As a lab safety professional, we know performing risk assessments is an integral piece of managing a safety program. In fact, assessing risks and identifying hazards are considered the beginning steps that must be completed when approaching the management of any safety-related area. Risk assessments are the starting point for handling a bloodborne pathogens program, chemical hygiene, personal protective equipment, and many other lab matters. But how can you be sure they have been performed correctly, and how often should they be performed?
OSHA gives simple guidance on basic assessment of risk in the workplace. “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).” They further state, “the employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the dates(s) of the hazard assessment; and which identifies the document as a certification of hazard assessment.”
OSHA’s Bloodborne Pathogens standard requires that labs perform an exposure risk determination for each employee. Labs must assess exposure risk levels by job classification, and then assess exposure risk for tasks performed in the department. The Hazard Communication standard explains the need for chemical hazard determination. There are many types of risk assessments that must be performed, and regulations stipulate that they must be reviewed and updated (if necessary) every year. Things change in a dynamic department like the laboratory, and understanding the changing risks of harm can be key to keeping staff safe.
The four basic steps included in a risk assessment are hazard identification, identifying those at risk, choosing control measures, and reviewing the findings. It may sound easy, but lab hazards can come in many forms (physical, mental, chemical, biological, etc.), so walk around the department to look for those you may have missed. Review incident records as well to see what harm is occurring in the lab. Next, determine what employees may be harmed and how. Consider those who work in the lab each day and those that are just passing through the area. An evaluation of the risks follows. If the risk cannot be removed, decide what controls (engineering, administrative, PPE) need to be in place. Finally, review each risk assessment on a regular basis. Things change in the lab, and with change may come new hazard risks – or even the reduction of potential harm if risks have been reduced via elimination or substitution. Again, examine these assessments at least annually or whenever major changes occur in a particular lab safety arena.
For many laboratories, the advent of the COVID-19 pandemic brought new testing platforms and procedures to the department, and this testing had to be implemented quickly. Is there a way to use risk assessments to help introduce new processes safely? Absolutely! The use of a standard form to assess the potential hazards of new or updated processes and/or equipment is actually a high quality finishing touch on an overall assessment program, and unfortunately, it is something that is often missing in many labs.
Considering the tasks, sample handling, equipment, reagents, and overall biosafety of the new process, choose the likelihood of hazard incidents (rare, possible, likely, etc.), and classify the consequences of each occurrence (minor, moderate, major, etc.). Use a matrix to calculate the overall level of risk for the new procedure or equipment. For example, if a new COVID-19 test platform requires opening samples, the likelihood and risk of exposure may be designated as “high” or even “very high.” Next, determine the controls that should be put in place to decrease the exposure opportunities. For example, if centrifuge rotor covers, a biological safety cabinet, and a surgical mask is added to the normal lab PPE, the overall risk of that testing process is reduced. Document the decision and keep those records available for any future reviews that may be needed. Once the assessment is complete, complete the appraisal of the new process with a quick safety audit. Look for additional biohazards encountered, chemical safety, electrical safety, and even potential waste handling issues. If you couple that safety analysis with the risk assessment, you are doing an above-average job at circumventing hazards in the department. (For examples, go to https://www.aphl.org/programs/preparedness/Documents/APHL%20Risk%20Assessment%20Best%20Practices%20and%20Examples.pdf)
Keeping staff safe from exposures and injuries in the laboratory is a massive and time-consuming task, but it is required by our regulatory agencies and it needs to be a top priority. When used properly and completely, a risk assessments can be a powerful tools that begins your look into safety hazards and then closes the loop to avert them. Having an awareness and control of departmental hazards is one way to rock safety in the laboratory.
–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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