Lab Inspections

Violations documented during laboratory inspections activity are defined as follows:

Other-than-serious (Other):

A condition that could result in an accident or injury that is less than serious in nature.

Serious:

A condition that could result in death or serious physical harm or major regulatory action against the University (penalties of $5,000 or more).

Repeat:

A serious violation of the same type observed in two consecutive inspections.

Willful:

A serious violation of the same type observed in three consecutive inspections.

Facility:

A condition whereby equipment associated with the laboratory, e.g., emergency eyewash/showers, a chemical fume hood, fire extinguishers, etc., is compromised and requiring repair.

Note:

When two or more individual violations are found which, if considered individually represent Other-than-serious violations, but considered in relation to each other create a condition that could result in death or serious physical harm or major regulatory action against the University (penalties of 5,000 or more), the individual violations will be documented as serious.

After the laboratory inspection has concluded, present available laboratory personnel are counseled on the violations and actions to correct. Violations that are easily corrected are encouraged to be corrected at this time. Any additional concerns or questions are also discussed. The inspection report consisting of the violations and actions to correct is then forwarded via email within 5 working days to the Principal Investigator, a departmental contact if one is appointed, and to the chairs of the departments.

Effective January 1, 2007, inspections will document violations that persist year after year as a Repeat Violation. When a Repeat Violation is documented, a follow-up inspection will be conducted within 30 calendar days from the date the violation was documented. If the violation has not been corrected at the time of the follow-up inspection, the violation is referred to the appropriate senior academic official or administrative official for action.

If a Facility violation is documented, Occupational Health and Safety (OHS) will forward a notice of deficiency to the appropriate department for correction, e.g., Physical Plant Division, Fire Marshal's Office.

It is the department's responsibility to determine how best to follow-up and ensure these violations are corrected. Many departments have used their safety committees for this function. OHS remains available to assist in correcting any and all violations.

Violation Examples

The violation examples below are the most common violations found at the University of Kentucky.

Chemical Storage
CHP Manual
Compressed Gas Cylinders
Controlled Access
Door Signage
Electrical
Eyewash
Fire Extinguisher
Flammable Storage
Food
Fume Hood
Hazardous Waste
Housekeeping
Labeling
Other
Peroxide Former
PPE
Safety Shower
Training

Legend:

S - Serious Violations

O - Other than Serious Violations

F - Facilities Violations

Chemical Storage

S	Incompatible Chemicals Stored Together Acids/bases Flammables/oxidizers Organic/inorganic Acids Water Reactives/Water or Water-based Compounds Oxidizers Stored on Incompatible Shelf Material	Example Example
	Containers Not Sealed Properly	Example
	Containers Compromised Corroded Cracked Leaking	Example
O	Fume hood utilized for storage while actively being utilized for chemical operations
F

CHP Manual

S	None	Request
O	Not Completed	Example
O	Varying degrees of incomplete No SOPs for Select Carcinogens, Reproductive Toxins and Acutely Toxic Chemicals No Chemical Inventory No Lab Specific Training Documentation Incomplete ID Page Information Not Current	Example
F

Compressed Gas Cylinders

S	Unsecured	Example
	Not secured properly
	Exceeding limits for storage per UK policy	Fact Sheet
	Toxic gases not in continuously ventilated hood or gas cabinet¹. Would include but not be limited to: arsine, diborane, germane, phosphine, nitric oxide, methyl bromide, boron trifluoride, chlorine, chlorine trifluoride, dichlorosilane, hydrogen fluoride, nitrogen dioxide, phosgene, sulfur tetrafluoride, ammonia, boron trichloride, boron trifluoride, carbon monoxide, carbonyl sulfide, ethyl chloride, hydrogen bromide, hydrogen chloride, hydrogen sulfide, silane, and disilane	Example
	Incompatible gases stored together • Flammables/oxidizers
	Utilizing regulator as isolation device	Example
O	Valve caps not on cylinders in storage	Example
F

Controlled Access

S
O	Lab left unlocked and unattended
	Children in lab	Example
	Pets in lab
F

Door Signage

S
O	None	Forms
	Incomplete
	Outdated/incorrect information
F

Electrical

S	Damaged/frayed power cords
S	Use of appliances not UL listed for application • Blenders • Heat guns/hair dryers
O	Ext cords utilized for permanent wiring	Example
	Use of multiple power strips inline	Example
	No strain relief on energized cords	Example
F

Eyewash

S	Blocked/obstructed eyewash	Example
O
F	Non-compliant eyewash	Example
F	No eyewash

Fire Extinguisher

S	No Fire extinguisher	E-mail
	Fire ext. discharged and not reported
	Fire ext. blocked	Example
O	Fire ext. not in wall mount
F	Fire ext. not inspected annually
	Fire ext. not charged – “not in the green”	Example
	Fire ext. not mounted

Flammable Storage

S	Storage amounts exceed Solvent Storage Policy	Policy
	Flammables stored in unapproved refrigerator
	Unapproved flammable storage cabinet • Three latch inoperable • Not FM or UL listed
	Cabinet not closed	Example
	Vent caps removed
O
F

Food

S	Evidence consistent with eating and/or drinking in the lab	Example
S	Storage of food in lab area	Example
O
F

Fume Hood

S	Sash above working height during use	Example
	Alarm rendered inoperable via tampering
	Using hood when failing	Example
	Baffles obstructed	Example
	Incompatible chemical utilized with standard fume hood • Perchloric acid	Policy
O	Excessive chemicals/equipment in hood	Example
F	Hood in alarm mode	E-mail
	Alarm not functioning	E-mail
	No flow indicator and/or alarm	Guide

Hazardous Waste

S	No label
	Label incomplete • “Hazardous Waste” not on label • No date as to when full • No name of contents listed	Example
	Waste not ticketed for pick-up when container full	E-mail
	Open containers of HW	Example
	Evidence of improper disposal
O
F

Housekeeping

S	Means of egress, i.e., aisles, doorways blocked
O	Chemical stored in aisle ways – obstructing egress and spill potential
	Slip/Trip hazards – power and extension cords, liquids on floor	Example
	Overabundance of combustibles
F

Labeling

S	Chemical containers not labeled	Example
	Illegible container labels	Example
	Label incomplete • No chemical name
O	Food stuffs utilized for research not labeled for intended use, i.e., “food not to be used for human consumption”
F

Other

S	Machine not guarded
O	No vacuum trap utilized with vacuum source
	Utilizing chipped or broken glassware
	Improper disposal of glassware (deposited in regular trash in lab)
	Overfilled sharps container	Example
	No annual certification of biological safety cabinet	Example
F

Peroxide Former

S	Not dated for disposal in accordance with guide sheet	Policy
S	Not disposed of by mfg’er expiration date	Example
O
F

PPE

S	Not wearing PPE in accordance with CHP PPE Hazard Assessment	Request
	Improper storage • Contamination of PPE • Degradation of PPE	Example
	Improper PPE selected
	Improper use of PPE • Improper type • Wearing gloves outside of lab
O	Improper attire
F

Safety Shower

S	Blocked/obstructed	Example
S	Shower activation handle tied back	Example
O
F	No shower
	Non-compliant shower • No stay open valve
	Handle height greater than 69

Training

S
O	All affected employees not received Chemical Hygiene Plan/Laboratory Safety Training	Training Page
O	All affected employees not received Lab Specific Training	Training Forms
F

Research Safety