UCLA Policy 906 : Undergraduate Researcher Laboratory Safety
I. BACKGROUND & SCOPE
The University of California (“University”) is committed to providing a healthy and safe workplace for all members of the campus research community and to ensuring compliance with all applicable health, safety and environmental protection laws, regulations, and requirements. This Policy operates in conjunction with other applicable regulations and UCLA policies, including but not limited to UCLA Policies 905, 907, 992, 994 and 996.
This Policy applies to all Principal Investigators and lab staff working with Undergradauate Researchers in UCLA research laboratories. The safety requirements outlined in this Policy pertain to all research and teaching laboratories. This policy does not apply to students enrolled in regular laboratory courses for credit (e.g., Life Sciences 23L).
For the purposes of this Policy:
Direct Supervision is when the Principal Investigator or other Supervisor, the assigned mentor (s), or another fully trained lab member who is at least a graduate student, postdoctoral scholar, or staff member, is directly watching the Undergradute Researcher during experimentation.
Principal Investigator is defined in UCLA Policy 900.
Supervision is when the Principal Investigator, Supervisor, assigned mentor, or other fully trained lab member who is at least a graduate student, postdoctoral scholar, or staff member is present in the room or in an adjacent room and is within hearing range of the Undergraduate Researcher.
Supervisor is the Principal Investigator, assigned mentor(s), or another fully trained lab member who is at least a graduate student, postdoctoral scholar, or staff member, who provides guidance and training to an Undergraduate Reseacher, and may not be another Undergraduate Researcher.
Undergraduate Researcher is an undergraduate student, whether from UCLA or another institution, and any other individual who has not completed an undergraduate degree, including work study and other student employees. It includes others such as high school students (e.g., volunteers and minors) conducting research in a UCLA laboratory.
Working Alone is when an individual is working unaccompanied, such that assistance is not readily available should an injury, illness, or other emergency arise. Working Alone is interpreted as being out of direct visual contact or hearing range of another lab worker for more than a few minutes, regardless of where the Undergraduate Researcher is working, or the time of day.
Undergraduate students may not have the scientific background, technical knowledge, or practical experience to ensure that they can engage safely in all research activities. As a result, additional safety measures are necessary for some research activities. Further, some activities that involve highly hazardous materials and/or conditions are prohibited, as described below.
A. General Safety Requirements for All Researchers
A number of safety controls protocols and trainings have been established to ensure safety in research laboratories. The following apply to all researchers:
- Completion of the Laboratory Safety Fundamentals online training course
- Review of the Laboratory Safety Manual, including the following key programs
- UCLA Chemical Hygiene Plan
- Departmental Injury and Illness Prevention Program
- Completion of required research-specific safety training (such as ARC-mandated courses and occupational health program enrollment, Biosafety ABC’s, IBC Compliance, Bloodborne Pathogen, Medical Waste Management, Radiation Safety, Laser Safety) as identified in the UCLA Lab Safety Training Matrix
- Completion of laboratory safety training mandated by the school or department hosting the Undergraduate Researcher
- Review of the research group’s Laboratory Hazard Assessment Tool
- Completion of the laboratory safety orientation for the research group
- Completion of laboratory-specific safety training within the research group
- Inclusion of all appropriate researchers, including Undergraduate Researchers, on Institutional Biosafety Committee and Animal Research Committee protocols as required by laboratory research plans
- Adherence to the Personal Protective Equipment (PPE) standards established by UCLA Policy 905
- Use of additional PPE required by the research group’s Laboratory Hazard Assessment Tool
- Use of additional PPE based on experiment hazard assessments
- Use of standard operating procedures (SOPs) on the safe use of equipment and chemicals
- Use of SOPs to guide safe execution of procedures
B. Additional Safety Requirements for Undergraduate Researchers
In addition to the general safety requirements outlined above, Undergraduate Researchers must also comply with the following requirements:
- Undergraduate Researchers under 18 years old (i.e., minors) must comply with the UC Policy Minors in Laboratories and Shops and submit a completed UC Release of Liability, Waiver of Claims, Express Assumption of Risks, and Hold Harmless Agreement to the Principal Investigator. See: https://www.ucop.edu/risk-services/_files/safety-resources/minors-in-labs-and-shops.pdf to the Principal Investigator. See the Information factsheet at: https://ucla.app.box.com/v/ehs-uc-minors-labs-impacts.
