4.1 Standard Operating Procedures

The OSHA Laboratory Standard requires that Chemical Hygiene Plans include specific elements and measures to ensure employee protection in the laboratory. One such requirement is Standard Operating Procedures (SOPs) “relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals.”

SOPs can be stand-alone documents or supplemental information included as part of research notebooks, experiment documentation, or research proposals. The requirement for SOPs is to ensure a process is in place to document and addresses relevant health and safety issues as part of every experiment. 

At a minimum, SOPs should include details such as:

• The chemicals involved and their hazards.
• Special hazards and circumstances.
• Use of engineering controls (such as fume hoods).
• Required PPE.
• Spill response measures.
• Waste disposal procedures.
• Decontamination procedures.
• Description of how to perform the experiment or operation.

While the OSHA Laboratory Standard specifies the requirement for SOPs for work involving hazardous chemicals, laboratories should also develop SOPs for use with any piece of equipment or operation that may pose any physical hazards. Examples include:

• Safe use and considerations of LASERSs.
• Use of cryogenic liquids and fill procedures.
• Connecting regulators to gas cylinders and cylinder change outs.
• Use of equipment with high voltage.

Etc…

SOPs do not need to be lengthy dissertations and it is perfectly acceptable to point laboratory personnel to other sources of information. Some examples of what to include as part of SOPs are:

EHS can assist laboratories with developing general and specific SOPs. Due to the variety of research and the large number of laboratories on the Cornell campus, it is the responsibility of each laboratory, department and college to ensure that SOPs are developed and the practices and procedures are adequate to protect lab workers who use hazardous chemicals.

Examples of Standard Operating Procedures and blank SOP templates include:

• How to write an SOP - Sample 1 
• Blank SOP Form - Sample 1 
• Blank SOP Form - Sample 2
• How to Prepare an SOP Form - Sample 2
• Chemical User Authorization Form
• Example of completed SOPs

4.2 Form 10

The Office of Sponsored Programs (OSP) administers awards for sponsored research, instruction, and extension projects at Cornell. The Form 10 is the internal academic approval form for sponsored programs. The form should be completed by the Principal Investigator and submitted with all proposals. Of particular note for laboratory personnel, compliance certifications are required for the following areas:

• Human Subjects
• Animal Use
• Recombinant DNA
• Genetically Modified Organisms
• Radiation
• Biological Agents and Toxins
• Hazardous Materials

As part of the Form 10 process, EHS will be notified upon submittal of the Form 10 to OSP when one or more of the following compliance items have been checked: animals, rDNA, GMOs, radiation, hazardous materials, or biological agents or toxins. Once EHS receives the Form 10, staff members within EHS will contact the Principal Investigator listed to discuss general aspects of the grant proposal and to ensure health and safety aspects have been taken into account. During the review process, EHS staff members will identify any special issues that may need to be addressed to ensure compliance with state or federal regulatory requirements.

More information can be obtained from the Office of Sponsored Programs website – Form 10: Internal Academic Approval of Sponsored Programs.

4.3 Procedural Controls

Procedural controls incorporate best management practices for working in a laboratory. These practices serve not only to protect the health and safety of personnel, but are a common sense way of increasing productivity in a laboratory. Through implementation of good practices, laboratories can expect an increase in the efficient use of valuable lab space, in the reliability of experiments due to less potential contamination, and an increase in the awareness of health and safety issues by laboratory personnel. Following the practices outlined in this Lab Safety Manual should also result in a decrease in the number of accidents, injuries, and spills. This will result in a decrease in the overall liability for the Principal Investigator, laboratory supervisor, and the University. Procedural controls are fundamental to instilling safe work behaviors and helping to create a culture of safety within the laboratory environment.

