Safety considerations in research proposals - ACS Publications

Whether considered from the vantage point of the student, the professor, the dean, or the financial officer, university research defies generalization...
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Edited by N O R M A N V . STEERE, School of Public Health, University of Minnesota, Minneapolis, Minn., 55455

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X. Safety Considerations in Research Proposals H. K . Livingston, Professor of Chemistry, Wayne State University, Detroit, Michioon. and Choirmon, Commiitee on Chemical Safety, Americon

Scientific research in the campus laboratories is one of the most exciting activities in the world of ideas, and one of the least orderly in the world of organizations. Whether considered from the vantage point of the student, the professor, the dean, or the financial officer, university research defies generalization. Each professor has his independent ideas as to how his work should be organized, and each student is the end result of a long process designed to make him believe in the worth of the individual in science and the importance of preserving his individuality in his approach to his work. X o two departments are organized alike, and funds come from a maee of sources varying from student breakage accounts to long-term research projects that represent large sums of money. This presentation originated with the work of the Committee on Chemical Safety of the ACS, and most of the information available to this Committee dealt primarily with chemistry and chemical engineering. The Americm Chemical Society is properly concerned that the profession of chemistry be practiced safely, insofar as possible. For example, in determining if the bachelor's degrees granted by an American institution should be accredited by the ACS, representatives of the Society visit the campus and reviews. number of points, one of which is that "careful attention should he given to modern safety practices in the laboratory and in the storage and handling of chemicals." A part of the over-all safety activities of the ACS is represented by the Committee on Chemical Safety. We have been

ezperimental program embodying a prospectus as to what may be discmered and an evaluation as to why the results may be rlesirabla. Typically, a student outlines one or two specific experiments, points out how this may lead to a series of related experiments, and explains why these experiments may lead to surprising results that will lead to a well-regarded or otherwise "make a eontributian" to the field in whieh he and his Research teacher are concentrating. proposals may be i n t m l or ezlernal, formal or informal. Traditionally the research proposal on the campus was always of the internal variety. A student outlined a program using available equipment or chemicah, or things he could buy or make himself. Or his professor derrcribed an area of research and suggested that the student select a program that was within his means. Only with World War I1 did there begin to be any significant number of external proposals in which the professor, or the student working with his professor, proposed a line of experimentation to an outside agency, which would (if favorably impressed) make funda mailable r i a a research grant or research project that would finance the proposed research. An informal research proposal may simply take the farm of an oral colloquy between student and teacher, getting progressively closer to agreement, over a series of daily or weekly discussions, until finally it is realized that an agreement has been reached sa to what is proposed. On the other hand a formal proposal will be in writing, frequently with several draft,^ preceding the find version. Safety considerations

degree. Probably the" exposure hours to chemical hazard nn college campuses are a t least as great for graduate students zs they are for undergraduates. Most of the graduate student's laboratory time is spent in research. I n the course of this work, we have established that there is one common point in all student-teacher relations involving academic research, and this we have called the rmea~ch proposal. Once laboratory work has gone beyond the realm of the conventional undergraduate or graduate-level laboratory course, most laboratory work will be done on the basis of the research proposal, whieh we can define as f0l10m~S: A research pmposnl is a statement o j an

The labaratoly must be considered an unnatural environment for man. The temperatures and pressures encountered there cannot be dealt with "hare handed," things can happen a t rates that are much too f m t for human reaction times, and poisonous and noxious gases, liquids, and solids are commonplace. And yet in this environment the research student is expected to discover new science, which he ran do only by running experiments that have never been run before. Exploring the unknown in science means exploring the unknown in hesard. Certainly the objective is to mekesrientific discoveries, hut to do so without physical discomfort to the research man and

H. K. Livingston wor educated in the public high rchoolr of San Benito. Texar, and at Schreiner Institute (Kerrville, Texorl, the Univerrity of Texas, and the University of Chicago. He obtained his Ph.D. at the lartnamed institution in 1941. From 1941 to 1 9 6 4 he wor engaged in chemical research for the DvPont Company, holding o voriety of positions including laboratory director in the Organic Chemicals Deportment and director of pioneering rerearch in the ElesHe is ~urrentiy trachemicalr Deportment. professor of chemistry a t Woyne State University, specializing in polymer chemistry. Dr. Livingston hor been active in the ACS mr local section chairman and councilor. and i s currently chairman of the council's Camminee on Chemical Safety, a member of the Council'. Committee on Nominations ond Elections, and editor of the Synthetic High Polymer rection of Chemical Absfmcfr.

