Thursday, May 9, 2013

A very good point by Jyllian Kemsley

William Banholzer and a group of other high-level chemical corporation executives wrote a letter in this week's C&EN, where they really took academic chemical safety to task* ** -- and used an interesting metric to do it:
The facts are unequivocal. Occupational Safety & Health Administration statistics demonstrate that researchers are 11 times more likely to get hurt in an academic lab than in an industrial lab. There have been serious accidents in academic labs in recent years—including fatalities—that could have been prevented with the proper use of protective equipment and safer laboratory procedures.
 Most chemistry and chemical engineering graduate students will find employment in industry. As new hires come on board, many companies spend weeks on remedial safety training before new hires are allowed to work in their labs. This clearly shows that the current state of graduate safety education is lacking and that there is a clear need to address it. If the report is supposed to focus on “preparing graduate students, about the future,” how can this not be a relevant topic?
Jyllian Kemsley unequivocally rejects the use of the metric yesterday (but agrees with them on the general need for academic chemical safety reform):
The “11 times more likely” statistic is inaccurately framed. I followed up on it with the letter authors and Lori Seiler, Dow’s associate director for environmental health and safety in research and development. The numbers actually compare the overall injury and illness rate for academic institutions (including those that might occur, for example, in grounds keeping or a dining hall as well as in laboratories) to Dow’s overall rate. Seiler adds that the injury and illness rate for Dow’s research laboratories is consistent with the company’s overall rate, when calculated per employee. 
That said, it seems like it would be wise for the academic community to take this letter to heart.  Banholzer, Calabrese, and Confalone are not writing in a vacuum—they see the skills that chemistry graduates lack, and those skills are necessary whether those graduates are going on to work in industry, academia, or elsewhere.
This is not the first time that Dr. Banholzer has used this metric; here's a tweet where he said it in February. (Interestingly, Jyllian Kemsley raised the same concerns. Even more interestingly, the statistic seems to have grown from a 7:1 academia/Dow ratio to 11:1.) I believe that this metric was used in Dr. Banholzer's presentation to the President's Council of Advisers on Science and Technology.

While I am also in agreement that academic chemical safety could learn from industry, I think that Dr. Banholzer is missing the regulatory aspect of the different approaches between corporations and universities. Corporations are employers, and thus have legal responsibilities to provide a safe workplace and state and federal regulatory agencies to help make that happen. There is no similar requirement or regulatory agency for graduate students and universities. (Note that Sheri Sangji was a research technician and an employee of UCLA and Professor Harran, thus involving Cal/OSHA -- if she had been a graduate student, I'll bet the outcome would have been very different.)

I also really doubt this comment in the letter:
As new hires come on board, many companies spend weeks on remedial safety training before new hires are allowed to work in their labs. This clearly shows that the current state of graduate safety education is lacking and that there is a clear need to address it.
I doubt that it is literally "weeks", and if so, I suspect that it's 6 days of bureaucratic nonsense about the structure of EH&S management and accident reporting, and 4 days of actual useful training. I'm more than willing to believe that industry does a better job of safety training, but I just don't think this is a very probative statement.

Finally, I also think that it is unfair for large corporations (Dow, DuPont and Corning) to compare the safety rates of experienced employees (what is the median age of a Dow bench scientist? 42? 45? The median age of an industrially employed ACS member in 2010 was 48) versus the safety rates of the relatively young graduate students and postdocs that populate academia. They're very different populations with very different risk assessment capabilities.

*Background: Some people, including Richard Zare, were quoted by Celia Henry Arnaud in her comprehensive article that the safety section in the report seemed a little out of place.  

** While we're at it, it is frustrating to me that this report makes vague references to recent incidents in academic chemical safety, yet refuses to talk about specific cases (e.g. Yale/Dufault, TTU/Brown, UCLA/Sangji.) 


  1. I still think that there is consulting money to be made from someone who comes up with a good program for installing REAL chemical safety procedures in universities. Harran and Sangji are at the front of many department's minds right now. So ... now's the time ....

    1. Calling BioRAFT, BioRAFT, come in, please.

  2. "There is no similar requirement or regulatory agency for graduate students and universities."

    Actually, that's entirely wrong. Speaking as a grad student in the UC system, it has been made abundantly clear to us that we are in fact employees and fall very firmly under Cal/OSHA. (We have also been told to expect Cal/OSHA inspections. Oh joy.)