4.4 Housekeeping

Housekeeping refers to the general condition and appearance of a laboratory and includes:

• Keeping all areas of the lab free of clutter, trash, extraneous equipment, and unused chemical containers. Areas within the lab that should be addressed include benches, hoods, refrigerators, cabinets, chemical storage cabinets, sinks, trash cans, etc.
• Keep all containers of chemicals closed when not in use.
• Cleaning up all chemicals spills immediately, regardless if the chemical is hazardous or not. When cleaning up a chemical spill, look for any splashes that may have resulted on nearby equipment, cabinets, doors, and counter tops. For more information on cleaning up spills, see the Chemical Spill Procedures section.
• Keeping areas around emergency equipment and devices clean and free of clutter. This includes items such as eyewash/emergency showers, electric power panels, fire extinguishers, and spill cleanup supplies.
• Keeping a minimum of three feet of clearance (as required by fire codes) between benches and equipment. Exits must be clear of obstacles and tripping hazards such as bottles, boxes, equipment, electric cords, etc. Combustible materials may not be stored in exits (including corridors and stairways), exit enclosures, boiler rooms, mechanical rooms, or electrical equipment rooms.
• When storing items overhead, keep heavier and bulkier items closer to the floor. New York State (NYS) Building Code prohibits the storage of combustible material (such as paper, boxes, plastics, etc.) within 24" of the ceiling in unsprinklered rooms. In sprinklered rooms, All storage, including both combustible and non-combustible materials, must be kept at least 18” below the level of the sprinkler head deflectors to ensure that fire sprinkler coverage is not impeded.
• Always use a stepladder when reaching for overhead items, do not stand on chairs or countertops. If you do not have a stepladder available, then contact your Building Coordinator.

In summary, good housekeeping has obvious health and safety benefits and can have a positive mental effect on laboratory personnel who work in a clean environment, which can lead to increased productivity. Also keep in mind that during an inspection by a state or federal regulatory agency, the general condition of the laboratory observed in the first few minutes of the inspection (the housekeeping of the lab) can have a significant impact (positive or negative) on the rest of the inspection process.

4.5 Personal Hygiene

Good chemical hygiene practices include the use of personal protective equipment (PPE) and good personal hygiene habits. Although PPE can offer a barrier of protection against chemicals and biological materials, good personal hygiene habits are essential to prevent chemical exposure, even when using PPE.Some general guidelines that should always be followed include:

• Do not eat, drink, chew gum, or apply cosmetics in a lab or other area where chemicals are used.
• Do not store food or drink in refrigerators that are used to store chemicals.
• Do not ever try starting a siphon or pipette by mouth, doing so can result in ingestion of chemicals or inhalation of chemical vapors. Always use a pipette aid or suction bulb to start a siphon.
• Always confine long hair, loose clothing, and jewelry.
• Wear a lab coat when working with hazardous materials.
• Shorts and sandals should not be worn in a lab when anyone is using corrosives or other chemicals that present a skin contact hazard or where the potential for physical hazards such as dropping pieces of equipment or broken glass are present. 
• Remove laboratory coats, gloves, and other PPE immediately when chemical contamination occurs. Failure to do so could result in chemical exposure. 
• After removing contaminated PPE, be sure to wash any affected skin areas with soap and water for at least 15 minutes.
• Always remove lab coats, scrubs, gloves, and other PPE before leaving the lab. Do not wear lab coats, scrubs, or other PPE (especially gloves) in areas outside the lab, particularly not in areas where food and drink are served, or other public areas.
• Always wash hands with soap and water after removing gloves and before leaving the lab or using items such as the phone, turning doorknobs, or using an elevator.
• Always wash lab coats separately from personal clothing. Be sure to identify contaminated lab coats to commercial laundry facilities to help protect their workers by placing the contaminated lab coat in a separate plastic bag and clearly identifying the bag with a note or label indicating the lab coat is contaminated. 
• Smoking is prohibited in all lab areas at Cornell.

4.6 Eating, Drinking, and Applying Cosmetics in the Lab

Chemical and other toxic materials exposure can occur through ingestion of food or drink contaminated with these items. This type of contamination can occur when food or drinks are brought into a lab or when food or drinks are stored in refrigerators, freezers, or cabinets with laboratory materials. When this occurs, it is possible for the food or drink to absorb chemical vapors or other contaminants and thus lead to an exposure when the food or drink is consumed. Eating or drinking in areas exposed to toxic materials is prohibited by the OSHA Sanitation Standard, 29 CFR 1910.141(g)(2).

