is identified for repair, the submission of a work order request will qualify as an attempt to correct the deficiency. Labs will also receive notification after the corrective actions have been submitted and the report has been reviewed and closed by EHS staff.

Please contact your EHS representative if you have further questions on any of these topics or email at [email protected]. Thank you for your continued engagement in protecting and preserving a healthy and safe University of Michigan community.

A. RCRS requirement for the U-M research and scholarship community: All persons engaged in research and scholarship, including faculty, postdocs/fellows, students, and staff, shall complete the PEERRS-RCRS online course. This course meets the minimal requirements for all individuals engaged in research and scholarship, including NSF and USDA NIFA RCR requirements for all trainee populations.

PEERRS-RCRS completion certifications are valid for three (3) years from the last completion date.

• Training must be completed by June 30, 2021
• New hires must complete training within 30 days.

B. RCR requirement for NIH-supported trainees, fellows, participants, and scholars: In addition to completing the PEERRS-RCRS online course, those receiving support though applicable NIH training and career development grants (e.g., D, T, F, and K type awards) must participate in an appropriate instructor-led RCR training course/workshop for a minimum of eight (8) contact hours. Training must be completed at least once during each career stage, and no less than once every four years. This instructor-led training must be completed within one (1) year of being awarded or added to an applicable NIH grant. These sessions will continue to be organized and conducted by appropriate schools, colleges, and/or training programs.

C. Rackham Graduate School RCRS requirement for Ph.D. students: The Rackham Graduate School has an academic requirement that all Ph.D. students complete RCRS training before advancing to candidacy. The training must include eight (8) hours of instructor-led contact. These sessions will continue to be organized and conducted by appropriate schools and colleges. The instructor-led RCRS courses that some units have established for training Ph.D. students may also satisfy the NIH RCR training requirement in B (above), if they meet content and format requirements. (https://rackham.umich.edu/academic-policies/section4/#4-2)

To meet the NIH (B) and Rackham (C) requirements, each U-M school/college has developed an RCRS training program for undergraduates, graduate students, and postdoctoral researchers. Contact your school/college(link is external) for information regarding this RCRS training. An individual with a U-M faculty title but receiving support from an applicable NIH grant would still be required to complete RCR training as described in (B).

Chemical Labeling Promotional Toolkit

To support University of Michigan researchers in their efforts to reduce the number of mislabeled or unlabeled chemicals, the Research Academic Safety Committee (RASC) is encouraging all laboratories, studios and shops to set aside time during the month of May to organize and properly label chemicals and other substances being stored in your space.

The beginning of the new summer semester is a great opportunity for laboratories and other research and academic spaces to dedicate time for personnel to take stock of supplies, and to update your chemical inventory.

Any expired or unneeded chemicals, reagents or solvents should be properly disposed of. To request waste pickup or supplies, contact EHS Hazardous Materials Management at (734) 763-4568 or complete an online Waste and Supply Request Form. 

The RASC is committed to supporting a safe work environment for all U-M employees and greatly appreciates the efforts of all our research community members.

Chemical Secondary Labeling Resources

Many university workplaces, including laboratories, shops, and other facilities purchase hazardous chemicals or products in large quantities, concentrates, or for mixing with other chemicals. To use the chemical/product, it may need to be transferred from the original labeled container to a smaller or different “secondary” container (e.g., vials, flasks, bottles) for dilution, mixing, or general use. Secondary containers of chemicals and any in-house dilutions made from stock chemical bottles are required to be labeled with the following information:

• Full chemical name (no abbreviations)
• Concentration (e.g., percent, molarity)
• Hazards, if known or suspected (e.g., “flammable”, “corrosive”, “irritant”)

If you transfer a hazardous chemical into a secondary container, the secondary container must be correctly labeled to ensure workers are readily aware of the contents and understand the hazards. Labels can be handwritten or printed.

Secondary container labels are not required if both of the following apply:

• the reagent, stock solution and chemicals mixed for use are under the direct control of the person who transferred or prepared it; and
• the container will be emptied during that person’s work shift.

EHS has developed templates for labs to make their own customized labels for use on secondary chemical containers. All templates are sized for printing on Avery 5137 2” x 4” label sheets.

• Click here to download a blank PDF template. Print and write on the labels.
• Click here to download a fillable PDF form. This form duplicates the fields across all 10 labels.
• Click here to download a similar word document version. Fill in the fields, or print and write on the blank labels.

EHS has a limited selection of secondary chemical container labels that labs can request. Click here for more details and to place an order. Labels will be delivered via campus mail.

In addition, the GoldFFX Safety Data Sheet program has the capability of creating and printing various size labels for use in the lab.

CSHEMA Lab Safety Awareness Week Resources

Safety is a core institutional value at the University of Michigan that is ingrained in everything we do – from academics to research and creative practice.

