Research Safety Updates

Research Safety First Initiative

April 2022

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

New EHS updates to lab, shops and studios inspections

July 2021

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 ehsanswers@umich.edu. 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).