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.

 

 

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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.

A Chemical Conundrum

In 1983, OSHA established its first version of the Hazard Communication standard. These regulations were made law in response to a lack of hazard information given to over 30 million United States employees working with chemicals. OSHA estimates that 650,000 chemicals are used in over three million work places across the country. Recognizing that the work performed in laboratories is unique—relatively small quantities of hazardous chemicals are used on a non-production basis—OSHA promulgated the Chemical Hygiene standard (more simply known as the Laboratory standard) in 1990.

The Chemical Hygiene standard regulations supersede HazCom standard regulations in the laboratory setting. However, there are still several HazCom rules that affect labs such as those involving hazard determination, chemical labeling, and Safety Data Sheets. The Chemical Hygiene standard brings another layer of exposure protection to the lab employee through the required establishment of a series of chemical safe work practices. Understanding how both sets of laboratory regulations work together is important in creating an overall lab chemical management program.

The regulations for creating a chemical inventory are expressed in the HazCom standard. OSHA requires a list of hazardous chemicals in every work place where they are manufactured, stored, or used. This inventory can be a useful tool for many reasons. Use the list to document the required chemical risk analysis. Review the chemicals in the lab for their hazards, and indicate on the inventory list any applicable hazard warnings such as the signal word and pictograms. CAP requires that you determine which chemicals in the lab are carcinogenic or reproductively and acutely toxic. Once that analysis is complete, it can also be documented on the inventory list. Record average volumes of the chemicals stored in the lab as well. This information may be helpful in a fire situation so that the fire department or other rescue workers will be aware of what they may encounter.

Laboratories must designate a Chemical Hygiene Officer, a point person who is qualified and responsible for providing technical guidance for the implementation and operation of the entire lab chemical management program. The Lab Standard even mentions the establishment of a Chemical Hygiene Committee if the lab or chemical program is larger. Details of this lab chemical safety structure should be spelled out in the lab’s required Chemical Hygiene Plan.

If you read the actual Chemical Hygiene Standard on OSHA’s web site, you can see it is not very long (unlike the HazCom standard or others). Because of the volume of chemicals used in labs, the standard’s main focus is protecting employees from those chemicals via written procedures, physical barriers (such as PPE and engineering controls), and health monitoring. A model Chemical Hygiene Plan must include exposure control methods, a chemical fume hood maintenance process, a detailed training program, and medical consultation and follow-up when chemical exposure limits are exceeded. Appendix A of the standard (called National Research Council Recommendations Concerning Chemical Hygiene in Laboratories) was created to assist laboratories with the development of a complete and compliant Chemical Hygiene Plan.

A third set of OSHA regulations that affects labs and chemical safety is the Formaldehyde standard. The exposure monitoring section gives instructions on how to perform vapor monitoring for this carcinogenic chemical. The laboratory has an option to monitor each employee individually, or it may set up a representative sampling strategy and measure exposures within each job classification and for each work shift. The purpose of this strategy is to properly characterize the exposure of every employee without having to monitor each one. Simply stated, that means if Jane and John perform the same duties and are equally exposed to formaldehyde in their work day or for a specific task, you may monitor only Jane’s exposure and share the results with both employees. That said, the CAP standard on the Anatomic Pathology inspection checklist states that each new employee should have formaldehyde vapor monitors performed. While it references the OSHA formaldehyde regulations, the standard fails to include OSHA’s wording about representative monitoring. That can be an issue if a CAP inspector follows strict adherence to those standards and does not subscribe to OSHA’s intent. Clearly representative vapor monitors make sense and are safe, but you may have to challenge the case with certain inspectors.

Chemical management in the laboratory can certainly seem daunting, and there are many regulations (federal and otherwise) that affect how the lab program may be run. The basic safety strategies exist for the purposes of protecting the employee from chemical exposure, but so many details are involved with the process. Proper storage of flammables and corrosives, labeling, and waste handling are just some of the topics not even touched upon in this article, but they also must be considered for safety purposes. If operating the chemical management program is your duty, be sure to understand the regulations, and build a team of staff who will work together to ensure safe chemical processes in the laboratory.

 

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.

Bringing it Home

A recent report from the Centers for Disease Control (CDC) found that twenty-four laboratory workers were infected with a strain of Salmonella typhimurium, an enteric pathogen. The infections were reported in sixteen states across the country. Of those infected, six were hospitalized with symptoms such as diarrhea, fever, and severe abdominal cramps. Luckily, there were no deaths reported. These infections occurred in various teaching and clinical laboratories. The worst part? This could have been avoided.

