4301 Working Alone in Laboratories

Please see Appendix A: Prohibited Materials and Equipment When Working Alone in Laboratories for additional information and examples of materials and equipment prohibited from use when Working Alone.

PIs must be aware of and understand the risks associated with materials and equipment in their Laboratories.  If they allow Laboratory Members to Work Alone with materials or equipment that present risks to those individuals, the PI must create a documented protocol for Working Alone.

This protocol must, at a minimum, include the requirements of this University policy and should identify activities specific to their Laboratory.  PIs are encouraged and authorized to develop protocols that set specific and more restrictive requirements than described in this policy for those individuals Working Alone in their individual Laboratories.  The PI or their trained Laboratory representative should communicate their specific Laboratory’s protocol for Working Alone to all Laboratory Members.

Please see Procedure 4301 PR.01 Procedures for Principal Investigators on Establishing Working Alone Protocols for Their Laboratories.

Except for Yale College Undergraduates, Minors 16-17 years of age must be approved by Environmental Health and Safety (“EHS”) before being allowed to work in a Laboratory at Yale University.  Minors must be under Direct Supervision by the PI, or trained Laboratory Members designated by the PI, at all times and must abide by Minors Participating in Research or Clinical Activities.  Minors 15 years of age or younger are not permitted in Laboratories.

Visiting Undergraduates and Yale Undergraduates must always be under Direct Supervision by the PI, or trained Laboratory Members designated by the PI, when working with hazardous materials or equipment in a Laboratory.

See Visiting Undergraduates Participating in Research or Clinical Activities for additional information.

If, in an exceptional circumstance, a PI believes that it is necessary for an individual to Work Alone with a class of material or equipment defined in Section 4301.1, above, or Appendix A, below, they may petition EHS and the Laboratory Safety Committee for a policy exception.  An exception must be requested and granted well in advance of the work.  The PI must submit a plan to mitigate the risk with their request for the exception.

The request and accompanying plan will be reviewed by EHS and the Laboratory Safety Committee (“the Committee”).  The PI will be notified by EHS of the Committee’s decision.  Under no circumstances should the work proceed without explicit approval communicated by EHS.

Principal Investigator (“PI”)

Principal Investigators are responsible for:

• Having an in-depth understanding of the hazards of the materials and equipment in their Laboratories as well as the procedures for safely handling those materials and working safely with the equipment.
• Modeling appropriate lab safety behavior, including wearing the appropriate clothing and required personal protective equipment, and requiring Laboratory Members to do the same.
• Planning and conducting research in accordance with the Yale University Chemical Hygiene Plan.
• Understanding and implementing this policy with respect to prohibited activities applicable to each category of Laboratory Members working in their Laboratory.
• Communicating the requirements of this and other relevant safety policies to all Laboratory Members working in their Laboratories.
• Ensuring that all Laboratory Members, including themselves, have been trained adequately on safety policies and protocols, especially in the use of hazardous materials and/or equipment.
• Conducting a risk assessment if they allow people to Work Alone with hazardous materials or equipment.  
• Developing a protocol for Working Alone in their Laboratory, if indicated by the risk assessment.
• Requesting exceptions to this policy from EHS and/or the Laboratory Safety Committee and receiving authorization from EHS and/or the Committee before allowing Laboratory Members to Work Alone and engaging in the hazardous work.

Laboratory Members

Laboratory Members are responsible for:

• Understanding and following this policy.
• Being familiar with the materials and equipment used within their Laboratory and understanding which of those are prohibited when Working Alone.
• Following the Working Alone protocol established for their Laboratory, including any additional more restrictive protocols as set forth by their Principal Investigator.
• Being trained adequately on the hazards of the materials and equipment in their Laboratories as well as the procedures for the safe handling those materials and working with the equipment.
• Wearing the appropriate clothing and required personal protective equipment.
• Planning and conducting research in accordance with the Yale University Chemical Hygiene Plan.

Environmental Health and Safety (“EHS”)

EHS is responsible for:

• Communicating this policy to Principal Investigators and Laboratory Members.
• Reviewing and updating this policy and referenced procedures on a periodic basis.
• Developing and providing training on the appropriate use of hazardous materials and equipment.
• Auditing Laboratory-specific Working Alone protocols during their annual Laboratory inspection.
• Addressing any deficiencies identified during the annual Laboratory inspection and escalate as appropriate.
• Reviewing requests for exceptions to this policy and making recommendations to the Laboratory Safety Committee regarding dispensation.

