A Snap of the Fingers

In the latest Avengers movie (if you haven’t seen it, beware, there are spoilers ahead), the villain Thanos goes through much trouble to gather all six infinity stones from the far reaches of the galaxy. Once he has them, he snaps his fingers, and half of the people in the universe disappear. While that is not a very nice thing to do, the ability to get something done with a snap of the fingers is very intriguing- especially if that accomplishment could lead to something that improves your lab safety culture. Is that possible? Are there things that can be easily and quickly done that a safety professional can do to help reduce injuries or exposures and improve safety compliance? Of course there are!

One of the easiest safety snaps is a walk-through of the department. If you have developed your “Safety Eyes” enough to see lab safety issues in the department, then the immediate snap fix is taking action to rectify the issue. Many safety issues in the lab are clearly visible, but seeing them is useless if there is no follow-up. If it seems overwhelming, try to pay attention to one thing at a time. On day one, look for PPE issues. Are people wearing the correct shoes? Are their lab coats unbuttoned, or are the sleeves rolled up? What about face protection? Is it used with open specimens and chemicals? Once these issues are seen, make the corrections. On day two, focus on fire safety issues. On day three, look at the physical environment to make sure there are no trip hazards. If you focus on one safety subject each day, you can make quite an impact on safety in just one week. It can be quite powerful.

Another quick snap that can improve a safety culture involves safety drills. Not all drills have to include every staff member and take a long time to complete. Conduct mini drills by asking pointed questions and providing education. Ask one staff member where the spill clean-up kit is located and how to use it. Tell another her computer terminal just caught fire and ask how she would respond.  Tell a co-worker you splashed a chemical in your eyes and need to know the correct first aid response. Ask an employee how to respond if a tornado warning were sounded. If staff is unable to answer these quick quizzes or drills, provide them with the information on the spot. That will lead to a better staff knowledge of safety procedures.

A third quick snap is the five minute review. Many lab safety professionals struggle keeping up with the latest safety regulations and incorporating them to maintain up-to-date procedures. Set aside a quick five minutes every day, whether it is in the morning or at the end of the day. Use that time to peruse safety articles or news stories and updates. Use internet alerts or sign up for safety newsletters to get this information and stay in the know about the latest regulatory changes and updates. Take another five minutes and look at one safety policy each day. Updating all of them can be daunting, and it can be accomplished one fast piece at a time. Use the information you learn about updates and apply it each day to maintain a current set of lab safety procedures.

Lastly, use time with staff as a quick snap to raise safety awareness. Make sure you talk about safety at every staff huddle, at meetings, and even at on-on-one interactions. It doesn’t take long to bring up a safety topic or to tell a safety story at each meeting. You can even staff about their perception of the safety culture in conversations, in passing or during an annual evaluation. These quick injections of safety into these staff interactions are a powerful tool to raise safety awareness and to let the staff know where safety stands with departmental priorities.

While it would be fantastic if one snap of the fingers using magical stones could fix all lab safety problems, it’s not very realistic. However, even though the safety culture challenges in some labs seem daunting, if tackled one at a time, bit by bit every day, significant progress can be made. Choose one of the quick snaps above this week, and you will be surprised at the difference that can be made by the end of the week. Gather a team of “Safety Avengers,” and the process will go even faster!

 

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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.

Modern Radiation Safety in the Laboratory

In the “old days” in the clinical laboratory, the main sources of potential radioactive substances were found in the Radioimmunoassay (RIA) department. Techs who worked in this specialized testing area handled reagents which often were radioactive isotopes. The materials were used to label specific antigens which would compete with unlabeled antigen from patient samples. This method would allow the determination of high-quality quantitative diagnostic values. In the early 1990s, radio-immunoassays were commonly used to perform thyroid testing, narcotics assays, and a variety of hormone level analyses. Unfortunately, the use of such isotopes for testing was costly, difficult to automate, and their use was potentially hazardous to staff. Eventually this major testing method was replaced by ELISA testing, chemiluminescence, and other techniques, but some labs still do utilize RIA analysis today.