A similar principle of potential chemical or toxic materials exposure holds true with regard to the application of cosmetics (make-up, hand lotion, etc.) in a laboratory setting. In this instance, the cosmetics have the ability of absorbing chemical vapors, dusts, and mists from the air and when applied to the skin and result in skin exposure.

To prevent exposure to hazardous chemicals or toxic materials through ingestion, do not eat, drink, chew gum, or apply cosmetics in areas where these materials are used.

Wash your hands thoroughly after using any chemicals or other laboratory materials, even if you were wearing gloves, and especially before eating or drinking.

To help promote awareness, refrigerators and freezers should be properly labeled:

• Refrigerators for the storage of food should be labeled, “Food Only, No Chemicals” or “No Chemicals or Samples”. 
• Refrigerators used for the storage of chemicals should be labeled “Chemicals Only, No Food”.

Free refrigerator labels are available from the EHS Signs and Labels webpage.

Keep in mind that some exposures can result in immediate effects (acute exposure) while other effects may not be seen for some time despite repeated exposure (chronic exposure). Consuming food or drink or applying cosmetics in the lab can result in both types of exposure.

4.7 Working Alone

Whenever possible, laboratory personnel should avoid working alone when conducting research, especially when experiments involve hazardous substances and procedures. Laboratories should establish specific guidelines and standard operating procedures specifying when working alone is not allowed and develop notification procedures when working alone occurs. All work to be performed by someone working alone, and the monitoring system that is established, must be approved in advance by the Principal Investigator or laboratory supervisor. Check with your DSR to see if your department has specific requirements for working alone.

If a laboratory person determines it is necessary to work alone, consideration should be given to notifying someone else in the area – in an adjacent room, another lab on the same floor, or a lab on a different floor. It is recommended that a “buddy system” be established for regular, routine checks on personnel working alone, such as every 15 – 30 minutes, to ensure no accidents have occurred. This could be accomplished by physically walking to the room where the lab worker is or through the use of a phone. If the person working alone is doing highly hazardous work, then the person checking on the lab worker should not enter same room. A system of visual checks should be established to indicate there are no problems or to determine if help is needed.

In the event of an emergency that requires the buddy to leave prior to the completion of an experiment involving highly hazardous chemicals, the buddy should notify Cornell Police at 607-255-1111 of the name, location, and end time of the experiment involved. The buddy should also notify the person conducting the experiment. The person conducting the experiment should make an effort to complete the experiment in a safe manner and notify Cornell Police upon completion of the experiment.

Examples of activities where working alone would be permissible include:

• Office work such as writing papers, calculations, computer work, and reading.
• Housekeeping activities such as general cleaning, reorganization of supplies or equipment, etc., as long as no moving of large quantities of chemicals is involved.
• Assembly or modification of laboratory apparatus when no chemical, electrical, or other physical hazards are present.
• Routine lab functions which are part of a standard operating procedure which has been demonstrated to be safe and not involve hazardous materials.

• Examples of activities where working using a “buddy system” should be considered include:

• Experiments involving toxic or otherwise hazardous chemicals, especially poison inhalation hazards.
• Experiments involving high-pressure equipment.
• Experiments involving large quantities of cryogenic materials.
• Experiments involving work with unstable (explosives) materials.
• Experiments involving Class 3b or 4 Lasers.
• Transfer of large quantities of flammable materials, acids, bases, and other hazardous materials.
• Changing out compressed gas cylinders containing hazardous materials.

4.8 Phones in Labs

All labs are strongly recommended to have a means of communication in the event of an emergency. This can include a phone or cell phone (if service is available) or two-way radio within the lab or access to a central phone located in the hallway. If a phone is not available within the lab, it is advisable to post a sign and/or map indicating where the nearest phone is located.

4.9 Unattended Operations

Whenever it is necessary to have unattended operations occurring in a lab, it is important to ensure safeguards are put into place in the event of an emergency. Laboratory personnel are strongly encouraged to adhere to the following guidelines when it is necessary to carry out unattended operations.

For unattended operations involving highly hazardous materials, a light should be left on and an appropriate warning/explanation sign should be placed on the laboratory door, or in a conspicuous place that could be easily seen without putting someone else in danger in the event of an emergency.

