Dan The Lab Safety Man - Blog

Every year the United States Occupational Safety and Health Administration (OSHA) reports out a list of the top ten most cited violations from the facility inspection they conduct. The preliminary information arrives as the first of three report phases, and it is disseminated after the close of OSHA’s fiscal year which ends September 30th. The top ten citation list is compiled after a look at the 32,000 workplace inspections conducted by OSHA over the year, and the list has not changed much in the past several years. Not all of the items on the list affect laboratories, but one hot topic (reaching number 2 in 2016) has been an area of concern for laboratories for a very long time- Hazard Communication.

5,665 citations were levied against employers in the last year for lack of compliance with the Hazard Communication standard. It was, after all, a big year for the standard in the U.S. since all chemical handlers were affected by OSHA’s final GHS implementation deadline. The OSHA citations reported specifically dealt with failure to implement the HazCom plan, a lack of employee training, incomplete or improper maintenance of Safety Data Sheets (SDS), and a lack of employee knowledge about chemical labels and obtaining hazard information. Given these violations, it does not appear as if the GHS implementation was difficult for employers, but it also means that long-standing workplace HazCom issues continue to vex employers.

You’ve worked diligently during all phases of the GHS implementation to ensure the safety of your staff. That said, it may be time to step back to look at the rest of your laboratory Hazard Communication program. Is it functioning as it should? Could you be cited for any of those violations mentioned for 2016?

All laboratory employees need complete training on the hazards of the chemicals they handle. That training needs to include information about where hazardous chemicals are stored and used in the workplace, knowledge of the specific hazards from the chemicals used, and measures that can be taken to protect employees from the known hazards. HazCom training should be an extensive and on-going part of your overall lab Chemical Hygiene Plan.

Chemical labeling, the use of pictograms, and updated Safety Data Sheets have changed in the past few years, but how well can staff speak to this information? Labs should have immediate access to up-to-date SDS for all hazardous chemicals in the workplace. That access may be electronic or it can be a paper copy. Understanding chemical labels should be a part of employee training, but don’t assume everyone will retain that knowledge for the duration of their employment. Annual refresher training should occur, and chemical hazards should be a part of that.

OSHA’s Chemical Hygiene standard supersedes the HazCom standard for laboratories. That means that there are standards for labs that go above and beyond the HazCom requirements, and that is because OSHA recognizes that labs are unique workplaces when it comes to chemical management. However, it does not mean that the Hazard Communication standard regulations do not apply, and lab staff should have a keen knowledge of the regulations in both standards.

I receive more questions about chemical management than all other possible topics in the area of lab safety. It is a complicated and multi-faceted subject with several regulations to consider. Running a comprehensive laboratory chemical management plan takes time and a detail-oriented attention, but for the safety of lab employees, it does need to be managed properly. OSHA provides clear and concise information on their website (

www.osha.gov

As each year comes to a close, I usually try to figure out my lab safety goals for the next year. What topics need to be covered, and what education needs to be emphasized? There is a great deal of planning, but I never have to start with a blank slate. There is plenty of data to use in order to formulate a sensible safety plan for the new year. An in-depth review of the current closing year is the key.

The first thing to look at is the injury or exposure rates of the current year. Are they higher or lower than last year?  Take a look at the specific incidents and look for trends or repeat occurrences. There may be some training opportunities found from a review of this data. If there is a common cause for a specific set of injuries, you may need to create an education module for all lab staff to prevent further events.

Next, review the results of any laboratory safety audits that were performed this year. Scan the audits for common issues and look for problems that may remain unresolved. These issues might be a project you can focus on in the coming months. If you see that your safety audit results show no safety issues, ensure the accuracy of the reports. If audits are performed on a regular basis and they are merely “pencil-whipped” (people just checking ‘yes’ on every audit question and not truly looking), the tool becomes worthless. Educate those who perform audits about the importance of an honest, detailed inspection and how audits can produce a safe lab environment. If the lab was involved in an external audit or regulatory inspection this year, review those results as well. Tackling the large-scale deficiencies may be part of next year’s safety plan as well.

A review of the lab’s chemical hygiene should also help you determine what to do next with the overall lab safety program next year. Review any chemical incidents such as spills or staff exposures. Scan the results of vapor exposure monitors and hood inspection records to make sure no actions need to be taken in those areas. Also, ensure that action was already taken on elevated readings or failed equipment inspections.

There is specific safety training that lab employees must have, and the end of the year is a good time to review what has been completed and what is required in coming months. Fire safety, bloodborne pathogen safety, formaldehyde safety, and other chemical safety training should occur annually, but other training is required at different intervals. Packing and shipping training for category A and B substances is required by the DOT every three years. Waste manifest training is required every three years by the DOT as well for those who sign waste manifests in the lab.  

When putting your safety plan together for the next year, remember to also look at the safety successes you’ve had in your lab this year. It can be eye-opening to review a success in safety and think about the details of how that occurred. Those same steps may be used again to create an achievement for your next goal. Look to others who have had safety successes as well and discover how they were accomplished. Prevent extra work by learning about how others reached the goals you are seeking in your lab.

The end of the year is here. There may have been some rough roads along your lab safety journey this year, and those will likely offer insight and learning as you move ahead. Don’t forget to take some time to think about those smooth roads and the safety successes as well. If your goal is to improve the overall lab safety culture and protect the laboratorians you work with, you most likely have made a positive impact this year, and you will have power to accomplish even more in the next.

