EH&S Project Short-term Questions -
with Proposed Answers

Last updated by Jim Repa, 5/1/2002

Some terminology issues

• Recording of data vs. registration of a lab or other facility

  A number of questions have included the term "Registration". There should be two different processes going on related to data stored in the Labs Database, only one of which should be called "Registration".

  Recording of data

  Data on each lab or other facility will be recorded, including room(s), people working there, and generic hazard types.

  Registering a lab or other facility

  MIT will define a process by which a lab or other facility along with its supervisor (or PI) is registered to use radioactive materials, biologicals, etc.. This is a different process than merely recording the existence of the lab or other facility with its pertinent data. (It is possible that my definition of "registration" will be altered, but in any case, registration will certainly not be the same as merely recording information about a lab or other facility.)

The questions, and proposed answers

Question #	Question	Initials
Manual:
1	EMO Procedures?	MB
Emergency Response:
2	What are the data requirements for Emergency Response? JR's proposed answer: Shortest term: Uptodate list of contacts and phone numbers for each lab or other facility Short term: List of generic hazard types in each lab or other facility. (This list should not change very often, so it will not take much effort to keep it uptodate.) Medium term: Mapping of rooms so that we can quickly determine what hazards are present on the other side of a wall, floor, or ceiling Longer term: Real-time inventory of specific hazardous substances of interest to emergency response people, per room, with an estimate of the amount	TH
Organizational Structure:
3	Does registration register: lab, person or project? JR's proposed answer: We will "register" a lab or other facility + its PI/supervisor to have MIT's endorsement to use radioactive materials, biologicals, etc.. (The "registration" process is different from the process of "recording" information about a lab or other facility in the Labs Database. All facilities should be recorded in the Labs Database. It will take an extra step for a supervisor (PI) and his/her facility to get "registered" to use radioactives, biologicals, etc.)	JR
3A	Is there a trigger that initiates registration of a DLC that previously did not need to be registered? JR's proposed answer: I presume that Bill means "lab or other facility" instead of DLC. I also presume that he means "record" rather than "register". There are some events that should cause a flag to appear on a report that would indicate that someone may need to record a lab or other facility in the Labs Database. Periodically compare Facilities' SPACE table (in the Warehouse) with the Labs Database list of labs and rooms. The Labs Database should account for all rooms marked "RESEARCH LAB", "TEACHING LAB", etc. in the SPACE table. Flag any such rooms not accounted for in the Labs Database. When a new Supervisor or PI appears on COEUS, it is possible that the PI will be running a Lab. Periodically compare changes in the list of PIs from COEUS to the list of PIs from the Labs Database. Not all PIs have a Lab or Facility, so this comparison will produce many false alarms, but it may still be worth doing.	BW
3B	Who will input lab registration data? JR's proposed answer: Again, I presume that we're talking about just recording lab data, not going the extra step of "registering" a lab and its supervisor/PI to work with a certain class of materials. See questions 15 and 15A.
3C	What is the expected completion date for lab registration input? JR's proposed answer: (Let's drop the word "registration" from the question.) Fall of 2002?
3D	Are all Chemicals going to be registered? JR's proposed answer: (Change "registered" to "inventoried".) No. There will be a list of specific chemicals that we will track in the inventory, and we will ignore the rest. Presumably we'll start with the "list of lists", but there are going to be some tricky issues here (which I'm sure the Inventory team has been struggling with).
4	How do we ensure that the defined organizational structure maps to SAP M.M. JR's proposed answer: The EH&S Org Team should not be inventing a new organizational structure. There will be an official master org unit hierarchy defined under Dan Fitzgerald's new HR project, and this should be the one used by the EH&S team. There is a department hierarchy in the Roles DB now that can be used in the interim before Dan Fitz's org chart is made public. The Warehouse and Roles DB team have been thinking through the issues to make sure the new org chart will be well integrated with financial and other org units at MIT, and the linkage tool (between an org chart and other entities) should be able to handle links to MM objects if that becomes necessary. I've had a brief conversation with J-M Quilter and Steve Roach, and it seems that integrating the org chart with MM should be quite doable. We'll have to nail down the details at some point -- let's put that on the project plan for 6-12 months from now.	TH
5	Who will be your "B"/"C" in new structure? JR's proposed answer: My guess is that we'll have to assign these roles as an extra step -- they cannot be inferred from job title or any other existing system data. So, the question I'd rather ask is: Who will decide who the "B"/"C" person will be for any given DLC?	DW
6	What qualifications or background should a "B" have for the DLC?	DW
7	Does your DLC currently have a level "B"/"C" person now? If yes who?	DW
8	Who will be on the DLC Internal Committee?	DW
9	Which Organization model will your DLC choose? JR: What does this question mean?	DW
10	What basic tools will we give DLC's?	TC
11	Can the "C" legally be a Post Doc., Grad. Student, or non-employee? JR's proposed answer: Yes. Once we decide who gets to choose the "C" person, we let that person choose whoever they consider appropriate. Again, we need to set the rule for who decides the "C" person is. There can be a chain of command for making these decisions.	TC
