A critique of Standard Operating Procedures

SOP stands for Standard Operating Procedure. A standard, in this case, is often perceived as a rule set up by an authority to be strictly adhered to. This definition may give students and researchers a false sense of security and fails to provide the necessary flexibility to be critical of and to learn in a laboratory.

I seem to cringe internally when I hear "standard operating procedure" or "SOP" as of late. Laboratories are typically required to maintain SOPs with the goal of keeping personnel safe, but having an SOP does not lead to a safe laboratory. The purpose of this post is to explore the definition and utility of an SOP from the perspective of the student / reader, the teacher / author, and the policy maker.

The University of Washington (UW) adheres to policy put in place by the State of Washington. Environmental Health and Safety (EH&S) is a unit within UW whose charge is to help UW personnel understand and follow the State orders. For example, the Laboratory Safety Manual written by EH&S and amended by individual laboratories cites the Washington Administrative Code (WAC) chapter 296-828 for many of the laboratory requirements. This specific chapter is largely focused on hazardous chemicals in laboratory settings and serves to highlight the prospective of the policy maker, personnel safety. While I have played the role of student and teacher with respect to laboratories and SOPs, I have not played the role of policy maker. I presume the goal of the policy maker is to cast a wide safety net across all types of laboratories by requiring SOPs to be present and current. The policy maker is rightfully assuming that the SOPs are accurate and adhered to.

Personnel safety is of utmost importance. The presence of an SOP, however, does not make personnel safe. Personnel who are cognizant of and appropriately manage potential hazards does make a laboratory safer. This, of course, is the goal of SOPs; to inform personnel so they can make the safest decision. Often times, however, SOP documents are losing their audience. It seems as though SOPs are created as a matter of course and then filed away only to be pulled out to check a box. Indeed many institutions provide template SOPs for individual labs to copy and paste so as to fill the space with little thought of actual situations. As I create and read SOPs, I am mentally role playing scenarios involving a spill or an exposure making it impossible for me to just copy and paste and I am often left scratching my head for realistic text to put into the required sections.

EH&S divides SOPs into two categories: (1) Process SOPs and (2) Chemical SOPs. Process SOPs are steps to follow to accomplish a task that include hazardous conditions and safety considerations. Chemical SOPs are steps to follow when handling a specific chemical or class of chemicals. A laboratory procedure or method may have several process SOPs and chemical SOPs within it. A standardized procedure implies an authority and the authority is assumed to know the right way and the safest way. This risks students blindly following SOPs without thinking for oneself. Students and researchers should have a feeling of guidance and advice from a documented procedure and not a feeling of obedience. A chemical SOP, on the other hand, is a Safety Data Sheet (SDS) specific to an individual laboratory. The authority of a chemical SOP is the SDS which is required to be supplied by the chemical manufacturer.

Certainly within any procedure, if written properly, readers will recognize steps that have less flexibility. "Easy" hazards need no description at all. For example, items that are visibly very hot need no verbiage to express the presence of a hazard. Students intuitively know not to touch the hot parts and will then seek out information (e.g. through training or an SOP or both) about how to handle, for example, a 1000 °C quartz tube (as in the nearby photo). The difficult hazards are those that do require training or an SOP before they are even recognized as hazardous. Here, the student relies exclusively on the authority for information.

An SDS seems to be the ultimate authority when it comes to handling chemicals. The accuracy of an SDS is presumed absolute. However, some flexibility, or at least critical thinking, around handling chemicals is warranted. For example, according to this SDS for water, the person exposed shall take off all contaminated clothing and rinse with (dramatic pause) water. I live in Seattle. It rains here. If the subject has the reagent water in their eye, they are supposed to rinse with (another dramatic pause) water. This is an extreme example for certain, but it illustrates the point of accuracy. It seems most plausible that the reason for having such inaccuracies is document creation from templates or automated scripts. How are students and researchers less familiar with the various substances in a laboratory supposed to know if the SDS is accurate or not? Some of us may be able to recognize the hazards associated with such chemicals as concentrated hydrochloric acid but only after experiencing its strength first hand. Without such experience, we rely on an SDS to tell us that immediate removal of contaminated clothing and rinsing with water or taking a shower is the appropriate response. Some students (and chemical hygiene officers) that are not familiar with a specific chemical may become numb to such canned statements and hence, overly relaxed. When SDSs are created from templates or scripts without true consideration for the real hazard, the authority is called into question and the document itself becomes moot.

The recent shift from MSDS to SDS did accomplish a standardization of format but they are still less helpful than they need to be. A recent exchange on this topic with a student resulted in the following question:

If the ultimate authority for chemical hazards is the SDS and they are perceived as inaccurate to the point of not reading or ignoring, where can we turn? Who writes modern SDSs? Would a Chemist write a formula for sodium chloride as ClNa? Maybe the authority is a computer script that sorts the chemical formula alphabetically before slapping it together with a bunch of canned statements?

One place where more laboratory personnel may gain experience is at home, in a kitchen. However, this experience may conflict with the advise given in an SDS. For example, if I breath vapors from vinegar (~5% acetic acid) in my kitchen, I do not consider myself "exposed". However, if I breath vapors from a 5% acetic acid solution created in a laboratory have I been "exposed"? Must that be reported to an accident reporting system like OARS? Likewise, pouring a teaspoon of salt into ones hand before adding it to a pot of water to make pasta is a practice of many, not a chemical exposure that requires taking off immediately all contaminated clothing and rinsing skin with water or taking a shower. This intuitive sense for the real hazard juxtaposed with the written authority supports students feelings of SDSs being useless, albeit required.

In the absence of personal experience, perhaps a resource that should be required are videos that depict real reactivity and real hazards. One example is the Periodic Videos series. These are absolutely spectacular and show viewers various scenarios with informed chemistry and the periodic table at the forefront. Compressed gas cylinders can be hazardous and few witness the missile going through a brick wall. Of course, we need to be critical of online content, but they may serve as a way give students a true sense of some hazards.

Methods, as in a peer reviewed publication, should be of sufficient detail so as to allow others to repeat the experiment. Those same methods sections, however, do not demand obedience. Indeed, readers of a paper should feel a level of flexibility around the published methods section because their resources or needs may differ. The same is true when running a mass spectrometer. Students should be able to repeat a historical method if they choose, but also have a sense of freedom to explore the method. Ideally process and chemical SOPs would convey the boundaries around the hazard and provide real experience-based information specific to the situation rather than cookie cutter box checking content so that students, teachers, and policy makers can all genuinely achieve a safe functioning laboratory.