Office of the State Inspector General Who is OSIG? Established July - PowerPoint PPT Presentation

C OMMONWEALTH OF V IRGINIA OSIG U PDATE B EN S UTPHIN D AVID G ARRISON Z ACH Y ARBROUGH O FFICE OF THE S TATE I NSPECTOR G ENERAL

Office of the State Inspector General • Who is OSIG? • Established July 1, 2012 • Chapter 3.2 of the Code of Virginia • Program Areas • Audit • Investigations (including the State FWA Hotline) • Behavioral Health • Internal Audit Oversight 2

Office of the State Inspector General 3

Audit Selection Process • Sources of potential audits: • Factors considered when selecting performance audits: • Secretaries • Budget impact • Hotline • Public safety • News articles • Citizen impact • JLARC • Efficiency in government • Audits done by other IG functions • Audit Staff Input

Potential Upcoming Audits of Higher Ed. • Clery Act • Building Construction Permits • SCHEV – Tuition Assistance Grants Allocation

Chemical Inventory Management • Background: • Scope: • ACLU report on safety culture • Chemicals used in teaching and/or research laboratories • CIM is a small part of EHS duties • Not including Schedule I and II drugs, biologics, or radioactive material • Institution Selection: • Not laboratory safety • Survey of EHS • Prior audit coverage • Level of degree awarded by institution

Chemical Inventory Management 1. Determine if University requirements for managing chemicals, includes the purchase, approval and storage of the chemicals and is documented in their policies and procedures. 2. Determine if inventory counts are performed and reconciled to the inventory system at least annually. 3. Determine if Safety Data Sheets are “readily accessible” in accordance with 29 C.F.R. 1910.1450(h)(1)(ii). 4. Determine if periodic inspections of hazardous waste accumulation areas are being conducted and records of the inspections are maintained in accordance with applicable federal law. 5. Determine if hazardous waste is disposed of timely according to §262.16(b)-(d) and that hazardous waste manifests are prepared and maintained in accordance with §262.20 and §262.40.

Chemical Inventory Management 6. Determine if the institution uses a chemical inventory management system to track chemicals through the chemicals’ lifecycle on campus (chemical delivery through chemical disposal). 7. Determine whether the likelihood of fraud by PI's or EHS personnel in the chemical lifecycle for laboratory or research chemicals is significant at selected universities. 8. Determine if the institution has a process in place to assess its chemical inventory against the Department of Homeland Security’s Chemicals of Interest requirements. 9. Determine if the institution provides its chemical inventory to authorized outside entities as part of its efforts “to make arrangements with the local police department, fire department, other emergency response teams” required in C.F.R § 262.16 (b)(8)(vi)(A). 10. Determine if the institution has an established process to submit the Tier II form per Section 312 of the Emergency Planning & Community Right-to-Know Act.

Chemical Inventory Management • Potential findings • Have a chemical inventory • CAS # • Amount • Location • Chemical name • Contact information • Perform an annual inventory • Keep laboratory doors closed and locked • Provide EHS a list of new and departing employees • Do not donate chemicals nor accept donated chemicals • Regularly provide first responders with a chemical inventory • Display chemical hazards and contact information on laboratory doors

Chemical Inventory Management • Prudent practices • Waste disposal comes out of EHS’ budget • Order the minimum amount of chemicals required • Check existing inventories prior to ordering chemicals • Substitute hazardous chemicals for less hazardous chemicals

Questions?