As Hurricane Matthew, a powerful category 4 storm, approached the United States last month, many East Coast hospitals made preparations. Some hospitals evacuated completely. Think about what that might mean if your laboratory were in one of those hospitals. Is lab staff assigned to help re-locate patients? Must they work in a different temporary location? What supplies may need to be moved? What preparations are needed to shut down a department that usually runs all day and night?

As a lab safety officer, I have spoken to several laboratorians who have been involved in disaster situations ranging from floods to tornadoes, and from hurricanes to blizzard conditions. Every disaster is different, and every response tends to be different even if the emergency scenario is the same. Because it is not possible to create a plan for every possible disaster, a complete laboratory emergency response plan needs to be comprehensive, and it needs to be usable in many different types of situations.

Begin with the basics: the lab emergency management plan needs to be available to all staff. That means keeping only an electronic version may not be sufficient. A complete power outage with no functioning generator could make that computer-based plan unavailable. The plan should be straightforward and easy to read. Every lab staff member should be able to easily read, understand, and be able to follow the steps necessary to respond to an emergency situation.    

Once you have a lab plan in place, make sure the lab team - including leaders and medical directors – review it and are aware of how they will be affected when the plan is enacted. If your lab is part of a larger facility or hospital, be sure to present the plan to the facility emergency manager for approval. A coordinated facility disaster response is only possible if multiple departments know each other’s plan and can work them all together for the safety of staff and patients.

An evacuation plan is a critical part of the overall emergency operations procedures, and care should be taken to ensure a safe and logical withdrawal from the department should that become necessary. In larger facilities work with other departments to make sure all staff have evacuation routes that won’t be over-crowded by other retreating employees from different areas. Each department should have its own designated meeting place, and there should be a mechanism in place to ensure all staff is accounted for.

A laboratory emergency response plan should be tested to ensure it will function adequately when a real disaster occurs. One practical way to check it is to perform “table-top” drills. A table-top drill is achieved by bringing key players together to react to a given scenario. For example, to test the lab response, a facilitator could start by giving a situation (such as a tornado striking the hospital).Using the written plan, participants should discuss immediate actions. As the situation evolves (water pressure goes out, the emergency generator fails, etc.), team members continue to respond while making sure the plan contains adequate instruction for a complete response. As issues are discovered with the plan, make adjustments as needed. Drills should be conducted often to ensure the plan works, and to ensure that staff know how to use the plan.

October is near, and it’s that time when you should be raising awareness about fire safety in the laboratory. It’s National Fire Safety/Prevention Month, and fires occur in high enough numbers in the United States (even in laboratories) that we need to pay attention and focus on prevention.

The College of American Pathologists uses eight checklist standards to cover lab fire safety, and even though they have made some changes in the past few years, all of the elements are there to help you prepare and protect your staff in the event of a fire. There are many fire sources in the lab setting, and even more fire accelerants, and those alone should help us realize the importance of fire safety knowledge. However, many go through their daily work routines without giving it a second thought. When the fire occurs, they will not be ready, and the results could be devastating.

Fire safety training should occur with all staff. OSHA requires that if fire-fighting equipment is in the facility, staff must have documented training. CAP “strongly recommends” hands-on fire extinguisher training tht includes actual activation of the equipment. I agree, and I also recommend that this is performed at least annually. Operating a fire extinguisher is not a natural process, and some people struggle with it. Extinguishers can be heavy, and pulling the pin can sometimes not be a smoot, easy motion. Staff should practice these tasks and not experience them for the first time in an actual fire event. Most use the acronym PASS (Pull, Aim, Squeeze, and Sweep) to help people remember how to use an extinguisher, but there are other things to consider as well. If the fire is larger than the size of a waste basket, get out and let the professionals handle it. Never use two fire extinguishers at the same time, the force can actually push burning debris back onto someone who is trying to stop the fire. Also, make sure you are always between the fire and an exit- never let yourself be trapped in the room by the fire. These are training nuances that shouldn’t be herd once during a lab employee’s career.

CAP used to enforce the actual evacuation of each employee in a fire drill, but that is no longer required. Now an annual documented assessment of the evacuation route is considered sufficient. Again, a fire situation, especially one where evacuation is necessary, is not when you want staff learning for the first time how to get to a designated evacuation location. There should be primary and secondary routes, and if staff has not walked them, they may not know how to go there safely and efficiently in an emergency. Walk with staff annually so they know where to go- take a few people at a time, you do not need to stop work to make this happen.

OSHA and CAP do require annual fire safety training. That training should include knowledge of other fire-fighting equipment (such as fire blankets if provided), the location of fire alarm pull stations, and staff responsibilities during a fire. It is considered to be acceptable to review all of that safety information via a computer or a test. Again, I state strongly that the annual review needs to be more comprehensive in order to be truly effective. Fire drills are often required via local fire code or hospital and clinic regulatory agencies. Make sure your staff is participating to the fullest extent.

I don’t watch sports often, but I must confess I enjoy watching the Olympic Games when they come around. This year there was a heated rivalry between swimmer Michael Phelps and South Africa’s Chad le Clos that ended with Phelps defeating le Clos in a 200m butterfly final meet. In one particularly good photograph of the event, the two rivals are side by side. Michael Phelps is staring straight ahead while le Clos is watching Phelps. On social media, the caption on that picture often read, “Winners focus on winning, losers focus on winners.” I don’t know if I agree with that philosophy in general, but it definitely does not apply to laboratory safety.