In the Anatomical Pathology areas, there has been potential radiation exposure from certain specimens in the past, and newer techniques have introduced other sources into the lab as well. Tissues (such as thyroid gland sections) are not typically removed from patients when treated with radioactive dyes, but it can occur. Good communication to the lab from surgery staff is important so that no one is unnecessarily exposed. Sentinel lymph node biopsies are sometimes infused with radioactive tracer dyes. Pathology staff may also receive radioactive seeds used to treat prostate cancer. Usually these seeds have decayed sufficiently and are inert, but that may not always be true. Again, clear communication about these samples is important. Other radioactive seeds are now used for breast tumor localization, and these do arrive in the lab while radioactive, and they must be handled and stored with care.

The best protection from radiation exposure is distance, duration, and barriers. Being away from a radiation sources isn’t always possible, but working with them for short periods and using some form of barrier protection will help. The types of radioactive material handled in labs today generally emit low levels of energy, and the use of Standard Precautions offers sufficient protection. Gloves, lab coats and face protection will provide the necessary protective barriers when handling these standard materials (Note: items like thyroid tissue that have been infused with Iodine-125 contain above-normal levels of energy and should be treated with extra care).

The College of American Pathologists (CAP) updated its regulations last year regarding radiation safety in the laboratory. Some of the standards were moved from the Anatomic Pathology checklist, and some are new. When asked, the CAP has stated that these standards do not apply to laboratories that handle low-level radiation samples such as sentinel lymph node biopsies.

First, the regulations require radiation safety handling policies and procedures which are maintained in a radiation safety manual. This manual can be paper or electronic, and it does not need to be separate from other lab safety policies. The policies should need to spell out who in the lab is authorized and restricted from handling radionuclides. Specific procedures should also be maintained to describe what actions to follow in the event of a radionuclide leak or damage to radioactive seeds. All radioactive materials and supplies should be inspected to ensure that there is no leakage or compromise that could expose staff unnecessarily.

The updated standards also require workplace radiation decontamination procedures, and labs that perform this type of work must keep records that document the effectiveness of the decontamination processes. Laboratories that handle radioactive substances must post radiation warning signs to communicate to others the potential dangers present, and all laboratory and medical staff must have comprehensive training prior to handling radioactive substances. Lastly, the CAP checklist now requires that if radioactive substances are handled in the lab, a laboratory representative must participate as a member of an institutional radiation safety committee.

Many things have changed in the laboratory setting over the past decades, and the regulations keep changing in an effort to stay current. The bottom line for radiation safety regulations in the lab is that staff need to be aware of what radioactive substances they may become exposed to, so they need to know safe handling processes as well as emergency response procedures. In the real world of lab medicine, radioactive substances do not glow, so lab staff may not be aware of the dangers when they enter the department. If the proper communication and practices are in place, however, everyone can maintain the minimum radiation exposure levels needed to live long and safe lives.

 

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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.

Transparency in Injury Reporting

Susan was getting ready to work in the microbiology lab. She sat down after donning her lab coat, but before she put on gloves, she picked up some reports that were on the counter. As she picked them up, she noticed she got a small paper cut on her finger. Thinking nothing of it, she put her gloves on and went to work.

Chuck opened the door to walk into the back of the main lab. A cardboard box was in the walkway, and Chuck hit it with his toe and fell to his knee. He figured he wasn’t hurt, so he didn’t say anything since filling out paperwork was such a nuisance- and no one saw it happen.

Jean was walking into the hospital during the ice storm to get to work. Shortly after she closed the car door, she slipped and landed on her wrist. It hurt a little, but she figured it would be fine, so she didn’t say anything.

Accidents happen often in the laboratory setting, and many of them go unreported. The first thing that should occur after an injury is first aid. Then the incident needs to be reported. That may mean telling someone in charge in the department- a lead technologist or a manager. That can vary depending on the department and the time of day. Next, the incident should be reported to an institutional Occupational Health department or to a designated authority (such as the emergency Department) if the Occupational Health office is closed. This step is vitally important.

Make sure the details of the incident are recorded accurately, and that any witnesses are identified. Some facilities use an electronic reporting system, and others require a nurse to fill out the forms. Good communication is important here so that a thorough follow-up by the lab safety professional can occur later. The fewer details left out, the better.

