Phlebotomists and PPE: How Do You Decide?

When it comes to making a decision about Personal Protective Equipment (PPE) in the laboratory, OSHA is pretty clear about how to go about making the selection. The use of risk assessments and task assessments is required by OSHA’s Bloodborne Pathogens standard, and these can be essential tools in making decisions regarding safety throughout the laboratory. The decision-making tools and processes can be applied to the patient collection area as well. You might think selecting PPE for phlebotomists would be straightforward, but in some cases, it is not.

Deciding on gloves for phlebotomists is easy. The Bloodborne Pathogens standard states, “Gloves shall be worn when it can be reasonably anticipated that the employee may have hand contact with blood … (and) when performing vascular access procedures.” (The one exception here is when collecting blood at a volunteer donor center, although gloves may be worn there as well.) So, if you have phlebotomists on your team, whether they collect blood on the patient units, at client sites, or in the lab, they all need to be wearing gloves, and it is required that they change those gloves after each patient contact. The gloves should be constructed of latex, nitryl, or another material that prevents the passage blood or body fluids (vinyl gloves should not be used).

Some of the decisions about the use of lab coats and phlebotomists are, unfortunately, more complicated. This first part of this conversation is easy. The BBP standard requires lab coats “in occupational exposure situations.” That means that if phlebotomists perform any work in the lab- if they process blood, spin it down, pour it off, etc. – they are in such an exposure situation and need a lab coat (and face protection if they handle open specimens or chemicals).

The second part is a bit more troublesome. Do phlebotomists need to wear lab coats when collecting blood from patients? According to OSHA, the answer is a clear “no.” A 2007 OSHA letter of interpretation states, “ Laboratory coats… are not typically needed as personal protective equipment (PPE) during routine venipuncture.” The letter does also go on to say that employers should perform risk assessments for any potential exposure situation in order to make decisions about lab coat use.

I do not favor the use of lab coats for phlebotomists, and I have my reasons. In my years of collecting specimens, I never obtained a splash of blood above my wrist, and I believe the risk of such a splash is minimal. As a Lab Safety Officer, I also know the use of a lab coat for phlebotomists creates several issues. If a lab coat is worn as PPE, should the same coat be worn from patient to patient? That would never happen with gloves, so if the lab coat is for protection against blood spatter, should that used and potentially contaminated protection be re-used? If a phlebotomist uses a lab coat while processing specimens in the lab, should that same lab coat be used with patients? No, OSHA says PPE used in the lab should never be worn outside the lab. Will phlebotomists change their lab coats? That is not convenient for them, and it opens the door to regulation violations and potential patient harm.

When having conversations about this topic, I have heard the argument that clothes or scrubs are worn from patient to patient if lab coats are not used. What’s the difference between that and wearing the same lab coat? The difference is that clothes and scrubs are not PPE. They are not designed to offer protection against splashes. Once you use an item as PPE, the OSHA regulations that cover the employee and how it should be viewed change.

On the other side of the coin, however, is a survey that was conducted in 2008 by DenLine Uniforms, Inc.[1] 180 phlebotomists across the country responded to questions about exposure and lab coat use. 64% of those surveyed regularly used semi-impermeable lab coats as PPE while collecting blood. 74% of respondents said they had encountered blood splashing beyond the hand area multiple times during the years they had been drawing blood. Given just this data, it seems clear that there is a high risk of blood exposure while performing venipuncture procedures, and that should mean that a lab coat should be used.

So how do you decide what to do with phlebotomists and lab coats in your lab or hospital? First, start with a risk assessment. Determine the risk of exposure above the wrist based on the collection equipment and procedures used at your location. If the risk is low, you should feel comfortable choosing not to provide lab coats for this process. If you find the risk of splash is high, implement the use of lab coats. Use caution, however, and consider the impact to patients of wearing what you consider to be contaminated PPE from patient to patient. As with all decisions about lab safety, think about the regulations, but if they don’t give you the answer you need, fall back to the choice that offers the best safe practice for your staff.

[1] https://www.denlineuniforms.com/assets/images/pdf/Blood_Draw_Exposure_Survey-October_2008.pdf

 

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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.

