Getting Serious about Training by Paul Rubock
EH&S is charged with ensuring adherence to the training requirements of many safety and environmental regulations applicable to research activities. The purpose of this oversight is two-fold: people trained about workplace hazards are less likely to suffer the consequences of over-exposure to them and, the regulatory bodies frequently conduct unannounced site visits to determine compliance. The first thing they look for are training records. So even if personnel are operating totally within the letter and spirit of a specific regulation, a violation exists if training has not been documented.
EH&S can assess training compliance for Columbia personnel listed on IACUC protocols requiring Hazardous Materials Appendices. When an appendix is attached to a protocol, RASCAL populates it with the Laboratory Safety and Biosafety/Bloodborne Pathogen training dates of protocol personnel. Those with solely administrative or review functions on the protocol must be actively "unincluded‟ from the Appendix or they will receive a training notice that does not apply to them.
Starting February 2011, any Appendix submitted with an IACUC protocol with personnel who are not current on their training will be "held‟ possibly delaying protocol approval until training requirements have been fulfilled. To determine your training requirements, go to:
Controlled Substances: What's New? by Lauren Kelly
Over the past year EH&S has been assisting researchers in meeting federal and state regulatory obligations as summarized in the University's Controlled Substances Policy, as well as on EH&S's Use and Management of Controlled Substances webpage. The Policy and the associated resources and reference documents are continually updated to reflect our most current knowledge of the regulations based on interaction with the regulators. Please check the website (http://www.ehs.columbia.edu/ControlledSubstances.html) frequently for updates to the Policy, Resources and Reference documents. The most significant update for the research community is the requirement, starting February 2011, that Purchase Orders for controlled substances be accompanied by copies of the purchasers‟ DEA Registration, New York State License, and their RASCAL training certificate. The latter document can be obtained by completing RASCAL module TC0502. Purchase orders will not be processed without all accompanying documentation.
The following is a brief summary of some recent additions:
- Updated Policy, including clarification on the difference between Schedule I and II-V
materials as well as direction on reverse distribution, which is more environmentally friendly that other disposal methods for unwanted or expired controlled substances.
- An inspection checklist for license applicants who are preparing for a NYS DOH inspection.
- The name of an additional vendor for purchasing approved narcotics cabinets.
- Updated recordkeeping templates, which should be used in place of the prior templates.
As always, please contact EH&S with any questions or concerns regarding Controlled Substances use in research.