We are human, and accidents happen, but the route to a better safety culture in the department is transparency. All injuries at work need to be reported. There is no shame in an injury, and there should be no reprisals, and reporting leads to prevention of injuries. The communication about the event is crucial- the reporting may prevent someone else from being injured in the same way. In some labs there have been serious injuries that occurred because no one reported a previous similar event. That can and should always be avoided. There are other reasons to report injuries as we – those stories at the beginning of the article did not have a happy end – because they were not reported.

After a week, Susan noticed that her little paper cut had become red and swollen. She made an appointment with her physician who prescribed an antibiotic. The antibiotic didn’t work, and after a serious bout of septicemia, Susan had to have part of her hand amputated to prevent the spread of the rare bacterial infection.

A day after Chuck tripped, Elaine walked into the lab and tripped on the same cardboard box. Elaine fell hard and broke her hip. She needed immediate surgery. She would have retired in another month.

 

Two weeks after her fall in the parking lot, Jean decided to go to the urgent care since her wrist was still hurting. An x-ray revealed a fracture that would need a surgical repair. Jean went to the Occupational Health office to report the event. Because there was such a delay in reporting, the compensation department decided they could honor the claim, and Jean’s medical follow-up was not covered.

There are many reasons to report an injury at work. The first one is about you- protect your own health and your future- that’s worth a few minutes of paperwork and a short visit to the Occupational Health office. The second reason to report is about everyone else. If something is unsafe in your environment and it has caused an injury, let someone know. That sort of communication and transparency is important to the entire team. Accidents happen, but even when they do, we can respond quickly and communicate so that safety improves after the event. As a lab safety professional, make sure you talk about accident transparency, and make sure it is something practiced by the entire team.

 

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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.

Packing for the Trip

If you are sending specimens outside of your lab for testing or for other purposes, there are many things to consider. Not just anyone in the laboratory should prepare the specimens for shipment, specific training is required. Staff needs to have knowledge about packing procedures, specimen safety considerations, and how to fill out the necessary paperwork.

The safe transport of laboratory specimens is regulated by at least four different agencies. The United States Department of Transportation (DOT) generates specimen packaging and shipping regulations and updates them every October. They become effective on April first of the following year. The International Civil Aviation Organization (ICAO) provides technical instructions for domestic and international air shipments. Dangerous Goods regulations are published by the International Air Transportation Association (or IATA). These annual updates take effect every first of January, and they comply with ICAO instructions as well. The fourth regulatory body affecting specimen shipping is the United States Postal Service (USPS). The USPS regulations are synchronized with those of both the DOT and IATA. In fact, most of these regulatory agency’s shipping regulations are similar because they have been harmonized with the United Nations Model Regulations.

Dangerous Goods are categorized under classes and divisions, and laboratory specimens fall under Class 6, Division 2; Infectious substances. For the purposes of shipping, these infectious substances are further divided into Category A (specimens known or reasonably expected to contain pathogens) and category B (human or animal specimens which do not contain pathogens). Very specific training for lab staff is required for those who will package and ship these types of products. A laboratory that sends such specimens is considered the shipper, and shippers are viewed in the eyes of the law as responsible for the package until it reaches its final destination. That responsibility involves proper and regular training, specific packaging instructions, and management of shipping paperwork.

Dangerous Goods packing and shipping training includes General Awareness information. This includes an overview of the various regulations surrounding specimen shipment as well as enabling the trainee to recognize and identify the hazardous materials that fall under the regulations. Function-Specific training is general instruction on how to package dangerous goods, how to properly label parcels, and how to fill out the required paperwork. Training shippers about Safety is also required. Staff must be given information about the hazards associated with handling dangerous goods, and there must also be training given about how to handle emergencies such as accidents or spills. Lastly, Security training is required because the materials being shipped could be misused in a way that could cause harm to others (i.e. a terrorism event).

The paperwork that must be filled out and that must accompany the package is called a waybill or a shipper’s declaration. A lab must have two original completed and signed forms. Two of the signed forms travel with the shipment to its final destination, and one will be retained by the carrier. There are very specific instructions about how to fill out a shipper’s declaration, and only those trained should do so.