- Principal Investigators who wish to host Undergraduate Researchers who are under 18 years old (i.e., minors) must submit a Minors Research Proposal Registration Form to their Department Chair. The form is at https://policy.ucop.edu/doc/3500602/MinorsLabsShops.
- Undergraduate Researchers who are not enrolled at UCLA must submit proof of health insurance to the Principal Investigator.
- Undergraduate Researchers working in UCLA Health Schools (i.e., Medicine, Dentistry, Public Health, and Nursing) must register as “Volunteers” with UCLA Health Volunteer Services. Information is available at: https://www.uclahealth.org/volunteer/
- Undergraduate Researchers working in areas where radiation is being used are subject to UCLA Procedure 994.2: Volunteers and Visitors in Non-Clinical Radiation Use Areas.
- Use of some materials or equipment may require additional training or direct supervision as determined by the Principal Investigator and/or Supervisor.
- The conduct of many laboratory procedures requires Direct Supervision until proficiency is demonstrated. The Principal Investigator and/or Supervisor will determine when the Undergraduate Researcher has demonstrated sufficient proficiency and may conduct these procedures independently.
- Performing operations that use an open flame require additional training and may not be done alone.
- Use of hydrogen peroxide at greater than 5% concentration or organic peroxides requires that a detailed protocol be developed by the Principal Investigator and/or Supervisor.
- Conducting a scale-up chemical procedure that is more than four times a prior experiment or uses more than 100 grams of substrate requires prior approval of the laboratory Principal Investigator and/or supervisor.
- Working with pyrophoric reagents requires additional training and can only be done under Supervision.
- Working with reactions under pressure, using glass or metal reactors, or that may become pressurized requires additional training and can only be done under Supervision.
- Performing radiosynthesis requires additional training and can only be done under Supervision.
- Working with radioactive compounds requires additional training and can only be done under Supervision.
- Performing flow cytometry requires additional training and can only be done under Supervision.
- Handling of BSL2 materials, including primary human cells/tissues/blood, but excluding established human cell lines, requires additional training and can only be done under supervision.
- Working in a BSL2+ facility requires additional training and can only be done under Supervision.
- Working in shops (e.g., electronic, machine or wood) requires additional training and may not be done when Working Alone.
- Performing any hot work (e.g., welding) that requires a permit may not be done when Working Alone.
- Working with open beam class IIIB or class IV lasers requires additional training and must be done under Supervision. See Attachment B, item 6 for definitions and examples.
- Working with ultrafast lasers requires additional training and must be done under Supervision. See Attachment B, item 6 for definitions and examples.
C. Prohibited Research Activities for Undergraduate Researchers
Some research activities present hazards of such severity, that exposing Undergraduate Researchers to these materials cannot be justified. Therefore, the following activities are prohibited:
- Working with any materials or equipment that the Principal Investigator has not authorized.
- Working with any materials or equipment that requires training before the training has been satisfactorily completed.
- Supervising another Undergraduate Researcher.
- Working with materials commercialized as, or under investigation as, explosives. Examples are listed in Attachment B, item 1.
- Working with materials understood to be potentially explosive under ambient conditions. Examples are listed in Attachment B, item 2.
- Working with potent oxidizing chemicals that when combined with common substances, which can act as potential fuels, are well understood to create explosive mixtures. Examples are listed in Attachment B, item 3.
- Working with Listed Carcinogens as identified in Attachment B, item 4.
- Working with neat (pure) chemicals, but not diluted solutions, having exceptionally potent health hazards as acute toxins, carcinogens, and reproductive toxins. (These are a subset of Particularly Hazardous Substances, see UCLA Policy 907). Examples are listed in Attachment B, item 5.
- Working with replication-competent pathogens that require BSL2+ facilities (e.g. HIV).