Thanks to the tremendous efforts of our research community, the university has made great strides toward improving safety culture in our laboratories, shops and studios.

As faculty, students and staff continue to work together to pursue the impactful research that is a hallmark of our university, Research Safety Week is a time to remind ourselves of the university’s commitment to safety and the resources available through the Research Safety First Initiative led by Environment, Health & Safety (EHS) and the Research and Academic Safety Committee (RASC).

Resources:

• Environment, Health & Safety – Research & Clinical
• Training & Certification
• Lab Safety
• Onboarding & Offboarding Checklists
• Safety Coordinator Checklist

Ways to incorporate safety into everyday processes:

• Collaborate with designated EHS safety consultants to evaluate safety risks and use inspection findings as opportunities to incorporate preventative measures into everyday procedures
• Include the discussion of current safety issues as a permanent agenda item in team and faculty meetings
• Ask for guidance whenever there is uncertainty about a procedure or activity
• Integrate and implement safety-checks into complex procedures and activities
• Understand how to respond in the event of a safety incident
• Openly discuss any near misses or incidents that occur in order to understand root causes and prevent future occurrences
• Lead by example, demonstrating that safety and environmental protection are important facets of all university operations

The dedication of teams across our three campuses is essential to keeping U-M’s research community safe, elevating the university’s reputation as a global leader in research and scholarship.

Working together, we will continue to strengthen U-M’s culture of research safety, ensuring all faculty, staff and trainees work and thrive in a safe environment.

Dear University of Michigan Community,

We are writing to share some important updates about the Research Safety First Initiative. This effort is led by the Department of Environment, Health and Safety (EHS) and the Research and Academic Safety Committee.

The Research and Academic Safety Committee, formerly known as the Laboratory and Research Safety Committee, has recently been renamed to better reflect the wide range of spaces in which research and scholarly activities are conducted on and off-campus. The Research and Academic Safety Committee has oversight responsibility for academic and research activities that involve potentially hazardous materials or equipment, occurring in laboratories, shops, or studios affiliated with the Ann Arbor campus.

Thanks to the ongoing efforts of our research community, the university has made tremendous strides toward improving research safety since the 2015 launch of the safety initiative. U-M researchers have already formed unit-level safety committees, improved PPE adherence, and increased collaborations with EHS representatives. The dedication of teams across our three campuses is essential to keeping you and your colleagues safe and for elevating the university’s reputation as a global leader in research and scholarship.

In the first stage of the Research Safety First Initiative, the Research and Academic Safety Committee and EHS partnered with schools and colleges to establish policies and processes that help unit-level leaders to be more actively involved in ensuring their teams comply with university guidelines and policies. We’ve made great progress in addressing safety concerns during annual safety inspections, and we continue to strive for improvements in day-to-day operations.

In partnership with other campus leaders, we have initiated the next phase of our university-wide safety campaign which will move us toward an inspection-ready safety culture. The Research Safety First Initiative is built on a foundation of cooperation and aligns with process changes that were developed based on feedback from faculty, staff and students. This next phase is designed to make it easier to implement safety programs throughout campus, streamline regulatory oversight, and create programs that reduce burden.

What does a Safety First, Safety Every Day culture look like for U-M researchers?

• Collaborate with designated EHS safety consultants to evaluate safety risks and use inspection findings as opportunities to incorporate preventative measures into everyday procedures
• Ensure everyone in the lab feels encouraged to raise safety concerns without retaliation
• Reinforce that cultivating safe research practices is the responsibility of both mentors and trainees
• Make time to discuss current safety issues as a permanent agenda item in team and faculty meetings
• Commit to working continuously to improve the culture of research safety at U-M

One component of the Research Safety First Initiative is a new unit-level dashboard that provides updates on progress toward an inspection-ready safety culture. The dashboard will help research leaders and their teams track progress toward a safe and inspection-ready culture across the university.

Working together, we will continue to strengthen U-M’s culture of research safety, ensuring all faculty, staff and trainees work and thrive in a safe environment. For additional resources and information about the Research Safety First Initiative, please visit research.umich.edu/research-safety.

Sincerely,

Geoffrey Chatas, Executive Vice President and Chief Financial Officer
Susan M. Collins, Provost and Executive Vice President for Academic Affairs
Rebecca Cunningham, Vice President for Research
Marschall Runge, Executive Vice President for Medical Affairs

The Department of Environment, Health and Safety (EHS), working closely with the Research and Academic Safety Committee, develops innovative and responsive programs to enhance university safety.