I was a lab manager for 11 years when I decided to apply for the role of Lab Safety Officer for the hospital system that was my employer. I did not have a strong lab safety background. I managed a lab in which the staff food refrigerator was located near hematology (yes, right in the lab), and many of the staff did not wear lab coats regularly. When our hospital integrated with the larger system, I met the Lab Safety Officer and over time learned more about the importance of lab safety.  When I took over the safety role, my goal was to continue learning about lab safety and to improve the culture in the lab system. I wanted to be a winner. Who would I look to in order to make that happen?

Even though my role as a Lab Safety Officer was full-time (something that is very rare in the field), I knew I would need help to learn more and to know how to make a measureable difference in the safety culture. The first step was learning to look to the many resources available to me.  I met with my internal references- Occupational (Employee) Health, Infection Prevention, Facilities, Environmental Services, and Security. Then I began meeting some external references- the chemical waste handlers, the hood service company, the vapor monitor contractors, and the PPE vendors. All of these people had much they could tell me, and over time they have provided a great deal of lab safety knowledge regarding regulations and best practices. I also became familiar with other external references such as the EPA, OSHA, and the CDC.

Now let’s go back to that Olympic swimming – what does that have to do with safety resources? I have found over the years that because of the myriad regulations and guidelines it is very difficult for a safety professional to stay current without help. As a group, we need to rely on each other as sources of information, or as a support network. Networking is important so that safety professionals can focus on the best practices and successes we are achieving in our labs regarding safety. While it is important to concentrate always on improving our lab safety cultures- to focus on winning- it is also necessary to look at each other, and to learn how to apply those safety best practices in our own labs. If you are focusing on other labs and how they are winning the lab safety Olympics, that doesn’t make you a loser- it makes you smart. Not everyone is able to find the answers they need in their own back yard…or swimming pool.

Many years ago I worked in a lab that often received dry ice in boxes with our blood product deliveries. The habit in the lab was to dump the excess frozen carbon dioxide into one of our stainless steel sinks. The staff would get excited each time there was a delivery because they liked to run tap water onto the ice to make a “waterfall” of smoke flow onto the floor when they were bored. Before too long, this repeated incorrect placement of dry ice resulted in severe damage to the sink and pipes below. The stainless steel basin cracked and the sink fell down onto the broken pipes below. That particular plumbing is not designed to handle such a low temperature, and the repair was not cheap. Luckily, no one was injured.

Dry ice sublimates at room temperature. That means it transforms from a solid state directly into a gas. Too much of this gas in a small space will reduce the normal oxygen levels in the area potentially causing dizziness and asphyxiation. Letting dry ice sublimate in the work place is a dangerous practice. If you have dry ice to dispose of, the best practice is to set it outside (where other could not have access to it) so it can dissipate into the open air.

Dry ice is often used in the transport of specimens, blood products, and certain lab reagents. The Department of Transportation considers it a dangerous good, and it must be used and labeled specifically if it is to be shipped by land or by air. If dry ice is used in shipping, an additional Class 9 miscellaneous hazard label also must go to the right of the Class 6.2 infectious substance label. In addition to the Class 9 label, the outer box must be labeled with the net quantity of dry ice used.

Another common use of dry ice is with the transport of outreach or clinic lab samples in courier vehicles. Certain samples must be kept frozen for testing, and the use of dry ice provides a convenient method for maintaining the necessary temperatures. Dry ice is placed in a cooler in the courier vehicle, and samples are placed until delivery to the reference laboratory. With that, there are specific safety practices that should be adhered to when using dry ice for this purpose. Couriers are often overlooked when considering safety training, but they are an important piece of the lab sample and testing process. Be sure couriers have complete safety training, including training for the proper handling of dry ice.

Couriers should limit the amount of dry ice placed inside the cooler that will rest in the vehicle. No more than three pounds of dry ice should ever be placed in that cooler. The cooler should never be completely sealed (remember the ice sublimates to gas, and the volume of the gas in the cooler will expand). Also, if dry ice is kept inside of a vehicle, the windows should be left opened, even a tiny bit. There have been incidents where too much dry ice in a closed vehicle has caused a driver to become dizzy or even become unconscious. Obviously this is a potentially dangerous or even deadly situation and should be avoided completely.

The other day I went to get a haircut (yes, even though I don’t have the hair I used to have, I still go to a barber shop from time to time). The stylist was a nice young lady, and she was good at carrying a conversation.  I began to notice as she continued her work, however, that her touch was anything but gentle. She combed with vigor, leaving what I imagined were indentations on my tender scalp. At the end she hefted the clippers to trim up the hairs on my neck- I’m not entirely certain she didn’t leave scars. I have experienced haircuts in the past that were given much more gently, and the results were the same minus the mental and physical scarring. As I drove away I started to think about the applications here to laboratory safety.

In my years as a Lab Safety Officer, I have had to learn how to give feedback to those in the lab who are not following proper safety procedures. It is important. Usually if I need to speak to someone, they are in danger of becoming injured or exposed to some hazard. The safety coaching moment is necessary.  

The book Crucial Confrontations (by Grenny, McMillan, and Switzler) is an excellent resource which can be used to teach how to provide important coaching in any setting. One thing I learned to remember from that book is that if someone is acting in a way they shouldn’t – if they are doing something unsafe, for example – there are at least six possible sources of influence potentially guiding the action(s). Let’s use an example: You walk into the lab and see Mary on the phone at the hematology bench with no lab coat and no gloves.  Why is she doing that? Did she have proper training? Is the PPE located in a convenient area for staff to get quickly? Was Mary on her way to a break but no one else was there to answer the phone? Is Mary a non-compliant person? Is Mary following the general safety culture in the lab?