When interviewed, some of those who became ill said they remembered specific exposure events. Many others who were unsure of how they became exposed described unsafe behaviors in the laboratory. Those victims admitted to working in the lab setting without lab coats or gloves, and many reported not washing their hands before leaving the department.

If you’re a laboratory leader, you very likely work during the day shift. Hopefully, when management is on site, staff is compliant with safety. If not, you may need to examine your safety program and leadership style. Do you enforce safety regulations in the lab? Do you lead by example? Do you don PPE when you pick up the phone or use a computer in the lab?

If safety seems to be good during the day, you may want to make a visit during the off-shifts. Depending on the level of safety culture, there may be anything happening from solid safe practices to open eating and drinking in the department. I know that was the norm in many labs 25 years ago, but those unsafe practices and safety violations should now be ancient history. Unfortunately, that is not the case, and that is one reason we have bacterial infection outbreaks in our laboratories.

An experienced lab auditor will tell you it is not difficult to assess the lab safety culture in a department, even on inspection day. I once entered a lab as part of an accreditation inspection team, and I watched as the lab staff struggled to find gloves. Even though they knew the inspection was imminent, they could not hide the fact that glove use was not the norm for them in that lab. A complete lab safety audit can reveal a number of inappropriate practices such as improper PPE use, gum chewing, cell phone use, and many others.

The National Institute for Occupational Safety and Health (NIOSH) has educated workers for years about hazard and exposure control. The “Hierarchy of Controls” is an excellent model to use in the laboratory setting, although certain facts about it may be surprising. The first and best two controls to remove hazards are elimination and substitution. Of course, these are not always possible in the lab setting. While there are substitutes for hazardous chemicals, the inherently dangerous specimens that are handled cannot be replaced or removed.

Engineering controls create physical barriers between the hazard and the employee. Biological Safety Cabinets (BSCs) and Chemical Fume Hoods are powerful engineering controls. Administrative and Work Practice controls are the safety policies and actual practices that help prevent infection. Written safety procedures are designed to change the way people work, and standard work practices include not eating or drinking in the lab setting and practicing hand hygiene when necessary.

The final control for infection prevention is Personal Protective Equipment (PPE). In the hierarchy, PPE is considered the last resort for staff protection. Since the lab hazard cannot be eliminated, and since humans commit errors with procedures, that final method of protection must be utilized. Lab coats, gloves and face protection need to be used at all times when working in the laboratory. Without it, the worker is at great risk for exposure- and that is what happened in the labs where the Salmonella infections occurred. Each of the controls that should be in effect in the lab were bypassed, and there were consequences.

It is always better to read about incidents that occur in other laboratories rather than have to report them about your own. When I hear of such stories, I always look at my own labs to see if such an event could occur there. What opportunities exist in my lab safety program? What about yours? Be sure to learn from these unfortunate events and keep your own staff safe.

The personal (and probably painful) part of the infection outbreak was that these laboratory workers were infected on the job, and then they brought it home. The CDC report says nothing about infections being spread to family members or friends, but it certainly could have happened. If there are weaknesses in your lab safety program, what could your staff be bringing home? What infections or diseases could be spread because of unsafe work practices? Now is the time to take the lead for your safety program before such an event can occur. Bring safety home for your staff. Teach them and lead them so that the unsafe practices of the past turn into practices that keep everyone healthy into the future.

 

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.

Owning Safety in the Autopsy Suite

The hospital security guard placed the deceased patient into the morgue refrigerator while chatting with his co-worker. They walked away without realizing the door did not close completely. Within the hour the automated temperature recording system sent an alert to the lab on the third floor.

The body had been unclaimed, and it stayed on the bottom shelf in the morgue. No one in the hospital wanted to take ownership of it. After a couple of months, fluids began to fill the shelf where the body was. The environmental services staff refused to clean up the mess since some staff were afraid.

The pathologist wanted to finish the autopsy quickly, so he started before the complete patient chart arrived. When the phone rang in the morgue, the physician on the other end of the phone said he believed the patient may have Creutzfeldt-Jakob Disease (CJD).

Managing safety in the autopsy suite can be difficult, but as these case studies show, it is important. One reason for the struggle is that clear ownership of the area is often not defined. Multiple internal departments and even external agencies may work in the morgue and autopsy suite. Pathologists, medical examiners, research physicians, security personnel, nurses, and organ procurement staff are just some of the various people that may perform tasks in the autopsy suite. This can create some unique and unwanted problems. The laboratory should take the lead in making sure all safety regulations are followed and that other users of the suite comply to avoid any unfortunate mishaps.