The warning sign should list the following information:

• The nature of the experiment in progress.
• The chemicals in use.
• Hazards present (electrical, heat, etc.)
• The name of the person conducting the experiment and a contact number. A secondary name and contact number is also recommended.

When setting up an experiment that will be left unattended, try to take into account potential incidents that could occur if something went wrong. For example:

• Use secondary containment such as trays to contain any spills that may occur.
• Use safety shields and keep the chemical hood sash down low to contain chemicals and glass in case an explosion occurs.
• Remove any chemicals or equipment that are not necessary for the experiment or items that could potentially react with the chemicals or other materials being used in the experiment.
• Whenever possible, use automatic shutoff devices to prevent accidents such as loss of cooling water shutoff, over-temperature shut off, etc.
• Use emergency power outlets for those pieces of equipment that could be negatively affected in the event electric service or other city utilities are interrupted.

4.10 Access to Laboratories

Access to Cornell University laboratories, workshops and other work areas housing hazardous materials or machinery is restricted to Cornell faculty, staff, students, or other persons on official business.

4.11 Chemical Purchasing

Before ordering new chemicals, search your existing inventories and use those chemicals currently in stock. An accurate and up-to-date chemical inventory can help to minimize purchase of chemicals already on hand and can facilitate acquisition of  Safety Data Sheets (SDS). Cornell has an institutional subscription to the Vertere chemical inventory system that can assist with maintaining a chemical inventory. If you are interested in learning more about the Vertere system, contact askEHS@cornell.edu.

If it is necessary to purchase new chemicals, laboratory personnel should order the smallest size necessary to carry out the experiment. Avoid ordering extra quantities because the chemical “might be needed in the future”. Try to take advantage of chemical vendors “Just-In-Time” delivery rather than stockpiling chemicals in your lab. Before ordering chemicals, be sure to check Cornell purchasing guidelines for preferred vendors and pricing.

Some chemical purchases may require special approval or permits, such as the Drug Enforcement Administration (DEA) controlled substances and/or listed chemicals; Alcohol, Tobacco, and Firearms (ATF) listed substances; select agents or particularly hazardous substances. Building and fire codes restrict the amount of hazardous materials that can be stored in any one room, floor, and building at any given time. For more information, contact askEHS@cornell.edu.

4.12 Ordering New Equipment

Whenever large pieces of equipment are planned to be purchased and installed in laboratories, especially equipment that is required to be hooked up to building utility services such as electric, water, or gas, laboratory personnel must first consult with Facilities Engineering, EHS, and the appropriate PDC shops to ensure the building has the necessary resources to support the new piece of equipment. Lab personnel should not assume they can purchase equipment first and then expect the building to be able to handle the service requirements later. By preplanning and communicating well in advance with appropriate campus groups (such as Facilities Engineering and EHS), any potential issues can be identified ahead of time, which in turn will help make the transition to getting new pieces of equipment up and running quickly after the purchase is made.

Additionally, as with installation of fume hoods, certain pieces of equipment require special installation due to their potential impact on the rest of the building ventilation system and utilities, and cannot be hooked up by laboratory personnel, building managers, or private contractors without first consulting with Facilities Engineering and EHS. Laboratory personnel are strongly encouraged to be proactive and to consult with the appropriate departments ahead of time, before purchasing new pieces of large equipment.

Laboratory personnel are strongly encouraged, as responsible campus members, to give consideration to purchasing “Energy Star” energy efficient pieces of equipment to help conserve natural resources and long-term operating costs. When discussing purchases of equipment with vendors and equipment manufacturers, ask about what “Energy Star” alternatives they carry. For more information, see Energy Conservation in Laboratories.

Before ordering new equipment, check the Cornell purchasing guidelines for preferred vendors and pricing.

4.13 Work Orders and Ticket Requests

In the event of a maintenance issue or if repairs are needed to equipment, laboratory personnel should first consult with their Building Coordinator, who will submit the appropriate paperwork with Customer Service to have repairs initiated. Please note that due to NYS building codes and liability issues, laboratory personnel must not try to repair utility services (such as electrical, plumbing, or gas issues) by themselves. These repairs must be handled by qualified personnel only.