How you approach Mary here is critical. You could yell at her. You could angrily tell her to get PPE since you’ve discussed this with her before. You could tell her she will be written up. Then Mary hangs up the phone and tells you she just learned her mother has passed away. That certainly changes the scenario, and it casts a negative (perhaps permanent) pall on your working relationship. That will be difficult to change, and it will be difficult to influence Mary in any way about safety in the future. It is vital to be careful about any coaching event you have in the laboratory. Your approach affects the outcome, and much of that approach is determined by what you are thinking as you begin. A light touch in a coaching situation will produce more gains than a heavy hand. It will also build your credibility as a safety advocate in the department.  

Approaching Mary is the right thing to do, no matter her situation. She is at a lab bench touching contaminated surfaces with no PPE. That needs to be dealt handled. If you ignore it, you promote the behavior, and if others witness that then you are responsible for untold harm to the overall lab safety culture. Even if Mary tells you she received bad news, it is still important to call her on her inappropriate safety behavior, especially if you have seen the behavior before - but it should be done at a later time.

OSHA’s adoption of the Globally Harmonized System for the classification and labeling of chemicals in the workplace (GHS) was implemented in several phases beginning in 2013, and its last deadline falls on June 1, 2016. The effects were immense for those who manufacture, transport, and handle chemicals, and of course it affected laboratories everywhere. There were a few hard questions that arose along the way, and OSHA has done its best to handle the majority of the, but as one would expect with a subject so broad, a few issues still remain.

Chemical container labeling is a topic that has caused much confusion in the past couple of years. With so much attention focused on the new labeling elements of primary containers, the issue of secondary container labeling seemed overlooked. The GHS hazard ratings were new to the United States, and they ran exactly opposite of NFPA and HMIS hazard warnings- systems that had been in place for chemical labeling for years. Fortunately, the updated Hazard Communication standard did not require placing GHS hazard ratings on chemical labels- there were already plenty of hazard indicators including pictograms, signal words, and precautionary statements. Because of this, it was clearly determined that labs would be allowed to continue to use NFPA or HMIS label conventions for secondary chemical containers after June 1 of this year. They would, of course, also have the option to use GHS labels as well, and some manufacturers provide those labels and pre-labeled containers for labs.  

A second and more controversial issue involved the interpretation of the standard to determine what primary chemical containers should be in the lab after the final deadline. Should older chemicals that do not have GHS-compliant labels be removed from the lab by that date? The answer is yes, and though it may not be completely clear in the standard, if you follow the path through the GHS implementation steps, it may become clearer.

Chemical manufacturers had until June of 2015 to stop creating containers with non-compliant labels, and OSHA gave them six months to ship out that old inventory to customers. That meant that labs could potentially receive non-compliant labels through December of 2015. OSHA placed the last implementation deadline on June of 2016- that also gave labs six months to use up those chemicals that had out-dated labels, even those received as late as December of 2015. The last deadline states that employers must “update alternative workplace labeling and hazard communication program as necessary...” The final Hazard Communication rule states: "The phase-in period for the revisions to the HCS provides adequate time for firms to deplete products in inventory that are not labeled with GHS-compliant labels and to replace workplace containers or signs/permanent labels (such as regulated area signs) in the course of the normal cycle for wear-and-tear replacement." That pretty clearly says that labs should not have older chemical labels on site after June 1.

So how do you get rid of these chemicals? You may not re-label a primary chemical container- OSHA forbids that. One method may be disposal. Have the chemicals removed by your contracted waste hauler. If you have smaller amounts of a chemical, it is possible to transfer it to a secondary container and label it properly.

Certainly other elements of the last implementation deadline are easier to handle. Safety Data Sheets, paper or electronic need to be updated to the new standardized 16-section format. Any posted formaldehyde warning signs need updated wording, and other chemical hazard warning signage should be up to date.

Hopefully your lab has been working on this topic for the past three years or so, and you are ready for this one last deadline. If not, you are not alone. Many labs have not done much work to prepare, and there are chemical manufacturers who have struggled to comply with the imposed changes and dates. OSHA is not unforgiving, however. If they can see that an organization is working diligently to implement the changes, they may grant some flexibility for the employer to complete the changes. Moving forward, your lab will completely comply with the updated Hazard Communication standard, and the uniform labeling and warning conventions will enable you to continue to operate safely in the laboratory.

Marlene walked by the chemistry department and noticed several lab safety issues with Doug who was working there that day. Doug was wearing mesh sneakers. He had on a lab coat but his sleeves were rolled up. He was chewing gum, and he was placing open specimens on the analyzer with no face protection. When Marlene approached Doug about these issues, he acted confused. He understood why his lab coat sleeves should be rolled down, and he knew he should be wearing a face shield, but he did not agree with Marlene’s comments about his shoes and the gum. What was unsafe about that?

OSHA’s Bloodborne Pathogens Standard was signed into law in 1991, and its impact in the laboratory to this day is massive. The regulation has an effect on a wide variety of lab safety policies and procedures, but it means little if the staff is not aware of it. The concept of Standard Precautions – treating all samples as if they are infectious – has its basis in this important standard, and education about this for laboratory staff is critical. Let’s take a look at some of the elements of the Bloodborne Pathogens Standard and connect them directly to processes that should be followed in the lab:

Exposure Risk:

One of the first safety tasks that should be performed in a lab is to look at each different job title and assign to it a level of risk of exposure to blood or body fluids. Then each lab task needs to be assessed for that same risk of exposure. These determinations will help you to design safe work practices and utilize proper engineering controls to protect staff. They also play a large role in understanding what PPE should be used for the various lab tasks and procedures.