The morgue should be treated as a laboratory space, and it should be designed similarly to a BSL-3 laboratory space which includes an anteroom. Warning signs indicating the presence of biological and chemical materials should be placed on entry doors. Whenever work is performed in the area, proper personal protective equipment should be utilized. This PPE may include lab coats, gowns, gloves, respirators, and face protection. Make sure PPE is available in the area at all times. The autopsy space should be adequate, such that procedures may be performed effectively and that items such as knives and saws can be stored and used safely. Ventilation should be adequate (with a recommended minimum 12 air exchanges per hour), and the ambient temperature should be monitored as well.

While other personnel may access the morgue body storage refrigerator, it is often the lab or security departments who monitor the temperature. Since CAP inspectors set specific morgue refrigerator temperature ranges (1.1 to 4.4° Celsius), it can be important to communicate with the people who utilize the unit often. If placing or removing a body takes longer than expected, make sure there is adequate communication so that proper documentation of the temperature outages can be made. If a department other than the lab is responsible for temperature monitoring, make sure it is done correctly so there are no citations during an inspection.

Proper decontamination in the morgue is crucial. Instruments, tables, and counters must be disinfected to remove contamination of bloodborne pathogens. Use a chemical germicide for instrument and surface decontamination such as a 10-percent solution of sodium hypochlorite (or bleach). This intermediate-level disinfection will eliminate most bacteria (including Mycobacterium tuberculosis), and all fungi, and it inactivates viruses such as the hepatitis B virus. Rinsing with water or ethanol after disinfecting will help prevent the pitting of any stainless-steel surfaces.

Dealing with Creutzfeldt-Jakob Disease (CJD) in the autopsy suite requires special safety measures. Procedures should be posted in the area directing staff how to handle tissue and clean up in cases where patients are infected with CJD. The intact brain should be fixed in formaldehyde for one to two weeks before handling or cutting in order to reduce the prion activity. Non-disposable implements used with such patients should be immersed in 1N sodium hypochlorite (NaOH) for one hour before reuse. Surfaces on which autopsies occurred should also be immersed in NaOH for one hour for disinfection purposes.

Chemicals are stored and used in the autopsy suite, and standard safe lab practices should be used. Make sure staff is trained in proper the handling, labeling, and storage of chemicals as well as prepared to handle spills. Spill kits should be available and suitable to the chemicals used in the area. If formaldehyde is used, be sure an appropriate neutralizer is available for spill incidents.

As the most involved and best educated about its dangers, laboratory personnel should take the lead in making sure safety is a priority in the morgue, and educate all who may enter the area. Make sure communication is clear about who will use the suite and when- it’s never good to have someone walk in during an autopsy or organ removal. Use signage when necessary, and be willing to help in any unusual situations, because with a morgue, they definitely will arise. Work together as a team with all who utilize the area, and that ownership of safety will translate into safety for all.

 

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.

Safety Success in the Anatomic Pathology Laboratory

The pathologist walked into the histology laboratory every morning to say hello to the staff. As he did so, he drank from his cup of coffee.

The gross room was very small, and the eyewash station was placed on the faucet in the only sink in the room. One foot above the sink were the sharp ends of all of the cutting tools that hung on the wall. That was also the hand washing sink.

The morgue was the only space in the hospital where chemical waste could be stored before being picked up. The waste containers were not dated, and a funnel was left in the opening of one of them.

It can be difficult to oversee safety for a clinical laboratory, but often the people responsible for it have a clinical lab background, so the understanding of the regulations is clear. However, if you are responsible for the anatomic pathology (AP) areas as well, you may need to broaden the scope of your safety learning. Each of the lab safety situations mentioned above are real, and detecting and resolving those and other issues is important. Knowing the regulations for histology, cytology, and the morgue settings is a good place to start. Next, spend some time in those areas, and learn the processes that occur every day. Ask questions and look at procedures.

Bio-safety regulations in the AP lab are no different than for clinical laboratory staff. Many specimens, body parts and cadavers may be handled, and Standard Precautions should be used. That includes the use of gloves, lab coats, and face protection.

Chemical hygiene is also important in the AP lab, and since these areas tend to utilize many more chemicals than others, the management of them can seem daunting. Be sure to keep an updated chemical inventory which designates carcinogens, reproductive toxins and acute toxins. Ensure all staff have access to Safety Data Sheets (SDS) and that they have been trained to properly store chemicals. That means strong acids and bases should be stored near the floor, and they should never be stored together. Other incompatible chemicals should be separated as well. Ensure that proper spill supplies are available, and that staff can clean up various types of chemical spills. Conducting spill drills is a great way to keep staff ready for the real event.