Toilet Paper Safety

As the years have passed, I have noticed many changes in the toilet paper dispensers in the healthcare setting. First there was the standard rolling style. This was great- you could get as much paper as you wanted, and the only issue was whether or not the roll was installed properly (I prefer “over”). The next style to come along was the bumpy roller. As it rolled out, the lop-sided holder would cause tissue to rip off before the user was ready. Then came covered paper holders that forced the user to reach under a sharp edge for paper access. The latest version I have seen completely covers the roll leaving a tiny access port that allows one piece of paper to be ripped off at a time.

As each dispenser style was replaced by a newer, more insidious model, I began to wonder why hospitals were being so cheap with the paper. Was it being stolen often? Was there a black market for toilet paper? Did the hospitals understand that each newer model forced staff to remain in the rest rooms for longer periods of time in order to get an adequate tissue supply? Surely this was affecting productivity in the work place. Clearly I had given this too much thought, and I let it bother me. I learned this year, however, that I was wrong about the topic for many years.  I found out that in hospital rooms with patients under contact precautions (such as patients who have contracted C. difficile) all of the open paper products must be discarded. In fact, it is a common practice to dispose of any open tissue when any patient room is cleaned. This latest dispenser designs prevents the wasting of paper and actually saves money. Once I received education about the issue, I had a better mindset about the tissue issue.

This is often true with laboratory safety, and providing the necessary education can truly improve safety compliance. There are many who have worked in the lab setting for years, and some have ignored safety regulations while others have followed them grudgingly. Often, the staff approach to lab safety can be improved with basic knowledge; information about the regulations, leadership expectations, and potential consequences of non-compliance.

I approached a lab manager about the need for his staff to utilize face protection when pouring chemicals. He said he was not aware of the need, and it would be an enormous change for the staff. We had a discussion about OSHA’s Chemical Hygiene standard and the Bloodborne Pathogen standard, both of which require face protection when handling open specimens and chemicals. Once he knew this and could also locate it in the safety policies, he immediately covered the information with his staff and compliance was improved. In this case, simple knowledge of the regulations was enough reason for the lab safety to be improved. Knowing the reason why is an important motivator for lab staff.

Lab leaders can make a strong impact on PPE compliance both by voicing expectations with staff and by being a good role model. If you lead lab safety, talk to new employees about what is expected, and regularly remind current staff about the safety policies that are to be followed. Every successful leader also has to be a positive role model. If you expect certain safety practices to be followed, you need to make sure you follow them when you are in the lab as well. A safety professional that walks through the lab in mesh sneakers is going to have a (pardon the pun) paper-thin positive impact on the overall culture.

Some long-term lab employees who regularly comply with safety regulations do so because they have learned an unfortunate lesson. Lab staff that has been the victim of an exposure or injury knows the consequences, and sometimes the cost has been very high. Exposures from an unknown source, for example, can result in treatments that cause illness and that will interfere with personal lives. An exposure that results in contracting an illness or a career-altering injury can be devastating. Our goal as lab safety professionals should be to get staff to comply with regulations proactively, rather than as a response to an incident. Teaching about potential consequences often can have an impact on safety behaviors. You may be surprised at how little laboratorians (and lab leaders) may think of the effects of poor safety conduct. Use real life incidents to tell stories and discuss other possible bad outcomes of non-compliance.

As the average age of laboratory professionals in the country continues to rise, we may be working with some folks who have had the same weak safety mindset for quite some time. They remember the days of eating, drinking and smoking in the lab, and they don’t understand why all of these rules are now in place. They’re healthy today, aren’t they? It’s time to change that way of thinking. It’s time to explain that while they may have practiced unsafe behaviors without incident, it just means they were lucky, not smart. Getting staff to think about the regulations, the expectations, and the consequences will help them to have a new and positive mindset about the lab safety issue.

 

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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.