12	How much time does "B"/"C" take currently to do duties?	DW
12A	How much time will "B"/"C" need to do duties in new structure?	DW
12B	Would 1 hour per month pose a resource problem for DLC? JR's proposed answer: I sure hope not. We cannot pretend that the data we need for any realistic system will just materialize out of thin air (or out of other systems that never have and probably never will record it), so somebody has to spend some time recording and maintaining some data. If it is necessary to give the DLCs support from central resources, that will be fine, but they still need to be involved.	MD
13	What are the top 3 EH&S issues that you feel your DLC needs to focus on to ensure MIT is in compliance with applicable EH&S laws and regulation? JR's proposed answer: My top three (for the short term) would be: Make sure that the data in the Labs Database is kept uptodate for labs and other facilities within your DLC. Without these data, we cannot be certain that we've identified all the people who need to be properly trained. Data in the Labs Database will also help us with other auditing efforts. Make sure that your DLC assists in the review of lists of people in each lab and whether they have met training requirements. Make sure that your DLC encourages an atmosphere of awareness and responsibility regarding MIT's environmental policies.	MD
14	The MIT EH&S MS is conducting a facilitated workshop(s) in April to get DLC involvment, are you willing to commit a person for this workshop to make this program a success? JR's proposed answer: Too late.	MD
15	Who puts new labs in the Labs DB?(A/B/C?) JR's proposed answer: It needs to be departmental adminstrators (B-level people?) or their designees. This questions relates to recording the existence of a new lab or other facility along with its rooms and its PI, but not the details of people, contacts, or hazard types.	JR
15A	Who will maintain, update people and contacts for Labs DB? JR's proposed answer: This question relates to recording, and periodically updating, the list of contacts and other people working in a lab or other facility, along with a list of generic hazard types. This needs to be someone close to the lab or other facility - a C-level person, most likely. If this is not acceptable to the labs, then maybe we need to hire and assign additional assistants for the DLCs. We cannot get these data for "free" from any other existing system, but they should be viewed as a natural extension to the existing Green Cards.	JR
15B	Who will enter the new Post Doc. Into the LPH DB? JR's proposed answer: This is covered by 15A.	TC
16	How will partnering work outside EH&S? JR: What does this mean?	MB/JR
16A	Is there a team and how will it work? JR: What does this mean?	TC
Training:
17	How should proximity to hazard types VS. personal role/function be handled for training needs? JR's proposed answer: The training needs assessment program will be able to key on any combination of a person's role/function or hazard types (as well as DLC affiliation, specific academic lab course, and possibly job title). Initially, we will probably not base training needs on proximity to hazard types in a lab, because we may not have complete information about this, and because the training team prefers to use role/function (e.g., uses lasers, uses chemicals in a lab, etc.). However, I think we will eventually want to base at least some course requirements, e.g., biological or radioactivity "awareness training", on the fact that someone works near these materials. In addition, there may be auditing or reasonableness checks concerning the percentage of people in a lab with a given hazard type who have been trained for using it, just to make sure we are being honest about recording who works with various hazard types.	JR
18	Who will train level "c"?	MG
19	How to tie training to overall DB? JR's proposed answer: I think my data flow diagram answers this.	MB
20	How much time will be needed by the "B"?	DW
21	When in May will we be training DLC's?	TC
22	What data is needed on Registration form?	MG
23	Will inventory purchases define the need for training? JR's proposed answer: No. Not directly. The criteria for who needs training were listed in item 17. Generic hazard types may drive training. The only connection with Inventory is that Inventory will be cross-checked against recorded hazard types recorded for a lab in the Labs Database. Another related question is "Do people need hazardous materials training before they can order chemicals or other hazards?" The answer must be "No", since the people ordering these things are not necessarily the people who use them. However, there should probably be some additional authorization or approval step for hazardous materials, so appropriate individuals either centrally or in DLCs sign off on these purchases.	TH
23A	If Inventory purchases define training need, what are the qualifications? JR's proposed answer: See item 23.	TC
24	When will other Web based training be available?	TC
25	How will training happen before new employee starts actual work in lab? JR's proposed answer: B or C level people will tell new lab workers to take the web-based training needs assessment and do training before they start to work in the lab. DLC officials will also enter data about people working in each lab so we can cross-check their data with each lab worker's self-reported training needs assessment data.	PG
25A	Can lab people work with Hazardous Materials before training? JR's proposed answer: My opinion is that MIT should have a policy that people must get training before working in a lab, and each DLC should implement its own procedures, with help from central EH&S people, to enforce this policy.
26	Should training records be restricted access, e.g. Biology can't see Chemistry? JR's proposed answer: In the first phase, no. We will have a list of people who are allowed to view training records, and they can view all training records. In a later phase, I think we should build in the flexibility to restrict access by DLC, but I don't know what rules the DLCs will agree on.	PG
