F. HOP #8-1060: Laboratories
2. The concealed carry of handguns is prohibited in areas where the discharge of a firearm might cause great harm, such as laboratories with extremely dangerous chemicals, biologic agents, or explosive agents, and areas with equipment that are incompatible with metallic objects, such as magnetic resonance imaging machines.
Implementation: F. Laboratories 1
The task force formed a subcommittee of faculty and staff members to review all laboratories. The task force developed a procedure for the University’s Handbook of Operating Procedures (HOP) to translate the President’s Policy Statements into university policy. For laboratories, the task force focused on language from Policy Statements 13 and 14 and the accompanying findings. These are found on page 6 of the Campus Carry Policies and Implementation Strategies, dated February 17, 2016:
“…the discharge of a firearm might cause great harm, such as laboratories with extremely dangerous chemicals, biologic agents, or explosive agents, and areas with equipment that is incompatible with metallic objects…”
“Such a discharge of a weapon could have grave and catastrophic consequences.”
“This policy is reasonable and addresses specific safety considerations necessary to ensure safety in these unique environments.”
“This policy does not have the effect of generally prohibiting license holders from carrying concealed handguns on campus.”
The task force’s major concern was that an exclusion of all laboratories or other areas containing hazardous materials might “have the effect of generally prohibiting” concealed carry from large areas of campus—and thus violate the law. Additionally, many of the university’s approximately 1,800 laboratories contain small quantities of hazardous materials and do not pose the same level of risk as laboratories with very large quantities of such materials. Thus, upon further review, criteria were developed to help identify unique areas where a discharge could have “grave and catastrophic consequences.” One classification that already existed within the university’s Department of Environmental Health and Safety (EHS) for identifying laboratories was the “high hazard” designation. Due to the specific nature and volume of materials within these laboratories, high hazard appears to meet the definition of Policy Statement No. 13, “extremely dangerous chemicals, biologic agents, or explosive agents.” Due to the nature of these materials, EHS inspects “high-hazard” laboratories more frequently than other laboratories. In addition to the “high hazard” laboratory criteria, which specifically include very hazardous gases, it was determined that cylinders of less hazardous gases, in large quantity and at high pressure could also pose a unique and dangerous threat if struck by a projectile from a weapon. For this reason, areas with large cylinders of National Fire Protection Association (NFPA) Category 2 or higher gases were also considered for exclusion. The reasoning is that if punctured, the contents of the cylinder could catch fire, explode or pose an immediate health hazard.
The task force recognized that most, if not all, of the approximately 1,800 university laboratories contain dangerous and hazardous materials. The focus of the task force investigation was on extremely dangerous chemicals, biological agents, and explosives. After lengthy discussion, the task force reached the following conclusions:
If all laboratories were excluded that contain dangerous and/or hazardous materials, then the task force would violate the provisions of the original law and would create a general exclusion on campus.
While there are, in fact, dangerous and hazardous materials in most laboratories, these materials are typically in small quantities and do not pose the threat of a catastrophic incident in the event of an accidental discharge in the laboratory.
The use of the “High Hazard Laboratory” definition, the additional gas exclusion, and criteria for magnetic fields describe the areas that pose the greatest risk for a catastrophic incident:
A. High Hazard Laboratories are defined by possession of
Greater than 55 gallons of Class I flammable liquids and/or significant quantities of acids, bases, organics, pyrophorics, peroxides, extremely toxic materials or pyrophoric or toxic gases classified NFPA 704 Category 3 or higher.
B. Hazardous Gases
K-size cylinders containing corrosive, reactive, flammable, toxic, and/or oxidizer gases classified NFPA 704 Category 2 or higher.
C. Strong Magnetic Field Laboratories
- Typically contain MRI and/or NMR equipment capable of generating significant magnetic fields
- Field strength of at least 5 gauss is measured outside the equipment. 5 gauss line typically at least 3 feet and as much as 20 feet from equipment
D. Large cylinders of acetylene
The university recognizes that the following are classified as potentially hazardous materials:
A. Any unsealed radioactive material
B. Biological materials categorized as BSL-2
C. Chemicals listed as select or regulated carcinogens
D. Chemicals listed as toxic, highly toxic or reproductive toxins
E. Flammable, air-reactive, or water-reactive chemicals
F. Corrosive chemicals in concentrations of one (1) molar or greater.
G. Known chemical irritants or sensitizers
However, the task force was concerned that the exclusion of all areas where any amount of these materials are stored or used would result in a general exclusion of concealed handguns for campus and thus be unlawful. However, the task force was concerned that the exclusion of all areas where any amount of these materials are stored or used would result in a general exclusion of concealed handguns for campus and thus be unlawful.