without physically handicapping him in his future work or damaging his research facilities. The position of the ACS on thia subject is made clear by its charter, granted by act of Congress in 1937, whieh lists among the obieets of the Society "by its meetings, contacts, reports, discussions, and publications to promote scientific interests and inquiry, thereby fostering public welfare and education. . . and adding to the material prosperity and happiness of our people." Nothing is so sure to subtract from "material prosperity and happinessm as knowingly or unknowingly jeopardizing health or property values, which is what we mean when we speak of an experimenter as being unsafe. This object of the ACS provides a good basis for defining safety conszdemtims that enter into research proposals. Safety consideratias are those mental processes that detwmine i f h a z a r h to health or (Continued on page A786) Vol. 41, No. 10, October 1964

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property values am likely to be involved i n a proposed c a m e of action, and evaluate the steps that can be t a k a to minimize those hazards. The word hazard is used deliberately in this definition. Among the antonyms to safety, this appears to be the most expressive word, based on the defiritiam given in Fernald's "Standard Handbook of Synonyms, Antonyms, and Prepositions" (p. 231 of the 1947 edition), which are: "Hazard is the inourring of a possibility of loss or harm for the possibility of benefit. Danger. may have no compensating alternative [of benefit]. In risk the possibility of loss is the chief thought." Thus, the possihility ni benefit is the

motivation for a research proposal; safety considerations assess the hazard involved.

Reasons for Concern for the Safety of Research Students The above analysis implies that safety is desirable without elaborating on the reasons why safety considerations are important in research proposals. Humanitarian considerations demand that new knowledge not be gained a t the expense of humen well-being. The history of science includes examples of scientists who have hamled their health hy deliberate selfexperimentation, under circumstances that seemed to allow them no other course hut toexpose themselves to hazard if they were

to obtain the information they needed. I t does not condone deliberate experimentation that endangered the health of others, except where the hazards were fully understood and willingly accepted. Certainly students should not be involved in this type of hazard. Probably a t the root of this particular concern is the ethical challenge embodied in the phrme "Am I my brother's keeper?" However this question itl amwered, it is certainly unethical for a teacher to expose a stulent to a danger that is apparent only to the teacher. Safety consideratiam in universities and colleges properly start with this ethical consideration. Legal requirements also enter into the question of safety in research, hut will not be dealt with in detail in this presentation, since they involve professional judgments outside the competence of our committee. Certainly if humanitarian and ethical requirements are met, there are not likely to be any issues that will require legal action. Sometimes safety considerations on the campus have taken s back seat to financial considerations. In the past, poor safety has sometimes been condoned because of "expediency," a euphemism for poverty. The financial support of the sciences today is such that anyone who feels an ethical or humanitarian responsibility to provide safety equipment can make a strong case for financial s u p port for his needs, relying on the problem of legal liability if necessary to clinch his argument. Hopefully we will never reach the paint where competition for research dollars is such that a teacher will skimp an safety equipment just to "submit n low bid."

Current Safety Practice Up ta this point, this presentation has dealt separately with the t e r n research proposals and safety considerations, attempting to define the terma and show why they are important in colleges and universities. I t is now proposed to cornhine the terms and review current uractice w ~ m l i n gauJ~/ctr/rmrri~lewli~me in r m ~ o r r h p o p m o l . ~ . Tlw infunnati.m nrcdvd for H rev it.^ hm Iwen ol81,~innl 1,). intrr\.icwiug twenty scientists representing different points of view concerning research propomk. The interviews were based on the following question: "In your own experience, a t what point do safety considerations enter into research proposals?" The scope of the experience of the scientists interviewed ranged from the direction of undergraduate research (the so-called B.S. thesis) to the direction of graduate research leading tn the Ph.D. degree, a s well as the direction of postdoctoral students. Also interviewed were 8. number of scientists e n.. a e..e d in the review $11rrsninlt pr.q,~.s:,l.; ~ubmittcdfor fin;$nvirl3upp e m 1r.v g,vcrlu~a.nt3gC1ww or by foundations engaged in supporting scientific research. The results of these interviews are wmmarized in Tables 1-3. We were fortunate to obtain a specific statement regarding safety practices in one large chemistry department, which follows: "Senior thesis research is arranged by the student and faculty member

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Toble 1. Research Proposals Classified by Type Type of proposal

Toble 2.

