For Your Records by Chris Pettinatoume
A University researcher was recently visited by two Special Agents from the US Drug Enforcement Administration (DEA). What began as a routine, unannounced visit to verify the address listed on the researcher’s registration, turned into a much more thorough, and time-consuming effort. As with all inspections, this one began with the inspector requesting to review the researcher’s controlled substances records; it was here where the inspection took an abrupt turn due to the researcher’s lack of awareness of the University’s Policy for the Acquisition, Use and Disposal of Controlled Substances (http://www.ehs.columbia.edu/ControlledSubstances.html).
Following the visit, the lab contacted EH&S for assistance (an aside, if you are visited by an inspector, please contact EH&S immediately). EH&S was informed that the DEA has some difficulty interpreting the lab’s records, which were being kept as entries into lab notebooks, as opposed to specific, stand-alone forms, as is typical. EH&S directed the lab to the Policy (website) which provides recordkeeping templates for researchers to use in documenting their receipt, use and biennial inventory for controlled substances, as required by DEA and New York State Department of Health Bureau of Narcotics Enforcement laws and regulations. The Policy is also supported by numerous Appendices, Resources and Reference Documents, including the recordkeeping form templates, as well as a Rascal-based training program which must be completed by all individuals involved in research (non-human) with controlled substances. Of note, the laboratory staff are now trained and are utilizing the template recordkeeping forms and we trust the DEA is satisfied with the lab’s efforts.
The Policy and the Appendices, Resources and Reference Documents, including the recordkeeping forms, should be reviewed regularly as modifications, based on experience through visits from NYSDOH and DEA occur. The Policy and Appendices, Resources and Reference Documents are accessible at http://www.ehs.columbia.edu/ControlledSubstances.html.
Is your lab moving? We are here to help! By Tasha Hightower
Columbia University is a dynamic and ever-evolving institution; at any given time a number of Researchers/PIs may be moving in and out of assigned lab space. Prior to vacating a Columbia University laboratory, whether it be for a renovation, relocation, or departure from the institution, certain procedures (Procedures for Vacating a Laboratory) must be followed to ensure the safety of all parties involved in the move, as well as the safe and efficient turnover of the space. The goal is to ensure that all staff members, outside venders and the environment are protected and not unnecessarily exposed to biological, chemical, or radioactive material. The Vacating Procedures and Clearance process also ensures that all applicable regulations are adhered to.
During vacating, EH&S and Facilities work together with the lab to ensure a smooth transition process. Time is of the essence, so once a laboratory knows they are moving, please notify EH&S immediately so we can assist you through the process. Lab space must never be abandoned, nor reoccupied, and construction cannot commence until the lab has been inspected and “Cleared” by EH&S. In spaces where the PI is permitted by the University to use radioactive material, the lab is also required to obtain Clearance from the Radiation Safety Program. It is the responsibility of the PI to leave laboratories in a state suitable for re-occupancy or renovation.
Please refer to the Laboratory Safety Manual (http://www.ehs.columbia.edu/Policy1.10.html) for more information on the University's lab vacating procedures or contact your Research Safety Specialist (http://www.ehs.columbia.edu/LabAssignment.html) for assistance and guidance.