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DIVISION OF RESPONSIBILITIES*

Surveillance of University practices dealing with radiation, chemical and biological hazards will reside with the Office of Radiation, Chemical and Biological Safety (ORCBS). The ORCBS will report directly to the Vice President for Research and Graduate Studies. Protective services, fire safety, accident prevention and general safety will be the responsibility of the Department of Public Safety (DPS). DPS reports to the Vice President for Finance and Operations and Treasurer. The special matter of risk management in the course of delivering treatment in MSU clinics or by MSU physicians, nurses and other licensed clinicians comes under the special risk management procedures of the respective clinic and the All University Risk Management Committee.

The Vice President for Research and Graduate Studies and the Provost are responsible for promoting liaison between the University faculty, students and staff engaged in interaction, research and service, activities involving radiation, chemical and biological hazards including related moral and ethical issues.

The University administration is responsible for ensuring that the Office of Radiation, Chemical and Biological Safety has access to personnel with competencies in radiation, chemical and biological hazards safety procedures.

Office of Radiation, Chemical, and Biological Safety Responsibilities

General Duties

The establishment and maintenance of a training program of a general nature for all involved personnel in the safe and effective handling and storing of hazardous substances, procedures for dealing with accidents; in the proper use of safety equipment, in packaging and disposing of hazardous wastes and in compliance with right to know regulation for unit supervisors in their obligations to inform employees of the risks when working with hazardous materials.

Safe transportation and disposal of hazardous wastes. Monitoring for the adequacy of containment facilities, the adequacy of safety procedures, and advising units on the proper numbers, placement, and function of safety equipment related to the Office of Radiation, Chemical and Biological Safety. By performing these functions, the ORCBS shall be responsible for compliance with State and Federal standards and preparing any reports called for.

It will be the responsibility of the units, (departments, institutes, schools, outlying field stations, service groups, and facilities, etc.) to ensure that all individuals working with radiation, chemical and biological hazards are informed of the "extent of risk." Material data sheets will be made readily accessible to students and employees as required by the Right-To-Know legislation and as new hazardous materials are introduced. Further, unit offices will be responsible for maintaining a record of informed consent from individuals whose duties require them to work with hazardous substances. The responsibility for maintaining a unit safety system in compliance with federal and state regulations and University policies for radiation, chemical and biological hazards lies explicitly with the chief administrative officer of the unit.

Therefore, each unit must:

1. Units shall have an identified unit safety officer.
2. Establish and maintain procedures for the acquisition, labeling, storage, use and disposal of radioactive materials and hazardous chemical or biological materials within their units. These procedures must conform to the policies of the University and to appropriate State and Federal laws or guidelines.
3. Provide an effective and periodic inspection system that will ensure continuity and compliance in the safety program.
4. Provide for a unit education program that will inform all staff, students and faculty of the unit's potentially hazardous conditions and the safety systems for radiation, chemical and biological hazards and that will periodically update the unit's safety procedures in the radiation, chemical and biological hazards area. The education program must be provided for students, staff, and faculty. The Units must maintain their policies and procedures in written form and must distribute them to new faculty, staff and students each year prior to their use of stated materials.
5. The Office of Radiation, Chemical and Biological Safety and the Advisory Committees on Radiation, Chemical and Biological Hazards will periodically review each unit's proposed policies and procedures, and when adequate, will certify that the unit practices are in compliance with University policy at least biannually and when appropriate. The unit will complete and forward to ORCBS the unit annual Safety Report.
6. Determine whether health monitoring is required for employees and students working with hazardous materials. ORCBS will assist in this determination and refer those individuals to the appropriate office for arranging the physical examination or treatment.

At a minimum, a unit safety program will contain the following:

1. A designated Safety Representative responsible for administration of the Unit Safety Program.
2. A designated Safety Committee or Safety Advisory Group made up of concerned individuals and empowered to implement safety protocols, changes, etc.
3. A mechanism to ensure that the Unit Safety Program conducts Safety Audits, in conjunction with the ORCBS Safety Audit system (SAS), on an annual basis.
4. A mechanism to ensure that the Unit Safety Program files a report of it's activities and inspections with the-Office of Radiation, Chemical and Biological Safety on an annual basis.

As a consequence of the highly specialized nature and diverse assignments in a university, the legal responsibility for the safety and well-being of all personnel in contact with any university-related activity utilizing radiation, chemical or biological hazards lies with the project director and the administrative officers responsible at the various university levels. The specific responsibilities of the project director are as follows:

1. The project director is responsible for ensuring that all personnel under his/her supervision have been instructed with regard to general safety requirements of laboratory or work area operation, as described in the Chemical and Biological Safety Manual available from ORCBS.
2. The project director is responsible for being aware of the then known radiation, chemical and biological hazards inherent in a proposed activity. If these hazards are not covered by the general program of laboratory or work area safety, the project director is responsible for instructing personnel in the nature of the risks and in safe practices or in directing personnel to sources of information concerning safe practices. The project director is responsible for understanding the risks associated with the acceptance into, or shipping from, his/her designated area all hazardous radioactive, chemical or biological agents. He/She is to be aware of the known dangers in working with each particular hazardous radiation, chemical or biological material and to take the necessary protective and containment measures. Because federal and state regulations control the use and shipping of radioactive materials, certain chemicals, venomous animals, insects, pests, and infectious microorganisms, the project director must be aware of these laws and comply with them.
3. The project director is responsible for informing and the special training of all personnel under his/her supervision of those specific radiation, chemical or biological hazards which are peculiar to his/her activities.
4. The project director must obtain periodically a statement of informed consent from all individuals, both employees and students, working directly under supervision of the project director in a University activity where potentially hazardous radioactive, chemical or biological materials are utilized and are specific to the activities for which the project director is responsible. Each individual must be informed of the "extent of risk" (where known) in utilizing hazardous substances.
5. In order to protect individuals from unwitting and unnecessary exposure, the project director is responsible for posting warnings and restricting entry to areas that contain potentially hazardous radioactive, chemical or biological materials. He/she is also responsible for posting signs as to where information for hazardous materials may be obtained. The principal investigator is therefore also responsible for the safe packaging of waste materials destined to be picked up by Laboratory Animal Care Service (LACS) or ORCBS. Hazardous materials may not be disposed of without approval of ORCBS.
6. The project director is responsible for knowing whether health monitoring for employees or students is appropriate. ORCBS will assist in this determination and direct the individuals to the Office for arranging the physicians appointments.

The individual lab employee or student is functionally responsible for his or her own safety. (The nature of the responsibilities differ among these individuals.)

All individuals performing work with hazardous substances must accept a shared responsibility for operating in a safe manner once they have been informed about the extent of risk and safe procedures for their activities. Individuals undertaking an activity without direct supervision by a project director become responsible for performing those activities associated with hazardous substances safely. This applies to all students, staff and employees.

* This information is available in full in the Policies, Procedures and Guidelines for Radiation, Chemical and Biological Safety Document, dated September 1989.