- Working in BSL3 facilities.
- Operating or repairing equipment that requires specialized user training or certification.
Principal Investigators may request exceptions to the requirements set forth herein by submitting a written request to the Office of the Vice Chancellor for Research Safety Oversight Committee (OSOC) (firstname.lastname@example.org). The OSOC will evaluate the request and respond to the Principal Investigator in writing. The request should include:
- Names of the Principal Investigator, Undergraduate Researcher, and other supervisors or mentors (if applicable)
- Description of the research activity involving hazardous materials, as listed in Attachment B, that the Undergraduate Researcher will undertake
- Reasons that it is appropriate for the Undergraduate Researcher to conduct the research activity involving hazardous materials
- Enhancements to safety procedures that will be implemented to allow the Undergraduate Researcher to safely conduct the research activity involving hazardous materials
The OSOC will review all requests for exemptions and make a determination about whether to grant the request. The OSOC may consult with EH&S and others and may request additional information from the Principal Investigator before making its decision. OSOC may impose additional conditions or restrictions as part of the approval process. The Undergraduate Researcher may not begin the research activity involving hazardous materials unless and until the request is approved.
All members of the campus community are responsible for taking appropriate measures to prevent laboratory injuries and illnesses. Specific responsibilities are assigned to designated campus authorities and members of the research and teaching community in order to implement and ensure compliance with this Policy.
A. Principal Investigators
The Principal Investigator must:
- Ensure that every Undergraduate Researcher has completed all of the required General Safety training as outlined in Section III.A. Attachment A, “Safety for Undergraduate Researchers Checklist” is attached to assist in this process
- Consider assigning a specific graduate student, postdoctoral scholar, or staff member as the official mentor or Supervisor for each Undergraduate Researcher
- Identify Undergraduate Researcher(s) and location(s) where they are working in the appropriate forms and the Laboratory Hazard Assessment Tool
- Ensure that every Undergraduate Researcher adheres to:
- all safety requirements set by UCLA (see Section III.A)
- additional safety requirements set by the host school and department
- laboratory-specific safety requirements set by the Principal Investigator
- all additional safety requirements detailed herein (see Section III.B)
- all prohibited research activities detailed herein (see Section III.C)
- Determine when an Undergraduate Researcher must work under Supervision or under Direct Supervision and ensure that these requirements are met
B. UCLA Office of Environment, Health & Safety (EH&S)
EH&S is responsible for many aspects of laboratory safety (see UCLA Policy 811) and will:
- Advise Principal Investigators on all aspects of laboratory safety, including participation of Undergraduate Researchers
- Ensure that required documentation and protocols are in place in the laboratory
- Notify Principal Investigators of any safety deficiencies involving Undergraduate Researchers and advise on recommendations for resolutions and hazard abatements
- Communicate with campus safety committees on safety requirements for Undergraduate Researchers
Principl Investigators who fail to abide by the safety requirements described in this Policy will result in progressive disciplinary action in accordance with EH&S procedures for unauthorized hazardous work in the laboratory and may result in temporary suspension of laboratory activities until corrective action is implemented. The responsible PI may also be prohibited from working with Undergraduate Researchers in the future. Repeat violations by Principal Investigators may be interpreted as a violation of the faculty code of conduct and violations by students or staff may result in disciplinary action under University policies or, as applicable, collective bargaining agreements.
- UCLA Policy 811, “Environment, Health, and Safety”
- UCLA Policy 905, “Research Labroatory Personal Safety and Protective Equipment”
- UCLA Policy 907, “Safe Handling of Particularly Hazardous Substantancs”
- UCLA Policy 992 , “Use of Biohazardous Materials and Recombinant or Synthetic Nucelic Acid Molecules in Research and Teaching Activities”
- UCLA Policy 994, “Radiation Safety”
- UCLA Policy 996,” Chemical and Physical Research Safety”
- UC Policy on Minors in Laboratories and Shops, https://policy.ucop.edu/doc/3500602/MinorsLabsShops
/s/ Roger Wakimoto
Vice Chancellor - Research & Creative Activities