Chemical Hygiene and Our Lab Freezer

Safety has been the buzzword in our department for about 6 months.  Over the past two years, my University has been increasing campus safety by implementing new chemical safety protocols ultimately designed to have us coast through 29 CFR 1910 (and related statutes) inspections.  This revamping has ultimately translated to an updated chemical inventory, mandatory safety training/seminars and surprise internal laboratory audits. 

In 2001, the EPA launched a voluntary audit initiative.  In electing to adopt this form of “self-policing,” enrolling universities could internally inspect their respective campuses and report the violations (and subsequent remedies) to the EPA in exchange for lessened violations.  Universities deemed “negligent” by the EPA could face governmental inspections with fines totaling in the hundreds of thousands of dollars.  My university has elected to comply with the audit initiative. 

This new approach to lab safety has been implemented in response to increased EPA violations over the past decade.  For example, in 2005 the EPA fined the University of Puerto Rico, at the Mayagüez campus, nearly $1 million for several violations including hazardous waste, clean water and clean air laws.  In a July 2000 EPA newsletter, it was reported that the University of Hawaii had paid $1.8 million in civil penalties over waste management issues.  Several of the following large universities have felt the financial sting of EPA violations: Boston University, Georgetown University, Villanova University, the University of Virginia, Brown University and George Washington University.

What has this meant for me, personally?  Cuts all over my hands and a sore back.  Our lab was cited internally for having frost in our freezer.  I spent the majority of yesterday defrosting said freezer (with a screwdriver, hammer and a heat gun, mind you) to get up to code.  It looks like the seal around our 5-year-old freezer was never correctly installed and as such our freezer has become a trap for atmospheric moisture.  If the seal’s not replaced, some lucky sap will have to pick up a hammer once a year.  Though I’m glad that I probably won’t be that sap a year from now, I’m trying to correct the problem for future grad students.  

I will mention that I'm not 100% convinced that frost in the freezer constitutes a "violation."  I could see how some reagents are sensitive to water (hence one of the reasons we keep many of them cold).  I'm not willing to make waves over something so mundane, but I have thrown the BS card.