Safety Considerations in Informal Proposalr: Results of Interviews with Faculty Advisors Item

Concensus from Interviews

Time a t which safety is most likely to be discussed

When proposal has defintely crystallized

Frequency of discussion of safety with student prior to final formulation of proposal

Rarely discussed in connection with his own research; more likely t o he a subject of general discussion or in conneotion with his responsibility as an sssistant in undergraduate laboratory CUUr8'8e8

Frequency with which safety is discussed a t some time before experimental work is actually started

Generally but not invariably

Frequency with which safety is discussed after experimental work is started

S u t likely to he discussed unless student 1s observed violating good safety pritctire

proposals (see below) Formal mitten research proposals are almost invariably required

Degree of responsibility for ssfety felt hy faculty advisor

Perha s not quite tw great as for students in Lburatories, sinre s. student doing research has demonstrated greater ability than the average student

concerned. I t is felt that, a t this level, the student cannot be expected to be familiar with all the hazards of his work. Accordingly the faculty members are expected to make the students aware of potential dsngers. Obviously, as the work progresses, the student is not under the eye of the supervisor a t all times, and aecordingly the student must develop a sense of responsibility regarding his and others' safety. Frequent conferences with the instructor are used to evaluate the proof the work and the proposed extensions of it. I n this way the staff member supervising the work is directly

involved in evaluating and appmving projects. "Graduate research is supervised in ti similar manner. Here, of course, the direct supervision of the research lessens as the student matures. Part of this maturing process is felt to be s critical evaluation of hazards involved in the work. I n cases of doubt the student is expected to refer to one of the texts (in the Chemistry Library) on hazardous materials or lsboratory safety. Final approval of potentially dangerous experimen& rests with the supervisor." It is difficult to determine the extent to

which the increasing importance of i o m a l research proposals on the campus is influencing praetires with regard ta informal proposals. I t can be predicted that any safety considerations that hberome hahitunl with regard to formal pmposxls will gradually come to be an nutu~natiepart of infmmal proposals as well. One must question the validity of the prevailing feeling that students who me qualified to do research are not a8 much of n responsibility to the faculty as far as ssfety is roneerned as are the ordinary (Conlintmion page A788)

Internal: B.S. Thesis Research MS.Thesis Research Ph.D. Thesis Research Post-doctord Research

Ezteml:

Formality Almhst alwaya oral and informal Usually oral and informel Likely to be oral and informal unless external proposals are closely related Little information was obtained on this point, roba ably b e c a u s e

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Table 3. Safety Considerations in Formal Research Proposalr: Results of Interview with Representatives of Granting Agencies Answers to Question:

Frequently Never First answer was "Never," but aa the interview continued, the answer was ehaneed - to "Sometimes" "If frequently considered, by whom?" Agency staff Advisory panel "Major rehanee for checking safety placed on:" Agency Institution a t which research will be done Individual under whom research will be done

50% 20%

30% 30%

students taking laboratory courses. Evidence an this point is hard to obtain, but it is significant that a study of 148 accidents in chemistry laboratories in California high schools [R.D. Macomber, Tam JOURNAL, 38, 367 (1961)l showed that, if minor accidents such as small cuts and burns were left out of consideration, most accidents occurred to A and B students. I t can be deduced from this study the accident frequency per exposure hour was much higher when the student was carrying out experiments that were not in the laboratory manual. Of course these sre high school students. The more mature student may become less willing to take a chance with an experiment, but it is also possible that the tendency to experiment in areas of unknown hazard does not change aa knowledge increases. I t may well be that the sise of the danger area (see Fig. 1 ) undergoes little change, and at any educational level the student needs to be told how to experiment safelu in unknown areas. I t will be seen from Table 3 that there is no standard approach to safety in f o m l research proposals. In no case do the procedures for writing a, proposal, as specified by the granting agency, require a statement on safety considerations. On the other hand, most agencies can cite one or more examples where safety considerations had a very important place in research proposals, in most eases a t the instigation of the agency. These examples Involved proposals to do research on explosives, with materials having an insidious toxicological chnraeter, or with high energy materials in metastable states. An interesting feature of the interviews with representatives of granting agencies was the fact (see Table 3 ) that several a t Brat stated that safety considerations did not come up in their agency's consideration of research proposals, but later in the interview the interviewee remembered cases where safety considerations had been a significant factor in the evaluation of the proposal. The Atomic Energy Commission is in a special situation with regard to proposals (Continued on page A780)