Regulated Medical Waste:

The handling of RMW (bio-hazardous waste and sharps) is clearly defined by the standard. Do lab trash cans need lids? Not necessarily, but they are required to have tight-fitting lids if and when they are moved out of the department. Sharps containers need lids on them at all times, and they must be prevented from tipping over. An exposure from an unknown source should be avoided at all costs.

No Eating/Drinking in Lab:

The BBP Standard and OSHA’s Chemical Hygiene Standard forbid eating, drinking, smoking, applying lip balm, cosmetics, and handling contact lenses in the lab. Their goal is to reduce hand-to-face contact in order to prevent the accidental transmission of bloodborne pathogens. While the BBP Standard does not mention chewing gum, the Chemical Hygiene Standard does – “Eating, drinking, smoking, gum chewing, applying cosmetics, and taking medicine in laboratories where hazardous chemicals are used or stored should be strictly prohibited.” In case staff asks you, this includes throat lozenges and hard candy.

Personal Protective Equipment:

Proper PPE training and use in the lab is required for all employees. Fluid-resistant lab coats and gloves are required, and face protection is needed “whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated.” That can happen any time staff handles open specimens in the lab. Proper footwear is also required. The BBP Standard states that “personal protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's …skin.” Since exposures can occur via this route, protective footwear must be worn. This means that shoes worn in the lab must be made of a solid material. OSHA’s separate PPE Standard does not require employers to pay for this protective type of footwear as it is not considered “specialized.”

Other BBP Elements:

The above items are just some of the topics covered by the very wide set of regulations known as the Bloodborne Pathogens Standard. Other subjects important to the lab include exposure follow-up, vaccination requirements, and signage and labeling. The standard even goes into detail about pneumatic tube use and specimen packaging.

The last section of the standard discusses the training that is required for all staff. When done properly, you might avoid confrontations like the one between Marlene and Doug. Staff is required to have initial and at least annual education about bloodborne pathogen epidemiology, exposure reduction methods, PPE selection and use, exposure response, and signs and labels. This one set of regulations should be explored and discussed regularly with your lab staff. A solid exposure control plan will reduce the number of laboratory acquired infections and work to improve the safety of our highly-valued staff.

Many lab managers and safety professionals tell me they cannot get staff to maintain compliance with the safety basics in the lab. There tends to be several different possible reasons for this, and you may encounter one or more of these in your work area:

-No management/medical director support of the lab safety program.

-No time for leadership to focus on safety.

-No safety education for staff/leadership.

-No understanding of consequences of unsafe behaviors.

There are safety savvy solutions for each of these areas, and they vary, but today we will focus on the last entry:  No understanding of consequences of unsafe behaviors. This can be a powerful educational tool in many ways when used to improve the lab safety culture. There are physical consequences, emotional consequences, and financial consequences for unsafe behaviors in the lab. Teaching any of these is beneficial, but things have changed in 2016, and the financial consequences to labs and hospitals have increased.

The Federal Civil Penalties Inflation Adjustment Act of 1990 allowed many Federal agencies to review and adjust their civil penalties once every five years. One exemption that was made at the time was that OSHA would be excluded from any penalty-adjusting authority. 25 years later, OSHA has been granted the ability to adjust its fines to match inflation rates. That means that OSHA fines could potentially increase in 2016 by up to 80%. That means a $7000 fine goes up to $12,600, and that’s just for one violation. A “willful” violation charge will move from $70,000 to $126,000.

These rate increases must be put in place by August of this year, and they can and will affect laboratories. This is information that can be used to explain to lab staff the importance of following safety guidelines. OSHA is visiting hospitals and labs in increasing numbers, especially since hospitals have been on their “high risk workplace” list for the past few years. Because of high worker injury rates, OSHA inspectors are coming for hospital visits, even without complaints or cause. Many hospitals have already been visited and inspected this year.

This is education that needs to be explained to staff, and should be connected to the importance of safety compliance in the lab. A sharps container with no lid is a single violation with a fine of $12,600. An employee working with open specimens and no face protection is a fine of $12,600. If a review of training records shows the employee was trained on PPE use, the fine becomes categorized as “willful,” and it increases to $126,000. If multiple violations are seen, the fines are multiplied as well. This can get very expensive, and in some cases it could close the facility. If personal safety doesn’t create compliance for your staff, use these numbers. They are real, and they can be quite impactful.

The fines levied by an OSHA inspector can vary. The actual amounts are at the discretion of the individual inspector, and it can be many weeks after an inspection before the exact fines are known. However, the inspector will not leave the lab without notifying them of what violations were recorded. Does your lab staff wear gloves when necessary? Do they button up their lab coats and keep their sleeves rolled down? Are they wearing shoes made of non-absorbent material? Is anyone chewing gum? These are the violations that can close the lab down if the circumstances are right.

Ergonomics tends to be a lesser concern in the realm of laboratory safety, and noise- an ergonomics issue- gets even less attention. Both the Occupational Safety and Health Administration (OSHA) and the College of American Pathologists (CAP) require that noise gets proper notice in the lab. Laboratories of all types must have a policy that outline how workers will be protected from over-exposure to noise. What is over-exposure? How can that be measured? Are you doing what needs to be done to meet these standards?

If you have never measured noise levels in your work area, then it is time to take that first step. OSHA requires monitoring in areas where employees may be exposed to 85 decibels (dBA) as measured over an eight hour Time-Weighted Average (TWA). Many laboratories have noise-generating equipment such as centrifuges, analyzers, Biosafety Cabinets, pneumatic tube systems, and more. Smaller labs and clinics may not have equipment that is noisy, but it is a good idea to at least document a baseline set of readings. If your work area is near or above the 85 dBA limit, you should take measurements on a regular basis. If readings are above 85, you must establish a Hearing Conservation Program for your laboratory, and regular noise readings will be a part of that.