    1. Really! That's very interesting. Do you have a relevant link?

    2. So will they make available the UC 401k or equivalent plans to grad students?



  3. I would not use Dow statistics because Dow has a rather infamous culture of hazing and firing employees with two (or more) reported work accidents - that's why the low level mishaps are covered up whenever possible because the affected people usually do not wish to go through the bureaucratic accident investigation report hassle and then have it hanging in their personal file forever...

  4. In grad school, we were also told that we fell under OSHA. However, the enforcement of good safety practices was severely lacking. I only wore safety glasses when I felt it was absolutely necessary and never wore a lab coat. In industry, my company strongly enforces safety rules and I wear both of those every time I step foot in the lab, in addition to proper footwear.

  5. The statistic is misleading perhaps but the point is right, I had no clue about safety rules coming into industry. The only thing I knew about was air sensitive reagents (I'll admit to being well-trained in this respect) and waste disposal. That's it.

    -- Unstable Isotope

  6. "As new hires come on board, many companies spend weeks on remedial safety training before new hires are allowed to work in their labs"

    I don't believe this at all. Out of post-doc, I worked for a company affiliated with both Dow and Corning (guess what it is called), and have worked for several others over the years, in multiple nations. In every case, I was in the lab doing reactions on week two, in full compliance with the safety rules. Additionally, the on-boarding week or so was the same regardless of my prior experience, and only one day or so was related to lab safety. It's not really hard to teach people "before you do a new reaction or scale an existing reaction up, fill out these forms and get them signed by X and Y", and click through the mandatory safety online learning presentations.

  7. Universities are supposed to follow OSHA rules and can be inspected, but in the vast majority of states OSHA is too overwhelmed with tracking the private sector to bother with universities and colleges. When I was in grad school back in the late 90s, CalOSHA in fact did nail a couple of the UCs. IIRC, I think it was Irvine's chem department that got the big fine. OSHA conducted a snap inspection over laser safety and found UCI didn't have their class III/IV lasers appropriately interlocked. As I remember the details, OSHA slapped a 50K fine for each incident on UCI and there were 6-8 labs out of compliance so a 300-400K hit on the dept as a result (at least on paper--no idea what the actual amount turned out to be). But I assure you the EH&S departments at the other campuses sprung into action immediately to get everyone else compliant the moment it happened because I was there at one of the other campuses and they were all like, "we have to do this today!"

    Fast forward a number of years and I was an Assistant Prof in (3rd tier univ in underfunded flyover state) having a conversation with EH&S people about this exact issue. Mine was one of 4 labs in our chem department with lasers not appropriately interlocked. When I pointed this out to EH&S they basically said yeah we know, but we can't do anything about that because we don't have any budget. When I pointed out that the fine could bankrupt the dept should OSHA decide to inspect, they said (and this is a near direct quote...) "We have brought this up with the appropriate adminstrators, but they have made the bet that OSHA in this state doesn't have the funds to inspect us. They are probably right. OSHA is more underfunded then we are. If they are wrong, yours won't be the only department bankrupt, all the others have their own problems." In contrast, EH&S was quite diligent about making sure every lab had their containers covered and labeled appropriately because EPA cares about that stuff and did their inspections every year.

    This is the mentality that governs universities in relation to safety. Until there are dollars at risk, nothing will change.

  8. Metrics or not, all I know is that during my years in academia I've seen one person die and another get badly injured. In industry I have not witnessed anything more serious than a case of hiccups. Luck of a draw I guess.

  9. Do we really think that improved academic training would alleviate the need for industry to provide its own, in-depth safety training for new employees? Would increasing sexual harassment training in grad schools mean I wouldn't have to sit through mind numbing (and occasionally unintentionally hilarious) sexual harassment training at an industry?

    A company will always be legally liable for the safety of its employees and, as such, legal departments will always require a certain (high) level of safety training. This being the case, I kind of wonder about the overall rationale for this letter. Maybe, deep down, they're just really concerned with the safety of graduate students....

    1. The part about "your guys are badly trained, and we have to retrain them" is total baloney, I agree.

      I suspect they actually are concerned, just like you say; I think they fail to see why other sectors have the constraints they do.

  10. To be fair, Dow has both grounds keeping and dining halls, and accidents that happen to non-Dow employees (employees of contracted agencies who work at Dow locations) are recorded in the aggregate statistics (at least the ones I know about).

    I don't know what the average age of a bench scientist is, but I do know, anecdotally, that technicians outnumber bench scientists. And that the higher up one goes, generally the less time one spends in the lab (kind of like PIs in academia).