Applies to:	Original Policy Date:	Effective Date of Last Review:	Approved by:
COES Lab Faculty, Staff, Student Workers, and Volunteers	August 2024	August 2024	Dr. John Nicklow, President

Document Code: PW-P1

Policy Owner: College of Engineering and Sciences Panther Works Operations Team

Policy Purpose

This policy ensures that all College of Engineering and Sciences (COES) lab employees adhere to the mandatory safety and compliance training requirements as specified by federal and state regulations, and Florida Tech COES guidelines.

Policy Scope

This policy applies to all COES lab employees, including faculty, staff, graduate student assistants, college role workers, federal work-study student workers, and all unpaid volunteers.

Policy Statement

All COES lab employees must complete mandatory safety and compliance training through the university’s online training management system, tailored to the specific risks associated with their lab spaces.

Procedures/Guidelines

1. COES Lab Supervisors:
   • Complete the P1-F1 Laboratory Safety Training Questionnaire form upon assignment to a lab space and whenever new risk factors arise.
   • Post the unique P1-F2 Laboratory Safety Training Requirements form in a visible location within the assigned lab space(s).
   • Complete the P1-F3 Training Group Request form for all individuals who intend to work in the assigned lab space.
   • Ensure all individuals working within their assigned lab space complete all safety and compliance training listed on the P1-F2 form annually.
2. Panther Works Lab Managers:
   • Use the P1-F1 form to create a P1-F2 form specific to each lab space.
   • Review and verify the completion of training requirements listed on the P1-F2 form before granting lab access to lab workers listed on the P1-F3 form.
   • Provide a deadline reminder to all COES faculty in January upon university return from winter break.
   • Provide a final deadline reminder to all COES faculty on the first business day of February.
3. Training Completion:
   • All training requirements must be completed upon hiring and every January thereafter.
   • HR training requirements must be completed within 30 days, and general lab and lab-specific training must be completed within 60 days of receiving the P1-F2 form from the Panther Works Lab Managers.
   • Lab employees (anyone being paid to work in the lab space) must only complete required training during working hours on or after their contracted start date.
4. Lab Access:
   • COES Lab Supervisors must ensure the lab workers have completed the training requirements on the P1-F2 form and then the P1-F4 form before allowing lab workers access to the lab space.

Compliance Reference

The laws and regulations encompassed within this policy:

• 29 CFR 1910.1450
• 1926.21
• 1910.38(e)
• 40 CFR 262.17(a)(7)
• 40 CFR 273.36
• 1910.157(g)(2)
• 1910.1200(h)(1)
• 29 CFR 1910.1030
• 49 CFR Parts 172-173
• 64E-4 F.A.C. and 21 CFR 1040
• 40 CFR 112.7(f)
• 1910.134(k)
• 64E-16 and 1910.1030

Responsibilities

COES Lab Supervisors: Florida Tech faculty and staff overseeing the day-to-day operations and management of a COES lab space. Additionally, they are responsible for ensuring all workers (both paid and unpaid) engaging in lab work within their assigned lab space complete the required training.

Panther Works Lab Managers: COES staff responsible for regulating the management and safety of lab spaces within COES. Additionally, they are responsible for reviewing and revising this policy to ensure its effectiveness and relevance to compliance requirements.

Enforcement

Enforcement Scope: Failure to complete the required safety and compliance training within the specified deadlines will result in a formal written reprimand from the COES Dean to the COES Lab Supervisor. A new deadline will be set to correct the training delinquency. Continued failure to meet the deadline will result in the shutdown of the assigned lab space.

Enforcement Procedures

Initial deadline and submission: All lab supervisors are required to complete the mandated safety and compliance training by the specified deadline to ensure the establishment of comprehensive laboratory standards in compliance with 29 CFR 1910. This standard emphasizes a "performance orientation" approach to safety and compliance training, indicating that employers are responsible for developing standard operating procedures in alignment with the general minimum requirements for safe working environments as outlined in the standard. These requirements should be tailored to the specific working conditions of all laboratory personnel. Completing the training courses specified in this policy is essential for maintaining safe laboratory operations.

First instance of non-compliance: If the required safety and compliance training is not completed by the deadline, the COES Dean will issue a formal written reprimand to the COES Lab supervisor. A new deadline will be set for the submission of the chemical inventory, and the COES Lab supervisor is responsible for ensuring the new deadline is met.

Further non-compliance: Continued failure to comply with the deadlines will result in lab space being temporarily or permanently shut down to ensure safety and compliance. The COES Dean will notify the lab supervisor and any affected personnel of the shutdown, along with the reasons and next steps.

Appeal procedures: Lab supervisors may appeal decisions by submitting a written request to the COES Dean and Director of Operations within the time period specified in the written enforcement communications.

Documentation

All reprimands, warnings, and notices will be documented and kept on file for future reference. The COES Dean’s office and the COES Operations team will keep these files. Lab supervisors may request copies of their documents at any time.

Related Documents

Document Code	Document Title
P1-F1	Laboratory Safety Training Questionnaire
P1-F2	Laboratory Safety Training Requirements
P1-F3	Training Group Request
P1-F4	COES Lab Access Request

Revision History

(0) Original document. Effective Date: August 2024