Laboratory Safety Committee

The Laboratory Safety Committee is responsible for:

• Establishing the parameters of this policy.
• Recommending this policy to the Provost for approval.
• Reviewing and recommending any revisions to this policy to the Provost.
• Making recommendations regarding any deficiencies identified and escalated by EHS.
• Together with EHS, reviewing and determining the dispensation of any requests for exceptions to this policy.

There are certain equipment and materials that pose such a significant risk that no Laboratory Member may Work Alone with these materials or equipment.  (Note: see Special Situations & Exceptions for exceptional circumstances).

A. High-risk Biologicals – biological materials that pose significant risk to individuals, as determined by the University Biological safety Committee on a case-by-case basis.

Examples:

• Select Agents;
• High-risk human pathogens or toxins;
• Work involving animal work and high-risk biohazards;
• Research with large volumes of biohazards;
• Use of high-risk equipment; and
• Biohazard work involving other high hazard materials (chemicals or radioisotopes).

B. Explosive Chemicals – chemical (solid or liquid) which is in itself capable by chemical reaction of producing gas at such a temperature and pressure and at such a speed as to cause damage to the surroundings.

Examples:

• Benzoyl peroxide;
• Ammonium perchlorate;
• Nitrocellulose; and
• Picric Acid.

C. Pyrophoric Chemicals – Chemicals that can ignite spontaneously on contact with air, moisture in the air, oxygen, or water.

Examples:

• Organolithium compounds (t-butyl lithium, n-butyl lithium, s-butyl lithium);
• Diethylzinc;
• Tributylphosphine;
• Trimethyl aluminum;
• Metal carbonyls (lithium carbonyl, nickel tetracarbonyl);
• Alkali metals (lithium, potassium, sodium);
• Finely divided metal powders;
• Metal hydrides (sodium hydride); and
• White phosphorus.

D. Acutely Toxic Materials– Substances that can cause severe adverse effects following oral or dermal administration of a single dose of a substance, or an inhalation exposure of 4 hours, at very low doses (LD₅₀ <50mg/kg oral, LD₅₀ <200mg/kg dermal, LC₅₀ <500ppm inhalation gas or odorless).

Examples – Gases:

• Ammonia;
• Chlorine;
• Carbon Monoxide;
• Hydrogen sulfide; and
• Phosgene.

Examples – Solids and Liquids:

• Acrolein;
• Bromine;
• Cyanide salts;
• Nickel carbonyl;
• Organic metal compounds; and
• Osmium tetroxide.

E. Highly Corrosive Chemicals¹ – these include strong acids and bases, dehydrating agents, and oxidizing agents.  A chemical that produces irreversible damage to the skin or eyes following direct contact with the substance is considered corrosive.

Examples:

• Hydrofluoric Acid;
• Piranha solutions;
• Aqua Regia;
• Phenol;
• Concentrated acids (Nitric, Hydrochloric, Phosphoric, Sulfuric);
• Concentrated bases (sodium hydroxide, potassium hydroxide, ammonia hydroxide);
• Strong dehydrating agents (phosphorus pentoxide, calcium oxide); and
• Strong oxidizing agents (>30% hydrogen peroxide).

F. Class 3+ tools in Laboratories – tools identified as class 3 or higher per the Student Shop Safety Policy.  These include powerful portable and small benchtop tools, light industrial tools, and large industrial tools. See Classification System for Student Access Shops.

Examples:

• Circular saw;
• Belt sander;
• Chop / miter saw;
• Router;
• Angle grinder;
• Bandsaw;
• Drill press;
• Lathe;
• Bench grinder;
• Table saw; and
• Jointer.

G. Highly Hazardous Equipment – equipment that pose inherent risk to the researcher

Examples:

• Parr reactors;
• Bomb flasks; and
• Some High-Pressure Vessels.

H. High Voltage Work – working directly on energized (i.e., live) systems greater than 50 volts, including repair, maintenance, troubleshooting, or testing of electrical circuits or components.

I. Certain Animal Work – handling of large or other animals which can cause serious injury, as determined on a case-by-case basis by the Yale Institutional Animal Care and Use Committee (“IACUC”).

1. De minimis quantities of Highly Corrosive Chemicals (<1 ml) are exempt from this restriction, providing that appropriate PPE is worn, and SOPs are followed.  Transferring from a larger container to create the de minimis quantity is prohibited when Working Alone.