Not all specimens and chemicals shipped by a lab are considered Dangerous Goods, and they may not fall under the regulations for labs that transport them. The DOT designates some items as “Materials of Trade,” and they are not regulated under transport laws. Material of Trade are those items which are carried on a motor vehicle to directly support a principal business of a private motor carrier (such as a private courier). That means that many diagnostic specimens and some hazardous chemicals (under 8 gallons depending on the chemical) may be transported without shipping papers, emergency response plans, and specialized training.

Proper training for those shipping Dangerous Goods takes time, and the information included in the training is much more in-depth than what has been discussed here. Those who are trained should be tested on the information taught, or they can provide a demonstration of proper packaging and paperwork management. Each successful trainee should be given a certificate of completion, and that record needs to be retained for at least 36 months. Training should be repeated every two years in order to satisfy the requirements of all regulatory agencies.

Laboratories across the country package and send diagnostic specimens for testing or for other purposes. Sometimes, depending on how and where those specimens will be transported, very specific regulations will apply, and specialized staff training will be required. Before you get those samples packed and ready for their trip, make sure your lab is following the regulations that will keep your staff (and those who will transport and receive the packages) safe from harm.

 

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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 Motivation

If you search for top motivational movie speeches, you will see things that might work in real life. The President’s speech from Independence Day (1996), for example, might influence you to never be oppressed by alien tyranny. Freedom will be your rally cry after listening to William Wallace in Braveheart (1995), or Maximus from Gladiator (2000) can speak to your heart about teamwork. Unfortunately, such speeches do to tend to maintain motivation for great lengths of time. Also, none of them will translate to a motivational discussion about safety with your lab staff.

Over many years I have watched what motivates people to do the right thing or take the safe actions in the laboratory, and that motivation varies. Different groups of people are persuaded by different forces, and understanding that can help you move your lab safety culture in the direction you desire. You may not agree with or even like some of the influencers, but learning them can help you be more effective in achieving overall safety compliance.

They say money is a motivator for people in all kinds of circumstances, and that’s true for lab safety as well, although not in the way you might believe (while some businesses may pay a bonus for fewer safety incidents, that is not typical in the lab setting). Lab staff who are concerned about finances are more open to following some lab safety practices if they realize the cost savings. Obviously, lab injuries and exposures cost the department both monetarily and with staff absences. Following proper regulations can reduce costly citations and fines that can be levied by organizations like OSHA, the EPA, or CMS. Some lab team members want funds available for new equipment or more staff. Use that to encourage them to follow proper safety procedures. Make sure staff properly segregates waste in the lab, for example, since doing things like placing paper into a sharps container costs the department extra money. Hospital and lab leadership also respond well to financial motivation. If you need something fixed or replaced because it is unsafe, always explain the financial consequences to the facility if the fix is not approved.

Knowledge can also be a powerful safety stimulator for some staff. Understanding the consequences of poor safety behaviors will discourage some, and education about those consequences needs to be given regularly. Let’s look at waste disposal again- those who are concerned about the environment should know that tossing clean items into a biohazard container could increase the need for biohazard landfills in the area- something we should avoid. Talking about the follow up testing and unpleasant effects of prophylaxis following an exposure from an unknown source can be very eye-opening. It may spur staff to be more careful when potential exposure situations arise.

You might not like to hear that punishment can be a motivator for correct behaviors, but for some staff members it is. Sometimes, explaining that a written corrective counseling or even termination will occur if safety practices are not followed will keep laboratorians working carefully and correctly. No one wants to “threaten” people to do the right things, but there will be those who are only motivated by not wanting to “get in trouble.” Knowing who those employees are can be important to guiding your leadership approach when working with them.