The ABCs of BSCs

Many labs have received notices this year that their Biological Safety Cabinet (BSC) certification company will no longer certify a certain type of BSC that those labs have had for years. NSF International (formerly the National Sanitation Foundation) is an organization that supplies product testing, inspection and certification. NSF is accredited by the American National Standards Institute (ANSI) to develop American National Standards, and in 2010 an updated version of the NSF/ANSI 49 was published. This is better known as the Biosafety Cabinetry: Design, Construction, Performance, and Field Certification standard.

The names can be confusing, but the important message is the revisions to the standard eliminated the option of direct-connected Type A cabinets (which had been previously allowed). Also, an alarm requirement was added for canopy connected Type A cabinets. There was time allowed for sites with these types of BSCs to make necessary adjustments, and in 2016 field certification agencies have been told they can no longer certify BSCs which do not meet the updated standards.

That means that some labs that have not updated their BSCs or purchased new ones, they are left with uncertified (and therefore unusable) cabinets.

There are three main classes of BSCs. Class I offers the least amount of protection, and it pulls air in and over the work area. The air is then exhausted via a HEPA filter. Class II BSCs are the most commonly-used cabinets in clinical laboratories. They offer a maintained inward airflow, a HEPA-filtered unidirectional airflow within the work area, and a HEPA-filtered exhaust into the room or to the facility exhaust system. Class III BSCs (or glove boxes) are for use with high risk biological agents, and they are typically sealed and gas-tight enclosures.

The commonly-used class II cabinets come in a variety of designs or types:

  • A1 – 70% of the air recirculates through the supply HEPA filter, the other 30% of air goes through the exhaust HEPA filter.
  • A2 – 70% of the air is recirculated through the supply HEPA filter, the other 30% of air goes through the exhaust HEPA filter. The air intake is faster than in a type A1 cabinet.
  • B1 – 40% of the air is recirculated, 60% of air is exhausted.
  • B2 –   No air is recirculated within, it is all exhausted into the facility system.

Some older Class II Type A cabinets had the exhaust directly connected to the facility exhaust system. This is no longer permitted since hard connections need to meet specific regulated criteria and is not considered the safest type of connection. If connected to an exhaust system, the cabinets must use a canopy (thimble or air-gap) connection which has an opening to the room. Because there is always the potential for equipment failure (and a possibility of air contamination to the room via the opening), an alarm system must also now be in place to alert the user of this possible danger. In 2016, all BSC field service workers were notified not to certify Type A cabinets with a hard connection or with a non-alarmed canopy connection. If you received a memo and had an issue with certification this year, that’s why!

No matter what Class II type of BSC you are using, there are some basic safety guidelines every user should know in order to keep protected while working. If the blower is not kept on all the time, turn it on about ten minutes before use. This will stabilize the protective air flow in the cabinet.  Adjust the seat height so that the user’s face is above the front opening. Set all specimens and materials that are needed inside the work space, and separate the clean from the dirty. Do not set anything on the front grille.  Objects too close to the front, side, and rear air grilles can disturb airflow and compromise the specimen and the worker’s safety.

When working in a BSC, avoid frequent and fast motions. When moving arms in and out of BSC, move them slowly and perpendicular to the sash. This will allow less interference with the air flow. Be sure to limit traffic in the area when working- people walking behind a BSC in use will disturb the air flow such that air will pass out of the cabinet into the breathing zone of the user. In general, fume hoods and BSCs should never be located in high traffic areas.

Once work is completed inside the BSC, properly dispose of all waste material. Disinfect the cabinet surfaces using an extension apparatus to reach the back wall. Never put your head inside the BSC. Use a bleach solution for disinfection. If damage to the surface is a concern, wipe down the surface with water after using the bleach. Let the BSC run for at least 10 minutes before turning off.

It is important to remember that a Biological Safety Cabinet is an engineering control designed to protect the worker, but it only does so if used properly. Make sure all users are properly trained to use a BSC safely. Have them certified annually, and let certified professionals perform the required maintenance. If you received a memo this year, it may be time to purchase a newer BSC in order to maintain safe work practices in your lab. Ask your field service representatives for the best option for your laboratory.

 

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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.