Noise readings can be taken in two different ways, via the use of a noise meter or a noise dosimeter. No matter which equipment is chosen, it must be calibrated. A noise dosimeter is a device that stores sound readings and integrates them over time to provide an average of decibels recorded over that given time. A dosimeter is a small device worn by the employee or placed in a given area. Alternatively, a noise meter may be used. This is a device which records single noise readings. Because the meter cannot provide a noise TWA, it is necessary to take multiple readings in multiple locations throughout the laboratory. I recommend at taking at least five readings per location. Be sure to take readings in all areas where employees perform their duties. When taking noise measurements, make sure the usual lab background noise is present- analyzers should be operating, centrifuges should be spinning, and radios (if present) should be playing. It may be necessary to take individual measurements at different times throughout the day. When using a noise meter, you will have to estimate the overall noise exposure and show that levels are under the 85 dBA limit. If you do not have the equipment necessary for monitoring sound using either method, check with the Facilities or Occupational Health department (if applicable), or you may need to contact an outside vendor who performs such readings.

If the noise exposure is determined to be greater than 85 dBA, then the Hearing Conservation Program must be put into place. The program must include continued regular monitoring of noise levels, audiometric testing of employees, hearing protection, and training. Audiometric (hearing) testing must be offered to all affected staff and be performed by a qualified individual (such as an Occupational Health nurse). Employers must provide hearing protection (such as ear plugs) that fit comfortably and offer sufficient protection. Train employees in the proper care and use of such devices. Employees should also have access to OSHA’s Noise Standard, and complete training on the program should be documented.

Once you have a noise program in place for the laboratory, remember to keep it active. If there is a change in equipment (a new analyzer, fume hood, etc.), or if equipment is moved, new noise readings should be taken. If employees complain about noise in a particular area, do not ignore the complaint- take measurements and report them to the affected staff.

A few years ago the average age of medical technologists working in the field was 51, and that number is climbing. Many are nearing what they hope to be happy and healthy retirement years. Sometimes, though, those years are not so happy and healthy. Issues may arise such as carpal tunnel syndrome, neck and back pain, tendonitis and bursitis, and issues with vision. Some of these health issues can be a direct result of how you performed your job in the laboratory – they may occur because you did not pay attention to ergonomics.

The word “Ergonomics” is formed from two Greek words; Ergon which means “work,” and Nomos which means “the study of.” Logically then, ergonomics means “the study of work.” Clearly that does not make a clear or helpful definition. Ergonomics is the science of adapting the job and the equipment and the human to each other for optimal safety and efficiency.

In the realm of laboratory safety, ergonomics tends to take a back seat to other safety priorities. Part of the reason is that the effects of poor ergonomic practices do not show up for years. Musculoskeletal disorders (MSDs) and repetitive motion injuries take a long time to develop, but they have long-lasting and sometimes crippling effects.

Ergonomics should be a part of any lab safety program. Train your staff how to work properly with equipment, to take breaks from repetitive actions, to use proper body mechanics, and to report potential ergonomics issues. Perform an ergonomics assessment and make necessary changes. Are foot rests and floor mats provided and adequate? Do chairs allow for the proper adjustments? Are counters and work benches set up for easy reach of materials and equipment? Is there special training for those who work at computers or microscopes for long periods?

If you don’t feel that you can expertly perform an ergonomics assessment in the lab, reach out to a resource to help. Check with your provider of Occupational or Employee Health services. They may be ready and willing to perform the assessments for you or even provide you with training. In time you will be able to watch for ergonomics issues in several aspects of lab work: sitting, standing, computer work, microscope work, micro-manipulation, and lifting.

Ergonomics issues have been costly to the United States medical system, and surgery costs are increasing. That added to the time away from work, the time and effort for training replacement staff, and the overall staff shortages make musculoskeletal disorders a major financial and productivity problem for laboratorians. The issue can be quiet and insidious.

For eight years, while performing lab safety audits, I have cited a couple of labs for having keyboards raised. The little legs on the rear of the computer keyboard were up and there was no wrist rest in place. Ergonomically, this is an unsound practice, and it is one item on my safety audit checklist. Needless to say, managers do not view this as a big lab safety issue- not when faced with things like PPE issues, out of date safety checks and various more immediate problems. However, a raised keyboard can create problems for those who perform at the computer often. These problems may not show up until later in life, but the stresses on the wrist of a hand working constantly at an angle (rather than in a straight line as is best) can be serious for that employee.

Last month, while conducting a safety audit, the manager asked me how her lab was doing so far. I reviewed with her the items I had cited, and one was that pesky keyboard issue. I stepped out of the department, and when I returned, I found a pile of keyboard legs on my laptop with a note- “now you can never cite for this again!”

You may not consider this a major safety victory, but it did illustrate a couple of points I have been teaching safety professionals for years.

1: The secret of a successful lab safety professional is that he or she never goes away- they never quit on an issue.

2: If there is only one person promoting safety in the lab, then that is enough to make a difference.

Point 1 is easier to see in this illustration. When I first began performing these safety audits in the labs, I was citing many areas for that particular ergonomics issue (among others). Some of the lab managers I work with strongly support safety, and others do not, but most were in agreement- this was not a big deal and they were not going to worry about it. I persisted. I cited it every year. I did not give up. I did not go away.