We would like to highlight several new and upcoming changes that are intended to further improve safety performance and strengthen the culture of safety across the research and academic enterprise. Many of these changes were initiated based on feedback from lab directors, unit safety committees, and others:

• Monthly Laboratory Self-Inspections
• New Reporting Option for Facility Issues
• New PPE Risk Assessment to Designate Areas Where PPE is Not Required
• 30 Day Completion Date for Corrected Deficiencies

Laboratory Self-Inspections
In an attempt to reduce burden, EHS has developed a new process for labs to conduct their laboratory self-inspection. Rather than completing a long checklist once a year, EHS has created short monthly checklists significantly reducing the time to complete this task while highlighting lab safety and recognition of potential safety concerns more frequently.

These proactive monthly checks will serve as a non-punitive way for researchers to audit and track specific safety proficiencies in their laboratory, thereby being more aware of factors that compromise safe working conditions. The monthly self-inspections are available in the MISP Portal as a complement to regularly scheduled EHS safety inspections.

Development of a Separate Report for Facility Issues
EHS is developing a new process for the remediation of hazards that are beyond the authority or ability of the lab director to correct (e.g., provision of safety showers, repair of building infrastructure). Once this process is complete, the EHS safety inspector will notify the appropriate group of the facility issue(s).

Each school or unit should designate the individual to be responsible for receiving these reports and ensuring the issue has been corrected and entering the correction in the MISP portal. Training for facility contacts will be provided prior to implementation. Facility issues identified will be included in the report to the lab director as a point of information.

Personal Protective Equipment (PPE) Risk Assessment Template
In response to faculty requests and in keeping with safe lab practices, EHS has recently developed a PPE Risk Assessment template to designate areas within a lab space where PPE is not required. This newly formalized process is best conducted collaboratively with the lab’s EHS research safety specialist.

The process involves briefly documenting the rationale for reduction in the level of PPE keeping in mind that the level of protection chosen should take into account hazards from work being carried out in the vicinity that could affect the worker. Examples where such an assessment may be useful include areas where hazardous materials are not present, areas protected by adequate distance (note – some desk locations are problematic), or areas protected by adequate physical shielding. The Risk Assessment template is available electronically in Section 6 of the EHS Document Binder. These documented assessments also serve as a training tool for the staff.

Change to the Completion Date for Corrected Deficiencies
All deficiencies identified as part of the EHS inspection are important to correct. Work to abate the deficiencies should begin as soon as feasible. Beginning September 1, 2021, items identified during EHS inspections must be corrected within 30 days of receipt of the laboratory inspection report. This is a change from the previously prescribed time of 60 days.

If corrective actions cannot be completed within the 30-day timeframe, labs must indicate the anticipated completion date in MISP. Once the correction is completed, faculty must provide the update through MISP. For instance, if a piece of equipment is identified for repair, the submission of a work order request will qualify as an attempt to correct the deficiency. Labs will also receive notification after the corrective actions have been submitted and the report has been reviewed and closed by EHS staff.

Please contact your EHS representative if you have further questions on any of these topics or email at [email protected]. Thank you for your continued engagement in protecting and preserving a healthy and safe University of Michigan community.

A. RCRS requirement for the U-M research and scholarship community: All persons engaged in research and scholarship, including faculty, postdocs/fellows, students, and staff, shall complete the PEERRS-RCRS online course. This course meets the minimal requirements for all individuals engaged in research and scholarship, including NSF and USDA NIFA RCR requirements for all trainee populations.

PEERRS-RCRS completion certifications are valid for three (3) years from the last completion date.

• Training must be completed by June 30, 2021
• New hires must complete training within 30 days.

B. RCR requirement for NIH-supported trainees, fellows, participants, and scholars: In addition to completing the PEERRS-RCRS online course, those receiving support though applicable NIH training and career development grants (e.g., D, T, F, and K type awards) must participate in an appropriate instructor-led RCR training course/workshop for a minimum of eight (8) contact hours. Training must be completed at least once during each career stage, and no less than once every four years. This instructor-led training must be completed within one (1) year of being awarded or added to an applicable NIH grant. These sessions will continue to be organized and conducted by appropriate schools, colleges, and/or training programs.

C. Rackham Graduate School RCRS requirement for Ph.D. students: The Rackham Graduate School has an academic requirement that all Ph.D. students complete RCRS training before advancing to candidacy. The training must include eight (8) hours of instructor-led contact. These sessions will continue to be organized and conducted by appropriate schools and colleges. The instructor-led RCRS courses that some units have established for training Ph.D. students may also satisfy the NIH RCR training requirement in B (above), if they meet content and format requirements. (https://rackham.umich.edu/academic-policies/section4/#4-2)

To meet the NIH (B) and Rackham (C) requirements, each U-M school/college has developed an RCRS training program for undergraduates, graduate students, and postdoctoral researchers. Contact your school/college(link is external) for information regarding this RCRS training. An individual with a U-M faculty title but receiving support from an applicable NIH grant would still be required to complete RCR training as described in (B).