27	What is a "Lab-Suite" and will it work for DLC's for inventory location vs. BT room? JR's proposed answer: A Lab-Suite is a laboratory composed of one or more rooms under the same PI in the same building. I think Inventory will record the location of containers of materials at a more detailed level than the Lab-Suite, at least at the room level, and possibly at the shelf location level.	TC
Inventory:
28	What must be inventories fields? JR's proposed answer: Since Inventory is a longer-term project, these are probably not short-term questions. However, I think the Inventory Team has proposed some answers for the structure of data they will store, and we should record these answers here and on the data flow diagram.	TC
29	Define content of inventory specifications, data beyond basic scope?	TH
30	What are the requirements of data output for reporting?	TH
31	Will all purchaases of potentially hazardious materials require approval?	MG
32	Inventory design?	MB
33	How much time will be needed by the "B"?	DW
Audit:
34	What is expected of Audit Team in the short term? JR's proposed answer: In the short term, the Audit Team should start listing the questions that must be answered that must be verified by the audits. What policies for storing substances, disposing substances, training people, etc. will we have? (Get this from other teams.) What questions must we answer to confirm or check on the compliance with these policies? Even a partial list will be useful to identify the sorts of questions to be answered and anticipate how data from other systems can be used.	MB
35	What are the data requirements for auditing? JR's proposed answer: Many of the data items described for other parts of the project should be considered as source material for verifying compliance with policies, including training records, people and their roles in labs or other facilities, hazard types in facilities, and later inventory items. In addition, Auditing should have its own database to record additional data, e.g., results of spot checks of storage procedures, disposal procedures, people in a lab or other facility properly recorded, etc..	TH
36	How much time will be needed by the "B"?	DW
37	Does your DCL currently have a written documented internal EH&S self assessment program?	MD
37A	Does your DCL currently have a written documented internal EH&S assessment reporting system?	MD
37B	if yes, would you provide the tool you are using?	MD
38	Would your DLC be willing to offer a person to be part of a team to implement the MIT EHS audit program?	MD
39	Will we be using a standard paper audit for next year? JR's proposed answer: It would be better to answer the right questions and record them in a low-tech way than to start by concentrating on devices to be used and short-change the issue of what you are going to audit.	MG
39A	Who will keep audit reports?(B/EHS)	MG
System Integration:
40	If A/B person defines existence of lab, will this map to SAP materials MGMT Systems? JR's proposed answer: Yes, after the data have been exported to the Data Warehouse each night.	TH
41	What is the role of the Facilities Space Management DB? JR's proposed answer: I'm working with the Facilities people to coordinate our proposed Labs Database with their system, so that we only have one system of record and entry point for the data.	BW
42	Should we schedule a "Demo" of the Facilities Management DB? JR's proposed answer: Bill has already scheduled a meeting concerning this.	BW
43	Can we show "Future Inventory System" on J.R.'s drawing? JR's proposed answer: Yes. Soon.	BW
Web Resources:
44	What EHS lab look-up information is missing from websites: MIT Env., Bio Safety, Env. MGMT Programs, IND Hygiene Programs, Radiation Protections & Safety?	LV
Communications:
45	How can we make this project an unbelievable success?	TC?
Overall:
46	How do we measure success for each thing accomplished?	LV
47	How can we make this project an unbelievable success?	TC?
48	What other strategic projects are happening through MIT that we should factor in? JR's proposed answer: The new HR project. This is a project that is struggling with the Lincoln Lab issue, and will not be in a position to deal with EHS-specific issues for at least a year, so we need to proceed without them and plan to get back together after their dust settles.	LV
49	What is the acceptable level of compliance?	MB
50	When are we going to go visit the EPA with the work up to date?	TC
Labs Database:
51	What general hazard types do we collect for labs? JR's proposed answer: Maybe we start out with a short list, related to training needs, and expand in a later phase.	JR
52	Do we do this now(MAY) or later? JR's proposed answer: The sooner the better. We should at least try to do a pilot with a couple of DLCs this summer.	JR
53	Will the general hazard types being defined match up to DOT class or other? JR's proposed answer: If we start out with a short list, initially, they will be simpler than the DOT classes and we should be able to map the DOT hazard types into our own, in most if not all cases.	TH
54	What are the categories of Hazards? JR: Same as 51.	TH
55	If A/B person defines existence of lab, will this map to SAP materials MGMT Systems? JR: Same as 40	TH
56	Who will maintain, update people and contacts for Labs DB? JR: Same as 15A	JR
57	Will allowing only one DLC designation work? JR's proposed answer: For Labs, yes, only one DLC per lab. (For reporting and accountability reasons, we should have one DLC-in-charge for each lab or other facility. I'd like to try to get the DLCs to agree to this.) For trainees, we need to record more than one DLC per trainee.	PG
58	Piloting lab DB: Who?(DLC) When? JR's proposed answer: We need to work with Bill V. on this one.	JR
59	In Lab DB are "contacts" a separate set of fields or the same as "Who works in this lab"? JR's proposed answer: I think they have to be different.	JR
60	Who do we need approval from for Labs DB?	JR
61	Can we do crash course of getting lab DB populated before June? JR's proposed answer: Let's make that some time in the fall rather than June.	JR