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submitted t o i t for research with manmade radioisotopes. Licenses from the Atomic Energy Commission or comparable state licensing agencies are required before any laboratory can work with such materials. Therefore a research proposal which states that radiological work will he carried on in a licensed leboratory automsticslly conveys the information t h a t certain safety standards will be met. If it did not make such a statement, facilities would be inadequate t o carry out the research. The arm of the AEC t h a t deak v i t h research grants therefore relies to s, considerable extent on the licensing function of the Commission, whenever radiological safety is a concern.

Conclusions I n general, it is not current practice t o require that a proposal to do laboratory research contain a statement on safety considerations. This fact may seem surprising. I n the case of formal proposals the reason probably is that the legal liability of the granting sgency is usually quite restricted, so such a statement is not felt to be required in what is, a t least in part, a legal document. Without attempting to go into any legal matters, i t can be stated that, when the expenditure of federal government funds is authorized, the extent of the governmental liability for damages that can be traced back to this authorization is in many cases limited to the size of the individual authorization itself, which is likely to be a rather small amount. There is the d e h i t e feeling that since in eponsoring resesreh the agency incurs little legal or financial liability, safety is someone else's problem-but because of humanitarian or ethical reasons, the sgency gives some consideration to safety anyway. Safety should not be approached through a search far liability-by trying to make 8samebody "it." If s. serious accident occurs a t a university, there is plenty of responsibility t a share; neither advisor nor department head nor dean can (or does) tell himself "I wasn't responsible." There is the now famous case nf R barge carrying four huge cylinders of liquid

chlorine, sunk by accident in the Mississippi River off Natchez, in which each of the parties concerned-the owner of the tugboat, the owner of the barge, and the owner of the chlarinebelieved it had no legd liability. So the chlorine (more than the total quantity used as poison gas in World War I ) sat on the river bottom, to remain there until a cylinder failure would release it. Finally, the combined efforts of the Army and Navy salvaged the cylinders and relieved the oonrern of the residents of Nstehez (downwind from where the barge sank). On the campus, personal relationships me too close and the ethical responsibility of the teacher for thebelfare and future of his students is too great to allow any question of legal liability to blur the importance of preventing accidents. The faculty and administration must be preserved from the weight of after-theaccident responsibility. This can be done by hefare-the-hazard precautions. Hnw can this he done in the rosea~ehlabnrataries? The following reaommendations should he considered: 1. Diseusrr openly with fa cult,^ members directing laboratory research the nature of their ethical responsibility. 2. Encourage the practice of talking about safety considerations in informal research proposels, specifically a t the time student and ndviaor agree on a proposal. 3. As a matter of university policy, have all formal research proposals contain a section entitled "Safety Considerations." 4. Make sure that the financial section of formal research proposi~ls includes adequate funds to implement the suggestions outlined in the sectinn on safety conaiderrttions. Eor~on'sNOTE: This subject matter was prepared for presentation on July 14. 1964, s t the 11th National Conference on Campus Safety, s t the meeting of the Cempus Ssfety Association s t Rutgers University, New Brunswick, New Jersey. The oral presentation was made by Dr. F.C.Naohod, Sterling-WinthropRezsrch Institute. Renssolaer, New York. Dr. Neohod d s o contributed aubatantiall.~to the preparation of the talk, as amemberof the ACS Committee on Chomirnl Safety, and his aasistsaoe is gratefully aaknorledged. Graduate Studenl

High School Student

::iE

hatched

circle.)

Figure 1. Schematic representation of the tendency of an inquisitive student to experiment ot the fringes of his knowledge.

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