This year, when the manager removed the keyboard “feet,” the story spread, and two other managers did the same. It was a minor safety victory- but it was a victory nonetheless.

Point 2 is a bit more obscure, but it is very important. I have worked with some lab safety professionals whose manager does not support safety in the department. They are trying to make a difference in their safety culture and they feel alone and useless. I strongly believe that the lab safety program will have faster success with management and medical director support, more members on the safety team is definitely of benefit. However, I also believe that one person alone can make a difference in the lab’s safety culture.

For the keyboard story, I was the only one who seemed to care about that one safety issue. I made no headway on it for eight years. Success came (albeit slowly) even though I was the only person talking about it. You might be the only person talking about safety on your lab, and you might be repeating yourself often. You might not see it yet, but you are making a difference.

As a lab safety professional, you may come to a fork in the road on your way to safety improvement. The path to the left could be a road of persistence- you may be fighting the same battle over and over again. To the right is the lonely road where only you seem to be supporting the lab safety initiatives. You might even take the middle road where both challenges occur.

No matter the path you may be forced to take in your work place, the same tactics will assist you in navigating to safety success. Be patient, be persistent, and keep talking about safety.

On which side of the aisle do you stand on the subject of change? Things change – or – things never change? The only constant is change – or – it’s always the same old thing? When it comes to the lab safety culture, there are some generally-accepted thoughts. Change is difficult. Change is slow. Change takes persistence and patience.

I’ve heard other things too- people hate change, or people like change as long as they get to be in charge of it. I do believe most of us like change. After all, we change our clothes, we re-arrange our furniture, we remodel a room in our home. It can be exciting- but the tables seem to turn if it’s a change that is forced upon us or that was not our decision. Changing your lab safety culture for the better can be difficult, but it can be done. First, however, you need to know the current culture and goings-on in your lab in order to be able to make a difference.

There are specific ways to determine the safety culture in your lab. An experienced safety professional can do it fairly quickly. For others, especially those who serve in multiple capacities (you know who you are- you’re in charge of lab safety but you’re also the lab manager, or the quality coordinator, or the POCT coordinator) – for them assessing the culture can be difficult, even with years of experience- because you have so many other things on your plate. That can hinder your ability to make quick assessments, but it will not hinder you completely from being able to make a true safety assessment.

To make an assessment you need to use specific tools that you likely have at your disposal. These tools may come in many forms.

Those who have followed my work for some time know about the tool “Safety Eyes.” This is a safety assessment tool I believe to be a “super power” that we all have and need to develop. It is so powerful, in fact, that a developed user can make a fairly good and accurate safety assessment with a quick glance into the department. Performing a lab safety audit is also a very valuable tool that can give you much information about the department’s culture. Perform a complete audit at least annually, and follow-up on the results. Otherwise, you have wasted your time and resources.

Another important safety culture gauge is the use of a written or electronic safety culture assessment. You may be able to tell what’s going on visually and physically by the evidence of your eyes and safety audits- but this tool is a way to actually get into the heads of your staff. What do they think of the culture? What is their opinion of it? What do they think needs improvement, and how would they suggest making those changes? A safety culture assessment can be given to everyone, or it can be used for specific lab groups. Survey the lab staff, survey those responsible for safety, or survey lab leadership. You should perform a lab safety culture assessment at least annually, but it can be done more often as needed.

Lastly, you can use laboratory data that you already collect to see the current state of safety in the department. Analyzing the data you collect about the injuries, accidents and exposures in your laboratory can be very eye-opening, and if you share the data as safety education, you may be able to lower the number of these types of incidents. Look at the chemical and biological spills in the lab. Analyze how they happened and how to prevent a re-occurrence. If you’re the quality coordinator for your lab or system, you know about root cause and common cause analyses. The incidents that occur in the lab that generate a root cause investigation may not always be about lab safety- but it’s possible that investigations show safety is a key factor, and those results should be reviewed with the safety person in the lab.  

One of the most important on-going activities for a safety leader is the training of the safety team- not just training on safety regulations- but training team members how to coach employees about safety issues as they are discovered on the job. A laboratory safety professional may know and understand every safety regulation, but if they cannot effectively approach and speak to others about safety problems, their usefulness in that role wanes.

How do you speak to employees or co-workers about observed safety failures? This is one of the most difficult jobs for a safety professional in the department, and using the correct approach is critical for success in a peer coaching scenario.    

Situation: John, the safety leader for the lab, witnesses Mary working in the chemistry area with open samples and no face protection. He spoke to her last week about this unsafe behavior.

Response 1: John remembers that Mary’s response to the conversation last week was uncomfortable for him. She did not take his coaching well. He decides to let it go. He can’t change her behavior anyway.

Response 2: John approaches Mary and says, “Mary, I can’t believe you are working again without face protection- especially after we argued about it last week. You need to change your actions and your attitude!”

In case you’re not sure (I hope everyone reading this is sure), neither response is appropriate. Response 1 is passive, and it accomplishes nothing. John shows no assertiveness here. Response 2 is the opposite- John shows too much assertiveness and speeds on ahead to aggression. This response is likely to be no more effective than the first. So how does John find the right level of assertiveness?

When it comes to assertiveness for the purpose of safety coaching, the path lies somewhere in the middle of these two extremes. Assertiveness is called for, but determining the right level is important in each coaching conversation. When coaching for safety, remember to address the real issue and not to get sidetracked. Address the issue in private, and discuss whatever barriers might exist that prevent the employee from taking the correct safe action(s). It is always a good idea to end the conversation with an agreement about future behavior. Here is an example coaching session for Mary and the situation John witnessed:

“Mary, I noticed you are handling open specimens without face protection. That can result in an exposure for you. I remember we talked about that last week. Is there a reason you don’t want to use a face shield?”