Facing CJD and Prion Diseases in the Lab

According to the National Institute of Health (NIH), Creutzfeldt-Jakob disease (CJD) is a rare, degenerative, fatal brain disorder that affects about one person in every one million people per year worldwide. In the United States there are about 300 cases per year. Some of us know the ailment better as “Mad Cow disease,” but that is only one form of this illness which is not caused by a virus or bacteria. CJD is a prion disease. A prion is a protein that exists in both a normal form, which is a harmless, and in an infectious form. The infectious form of the protein takes on a different folded shape, and once these abnormal proteins appear, they aggregate or clump together. Investigators think these prion aggregates may lead to the neuron loss and other brain damage seen in CJD. However, they do not know exactly how this damage occurs.

Since laboratory professionals may deal with specimens from possible CJD patients, we need to know how to properly handle them should such a situation arise. If the Operating Room calls your labs to process a brain biopsy specimen from a patient who was suspected of having a prion disease, would you know what to do? Can your lab do that? Should your lab do that?

Prions are dangerous, but CJD cannot be transmitted through the air or through touching or most other forms of casual contact. Prion transmission can occur, however, from contact with highly-infectious specimens. Brain tissue, eye tissue, and pituitary tissue are considered high-risk specimens, and contact with these should be avoided. When asked to handle a brain biopsy, medical staff and safety experts should work out a plan. For instance, a lab tech who is trained in Category A packaging could go to the OR, dress in fully protective PPE (including a body suit, gloves, and hood), and receive the specimen in the OR and package it there. The specimen is then ready for transport to the reference laboratory. If another department asks you to handle tissue samples from a suspected CJD patient, stop everything and escalate the issue immediately. Contact your medical director, your manager, or the safety officer and await further instructions.

There are other specimen types a lab might receive from a prion patient. Blood, serum, urine, feces, and sputum are considered no-risk specimens. Prions are not found in these types of specimens, and they may be handled and processed as usual.

The last category of specimens from prion patients is known as “low-risk.” These specimens include CSF, kidney, liver, spleen, lung, lymph nodes, placenta, and olfactory epithelium tissues. Of course the most common specimen a lab would see from this group is a spinal fluid, and labs do need to make sure they do not handle it as a normal specimen.

Lab staff should be notified when a specimen is going to be sent from a prion patient, particularly when a low-risk specimen like a CSF is on the way. Procedures should be in place, and it is recommended that such specimens have special labels on them to alert those of the potential risks.

There is no record of lab employees becoming infected with prions from handling low-risk specimens, but they must still be handled with care. All testing of low-risk specimens should be performed inside a Biological Safety Cabinet (BSC). Use disposable equipment as much as possible. For example, use disposable cups for stains or reagents where possible. Perform manual testing only; do not run low-risk specimens on automated analyzers as disinfection is not easily accomplished.

While using standard bleach solutions to disinfect surfaces is recommended after processing low-risk specimens, a lab spill of such a specimen is an entirely different matter, and this is why lab specimens should have special labeling. When a low-risk specimen spills, the area should be flooded with 2N Sodium Hydroxide (NaOH) or undiluted sodium hypochlorite (bleach). Remember, never mix bleach with formaldehyde as it produces a dangerous gas, so if a pathology specimen is spilled, only use NaOH. Leave the solution on the spilled material for one hour, then rinse with water. Place the spill materials into a sharps container so that they will be incinerated. If a spill of a low-risk CJD or prion specimen occurs, contact a manager, a medical director, or the safety officer immediately.

Laboratory professionals handle infectious specimens every day which is why it is so important that we utilize Standard Precautions. Wear PPE when working in the lab and treat all specimens as if they were infectious. It’s the only way to prevent a lab-acquired infection. If you see a co-worker not wearing gloves or a lab coat and working at a lab counter or computer, use coaching to remind them that those surfaces are potentially contaminated with pathogens, and they can be deadly. We can protect ourselves from low-risk prion disease (and other pathogens) with everyday PPE. If a specimen is processed in the lab and it is found later the patient was prion-positive, you do not want to be the one who wasn’t wearing PPE when you handled the specimens. The results will be potentially disastrous for you and your family.

