Research Personnel Protection – Policies and Policy Governance

Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including Keck Medicine of USC (“USC employees”). This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.

1. POLICY

Issued: July 2, 2020
Last Revised: July 2, 2020
Last Reviewed: November 18, 2022

2. Policy Purpose

To set forth operational protocols and the responsibilities of USC community members in providing safe places to engage in and perform research and related learning activities.

3. Scope and Application

This policy applies at all times to all USC schools, departments, and members of the USC community (e.g., faculty, staff, students, and guests), in all USC owned and leased properties, including laboratories and university-controlled remote field locations. The following are not governed by this policy:

Children’s Hospital of Los Angeles, which is responsible for its own safety operations;
Hospitals and clinics owned and operated by the Los Angeles Department of Health Services, which are managed by Los Angeles County;
Student activities not directed by a USC faculty or staff member, and not taking place within university owned or leased facilities.

4. Definitions

Term	Definition
Laboratory	Place where one conducts scientific experiments, processes, or other types of research. A place providing opportunity for experimentation, observation or practice in a field of study; or A place equipped for experimental study in a science or for testing and analysis.
Workshop	A facility or dedicated space where one constructs, repairs or makes things, which may involve the use of machine tools such as lathes, milling machines and various hand tools.
High-Hazard Environments	Specifically includes the following: Courses that are determined by USC Environmental Health & Safety (EH&S) to be bound by this policy. Typically, these are courses that involve using hazardous materials and have a “L” (laboratory) designation in the USC (course) Catalogue. Student clubs and other extra-curricular organizations that may expose students to unusual risks, as identified by the Vice President for Student Affairs in consultation with EH&S. Workshop spaces available to students that present potential hazards as determined by EH&S.
Core Lab	A facility that is open to authorized users from different research groups that contains expensive (analytical) equipment, and is managed by a Director or Manager, but can be assigned to a Principal Investigator, which is distinct from their oversight of their research group.

5. Policy Details

PRINCIPLES

Institutional safety is a core priority for USC with dedicated programs for personal safety, accident and injury prevention, wellness promotion, and compliance with applicable environmental, health, and safety regulations. As such, and in relation to university research and related activities, USC is committed to making all reasonable efforts to:

Promote occupational and personal health and safety;
Protect the health and safety of USC students, faculty, staff, and guests;
Share information regarding potential health and safety hazards to faculty, staff, students, and guests;
Identify and correct health and safety hazards and encourage reporting of potential hazards; and
Conduct activities in a manner that protects workplace environment.

All USC community members are expected to perform work safely, and in accordance with Cal/OSHA guidelines and requirements as described in the USC Illness and Injury Prevention Policy. Other hazard-specific policies and guidelines may apply to certain research and learning environments, which can be found in the Office of Research and Office of Environmental Health and Safety.

Responsibility for good health and safety practices begin with the supervisor in the workplace, laboratory or class, and supported by their managers as well as EH&S safety specialists. Managers and supervisors are responsible for taking appropriate measures to ensure the adoption of proper health and safety practices to protect those under their oversight. Please see specific details in “Responsibilities” section below.

HIGH-HAZARD CO-CURRICULAR COURSES & EXTRA-CURRICULAR ACTIVITIES

High-hazard environments require enhanced protocols and requirements to help ensure the safety of all those involved. In these instances, the applicable university dean or vice president must designate a USC employee to manage student safety and provide necessary recourses to effectively do so. The designated employee manager is responsible for the following:

Ensure students complete the USC General Laboratory Safety Training program before commencing activities;
Provide proper supervision of students participating in activities;
Understand and initiate departmental and university protocols in response to a hazardous emergency situation.

Co-Curricular Course Requirements: a qualified supervisor must be present, and supported by the responsible dean or vice president. The supervisor may be a teaching assistant, USC staff member, or faculty member knowledgeable in the course activity. If the immediate supervisor is a teaching assistant, then a USC faculty or staff member must also be present on campus and available to promptly assume the supervisory roles if needed.

Co-Curricular Field Trip Requirements: the course instructor is responsible for arranging appropriate laboratory or workshop safety training and equipment in coordination with USC Environmental Health & Safety (EH&S), and with resources provided by the relevant dean or vice president.

Student Club Requirements: a qualified supervisor must work with the student club and EH&S to develop a standard operating procedure for any club activities that engage in laboratory or shop work when their supervisor is not present. The supervisor is to provide a copy of any such standard operating procedures to the appropriate dean or vice president.

