4.5 Prior Approval Procedures for "Protocol" Chemicals
(See Section 5.3.2 for definition.)
It is clearly in the best interest of the College to provide wide latitude in the scope of research conducted by its faculty. However, the College's capacity to make the safety-related capital improvements required for some areas of research is limited. For safety reasons, certain hazardous chemicals can not be used within the College's facilities without a thorough and expert assessment of risk, and strict controls on quantities, procedures, and disposition of the waste products. Indeed, the use of some chemicals may be barred completely. Identification of these chemicals, hereafter referred to as "protocol" chemicals, will be aided by the review process described below.
The name is derived from a written, chemical-specific safety protocol that will be required for use of these materials, and that will specify safety procedures that go beyond those in this Chemical Safety and Hygiene Plan. This safety protocol should explain precisely how and where all aspects of a research project involving the protocol chemical will be carried out.
The protocol must provide sufficient information to allow a determination of the degree of hazard involved in the research and the type of containment needed to ensure adequate protection for the laboratory workers, facility and the surrounding environment. This suggests the following format:
An example of a written protocol in this format is reproduced in Appendix C.
The protocol, when completed, should be forwarded to the Safety Coordinator who will distribute it to the members of a protocol review panel. This panel will consist of the faculty members of the Hazardous Materials and Radiation Safety Committees. The review process shall determine the adequacy of the experience and training of personnel; containment facilities and equipment; procedures to minimize exposure; decontamination procedures; waste disposal procedures; and emergency procedures.
The Safety Coordinator shall conduct a safety audit of the proposed facilities and discuss the results with all personnel involved, addressing specific concerns raised by the review panel. The audit will be used by the review panel to determine subsequent approval, disapproval, or request for revisions and resubmission. The review process will normally be completed within two weeks following receipt of a completed protocol procedure.