lab safety – Page 10

The Final Countdown

As June 1 rapidly approaches, I hear many questions about OSHA’s final deadline in its implementation of the Globally Harmonized System (GHS) for the classification and labeling of chemicals. For laboratories in the United States, this journey began in 2013 when the first training deadline arose. All employees who work with chemicals were required to have training on the changing chemical label elements and the updated and standardized Safety Data Sheets (SDS).

Helpful Hint: Neither you nor your staff should be writing or saying “Material Safety Data Sheet” or “MSDS.” Those are outdated terms and should no longer be used. Unlike the old versions, the new SDS are standardized with 16 uniform sections that are the same no matter which chemical manufacturer provides the information.

The 2013 GHS training provided a good amount of information, and it raised many questions. Will manufacturers really be using pictograms and signal words to identify hazards? Would they truly be able to make those changes by the next deadline dates? How does that affect secondary chemical container labeling? What about changes to the lab’s chemical hygiene plan and signage? It was a great deal to absorb and digest.

The year 2015 held within it two more deadlines that would affect all laboratories. First, chemical manufacturers would have to create only products which contained GHS-compliant labels, and they would have to produce only GHS-compliant SDS. OSHA realized that these manufacturers would have a substantial amount of non-compliant inventory at this point, so there was a six month period before the next requirement would be enforced. That meant these companies would have six months to continue delivering non-compliant chemicals and SDS to laboratories. The second deadline in 2015 was the cut-off period for these manufacturers. They would no longer be permitted to ship chemicals with non-compliant labels or SDS. The last deadline would also provide a six month gap. OSHA has given laboratories time to accept and use these chemicals with non-compliant labels.

Helpful Hint: Walk around your laboratory and look at all of your primary chemical container labels. If you find any that are not GHS-compliant, you need to remove them from your lab before June 1 of this year. OSHA does NOT allow the re-labeling of primary chemical containers.

The final GHS implementation deadline, June 1, 2016, requires that labs complete the updates of all workplace labels, Safety Data Sheets, and any hazard communication policies and procedures. The lab Chemical Hygiene Plan should be updated to include newer terminology and labeling instructions. The chemical inventory may need updating as well to include signal words or pictograms if used on that form. While this last deadline has an impact on primary chemical container labels, it does not need to affect secondary container labeling. OSHA does allow the continued use of NFPA or HMIS labels for secondary containers in the lab provided staff is trained on those hazard warning systems as well.

Helpful Hint: For consistency and better staff understanding, choose one labeling convention for secondary chemical containers in the lab. Using GHS and NFPA/HMIS may be confusing. Labeling is an important piece of hazard communication, and staff needs to be clear on what hazards they may be handling.

Some signs in the lab may need updating in certain areas. Buried in OSHA’s Formaldehyde Standard (1910.1048) is a GHS reference that points to a required wording change. If the formaldehyde warning sign is posted in your lab, the GHS implementation requires updated wording. The sign is required in labs where the formaldehyde concentration exceeds OSHA’s limits as detected via vapor badge monitoring. The updated signage must read as follows:

DANGER

FORMALDEHYDE

MAY CAUSE CANCER

CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION

AUTHORIZED PERSONNEL ONLY

The full implementation of the Globally Harmonized System is here, and it is a modern system designed to adequately communicate hazards to those who work with chemicals. Many countries around the world have been or are in the process of adopting GHS, a system which provides standardized warnings and information. Once fully implemented in your laboratory, these updated chemical hygiene practices will assist in providing an environment for working with chemicals that is both comprehensible and safe.

Scungio 1

-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.

The “Safety Eyes” Epiphany

The manager walked into the lab to talk to Joan about the schedule. Joan was working with Mike, an older technologist who never seemed to follow the safety regulations of the laboratory. Joan was glad her manager was coming, because today Mike was wearing mesh sneakers and he was chewing gum! She couldn’t wait to see the manager chewing him out about that. However, the manager walked quickly to Joan, asked her a question and went immediately back to the office. She never said a word to Mike.

There are several things to be said about a scenario like this. First, why doesn’t Joan say something to Mike herself? Why doesn’t she feel empowered to speak up for safety? Has anyone ever taught her how to coach her peers for safety? Second, does the manager realize how much damage was just done to the lab’s safety culture? Intended or not, her ignoring Mike’s behavior is tantamount to permitting it, and therefore promoting it.