Additionally, all USC faculty, staff, and students engaged in field research should develop and utilize a Field Research Safety Plan via the template provided by EH&S.

ENFORCEMENT

In accordance with the university’s Reporting Wrongdoing Policy, all members of the USC community are to report suspected violations of this policy. Such violations may be reported to a workplace supervisor and/or to EH&S through the university’s “Report a Safety Concern” online form.

If an individual USC community member fails to carry out their responsibilities under this policy, then they may be considered a form of professional misconduct. Any such violation should be reported to the USC Office of Professionalism and Ethics (OPE). OPE will determine if the misconduct rises to the level of sanctioning, and if so, refer it to the appropriate sanctioning body, (e.g., Committee on Professional Responsibility, Human Resources Administration, or Student Judicial Affairs and Community Standards.

If a school, department, or other administrative unit fails to carry out its responsibilities under this policy, then the Office of the Provost and/or Office of the President will review and determine the appropriate disciplinary and/or corrective actions.

6. Procedures

Laboratory Safety Training: https://ehs.usc.edu/training/

Standard Operating Procedures for Laboratory Safety When Using Hazardous Materials: https://ehs.usc.edu/research/lab/sop/

7. Forms

Field Research Safety Plan Template: http://tiny.cc/usc-field-safT-plan

Report a Safety Concern (online form): https://ehs.usc.edu/report-a-safety-concern-form/

8. Responsibilities

POSITION or OFFICE	RESPONSIBILITIES
Office of Environmental Health & Safety (EH&S)	Ensures institutional compliance with applicable policies, statutes, and regulations; develops safety programs and monitors their effectiveness; and provides health and safety services, training, and support to university schools, departments, and administrative units. This includes creating programs, trainings, and protocols for the safe use of hazardous radiological, biological, chemical substances, and lasers in research and other learning environments.Facilitates regular, periodic inspections to identify, evaluate, and correct workplace hazards and unsafe work practices. EH&S has the authority and responsibility to curtail or shut down any university activity that constitutes a clear health and safety danger to the USC community. Develops and recommends university-wide health and safety policies for senior leadership review and approval.
Vice Presidents, Deans, Chairs, Directors, and other Administrators	Manages those under their oversight to ensure compliance with applicable health and safety policies, programs, and practices; provides proper resources and equipment to achieve compliance; and considers safety records and other safety criteria in regular employee performance evaluations.Ensures facilities under their management are compliant with university policies and governmental regulations. This includes ensuring workplaces, laboratories, and related equipment are properly used and maintained consistent with the EH&S guidance. Any non-compliance findings are to be corrected promptly.
Workplace and Laboratory Supervisors & Managers, e.g., Principle Investigators (PI), Laboratory Instructors, Laboratory/Workshop Manager, etc.)	Implements appropriate protocols and procedures in adherence to university policies to protect the health and safety of those working under their supervision (e.g., employees, students, and guests), specifically: Provides appropriate safety training and related information to those under their supervision, including for new hires or guests, when potential new hazards are introduced (via new substances, processes, or equipment), if there is a change in policy or required practices, and the provision and use of personal protective equipment;Promptly reports any unsafe conditions to their supervisor, EH&S, and workers who may be affected;Cooperates and participates in investigations of reported unsafe conditions, hazards, accidents, injuries or illnesses;Ensures employees participate in the university’s medical surveillance program as applicable;Maintains laboratory and shop equipment consistent consistently with regulatory and EH&S guidance. The PI who acquires equipment is responsible for its proper maintenance transfer, or disposal. In the case of a Core Lab, the Director is responsible for ensuring the laboratory equipment is under the care of an appropriate assigned custodian.Facilitates regular safety meetings with employees under their supervision to review reports of To fulfill these responsibilities, workplace managers must have current understanding of the university’s health and safety policies, practices, and programs; cooperate with EH&S to facilitate periodic, requested inspections; and adopt recommended corrections to remedy hazards as needed.
Faculty, Staff, Students, and Visitors in Laboratories and/or Workshop Spaces	Adhere to USC health and safety policies, programs, and practices; Participate in safety training programs as required by the university and/or as directed by their supervisor or instructor; Report any potentially unsafe practice and/or immediate danger to their supervisor, manager, instructor, and/or EH&S; and Communicate hazard information in areas where hazardous chemicals or physical agents are being used or stored. Such communications are to comply with the university’s research policies and hazard communication program.