UC Chemical Safety & Security Initiative – A Collaborative Approach

Erike Young, ERM Deputy & Director of EH&SLuanna Putney, Executive Director of Ethics and Compliance

Goals

• Understand the risks related to chemical safety and security in higher education

• Discuss considerations for prioritization of key risks

• Provide input on risk mitigation activities for sharing with UC Chemical Safety and Security Workgroup during first meeting in July

Regulatory compliance describes the goal that corporations or public agencies aspire to in their efforts to ensure that personnel are aware of and take steps to comply with relevant laws and regulations.The United States Sentencing Commission defines an effective compliance program as one that:1. Exercises due diligence to prevent and detect criminal conduct; and2. otherwise promote an organizational culture that encourages ethical

conduct and a commitment to compliance with the law.

Risk management is the identification, assessment, and prioritization of risks (defined in ISO 31000 as the effect of uncertainty on objectives, whether positive or negative) followed by coordinated and economical application of resources to minimize, monitor, and control the probability and/or impact of unfortunate events to maximize the realization of opportunities.

Risk Services

ComplianceA

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Managing Risk: Congruent Goals

• Targeted Risk Assessment

• Risk Financing• Risk Control /

Mitigation• Promote culture of

risk awareness

Risk Services

• Assess Regulatory Risks• Develop Mitigation Plan• Monitor Key Mitigation

Activities• Promote culture of

ethics and compliance

Ethics & Compliance • Assess Key Financial and Operational Controls

• Advisory Services• Key Management

Business Partner

Internal Audit

• Strategic Planning• Managing Identified

Risks from all Perspectives

Campus/Lab/OP Management

Assisting Campus/Lab/OP to Meet Operational NeedsAcross All Risk Venues

Understanding the Risks

In the News…..• UCLA Settlement

Agreement• UCSF Lawsuit regarding

Richard Din• UC Davis Chemical Surety

David Snyder

Understanding the Risks

Regulations galore…. Law enforcement….• Cal/OSHA• DOT• DOE• EPA• FAA• TSCA

Understanding the Risks

Enforcement focus…..• Proposed Changes to

Cal/OSHA Section 334 -Repeat Violations– Current regulations allow for Repeat

Violation when same violation occurs at same campus/department

– Proposed Regulation would allow for Repeat Violation when “employer” has same violation at another location in state.

– Potential for increase for• Repeat Violations - $18,000• Serious and Willful - $70,000

National trade organization attention….

What is “Risk”?

Risk is present in everything we do.

ISO 31000 definition of risk:

Risk = the effect of uncertainty on objectives.

Risk can be a threat or an opportunity

Anything that could harm, prevent, delay or enhance your ability to achieve your objectives = risk

What is ERM?

(Enterprise) Risk Management is a coordinated effort to direct and control all activities related to risk.

It defines risk as the effect of uncertainty on objectives. It therefore ties the management of risk to what is most important to the organization.

The responsibility for managing risk is spread across the organization to those who have accountability and authority – risk owners.

ANSI/ASSE/ISO 31000:2009

Types or Risk Exposures in ERM Hazard risk ◦ risks related to accidental losses, such as workplace injuries, liability torts, property damage, and

natural disasters. Financial risk ◦ risks related to financial activities, such as pricing, asset valuation, currency fluctuations, and

liquidity. Operational risk ◦ risks related to operations, such as supply chain, customer satisfaction, product failure, or loss of key

personnel. Strategic risk ◦ risks related with an organization’s long-term goals and management, such as partnerships, mergers,

and acquisitions. Compliance risk ◦ risks related to violations of or nonconformance with laws, rules, regulations, prescribed practices,

internal policies, and procedures, or ethical standards.

Reputational risk ◦ risks related to the trustworthiness of business. Damage to a firm's reputation can result in lost

revenue or destruction of shareholder value.

Fire Extinguishers• Cal/OSHA Title 8 CCR 6151- Fire Extinguishers

e) Inspection, Maintenance and Testing. • (1) The employer shall be responsible for the inspection, maintenance

and testing of all portable fire extinguishers in the workplace. • (2) Portable extinguishers or hose used in lieu thereof under Subsection

(d)(3) of this Section shall be visually inspected monthly.

(d) Selection and Distribution. • (1) Where portable fire extinguishers are provided for employee use,

they shall be selected and distributed based on the classes of anticipated work place fires and on the size and degree of hazard which would affect their use.

• (2) The employer shall distribute portable fire extinguishers for use by employees on Class A fires so that the travel distance for employees to any extinguisher is 75 feet (22.9m) or less.

Assessing the Risks

• Multiple models to identify and prioritize risks

Controlling Risks

• Concept of Undercontrolled and Overcontrolled

• What are examples of undercontrolled risk?

• What are examples of overcontrolled risks?

Case Study – Identifying the Risks

Billy is a 2nd year undergraduate at UCX and was just accepted into a large prestigious lab to conduct experiments related to the mammalian cell cycle. The experiments he will conduct require use of several dangerous chemicals to disrupt the cell cycle. He has never worked in a laboratory before and will be responsible for everything from ordering materials to disposing of experimental waste. What operational, strategic, financial, and compliance/ethics risks should be considered when thinking about chemical safety and security?

Case Study: Chemical Safety and Security Risk Assessment

• Risk Ranking Tool -- Exercise

Prioritization of Risks: Risk Ranking Using the UCB Model

First Meeting: July 24, 2014

What Does This Group Need to Know?

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