Regulating Your Lab Medical Waste

In general, there are two reasons employees in the laboratory should care about proper waste disposal. Improper disposal is expensive. Laboratorians like raises, bonuses, and updated equipment, but there is less money for those things when paper items are tossed into sharps containers or when used gloves go into red bag trash containers. Labs in many states also risk large fines if items with biohazard symbols are disposed of into regular trash containers. The other reason to care about trash disposal involves the environment. Regulated Medical Waste (red bag trash and sharps) has to be treated, and some of it is incinerated while some ends up in special biohazard landfills. Both of those are things we want less of in our environment.

As a lab safety professional, you may know of several other reasons to implement and maintain proper lab waste segregation, but in my years of safety training, money and the environment are the two that tend to hit home with staff. There are multiple waste streams generated in the lab setting, and while management in some departments may choose to offer only biohazard waste receptacles for everything, the safety savvy professional knows this is wasteful and perhaps a bit lazy. With proper education and training, laboratorians are capable of goo trash segregation that meets the regulations and meets best practice standards.

Appropriate trash segregation in the lab requires knowledge about what waste goes into what type of container, and it requires availability and proper placement of those containers. If a processing department only uses red bag trash cans, for example, then much of the non-hazardous waste will end up there. Assess the laboratory areas for proper placement of all necessary types of waste receptacles.   

In one lab, it was discovered that staff was throwing out urine containers with embedded needles into red bag trash containers. Why? There simply were no sharps containers in the area. It was a simple fix to move containers nearby, but no one was paying attention, and there could have been an unnecessary needle stick exposure. In another lab staff emptied urine sample cups into the sink and tossed them into regular trash bins. From a waste standpoint, that was fine, but because there was patient information on the container labels, HIPAA violations occurred.

Many venipuncture sample tubes used today are plastic, and they cannot be broken to create sharp edges. Given that, those items could be disposed of into biohazard trash bags. That can save a lab some money by reducing the volume of sharps containers used (they are more expensive to handle). However, glass specimen tubes are still available for purchase. Be sure to check for these in your racks before throwing out all lab tubes into a plastic bag. A broken tube can cause a very unfortunate exposure event.

Place patient information and extra labels into bins for shredding if available. Teach staff that in most cases it is acceptable to place used disposable lab coats and gloves into regular trash receptacles provided they are not visibly bloody. Other items can go into the regular waste stream such as plastic transfer pipettes, gauze pads, and paper towels (again, provided there is no blood visible on them).

If items can be broken to create a sharp edge, they should be disposed of into a sharps container. That includes specimen cups made of hard plastic, sharp pipette tips, and any glass item. Agar plates and wooden applicator sticks should also go into a sharps container. Remember, if the item breaks while a trash bag is handled, an employee may become exposed, and the incident would need to be treated as an unknown source exposure, something that should always be avoided.

Make sure staff know the proper disposal of chemical waste as well. Never pour chemical waste down the drain unless your facility has a permit to do so. Place chemical waste containers in appropriate locations and label them according to EPA regulations. Provide proper training for employees who sign waste manifests when hazardous waste is hauled away from the lab. If you take the easy route and combine all of your laboratory waste, you would be responsible for both increased departmental expenses and for unnecessarily adding bio-waste to the environment. Talk regularly to your group of trained lab scientists about proper waste segregation, use signage as reminders, and assess their lab waste knowledge regularly. Proper waste management takes work. Mistakes can be made easily, and some of them can cause injury and invoke heavy fines. Invest in a robust laboratory waste management program to avoid those issues and to create a safety savvy example for others.

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.

Safety Mistakes Your Lab Vendors Are Making

Laboratory professionals work with vendor representatives on a regular basis, and it is important to develop a good working relationship with them to ensure continued smooth operations in the department. They provide analyzers, products, equipment, and services. However, lab managers and employees may sometimes need to pay special attention to the actions a representative will take in the department or to some of the information they may provide. They should be experts about their products and processes, but they may not always be well-versed in your lab-specific process and the regulations.