I was a laboratory manager before I became a Lab Safety Officer. When I moved to the safety role, I was lucky to have the previous safety officer still on site to provide orientation. As we walked through the labs, my predecessor noticed several safety issues and corrected them. I was very disheartened since I didn’t notice any of them myself. I wondered if I could do the job. Not long after that, I had a “safety epiphany.” I realized I could not see those safety issues because I had not trained myself to see them. I had not yet learned how to use my “Safety Eyes.”

Since then, I have been training lab people that “Safety Eyes” is a super-power that all laboratorians have. It is a latent ability and it must be honed in order for it to be effective. In order to do that, you need to know what to look for- be aware of the lab safety regulations so you can discern between right and wrong when it occurs. Next, you need to practice. That is the most effective development method for “Safety Eyes.” Knowing where to start can be difficult, so it is best to start by focusing on one safety topic at a time.

Begin by looking at Bloodborne Pathogens issues. For example, are people wearing correct PPE? Are waste receptacles properly labeled? Are spill kits in place and not expired? Next, look at chemical hygiene issues. Are secondary containers labeled correctly? Are acids and bases stored near the floor? There are a large variety of safety items under each topic that can be checked visually in the laboratory. Move to fire safety and on to other topics. Choose one area per week to start, and over time you will become proficient in spotting safety issues with your now-powerful “Safety Eyes.”

During the first year of my role as a Lab Safety Officer, I would become angry with the lab managers who didn’t seem to support the safety program- those who would walk through their labs and not see what I considered to be obvious safety issues. Then I had to remember my days as a manager- did I pay attention to those things? No, I didn’t. In part that was because I had so many things on my plate that I was focused elsewhere- just like the manager talking to Joan about the schedule. I also did not have any Safety Eyes training, so I simply wasn’t equipped to see all of the problems.

Today, I provide Safety Eyes training to lab managers. I use photographs of safety issues- pictures taken of real issues in the lab. Using these visual aids hones their ability to see the issues the next time they walk through the lab, and it raises safety awareness for everyone. If you lead a laboratory, and if you do not focus on safety, I understand that. However, you should understand that is important to make a change- develop those Safety Eyes and advance your safety culture in a way your staff can appreciate and support.

Scungio 1

Lab Safety: A Deadly Ride?

Mumbai is one of the financial capitals in India, and millions of commuters ride its railway network to and from work every day. However, over the past several years, the available public transportation has not increased in proportion to the city’s rise in population. This has resulted in overcrowded trains and a staggering death toll from accidents and falls. In 2005, a total of 494 passengers lost their lives after falling from running trains. This figure went up subsequently in the coming years and climbed to 901 by 2013. In 2015 nine people a day, on average, lose their lives while on the move.

Knowing these facts, how inclined would you or your lab staff be to take a train ride in Mumbai? Not very. Yet, there are people in that city who willingly get on board every day. These conditions of danger are normal for them. This is their culture. They have become immersed in it, and it has become difficult for them to step back and look at the big picture–even for their own safety. They have to get to work.

In the past, laboratory professionals worked in departments where mouth-pipetting was normal, where eating, drinking and smoking was common, and where working without PPE was accepted. Today we look at old lab pictures of these behaviors and react (I hope) with surprise. But what applies to the commuters in Mumbai might also apply to labs of the past as well—those technologists were immersed in their culture.

Since those times, many lab safety regulations have been put in place, but that hasn’t fixed the safety culture everywhere. There may be, of course, other reasons for unsafe conduct in the laboratory. There may be behaviors that have been held onto after years of practice, there may be a lack of safety education, or safety may simply not be a priority for lab leadership. All of these factors are a part of the lab safety culture. Do you know the culture on your lab?

Assessing the culture in your laboratory is important. If you are in leadership, you should not assume that your singular view of the culture is accurate. There are several ways to evaluate the culture; make a visual assessment, review injury and exposure incidents, or have staff take a written culture assessment.

Provide adequate safety education for your staff. Are they aware that there might be a better, safer way? Do they know where the PPE and engineering controls are? Have they been trained in their use? Is there any safety leadership holding staff accountable so that there are not too many people on the train?

Laboratory professionals have to get to work, but unlike the workers of Mumbai, it’s not necessarily the trip to work that’s an issue; it’s the work places which are not inherently safe. It takes knowledge, education, training and focus to keep people safe in the laboratory. Put safety in its proper perspective: we are not dealing with falling from a train, but we do encounter injuries, exposures, and lab-acquired infections, some of which can be just as deadly as a fall. Know your safety culture, and learn what it will take to make the needed changes so that no one in your lab becomes a statistic.