Lastly, some lab staff are inspired to act safely because the environment is designed to make doing so easy. PPE is readily available- lab coats of all sizes are accessible, gloves are out and not in a drawer, and face protection is mounted conveniently. There are hooks for lab coats near exit doors and hand washing sinks so that staff can properly doff and exit. Cleaning supplies and spill kits are readily available and instructions to use them are posted and up to date. Warning signs are there for staff and for visitors not used to the dangers in the department. I know that many labs are older, and the physical layout is not always conducive to making safety easy, but there are always steps that can be taken in order to make safety easier to achieve. You may need to step back and look at your environment with fresh eyes in order to envision what can be done to make improvements.

Think about what incentives are important to you when it comes to lab safety. Is it simply self-preservation? That’s good, but for many who are complacent about safety, their motivation may be different. Finding their reasons to be safe is a worthwhile task. It helps you understand better who your staff is as a people, and it will help you gain expertise for providing the stimuli they need to continue to work safely today and every day.

 

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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 in the Pre-analytic Phase

The courier suddenly became sleepy in the middle of his daily driving route. It was cold outside and he had all of the windows in the vehicle closed. He also had filled his cooler with four pounds of dry ice, and it was sitting in his back seat.

There was no education at the hospital for specimen collection staff regarding proper label placement on collection tubes. Since the CBC analyzer would not accept tubes with labels that were too long, the lab techs kept a razor blade handy to slice off extra label paper. It wasn’t long before someone cut their finger.

The phlebotomist completed the outpatient collection, but the large elderly patient was unable to stand up from the chair without assistance. The phlebotomist bent at the waist and attempted to lift the patient to standing. The back muscle pull that followed kept the phlebotomist out of work for two weeks.

Every laboratory professional understands the value of quality in the pre-analytic phase of laboratory testing. If you have ever worked where phlebotomy has been decentralized and is no longer overseen by the laboratory, you may have experienced the many pitfalls due to inadequate specimen collection techniques. Laboratory professional by nature want to provide good diagnostic results, and compromised specimens hinder that resolve. Sometimes, however, the aspects of safety that are important during the pre-analytic phase of lab testing get overlooked.

Needle safety and ergonomics should be considered during blood collection from patients. Using a needle with an attached safety device and activating it as soon as possible are important steps in needle stick prevention. Make sure there is a sharps disposal container near the point of collection or wherever needles are used so that the potential hazard can be eliminated quickly. When collecting blood, be sure to raise the bed height (or the arm height if in a chair) so that excessive bending is avoided. Use a chair or a task stool to sit on while performing the collection to maintain a better posture throughout the procedure. Never attempt to lift patients by yourself, always ask for help. Thousands of back injuries occur every year in healthcare due to avoidable patient lifting errors.

For many laboratories, couriers are a vital part of the pre-analytic process. They bring specimens from clients and other labs, and their safety should be considered as well. Teaching dry ice safety is vital if it is used, and both couriers and lab staff need to be taught how to handle it appropriately. Dry ice sublimates (or changes to gas from a solid state), so it should never be placed into a sealed container, or the building pressure from expansion will cause the container to explode. Couriers should never place more than one pound of dry ice inside a vehicle, and the windows should be opened when transporting it to create good ventilation. The gas created from dry ice quickly reduces the oxygen content in the air, and the elevated Carbon Dioxide levels can quickly cause unconsciousness or even death. Never place dry ice leftovers in the sink for disposal. While it might be fun to run water on it to see movie special effects, the cold temperatures can burst sink pipes and even make the entire sink fall out of place.

If specimens for analysis arrive in the testing area, and they frequently aren’t ready for analysis- for instance the labels aren’t placed properly- go to the source of the error to make corrections. If inappropriate labeling is a constant problem, staff will create work-arounds to get the work done, and some of these work-arounds may not be safe. Poorly-labeled samples may prompt a lab tech to remove gloves in order to adjust the sticky labels, and that should never occur. The use of sharp blades may be another work-around, and staff injuries can occur. Be sure to explain to specimen collection staff the importance of proper labeling. Turnaround times are delayed, but staff safety is also a concern.

Lab Quality and Safety are often related, and rarely is it more so than during the pre-analytical phase of testing. Proper collection, labeling, and processing are all vital in order to provide high quality lab results, and that is the crux of what laboratorians wish to do. The same can be said for laboratory safety: that pre-analytical process can’t be done well without proper safety considerations. Safety events here will create staff injury, turnaround time delays, and potential errors with test results. Make sure staff understand the impact of good quality as well as safety in the pre-analytical phase.