Whenever maintenance workers will be working on your hood system or in your laboratory, please remove all chemicals, laboratory apparatus, and equipment from the area requiring maintenance work. Ensure the work area is clean and inform the maintenance workers of any potential hazards present in the near vicinity either verbally or by leaving a sign with the appropriate information.

4.14 Changes in Lab Occupancy

Changes in laboratory occupancies can occur when faculty retire, new faculty come to campus, new lab staff are hired, students graduate or leave for another university, or when facility renovations take place. When changes in lab occupancy occur, it is important to address any potential issues BEFORE the occupants leave.

Failure to address the change in occupancy can result in:

• Old, unlabeled chemicals, samples, or hazardous waste being left behind in refrigerators, freezers, and cabinets.
• Valuable furniture or equipment being moved or thrown away.
• Unknown chemical spills or contamination being present.
• These issues can result in costly remediation efforts and wasted resources for both the department and the University.

If you are planning to leave your laboratory or if you know of a research group or students that are planning to leave, there are a few simple steps that can be followed to ensure a smooth transition:

• Notify your department chairperson, lab supervisor, and DSR well in advance of the planned move.
• Ensure all chemical containers are properly labeled.
• Properly dispose of any hazardous and chemical waste left in the laboratory.
• Ensure all chemical spills and contamination has been cleaned up.
• Review the EHS Lab Move Guide.

4.15 Laboratory Design and Construction

Project Managers planning construction or renovation of a laboratory should include EHS at design scoping phase of the project.

Research Safety lab design elements include:

Americans with Disability Act compliance: This may involve the determination of types and location of fume hoods, safety showers and eyewashes, autoclaves, sinks and other lab equipment.

Chemical inventory: A chemical inventory that includes quantity and intended usage will be expected at Scoping phase of all laboratory projects.

The chemical inventory must also include all cryogenic liquids and compressed gases. A risk assessment must be conducted to determine the need for a gas cabinet, low exhaust diffusers, oxygen monitoring, emergency ventilation shut-off. Specialized storage may be needed for certain chemicals such as acutely toxic, air/water reactive, and controlled substances. Examples include double lock boxes, flammable or explosion proof refrigerators or storage cabinets dedicated to a specific hazard class.

Emergency Showers and Eyewashes: These are required in laboratories that use chemicals that may spill or splash onto anyone working in the lab. Showers are required for volumes greater than a gallon.

Laboratory Ventilation: Air exchange rates are determined by EHS and are based on volatile chemical use, hazardous gas use, and/or biological agents. Other drivers are heat and the exhaust requirements for equipment in the room.

Volatile and corrosive chemicals produce airborne contaminants that must be controlled when in storage as well as when in use. This could include ventilated storage cabinets, a sufficient number of fume hoods, or other enclosures and local exhaust.

The design will also include directional general ventilation in lieu of local exhaust ventilation where it is not possible for the lab population to utilize, such as in Gross Anatomy in the Veterinary College.

Directional airflow relative to the hallway and adjacent rooms must be discussed for all laboratory projects.

Fume hood and other exposure control devices: The type and quantities of fume hoods, location in the lab suite, and face velocity (with minimum velocities) must be determined at design. Local exhaust may include snorkels, canopy, heat extracting hoods, or other types of tables.

Specialty hoods: Wet benches (for corrosive chemical use), solvent benches, and perchloric acid fume hoods (with the washdown feature) must be discussed with EHS to determine requirement and special considerations.

Biological Safety: A review of the nature of proposed research biological agents, including plants or animals, must happen to determine room design elements. The researcher must register with the Institutional Biosafety Committee for work with disease causing agents in humans, animals, and plants. Approval may also be required by the IACUC and the Institutional Review Board.

Specific design elements include:

• Type and location of biosafety cabinets;
• Types, location, and electrical requirements for ULT freezers, incubator, growth chambers, and other floor or benchtop equipment;
• Floor materials, sink locations, and environmental conditions for the room or a support lab.  

Radiation Safety: Users of ionizing radiation require a Cornell Permit. Most non-ionizing radiation equipment requires registration. The following programs are managed by the Radiation Safety group who must be contacted by project managers during the design scoping phase when any proposal involves the use of this equipment. There are specific room requirements.

