The Disaster Risk Assessment

There are multiple types of risk assessments required when managing a laboratory safety program. OSHA’s Bloodborne and Airborne pathogens standards require assessing the risk of employees’ exposure to particular lab hazards. Risk assessments can be used to determine whether or not to add an emergency eyewash station, and all lab chemicals need to be assessed for the hazards they pose. These are just some assessments that are needed, and there are particular steps to take when performing them. But what about the lab emergency management plan? Should the lab perform a risk assessment for that? The answer is yes, although the terminology used may be different. To prepare a disaster readiness plan for the lab, the risk assessment that is needed is known as a Hazard Vulnerability Analysis (HVA).

The Centers for Medicare & Medicaid Services (CMS) requires that all healthcare facilities use an “all-hazards” approach when considering emergency preparedness and planning. While some laboratories may be included with the facility-wide disaster plan, the lab should absolutely have its own plan with specific instructions that apply directly to the department. That means the lab should also consider an all-hazards approach.

It may seem daunting to try to consider every possible disaster that could occur in the department, but that is not exactly what the directive from CMS dictates. An all-hazards approach means that emergency plans should be scalable or flexible so that it can be used for many types of disasters. The plan should focus on the lab’s ability to continue to offer services, especially those deemed critical, as a disaster situation unfolds.

The first step to the plan creation is the risk assessment- the Hazard Vulnerability Analysis. The HVA can be a table that lists all of the potential types of disaster; natural, man-made, facility-specific, etc. List as many as you can think of, and be sure to include specific disasters that may be particular to your locale (earthquakes, blizzards, etc.). Rate each disaster type by probability, severity of impact, and level of readiness of the lab to respond. Using that data, you can calculate the risk percentage for each emergency type.

One other requirement imposed by CMS is that facilities must include emerging infectious diseases as one potential type of hazard class. With the advent of particular diseases in the past years like Ebola, Zika, and certain influenza types, it is important to consider how an outbreak would affect lab operations and staffing. The risk level of infectious diseases may vary as incidents and outbreaks occur in particular geographic regions or if pandemics arise.

The HVA should be reviewed and updated as necessary each year. Things change that can affect what is on your HVA list. The addition of a nearby airport might make you consider adding airline disaster to the HVA. A change in weather patterns could occur as well. In 2011 a surprise earthquake in Virginia made state facilities re-look at their HVA list of possible emergency situations. Also, the actual list of disasters might not change, but there may be a change in the potential of a particular incident occurring.

If your lab or facility has not yet performed the HVA risk assessment, there is no need to panic. There are several model HVA tools available on line that can be used. As with any risk assessment, be sure to keep documentation readily available, review it each year, and make sure staff are trained about not only the HVA process, but in how to use the emergency management plan as well. There is a great amount of work that can go into preparing for a disaster, and training and drills for your staff will help to facilitate a smoother activation of the plan when the real emergency situation 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.

Think S.P.I.L.L.E.D.

Large biological and chemical spills are not a common occurrence in the laboratory. That’s a good thing, but when they do occur, they can create a very dangerous situation. It is vital that lab staff know how to handle such events even though they may not be commonplace.

Some laboratories differentiate between large and small spills. They may have an emergency number to call for a hazardous spill response team. Other smaller facilities simply don’t have that in place. Either way, it’s important for laboratory professionals to know they are the experts about the biological and chemical materials they use, and they need to be in charge as the experts when a spill situation needs to be managed.

Most laboratory spills can be managed using a standardized step-wise process known as the S.P.I.L.L.E.D. procedure. I don’t usually ask lab staff to memorize the acronym, but having the information contained on a poster with the lab spill kits can make a clean-up procedure go smoothly.

S = Secure the Site – Make sure no one walks through the area where a spill has occurred. It could be a dangerous situation if a hazardous chemical is spilled, and you would never want someone slipping in the area or tracking the spilled material to another area.

P = Protect Yourself – Arm yourself with the appropriate Personal Protective Equipment (PPE). In a lab spill event, this would mean using a lab coat, gloves, and face protection to prevent accidental splashes.

I = Inspect the Spill – Look to see what was spilled. If it is a hazardous chemical, is there a concern about fumes? Obtain a Safety Data Sheet to see if section 6 will give any special information about handling the accidental release or spill of that chemical. Consider other spill concerns such as broken glass or possible ignition sources if flammable material is involved.

L = Lay Down a Barrier – If the spill is large and spreading, lay down spill pillows or booms designed to contain a flow of liquids. Surround the spill area with these materials. Sometimes, the use of an emergency shower can create the need for a barrier to be made.

L = Lay Down Absorbents – No matter the size of the spill, the next step is to place any absorbent powders, granules or clean-up pads to soak up the spilled material. If the absorbent is also a neutralizer, make sure you allow the necessary time for neutralization to occur.

E = Extract the Mess – Use implements to pick up the materials used for stopping and absorbing the spill.

D = Dispose of the Waste – Properly dispose of all materials involved with the spill clean-up. If there was glass involved, be sure to use a sharps container.  Biohazard material should go into an appropriate container, and chemical waste materials may need to be disposed of separately for pick-up by a chemical waste vendor.

Lab staff should be able to access spill control materials quickly, and the necessary items should be stored in a location designated by signage. Perform an inventory of spill supplies and make sure there are adequate materials that could handle spills of the biohazards and chemicals stored and used in the department. Be sure items in the spill kit are not expired, and if there is no expiration date for absorbent powders, check them at least annually for effectiveness.

All laboratory staff need to have complete spill clean-up training. Give information about the types and locations of spill kits and how to handle various types of spills that can occur. Once that training is done, it will become important to perform spill drills in the department. Drills can be performed a number of different ways, but a common method involves having a “victim” spill water onto the floor and claim the material splashed into their eyes. Watch from a distance to see how the staff reacts. Do they provide appropriate first aid? Do they inspect the container label? Do they access the correct clean-up supplies and facilitate cleaning efficiently? Make notes of how the drill went, discuss them with the staff, and repeat the drills until all staff are comfortable with a spill situation. Biological and chemical spills should not be a common occurrence in the lab. When they do occur, however, the situation can become serious quickly, and a fast and effective clean-up needs to occur. Because these events are rare, it becomes important to provide regular spill training and drills so staff can remain ever-ready to handle them.

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.

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.