One common safety mistake representatives make has to do with proper use of personal protective equipment (PPE). Not all vendors provide adequate PPE training, and many of the representatives may not have a laboratory background. Check to make sure vendors wear lab coats and gloves when working in the lab, and offer face protection if they open up instruments for repairs or diagnostics. Some reps bring their own lab coats and use them in different settings where they work. This is common, but it is also a violation of OSHA’s Bloodborne Pathogens standard. PPE used in a lab should never be taken out of the department (except as waste). Don’t let your vendor roll up his used lab coat and place it into his work bag for his next stop. Let him know about the regulations and offer him a new disposable coat upon each visit.

Another common issue with lab vendor reps is the use of laptop computers and cellphones in the laboratory. In some cases, they must use their computers to connect to instruments or to the company control center, but they should be decontaminated before removal from the department, especially if they were set on top of a lab counter or analyzer. Can reps use lab phones instead of their cell phones? It’s a worthwhile question, especially if cell phone use is against your lab policy (it should be), and if allowing vendor use of the cell phone will be a detriment to your lab’s safety culture. Again, as with PPE use, this safety knowledge may not be known by the vendor company, and certainly they need education about local policies as well.

Laboratory vendors that manufacture analyzers or that design testing processes know their products inside and out, but their set-up work and lab staff training should be monitored, particularly if the information pertains to local or state regulations. For example, some lab analyzers are put in place using an extension cord for power because the analyzer cord doesn’t reach the outlet. In many locales, the permanent of an extension cord is not permitted. Often a vendor will train staff to incorrectly dispose of bio-hazardous or chemical waste. That can lead to large citations and fines if the mistakes are not caught and corrected. If a new process or analyzer generates a new waste stream, be sure all waste regulations are being followed. For example, if an instrument waste line is tied to a drain, contact your local wastewater treatment center to obtain approval for drain disposal.

Labs need vendors and their representatives, they play a vital role making sure the department can provide quality patient testing and care. Be sure these valuable team members understand your operations, and provide lab safety training in order to prevent injuries or even lab-acquired infections. Ask questions, and communicate with the vendor to ensure that all lab safety procedures are being followed and that safety regulations are not violated. Keeping that eye on safety when dealing with vendors will help to ensure that the important relationships created with them will last.

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 System

Outside the city of New Bern, in Craven County, North Carolina, there is a particular system for residents to dispose of their garbage. Locals must go to the nearest participating gas station and purchase stickers which cost about $2.00 each. These stickers must be placed on each bag of garbage generated in the household, otherwise they will not be picked up during the weekly trash collection. In order to save money, a group of widows has formed a club in which members scout out the open dumpsters in town (usually behind stores or gas stations). Then they call and let group members know where they can covertly dump their trash for free that week.

This story may seem funny, but for the most part, it is true. I have no doubt this also occurs in other parts of the country where the system for trash collection is similar. Why do people behave this way? Are they purposely trying to circumvent the trash collection system in place or is the system just not easy for locals to utilize? If you’re having difficulty getting people to change safety behaviors (like PPE compliance) in your laboratory, you might need to determine that for the systems you have in place and ask similar questions.

In one laboratory the manager struggles with staff who work part of the day in a clean office and another part in the lab itself. When the employees go into the lab for brief periods, they often fail to don their PPE. Upon further investigation, you would learn that staff are not allowed to keep their lab coats on their chairs and that all PPE is kept in one lab store room located on the opposite side away from the offices. The system is set up to reinforce PPE non-compliance.

In another lab the manager placed a permanently-mounted counter face shield in the chemistry department so that staff would be forced to use it when popping specimen caps. Staff loaded instrument racks behind the shield, but when they carried the racks over to the analyzers, their faces were not protected from splashing. Exposures continued to occur. Here the system is at play again. A face shield was put in place to change behaviors, but it was only a partial solution. In order to protect staff fully here, they would need goggles or a face shield that can be worn. Offer light-weight reusable or disposable face protection that staff can use easily. Be sure to give them a say in whatever option is chosen.