Lasers: Class 3B and 4 lasers. The facility housing these must be designed to mitigate the laser hazards. These must be registered for use on campus.

Magnet/UV/RF: Magnetic fields are produced by this equipment can be hazardous.

Radiation Producing Equipment includes X-ray equipment (x-ray diffraction, x-ray fluorescence, x-ray radiography, ion implanters, electron microscopes).

Radioactive materials, including unsealed materials and sealed sources.

References (Use most recent versions):

1)    ANSI Z9.5 Laboratory Ventilation

2)    ASHRAE Classification of Laboratory Ventilation Design Levels

3)    ANSI Z358.1 Emergency Eyewash and Shower Equipment

4)    Biosafety in Microbiological and Biomedical Laboratories

5)    National Institutes of Health Design Requirements

6)    Care and Use of Animals

7)    Practical Guide to Containment: Plant Biosafety in Research Greenhouses

8)    Arthropod Containment Guidelines

4.16 Ventilation Rates

As part of energy conservation measures, ventilation rates for laboratories are determined based on the occupancy and the type of research being conducted. Please see the Laboratory Ventilation page on this website for further information about the program.

If the function of a room changes due to new researchers coming to campus notify EHS through askEHS@cornell.edu about the change.  EHS will then verify if the ventilation rate for a given room is appropriate for the type of research being conducted.

4.17 Energy Conservation in Laboratories

Laboratories are energy intensive facilities, consuming many times the energy use of the average non-lab academic buildings. Laboratories use large quantities of air for ventilation and fume hoods; electricity to operate fans, lighting, and specialized lab equipment; and large quantities of water and process chilled water.  Some laboratory facilities also use substantial quantities of natural gas.

There are a number of things that lab occupants can do to reduce the overall consumption of energy:

• Turn off the room lights.
• When possible turn off electrical equipment when not in use.
• Use timers to turn other pieces of equipment on and off automatically.
• Unplug equipment when not in use.
• Turn off your computer’s monitor when not in use. The monitor consumes over half of the energy used by the average computer.  Put your computer and monitor into "sleep" mode after 10 minutes and cut power use nearly to zero.
• Keep the sash closed on your fume hood.  This promotes both energy conservation and safety. 
• If you would like to temporarily turn off your fume hood, please contact your building coordinator.
• Rooms that are too hot or too cool may be due to faulty thermostats or other controls that are malfunctioning or have drifted from set points, resulting in wasted energy as well as uncomfortable conditions for you. If you experience these problems, then contact your Building Coordinator for assistance.
• Report drips of water from sink taps, chilled water connections or Reverse Osmosis (RO) faucets.
• Clean out and consolidate freezers and refrigerators at least once per year.
• Set refrigerator and freezer temperatures at necessary levels instead of the lowest set point the equipment can achieve.
• Consolidate incubator use and freezer storage to minimize the number of appliances used.
• Use shades and blinds as provided to help keep your space cool on sunny days.  The shade can reduce the amount of cooling required in a south or west facing room by over 30%.
• Use electric smart strips to minimize electricity used by items on the strip (EcoStrips).
• Discourage the use of space heaters.
• Develop maintenance schedules for scientific equipment, such as cleaning compressor coils on cooling devices, to extend the device's life and maintain its energy efficiency.

4.18 Green Labs

Green chemistry, also known as sustainable chemistry, is the design of chemical products and processes that reduce or eliminate the use or generation of hazardous substances.  Green chemistry applies across the life cycle of a chemical product, including its design, manufacture, and use.

• Substitute hazardous chemicals with less hazardous alternatives or chemicals that are drain disposable
• Redesign chemical processes to reduce hazardous chemical use and/or exposure to technicians
• Maintain an ongoing inventory of chemicals and dispose of outdated chemicals on a regular basis.

Find additional information on Greening your lab and certifying your lab as a Green Lab:

• EPA Pollution Prevention website for Green products
• CU Green Your Lab
• American Chemical Society Green Chemistry Institute

Additional information on energy conservation for both work and home can be found on the Department of Energy's website: Energy Efficiency and Renewable Energy.  Find energy savings tips for the home, office, and lab by going to the Utilities Department Energy Saving Tips webpage.

