While it doesn’t seem possible, another year is drawing to a close. At this time of year, I often ask my clients what they have worked on or what they have accomplished with regard to laboratory safety in the past twelve months. Sometimes they can readily answer, especially if there was a major project that took a big chunk of their time. Other people, though, struggle with an answer wondering if they did indeed accomplish any of their safety goals. I contend that we all have had successes and achievements, though, but we might need to dig a little deeper to find them.
Regulations in the realm of laboratory safety did not stay the same in 2018, and if you kept up with any of them, you made some progress. For many U.S. states, the beginning of the year brought about the Environmental Protection Agency’s Generator Improvement Rule (GIR). Among other things, this new set of regulations changed how labs (and other departments) label their waste containers. All hazardous (chemical) waste containers must now be labeled with the exact words “Hazardous Waste,” and there must be a description of the waste as well as some form of a hazard warning. That warning can be in the form of a pictogram or even a NFPA/HMIS warning legend. The GIR also now allows Small Quantity Generator sites to dispose of larger amounts of waste twice per year without needing to upgrade their EPA status to a Large Quantity Generator.
The College of American Pathologists (CAP) added some standards that affect lab safety practices as well. One new requirement includes the need for a laboratory security policy. Labs need to state how they restrict access of personnel into the area, and they need to spell out how to handle visitors to the department. Other new regulatory standards include the need for the safe handling of liquid nitrogen and dry ice. Labs must provide proper training and PPE for the handling of these dangerous materials, and there is even a new requirement for the placement of oxygen sensors where liquid nitrogen is used. If your CAP inspection window opens soon, you have probably already made these changes.
While keeping up with regulations might be your goal, sometimes lab inspection results can spur you on to making accomplishments for the advancement of safety. In one lab, an inspector found a freezer full of patient samples that were mixed with methanol. The freezer was not designated as explosion-proof as required by NFPA-45, the Standard on Fire Protection for Laboratories Using Chemicals. Upon further investigation, the lab safety officer found a few other freezers and refrigerators which were storing flammable materials inappropriately. This led to re-arranging some materials, and it also led to the purchase of more explosion proof units where needed.
Another lab received an OSHA inspection and received a fine for not following the training requirements of the Bloodborne Pathogens standard. The regulations state that during staff training, there must be an “opportunity for interactive questions and answers with the person conducting the training session.” Most labs offer an annual computer-based training for Bloodborne Pathogens, and that does not satisfy OSHA inspectors. The lab that was cited made a change to how the mandatory training program was offered, and they created a method for which staff could ask questions of the trainer. This was another example of an inspection which helped the lab make safety improvements.
In the world of lab safety, it sometimes feels like simply surviving day-to-day is the accomplishment. We’ve put out fires, we’ve responded to questions, and we’ve submitted our required monthly injury and exposure reports. It may feel like performing the job is simply a reaction to what is going on each day, and that is difficult for the lab safety professional. We realize that being proactive is better, we know that is how we decrease employee harm and improve the safety culture. However, I invite you to take a second look at your past twelve months. Yes, it may be that changes were made because regulatory agencies altered the standards- but there is no way to predict that unless you sit on the decision-making board of those organizations. Yes, you might have had to respond to inspection citations, but isn’t it good to have another set of eyes helping you to make safety improvements? Try not to always think about why safety improvements were made. Instead, remember to view them as positives- they are another step to improving safety the way you do it every year. They are truly accomplishments, and as you approach the new year, you can use them as stepping stones toward your next safety goals.
–Dan Scungio, MT(ASCP), SLS, CQA (ASQ) has over 25 years experience as a certified medical technologist. Today he is the Laboratory Safety Officer for Sentara Healthcare, a system of seven hospitals and over 20 laboratories and draw sites in the Tidewater area of Virginia. He is also known as Dan the Lab Safety Man, a lab safety consultant, educator, and trainer.