Institute Responses to Unsafe Actions and/or Unsafe Conditions in Laboratories

The following table provides guidance as to how laboratory hazard levels are identified and responded to by EHS. However, this list is not all inclusive; individual circumstances will vary, and the most appropriate action will be taken:

Level 1:  Imminent Hazard with Potentially Severe Consequences

Imminent hazard caused by unsafe conditions or unsafe actions which, in the judgment of the EHS representative on site, have the potential for severe consequences, and may result in

  • Loss of life
  • Serious injury with possibility of permanent damage to health or permanent disability
  • Injury (including those by chemical exposures) likely to result in hospitalization
  • May affect people outside of the lab
  • May involve multiple victims
  • May involve significant property damage, and/or building-wide business disruption and/or business disruption affecting the Institute.

Examples of imminent hazards with potentially severe consequences that may result from unsafe conditions or unsafe acts include but are not limited to:

  • Fires
  • Floods
  • Toxic or flammable gas releases or explosions
  • Releases of highly toxic materials
  • Releases of highly toxic materials to the environment
  • Detonation of  potentially explosive materials
  • Run away reactions with the potential to cause any of the above
  • Failure to use personal protective equipment or follow lab safety procedures while working with highly–hazardous substances such as pyrophorics or highly-energetic materials
Level 1 Response:
  • Safely shut down process. 
  • If necessary, close lab to protect personnel, contain hazard, or to prevent re-entry by unauthorized personnel.
  • Change locks if necessary.
  • Situation report to PI, Chair, Dean, Provost, EVP of Finance and Administration, and Director of EHS.
  • For unsafe conditions: lab may open as soon as conditions are rectified to EHS satisfaction/approval
  • For unsafe acts by individuals or unsafe practices by lab groups: lab re-opening and /or disciplinary actions to be determined by Chair, Dean and Institute Code of Conduct Procedures

Level 2: Imminent Hazard with Potentially Serious Consequences

Imminent hazard caused by unsafe conditions or unsafe actions which, in the judgment of the EHS representative on site, have the potential for serious consequences, and may result in:

  • Temporary  illness or minor injury
  • May involve victim(s) receiving outside medical attention such as from an Emergency Room or Occupational Medicine Clinic, but is not likely to require hospitalization.
  • May involve property damage and/or building-wide business disruption

Examples of serious events that may result from unsafe conditions or unsafe acts include but are not limited to:

  • Exposures to one or more individuals to chemical, biological, or radiological materials
  • Extremely poor housekeeping, improper segregation or storage of hazardous chemicals. Poor chemical hygiene
  • Failure to use protective equipment or follow lab safety procedures while working with hazardous substances.
  • Spills of chemical, biological, or radiological materials in a lab or in common areas
  • Odor releases of known or unknown substances
 Level 2 Response:
  • Safely shut down process. 
  • If necessary, close lab to protect personnel, contain hazard, or to prevent re-entry by unauthorized personnel.
  • Change locks if necessary.
  • Situation report to PI, Director of EHS 
  • For unsafe conditions: lab may open as soon as conditions are rectified to EHS approval
  • For unsafe acts by individuals or unsafe practices by lab groups: additional situation reports to Chair, Dean, Provost, and EVP of Finance and Administration.
  • For unsafe acts by individuals or unsafe practices by lab groups: lab re-opening and/ or disciplinary actions to be determined by Chair or Dean

Level 3: Not Imminent Hazard but Potentially Serious Consequences

Hazard caused by unsafe conditions or unsafe actions which, in the judgment of the EHS representative on site, have the potential for serious consequences

Examples of Not Imminent Hazard but Potentially Serious Consequences are generally the same as described in Levels 1 and 2.

Level 3 Response:
  • Situation report to PI, Director of EHS
  • Follow up in 24 hours
  • If no response, additional situation reports to Chair and Dean

Level 4:  Not Imminent but Potential for Undesirable Consequences

Hazard caused by unsafe conditions or unsafe actions which, in the judgment of the EHS representative on site, have the potential for undesirable consequences and may result in:

  • Minor or minimally dangerous chemical spills
  • Non- life threatening unplanned chemical reactions
  • Increased risk of fire
  • Increased risk of slips, trips, and falls

Examples of undesirable events that may result from unsafe conditions or unsafe acts include but are not limited to:

  • Spills caused by poor housekeeping or clutter
  • Unplanned reactions resulting from inappropriately stored chemicals or inadequately labeled waste
  • Slips, trips, or falls caused by clutter, or by wires or tubing across walk ways
  • Adverse impact to indoor environmental quality in the lab and/or the building.
Level 4 Response:

Situation report or Lab Inspection report to PI within 3 days

If no response or situation still uncorrected after 1 month – situation report to Chair and Dean

Level 5:  Repeat Violations/ Failure to Correct

Hazard caused by unsafe conditions or unsafe actions which, in the judgment of the EHS representative on site, have the potential for Level 1-4 consequences

  • For unsafe conditions- would include multiple deficiencies which have not been corrected by the lab group in the specified time period
  • For unsafe acts by individuals or unsafe practices by groups  would include repeated violation of basic safety rules including housekeeping, attire, and personal protective equipment
Level 5 Response:
  • Situation Report to Dean/ Request for 1 week lab closure
  • Close lab, change locks
  • Meet with PI and Chair
  • PI to present Chair and EHS with a written plan for correcting unsafe conditions and keeping the lab in the “corrected” condition.   
  • Lab to reopen at a time mutually agreed upon by EHS, Chair, Dean, and PI, not to exceed 1 week (assuming that all unsafe conditions have been corrected).

Other Circumstances:

For certain situations such as repeated and willful disregard and/or failure to use personal protective equipment (PPE), or grossly inadequate housekeeping, EHS is authorized to take appropriate action up to and including closing the laboratory until EHS, the Department and School Chair, Dean (or appropriate next level of supervision) authorizes re-opening.  The PI, Chair and Dean will be notified promptly when this action is deemed necessary.