Sometimes the system issues are not apparent until there is a safety event, and unfortunately, that can result in bigger problems. If your training program does not include regular fire safety training, a small fire situation may get out of hand quickly. Does your staff have experience handling a fire extinguisher? Would they easily be able to put out a fire? Do they know their evacuation routes and meeting places, and could they get there with ease? What about the lab emergency management plan? Have staff participated in a table-top drill so they have a basic understanding of how to respond during a chaotic disaster? These are examples of some safety systems that need to be in place to keep staff ready and safe at all times.

When people take shortcuts or find ways to circumvent the system, there is usually a pretty good reason, Often, it is the design of the system. In New Bern, elderly women can’t lift large heavy trash bags, so they use smaller bags. They don’t want to pay the same price for a garbage bag sticker that others are paying for big bags. There’s a problem with the system- and those ladies found a way around it. What problems do you see in your lab safety system? If you don’t know what they are, ask around. Staff will talk. It’s better to find out what the workarounds are now and to fix them before an injury or exposure occurs.

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 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.

The Three Biggest Safety Audit Blunders

There are several potential safety indicators that can be used to help someone assess the effectiveness of a laboratory safety program. The results of a properly performed safety audit can be one of those indicators, and it can provide useful information to a lab safety professional whether he or she is new to the role or has been there for years. You’ll note, however, that the term “properly performed” was inserted, and that was no mistake. Safety audits are performed in laboratories across the world, but in some of these locations the environment remains very unsafe, and performing the audits hasn’t made any difference. Mistakes can be made when performing a laboratory audit, and those errors can lead to dangerous situations. While all audit errors need attention, there are three that can cause the most damage to your lab.

Probably the most common safety audit gaffe is a practice known as “pencil whipping.” This happens when someone quickly marks “yes” on every single item of the safety checklist without really checking for compliance. Pencil whipping occurs for many different reasons. The person performing the audit may be in a hurry, they may feel like they have performed the audit often and just know the answers, or they may just not care about the audit results. Perhaps there is no lab leadership oversight as to how the audit is performed, or maybe the person performing the audit doesn’t understand what the checklist items mean. No matter the reason, this pencil whipping of answers is dangerous. It provides false results, and it masks real safety issues in the department that will likely not have resolution. In an environment where this occurs, a preventable lab injury or exposure is likely to occur, and it could have lasting or even career-altering repercussions for the victims.

Another safety inspection misstep occurs when the person performing the audit begins going down the checklist with pre-conceived assumptions or a specific focus in mind. Some auditors have their minds made up about a lab safety culture before they start, and their version of what they see while inspecting may be skewed. That may cause them to cite a lab falsely and without enough investigation into a particular issue. Some inspectors might be so focused on one thing- chemical labeling, for example – that they miss other obvious safety issues such as trip hazards on the floor. This narrow focus or mindset can limit the effectiveness of a safety audit as it can prevent the auditor from noticing other real hazards in the laboratory.

The third safety audit blunder (and probably the one with the worst consequences) is a failure to follow up on the audit results. In a larger laboratory, a complete lab safety audit can take several hours. It may involve a procedure review, an employee file review, and a look through lab drawers and cabinets as well as a walk-through. However, even if all of the findings from that work is well-documented, it won’t mean anything if there is no follow-up. A failure to review and act upon audit results negates the entire process, no matter how well it was performed. Make sure your lab inspection method includes that final step – someone should review all results and ensure that any safety issues are addressed or resolved as soon as possible. A healthy lab safety cycle will include that review as well as repeat audits to make sure safety compliance is maintained on an on-going basis.

A properly performed audit can speak volumes about the overall lab safety program. If your audit form remains constant, it can be a good idea to train multiple people to perform the audit so the lab can be viewed with fresh eyes each time. Regardless of who performs the safety audit, make sure they refrain from pencil whipping, that their focus is not narrow, and that the person responsible handles the follow up of any safety issues discovered. By avoiding common audit blunders, a positive improvement of the lab safety culture can be assured.

