The Educational Audit

The Lab Safety Officer (LSO) had years of experience, and he was proud about how far he had advanced the lab safety culture. He had focused on fire safety for a long time because when he started, very few staff members knew how to respond to fire drills or alarms. He studied fire regulations and educated staff about them. He performed safety audits, looked for and corrected potential fire safety issues, and overall felt fairly certain that he had learned all there was to know about fire safety.

When the hospital accreditation inspector walked through the laboratory, the safety officer accompanied her. The inspector opened a freezer containing patient specimens in one of the specialty labs. The safety officer had opened that freezer many times during audits, but this time the inspector asked a staff member if anything other than serum was stored in the specimen tubes. The staff member stated that there was methanol and other reagents added to the tubes. The inspector turned to the lab safety officer and stated she would need to cite the lab for inappropriate storage of flammable materials. According to NFPA-45, a national fire code for labs using flammable materials, these specimens need to be stored in a freezer that is designated as explosion-proof. In all his years, the LSO had never seen that regulation. Upon further investigation, he also learned that every laboratory refrigerator needs to be labeled as to whether or not it is capable of storing flammable materials.  

Later during the accreditation walk-through, the inspector noticed that the flammable cabinets in the laboratory did not have self-closing doors. The LSO asked if that was a requirement, and if so, where was it stated. The inspector said that self-closing doors was a requirement of the International Fire Code (IFC), and it was required if the state adopted the code. Again, upon further study, the LSO learned that 48 U.S. states had adopted IFC, and he now needed to consider replacing his flammable storage cabinets with self-closing units.

When the auditor reviewed the lab’s Exposure Control Plan, she asked how education about Bloodborne Pathogens was given to the staff. The LSO was happy to show the inspector staff education records which showed that every employee viewed a mandatory computer-based training program which covered all aspects of bio-hazard education. When the inspector asked how employees could inter-actively ask questions about bloodborne pathogens as required by the standard, the LSO could not answer. When he researched the OSHA standard, he found the requirement, and he told the inspector he would work with the hospital to figure out how to make the changes to their annual education.

As you might imagine, the safety officer wasn’t feeling quite as proud of his lab safety program after this inspection. In fact, he felt more than a little surprised that after so many years in the field that there was so much he still had to learn about lab safety regulations. He was disheartened, but he was able to turn that feeling around into a resolve to make the necessary corrections, to learn more about the regulations, and to continue to make improvements to the lab safety program.

One of the benefits of having an outside auditor come through your lab is having that new set of eyes in an area that you may see every day. Maybe the inspector has a very different background- perhaps they were a fire inspector previously – and they can enlighten you about specific regulations you hadn’t considered before. Be sure to look at audits as an educational opportunity, even if (or especially if) you receive several citations you were not expecting. The world of safety is always changing, and there will be changing regulations and other regulatory agencies you just didn’t know about. Take that as an opportunity to learn, to grow, and to always be working to improve your lab’s safety culture.

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.

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