4.19 Research Area Inspections

Laboratories and other research areas are regulated by OSHA laboratory safety standards and general industry regulations, EPA and DEC hazardous waste regulations, DOH regulations, NFPA life and fire safety standards, and building codes. Additionally, accreditation and granting agencies such as CDC, NIH, and USDA are increasing scrutiny over researchers and their compliance with state and federal laws. To assist researchers to be in compliance with these regulations and standards, Environmental Health & Safety (EHS) will conduct required inspections of all campus research areas.

The purpose of the inspections is to assist responsible faculty and staff members in identifying and correcting potential regulatory compliance issues or other issues that could affect granting activities, and identify potential health and safety hazards that could pose an unreasonable risk to laboratory personnel, students, and the campus community. To facilitate the correction of deficient items, a corrective action process has been implemented and will be tracked. EHS will schedule inspections by working with college-level contacts, Department Safety Representatives, Building Coordinators and staff throughout the colleges, departments, and buildings.

Research areas are strongly encouraged to conduct their own self inspections prior to EHS conducting an inspection of their research area to address any potential issues before the EHS inspection and to provide a training opportunity for research staff. To facilitate the self inspection process, EHS is providing research areas with the following self inspection checklist and explanation key which identify the same topics covered during an EHS inspection.

4.20 Research Area Space Registration Using HASP

All research spaces are required to be registered with the Department of Environmental Health and Safety (EHS) using the online Hazard Assessment Signage Program (HASP). While Facilities Services Space Inventory accounts for room function and type, Research Area Space Registration accounts for hazards present in rooms to facilitate regulatory compliance, identify training requirements, communicate hazards, and improve emergency response.

Research areas must be reviewed and registered on an annual basis, when roster or hazard information changes and upon notification by EHS. The registration process consists of using the online HASP tool and entering contact information, hazards present in the room, risk levels of hazards, access limitations, warning messages, and emergency response information. The entire process of completing HASP for one room should only take a few minutes for each room. Once a research area has been initially entered into the system, annual updates can be completed in less time. Only certain research area rooms types are required to be registered. The list of space inventory room types of interest that will be required to complete annual Research Space Registration using the online HASP tool can be found on the Research Area Space Registration webpage.

The following outlines responsibilities for implementation of Research Area Space Registration using HASP:

The Department of Environmental Health and Safety is responsible for:

• Providing information and assistance with the HASP system.
• Granting access to the users for their locations within the HASP system.
• Providing guidance and assistance on the identification of hazard types.
• Providing information, training, notifications, reports, and updates from the information provided.

Deans and Department Chairpersons are responsible for:

• Ensuring that research areas within their departments and units are registered in a timely manner upon notification by EHS and updated annually.

Principal Investigators and Research Area Supervisors are responsible for:

• Registering (or designating someone to register) their research areas using HASP in a timely manner upon notification by EHS.
• Updating their Research Area Space Registration using HASP when any new hazards or significant change of existing hazards occurs.
• Updating their Research Area Space Registration annually in a timely manner upon notification by EHS.

EHS will work with Department Safety Representatives (DSRs) and Building Coordinators to facilitate the implementation of Research Area Space Registration. Before getting started, persons completing the registration process (DSRs, Building Coordinators, Principal Investigators, research staff, or other college and department designated personnel) will first need to be given authorization to the HASP system for their organization, building, department, and/or specific rooms. To obtain authorization for specific areas, please contact askEHS@cornell.edu. For more information on using the online HASP tool and how to get started with the program, see the online training program for using HASP.

4.21 Laboratory Security

Laboratories need to take specific actions in order to provide security against theft of highly hazardous materials, valuable equipment, and to ensure compliance with state and federal regulations. EHS encourages each unit (college, department, and research group) to review and develop procedures to ensure the security of all hazardous materials in their area of responsibility.

Many laboratories already implement various means of security, including requirements to lock up controlled substances, syringes and needles, and radioactive materials. EHS recommends you review and assess the hazardous materials in your laboratory and consider security issues in protecting those materials. The intent is to minimize the risk of theft, especially targeting the five-minute window when the lab is left unattended.