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.

Over the River and Through the Woods…

Specimen handling and transport is a vital training topic in the realm of Laboratory Safety. There is much to consider here that affects specimen quality and integrity, and ultimately affects patient results. There are also considerations involving employee safety at every step of these processes. One group of employees that can easily be overlooked when it comes to proper safety training is lab couriers. They perform the important role of properly and safely transporting specimens for testing, but without the proper education and tools, these team members can quickly fall into situations of harm.

The courier was running late, and she had one last stop on her route at a medical office building with multiple physician offices and drop boxes. It was cold, and she decided to leave the vehicle running while she went inside to pick up more specimens and deliver lab reports. The car was also left unlocked. When she came back outside, the car was gone. It was found hours later in am empty field, but it had been set on fire. There were lab specimens and reports strewn all over the field and into the nearby woods.

Couriers need to be trained about the importance of their role, and that training should include information about security and protected health information (PHI). Be sure to include HIPAA training for all courier staff. When discussing security, enforce specific processes such as always turning off vehicles before exiting and properly securing all patient specimens and any paperwork being transported. Whether couriers use company vehicles or their own personal transportation for the job, making sure harm does not come to the vehicle nor any contents being transported is key.

The courier knew he had a long drive ahead of him because of the toll bridge, and he had several specimens that needed to be delivered as frozen. He went to the lab’s cooler and scooped a large pile of the dry ice into a big box using his hands. It was cold, but it helped to wake him up a bit. He placed the specimens in the box and placed it in the back seta of his vehicle. It wasn’t very warm out, so as he began his drive, the courier made sure the heat was on high and that all windows were closed. After a few miles, the courier began to fell very tired. He struggled to stay awake, and he couldn’t figure out why. After sitting in traffic on the bridge for a time, he pulled off the road and called the dispatcher to let them know he could not continue. When he got out of his vehicle, he began to feel better.

CAP regulations require that laboratory staff have dry ice safety training, but that requirement extends to anyone who may acquire the dangerous substance in the lab. Make sure staff are aware of the need for proper PPE use when handling dry ice. Insulated gloves, the use of a scoop or tongs, and face protection are necessary when scooping ice into a container. Couriers should carry no more than three pounds of dry ice in a vehicle, and there should always be adequate ventilation, including open windows in the vehicle when transporting dry ice. Dry ice converts rapidly from a solid state to a gas, and that gas rapidly displaces oxygen in the air making it difficult to breathe or stay conscious. High volumes of dry ice in a car can create a very deadly road situation in a short amount of time.

The courier was transporting pathology specimens in a cooler, but was unaware that the lid had popped off of one of the specimens and formaldehyde was splashing all over the inside of the cooler. As time went by, the courier began to feel queasy. After realizing that something did not smell right in the vehicle, she eventually stopped the van and pulled to the side of the road to investigate. She opened the cooler and quickly pulled out dripping specimens and set them on the carpet before feeling too sick to continue cleaning up the mess. She had to be taken to the Emergency Room for formaldehyde exposure symptoms while the Lab safety Officer had to bring spill clean-up supplies to the van to neutralize the formaldehyde. The carpet had to be removed and disposed of properly.

Courier vehicles need to be equipped with spill clean up supplies that can handle whatever types of spills could occur during transport. If formaldehyde is transported, couriers need training in the proper transport and clean up of that chemical. Biological spill kits should be available as well, and spill training should be a regular part of overall courier safety training.

I wish I could say that these were imaginary stories, but sadly, that is not the case. The stories, though, illustrate clearly what can happen when proper safety management and training are lacking. Every part of the laboratory pre-analytical process is important, and every lab team member involved in the process needs to be considered. Employ complete safety training, and assess safety competency on a regular basis. By providing the proper tools and safety training to couriers, you can ensure the quality of lab results, and you can prevent incidents like these with your employees.

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.

Safety for the New Year

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.