Exposure monitoring should occur depending on what chemicals are used in the area. Managing chemical safety also includes ensuring proper labeling of all chemical containers. Primary container should have current Globally Harmonized System (GHS) compliant labels, and secondary containers also need adequate labeling. Secondary containers may be labeled using a GHS format or NFPA and HMIS conventions may be used.

Chemical or Hazardous waste handling must also be monitored closely in AP areas. If chemical waste is stored in the lab in a Satellite Accumulation Area, the containers should not be dated, and they should be stored at or near the point of waste generation. Central Accumulation Areas are areas where waste is stored before it is removed from the site. In these areas, containers must be dated, and a log should be kept for weekly checks of the areas. Weekly checks include looking for container leaks, dates on containers, and making sure containers remain closed. All chemical waste containers must remain closed unless someone is actively working with them. Never leave an open hazardous waste container open or with a funnel in it while unattended.

Special safety consideration should be given to tissue cutting in the histology area. Microtome and cryostat use presents specific sharps dangers because of the large sharp blades in use. If a blade guard is included with the equipment, train staff to always engage it before placing hands near the blade. Use magnet-tipped implements to remove the blades and rubber-tipped forceps to install new ones. Follow manufacturer guidelines for cryostat decontamination, but avoid using formaldehyde fumes for that purpose.

If laboratory staff is exposed to formaldehyde concentrations greater than 0.1 parts per million in their routine work, there is a safety training program that is required by OSHA. This formaldehyde training needs to be administered at the time of initial job assignment and whenever a new exposure to formaldehyde is introduced into the work area. The training must also be repeated annually.

As a lab safety officer, I learned over time how to work with and coach pathologists for safety. There is no more coffee consumed in the lab. The cramped gross room was remodeled to improve safety. Understanding the issues and reporting them was the key to getting this done. It took a difficult inspection by the EPA to teach me how to properly handle chemical waste. Today the representative from the state is my best reference, and she is willing to come to the labs and help us with waste regulation compliance. If your background is clinical, don’t ignore the special considerations in the anatomic pathology areas. Use your resources to learn what happens there, and understand the regulations so that employees in every area of the lab can work safely.

 

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.

Leading Lab Safety

The number of medical laboratory scientists is dwindling. Baby Boomers have begun their retirement, and even before that started, there were more job openings than people to fill them. That means more opportunities in the lab world, and in some cases leadership roles are being obtained by less experienced people than in years past. Whether or not one has a long lab history, one aspect of any new leadership position that will be important to grasp is management of the lab safety program.

The first step for a new lab leader is to ensure the existence of a functional laboratory safety program. Do this by looking for specific components of the program, a laboratory safety manual, a safety committee, and lab safety indicators. If these items are in place and functioning as they should, you’re off to a good start.

The laboratory safety manual may be in paper or in an electronic format. It should be separate from the hospital or facility safety manual as there are many lab-specific safety policies and procedures that are required. Maintain document control of these safety policies, ensure they have medical director (or designee) approval, and review these policies in a timely fashion. It is important to remember that while some lab regulatory agencies (like CAP) allow bi-annual policy review, OSHA requires annual reviews. OSHA covers many safety policies in the lab such as the chemical hygiene plan, the exposure control plan and many more.

The laboratory should have a functioning safety committee, no matter the size. If the lab staff is very small, the leader may play a role in the larger hospital or facility safety committee. If the lab is larger, a committee composed of just lab staff is advised. If the hospital or lab is part of a system, the committee should include at least one member from each lab site. The safety committee should meet at least monthly. It is important not to skimp on meetings or cancel them on a regular basis. Let staff know this is a priority for the leadership in the lab. During the meetings provide education, review lab incidents, and raise safety awareness. Train committee members how to perform safety audits, how to develop “safety eyes,” and most especially how to coach each other and their peers in the department.

Another important component of a functioning lab safety program is the use of safety indicators. Much like quality indicators, this safety data can be used to help determine the overall safety culture in the department. A good example indicator includes monitoring the employee exposure and injury rate. By using the laboratory’s OSHA 300 log information, a lab can compare its reportable injury data to national benchmarks. Many safety indicators are typically reactive data (or lagging), but tracking safety meeting attendance can actually serve as a leading indicator for the lab.

Once you’ve assessed the lab’s safety program, the next step a new leader should take is to assess the overall lab safety culture. This can be performed in many ways. One part of performing the assessment is by using your “safety eyes” that was mentioned earlier. Scan the lab visually. What immediate safety issues are seen? What is on the walls of the department? What types of interactions are observed? What is the physical layout? With practice and experience, a leader may be able to do the visual portion of the culture assessment quickly.