 

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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.

Help! OSHA is in My Lab!

Hospitals and other healthcare facilities have been on OSHA’s “high-risk” workplace list for a few years. That means the regulatory agency has noticed an increased number of employee injuries there, and therefore OSHA inspections have increased in hospitals and labs as well. If an OSHA inspector arrives at your facility, you should not panic, but you should know some very specific steps to follow.

If inspectors come directly to your department and you belong to a hospital or larger facility, be sure to contact your administration and accreditation departments immediately. This is a government agency on site, and the facility representatives need to be aware and involved. Verify the identity of the inspector(s). Sadly, there are imposters who pose as inspectors for the purpose of collecting money. OSHA inspectors will never talk about fine amounts during an inspection, and they certainly would not collect money on site. To prove the inspectors’ identity contact the state or federal OSHA office and verify that an inspector is scheduled to be on site. Twenty seven U.S. states and territories operate OSHA-approved State Plans, and if that is true in your area, it will be the state inspector on site rather than someone from the federal government.

OSHA is legally authorized to conduct workplace inspections to enforce health and safety standards, so it is usually best to allow them to inspect if requested. That said, you do have the right to require the inspector to obtain a search warrant before allowing them into your lab. However, as you can imagine, this will give an inspector the wrong idea about what you may or may not be hiding. They may dig deeper when they do return with that warrant, so it may not be the best course of action to turn them away.

An OSHA inspection begins with an opening conference which details the scope and purpose of the inspection. In the initial meeting, it is acceptable to ask the purpose of the inspection and its anticipated length. Ask what documents the inspector will want to see, and ask if there are any specific employees he or she will need to interview. If the inspection was triggered by an employee complaint, ask for a copy of the written report. The inspector may review certain lab documents pertinent to the investigation, and these may include the chemical hygiene plan, exposure control plan, or other policies and procedures.

While on site, the OSHA inspector should always be accompanied by a representative of your employer, an escort, and their next steps will usually be a walk-through of the inspected areas to look for safety hazards and to talk to employees. The inspector may talk to staff, take notes, and take pictures. The lab escort should take copious notes while this is happening, and it is advisable to take pictures of whatever the inspector documents with photographs.

If the inspector asks to interview an employee, he may do so in private so long as the employee agrees to that. Train staff to never volunteer information during an OSHA inspection; they should answer only what is asked. An OSHA inspector may ask if the employee familiar with lab safety policies and procedures, and whether or not the employee follows those procedures. They will try to determine if staff is aware of hazards in the workplace. If the inspector points out safety violations he notes, do not agree to them; it may be taken as an admission of wrong-doing and could incur a fine. If you are able to correct the violation on site, do so immediately, but understand that you could still be cited. However, this goes a long way toward showing the inspector that your interest truly is in cooperating and keeping employees safe.

Once the investigation is complete, the inspector will hold a closing session on site. During that time the lab will be notified about citations that will appear in the written report. The inspector will explain your right to appeal noted violations and give information on how and by when to appeal. They will answer any questions you may have. If on-site corrections were allowed during the inspection, be sure the inspector states that the follow up was completed.

If a citation will be incurred, start right away to prepare your response while the information is fresh in your mind. An OSHA report can take up to six months to be sent to the facility. Post OSHA citations at or near the site of the violation in the department.  If the correction of the violation takes longer than three days, the posting must remain until the correction is completed. After correcting a hazard, notify OSHA in writing. Employers have up to 25 days to submit OSHA an abatement of the safety issue or issues. If the abatement will take a long time (greater than 90 days), the first abatement progress report is due to OSHA within 55 days.

OSHA fines increased in 2016 for the first time in over 30 years. A single fine amount can range from $12,500 up to $125,000 depending on the seriousness of the violation. That’s just one reason to make sure your lab is following OSHA safety regulations. Keep your staff safe, but if OSHA knocks on your door, remain calm, and follow the steps to ensure a smooth inspection and follow-up process.

 

 

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.