“Well, John, I don’t like the counter-mounted shield because I can’t get my arms around it when I’m working, and it isn’t convenient. I would like to wear the disposable face shields, but I don’t know where they are.”

“Oh. I should have told you about that last week. We keep the box in the supply room. Since you prefer those, I think we should keep some here at the work bench.”

“That would be good.”

“Ok, Mary, if we keep them here, can we agree that you will use them whenever you’re handling open specimens?”

“Yes, John, I can do that. Thanks,”

Every year I love to use October as the time to discuss fire safety. After all, many other organizations promote fire safety ever since October was designated as National Fire Prevention Month in 1922. This year, as always, I do want lab safety professionals to be “fired up” about safety, but there have been some questions about regulations in this area that need special discussion. 

The College of American Pathologists (CAP) is the accrediting agency for many labs in the United States, and they have specific regulations about fire safety on their General Checklist. 

One regulation states: “If the fire safety plan includes laboratory staff use of fire extinguishers, personnel are instructed in the use of portable fire extinguishers.”

If fire extinguishers are present in your laboratory, their purpose is to be used by the staff in the department, whether or not the safety plan includes staff using them or not. OSHA has something to say about this as well: “If fire extinguishers are available for employee use, it is the employer's responsibility to educate employees on the principles and practices of using a fire extinguisher and the hazards associated with fighting small or developing fires.” The CAP checklist strongly recommends that staff have hands-on fire extinguisher operation that includes the actual use of the device (or a simulator). They do not indicate how often this training should occur. Many labs I have inspected only provide the training once, but OSHA states that it must be provided upon hire and annually thereafter. That makes sense, and lab staff should be ever-ready and able to extinguish a small fire should that become necessary.

The next CAP regulation states: “Fire safety training is performed for new employees, with a fire safety review conducted at least annually.” 

This regulation was altered in 2014. In previous versions, CAP required fire exit drills for all lab staff. They have replaced that with a “physical evaluation of the escape routes  (that) must be performed annually, to ensure that fire exit corridors and stairwells are clear and that all fire exit doors open properly.” 

Many labs found the requirement to perform fire exit drills for all staff to be inconvenient, but I believe that process should still occur. Just as with fire extinguisher use, knowing how to respond quickly and efficiently in an evacuation is very important, and a review of this process should occur with all staff annually. The evacuation drill may be used as the method to document that physical evaluation of the escape routes that CAP now requires.

As a lab safety consultant, I get questions from many different lab professionals, and I share the answers to those questions in my monthly newsletter so that others with similar issues may benefit from the information. Most of the answers are derived from safety regulations or guidelines that are in place, but there are some questions that just don’t allow for an answer that is easy or straight-forward. Here are some examples:

Q: Why should chemicals be stored below shoulder level?

The closest standard that addresses this is from CAP which mandates that strong acids and bases are stored near the floor. However, other chemicals stored on high shelves or in high cabinets can be a danger as well. There have been many incidents where personnel have reached up to grab a chemical and had it spill into their face. Even new packages of chemicals or reagents can be defective and may leak. It is best to store all chemicals in the lab below shoulder level. Whose shoulders? The shoulders of the shortest person who may be working with those chemicals in the lab.

Q: Do trash cans need lids in the lab?

OSHA’s Bloodborne Pathogens Standard and CAP both have regulations dealing with this issue, but it often remains unclear to many. While in the lab and while in use, regulated medical waste containers do not need a lid. If the bags in the containers are removed from the lab, they should be placed into a bigger container with a tight-fitting lid. If the actual lab containers will be removed, they then need a tight-fitting lid for the removal process.

Sharps containers are different- they should always have a lid and should be prevented from tipping over. If the container does tip, the contents should be prevented from spilling out.  

Q: Do employees need to physically walk to the lab evacuation location every year?

CAP removed its standard in 2014 requiring labs to perform this particular duty, but they still require labs to perform and document a physical evaluation of the escape routes annually to ensure that fire exit corridors and stairwells are clear and that all fire exit doors open properly. The best way to do this is to continue walking staff to their evacuation location every year. Not only does this provide a check of the route, but it regularly reminds staff how to proceed in any evacuation situation.

Q: How long do I need to keep Safety Data Sheets?

The language in the OSHA Hazard Communication Standard can be confusing, but the bottom line is this: if a chemical has been involved in an employee exposure, you should keep the SDS for 30 years in case there is any legal follow-up. If you have hundreds of chemicals, or if you have not worked in the location for very long, you may not know which chemicals have been involved in an employee incident. In that case, it is best to keep all SDS in storage for 30 years. Keep old copies in a binder marked “retired.” If you have converted to an electronic SDS system and it contains the SDS from your current or past inventory, you would not need to keep any paper copies on site provided you can access them.  

As you can see, not all lab safety situations are easy to tackle, and the answers are not always straightforward. When a written regulation cannot be found to provide guidance to a safety question, I immediately look at what would be the best or safest practice. Regulations do not cover every area of lab safety, so as lab safety professionals, we need to think through those situations for which regulations are not clear. It is also very helpful to know what resources you have to use to help you solve safety issues. Know your internal resources (maintenance, infection control, biomedical engineering, etc.), and your external resources (chemical waste contractor, industrial hygienist, safety consultant, etc.) as well. Utilize all of these tools, and you will make smart safety decisions in your laboratory.