introduction +
roles & responsibilities
Sections
Introduction + Roles & Responsibilities
Pyrophorics Identification Spreadsheet
Planning for Safe Pyrophoric Work
Pyrophoric and water-reactive materials are high-hazard chemicals that can ignite spontaneously on contact with air, moisture in the air, oxygen, or water (see image of potassium metal/water reaction).
Failure to follow proper handling procedures can result in fire or explosion, with potential for serious injuries, chemical exposure, death and/or significant damage to facilities.
The fatal research lab accident in December 2008 involving tert-butyl lithium is a prime example. The PI was later deemed responsible for inadequate and insufficient safety controls and found criminally liable. The lack of safety controls included:
- Lack of appropriate PPE
- An unsafe work practice for measuring large volumes of pyrophoric liquid
- Improper emergency response procedures (safety shower was not immediately used)
- Lack of training and safety oversight
The takeaway message here is that it is extremely important to optimize safety controls, including adequate system design, supervision, and training to fully manage risk.
The sections listed above outline the hazards, proper handling, disposal and emergency procedures for working with pyrophoric liquids, pyrophoric solids, and GHS Category 1 Materials Which, in Contact With Water, Emit Flammable Gases. However, the following topics are excluded from consideration:
- Pyrophoric gases. These generally must be handled in professionally engineered systems incorporating extensive safety features including gas cabinets, alarms, and automatic shutoffs.
- GHS Self-Heating and Self-Reactive chemicals. These are far less hazardous than pyrophorics when handled on a typical lab scale.
- Categories 2 and 3 Materials Which, in Contact With Water, Emit Flammable Gases. These are significantly less reactive and hazardous than Category 1 materials and do not pose hazards of the same magnitude as pyrophorics.
- Materials which react energetically with water but which are not GHS Materials Which, in Contact With Water, Emit Flammable Gases and which have no tendency to ignition on water contact. Examples of these materials include phosphorus pentoxide, thionyl chloride, and anhydrous aluminum chloride.
NOTE: This is a broad overview of pyrophorics and water-reactive chemicals and shall NOT be a substitute for in-group expertise, detailed knowledge, and laboratory-specific training.
Roles & Responsibilities
These roles and responsibilities are universal in USC workplaces and are not just specific to pyrophoric safety in labs. However, due to the exceptional hazards of pyrophorics and the need for adequate safety controls, it is worthwhile to present a reminder.
Principal Investigator (PI)
The PI is ultimately responsible for ensuring that all handling of pyrophorics and water-reactives in their labs is performed by adequately trained and supervised personnel who fully understand the hazards, consistently use appropriate safety controls, and follow safe work practices.
PIs may delegate specific safety-related tasks (e.g., providing hands-on training or day-to-day safety oversight), but the PI retains ultimate management responsibility for ensuring tasks are delegated only to appropriate personnel (i.e., adequately senior, trained, experienced, and knowledgeable for the tasks delegated), and for ensuring delegated tasks are completed to the required standard. Refer to USC’s Injury and Illness Prevention and Research Protection policies for further information on roles and responsibilities.
If a PI does not have prior experience with these materials, it is incumbent upon them to gain the necessary expertise before their research group embarks upon work with pyrophorics/water reactives. It is recommended for inexperienced PIs to collaborate with faculty colleagues who have pyrophoric/water reactive expertise, which should include sending group members to the experienced PIs’ lab for their initial hands-on training. It is also recommended that PIs have experienced colleagues review their pyrophoric/water-reactive SOPs before embarking upon work with these materials.
PI/Manager/Supervisor Responsibilities
- Overall safety management: The PI (or other manager) has primary safety management responsibility for their personnel and facilities. They are ultimately responsible for providing a safe working environment consistent with USC policies, regulatory requirements, EH&S guidelines, and recognized industry standards/best practice.
- The USC Manager Gateway says this in regards to managers’ safety responsibilities [bold as original]: “…you best know your workplace, the employees, and the demands they face. Therefore, you play a critical role in ensuring health and safety in your area. Ultimately, you are responsible for the health and safety of your employees.”
- Refer to USC’s Research Personnel Protection Policy for further information.
- Key activities required to fulfill the overall safety management responsibility in the context of pyrophorics usage include (non-exhaustive list):
- Safety Rules: PIs shall develop and enforce laboratory-specific policies and procedures for the safe use of pyrophorics, in accordance with University and regulatory guidelines.
- Training: PIs are responsible for ensuring that all personnel working in their laboratory receive adequate training on the safe handling, storage, and emergency procedures related to pyrophorics. Training should include a hands-on component and must be documented.
- Risk Assessment: PIs should conduct thorough risk assessments to identify potential hazards associated with the use of pyrophorics in their laboratory and implement appropriate control measures to mitigate these risks.
- Equipment Maintenance: PIs are responsible for ensuring that all equipment necessary for safe handling of pyrophorics, such as glassware, glove boxes, blast shields, fire extinguishers, etc., is present, accessible, and properly maintained and inspected on a regular basis.
- Standard Operating Procedures (SOPs): PIs are responsible for developing SOPs to cover hazardous equipment/processes/materials in their laboratories.
- Monitoring and Oversight: PIs are responsible for being aware of the activities taking place within their labs, and whether their personnel are following the lab rules and safe work practices on which they have been trained. When personnel are not compliant, the PI is responsible for implementing corrective action, which in the first instance should always be re-training.
Lab Worker/Research Staff
The unusually serious hazards posed by pyrophorics and water-reactives and the specialized techniques required to handle these materials safely obligates research groups to possess a high degree of knowledge and expertise before purchasing or working with these materials for the first time. Note that the broad overview provided by EH&S shall NOT be used as a substitute for in-group expertise and detailed knowledge.
Responsibilities (non-exhaustive)
- Compliance: Must comply with all laboratory-specific policies and procedures related to the safe handling of pyrophorics, as established by the PI.
- Training: Participate in training sessions provided by the PI to understand the specific hazards associated with the use of pyrophorics.
- Safe Work Practices: Are responsible to follow the safe work practices in which they have been trained, and which are communicated via SOPs and lab safety rules.
- Monitoring and Reporting: Must be aware of their working environment and for reporting (to the PI or other safety personnel) any safety concerns they observe. Lab workers should notify the PI if they do not fully understand the hazards of the materials they work with or feel they need additional training or safety information.