Another safety culture indicator tool is a laboratory safety audit. The results of an audit can provide much information about safety practices in the lab such as PPE use, chemical storage, and awareness of fire safety issues. One good model safety audit that can be used is located in the appendix of CLSI’s document Safety in the Clinical Laboratory (GP17-A3). This is a very comprehensive laboratory assessment and it can tell you much about your overall safety culture. As stated before, audit results can be discussed at the lab safety committee meetings, and ideas for improvements can be considered.

Managing the overall lab safety program is a big job, and it is often only one task of many that belongs to a laboratory leader. Change occurs daily in the field of lab medicine, and new leaders are coming aboard. Whether you are new or experienced, however, utilizing these basic first steps will provide a leader with the information needed to identify the safety culture and to understand how the program is operating.

 

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.

Your Reaction to Safety

The toddler’s father let her hand go so he could pay for their dinner at the busy airport. The little girl quickly wandered away and suddenly found herself at the top of a long escalator that was going down. No one was watching.

Mrs. Anders was walking home as she did every day from the neighborhood pool. She was very hard of hearing, but she was as friendly as she could be. As she waved to you while crossing the street, you see the car speeding toward her at too fast a pace.

You may have encountered a situation similar to one of these, or you may have seen something like it in a suspenseful movie or television program. The scenario is something that can create a reaction in you, a feeling of sudden dread, and the urge to take quick action. That’s a good response, and it could save someone from a serious incident.

But is your reaction the same in the lab where you work?

Lisa processed some CSF samples at the front desk that were delivered from another lab. She later received a call from the sending lab alerting her that the patient was positive for CJD, a prion disease, and the specimens were sent in error. When she went to clean up the processing area and tell the other staff, Lisa saw her co-worker leaning on the counter and using the computer with no PPE.

In the morning, Ken dropped a glass bottle of hydrochloric acid on the lab floor, and it shattered and spilled. He went to get the spill clean-up kit, but before he returned, the pathologist walked into the department wearing open-toed shoes.

Now let’s try something a bit subtler:

Robert is working in the chemistry department and he uncaps the next batch of tubes to be analyzed behind the safety shield on the counter. He places the tubes in the rack and carries the rack over to the analyzer. He’s not wearing any face protection.

Sheila was the supervisor in hematology, and she was walking through the department as Dwayne was on the phone with a service representative about the broken analyzer. The rep asked to speak to Sheila. Dwayne hands her the phone with his gloved hands, Sheila is wearing no PPE.

As a lab safety professional, one of my goals is to help lab staff have that same urgent gut reaction- that feeling that something is wrong and needs immediate correction- in all of those lab scenarios above, particularly the subtle ones. In each of those moments, the risk of danger or infection is very high and needs to be mitigated. All too often, however, these events occur in labs and no one reacts. That’s a safety culture problem.

There are many possible reasons for that typical lack of response. People are busy, the unsafe practices are common, or safety is simply not a priority. Lab injuries and exposures continue to occur across the nation, so the issues need to be addressed, and there are ways to do that successfully.

One method I use in safety training (that I’ve written about before) is the development of “Safety Eyes.” I call that the latent super-power that everyone possesses, but it needs to be taught and honed. When you work in a particular environment every day, it can become difficult to see the safety problems without training and practice. Take pictures of unsafe lab practices or problems and show them to staff. Have them identify the issue. As they practice, they will begin to see issues more often. Take practice safety walks with staff and look for issues. These actions will help everyone’s “Safety Eyes” to develop and become powerful tools in the department.

Of course, just seeing the issue is not enough. The second important piece here is teaching staff to respond when they do spot a problem. That can take some training and empowerment that may be new ideas for many. Teach staff to coach their peers for safety. This behavior will show others that safety is a priority, and over time more and more staff will begin to follow suit.

To produce the reaction you want in your laboratory—the issue is noticed, there is a sudden sense of dread or a gut reaction, and then there is a correction made—takes consistency. The lab safety leader will need to provide education about the regulations. Next, develop the “Safety Eyes” of the staff through pictures and safety walks. Finally, teach them to respond to the problems. As people, we are aware of the immediate danger when we see a toddler at the top of the stairs. The possibility of harm is clear to us. If you can produce that clarity for your staff with lab safety issues, you can get those reactions that can only improve your safety culture, and you can drastically reduce those injuries and exposures.

 

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.