Remember, if you receive a phone call that a CJD or prion specimen is being sent to the lab, escalate the situation immediately. Find out if your lab is able to receive and process that type of specimen. Protect yourself, and keep your lab safe from CJD and other infectious pathogens.

 

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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.

 

Waste Not, Want Not

In the year 1987 medical waste became a national issue when syringes, needles and other medical wastes began to wash up on the shores of New Jersey. There were multiple episodes that both posed danger to the general public and revealed a potential healthcare-created environmental disaster. It was obvious that many hospitals and laboratories were not properly handling and disposing of their wastes. In the ensuing years, many laws and regulations were put into place that affect how labs and hospitals should handle their many different types of wastes. How is waste segregated in your areas? Do you separate regular waste from biohazard trash? Do you store chemical wastes in a room or department away from the lab? Some of these practices are not safe, and others may harm the environment and break the law.

There are multiple waste streams generated in the lab. Staff should be aware of each, and they should handle each differently. While a few waste streams may be combined legally, it is important not to do so in order to reduce department expenses and in order to protect the environment. Regular (non-hazardous) waste includes paper items, specimen transport bags, and gauze pads used for disinfection. In many areas of the country, items that are not visibly dripping with blood or body fluids (saturated) can be placed into regular waste containers. These items might include disposable lab coats, plastic transfer pipettes, and gloves. Knowledge of proper disposal here is key- fines can be levied against the hospital or lab for disposing of bloody items into the local landfills. Also, in many states, any item with a biohazard symbol may not be disposed of into the regular waste stream, even if the item is clean. Be careful about tossing away biohazard-labeled specimen transport bags.

Another common lab waste includes Regulated Medical Waste (RMW) which encompasses biohazard waste and biohazard sharps. RMW should be placed into containers that are closable and constructed to contain all contents and to prevent fluids from leaking during handling, storage, transport, or shipping. If the lab is responsible for changing its own biohazard waste bags, they should be tied in such a way that the bags will not leak (i.e. the use of a gooseneck knot rather than a square knot). Then the bags need to be placed into a container with a tight-fitting lid for removal from the department. It is not a requirement that RMW trash containers in use in the lab have a lid (unless it is a sharps container). RMW removal is expensive, and it is typically charged by weight. Sharps container disposal is also charged by weight and is much more expensive than bag disposal since these containers are usually incinerated.

This is why trash segregation in the lab is critical, and teaching it to staff is not difficult. Some biohazard waste ends up in biohazard landfills. These landfills are more expensive to create and to maintain, and the potential for environmental contamination is greater than from standard municipal landfills. If environmental concerns aren’t a motivator on the lab, then cost may be. Throwing items into biohazard trash bags and sharps containers that do not belong there creates unnecessary spending. That money would be better utilized for product purchases, equipment, and salaries. Many labs decide it is easier to provide only biohazard trash containers and no waste education. That is not a good practice.

A third lab waste is Hazardous or Chemical waste. Often hazardous waste is removed from the lab via a contracted waste handler which may charge the lab by chemical weight, number of barrels, or even time spent in waste collection.  Final disposal of the chemical waste usually occurs via incineration, fuel blending, or even burial. Once hazardous waste is generated in the lab, the labeling, storage and tracking of it become vital processes that must be properly managed. A Satellite Accumulation Area (SAA) is a place in the lab where chemical waste may be temporarily stored before it is moved to a Central Accumulation Area or until it is picked up for final disposal. The SAA should be within view of the point of generation of the waste- you should not move the waste to another area unless that area is a CAA. A Central Accumulation Area (CAA) is where hazardous waste is stored until it is picked up for final disposal at an outside facility. These regulations about chemical waste may vary by facility depending on the facility’s EPA waste designation- bit that’s a topic for another time. If you aren’t aware of that designation, speak to your facility director to find out.

Some laboratories generate other types of waste that may need consideration. Radioactive waste, universal waste (batteries, light bulbs), and mixed wastes (hazardous and radioactive) all need to be managed and require proper disposal. Labs should also look at waste reduction methods such as solid and liquid recycling and replacement of hazardous chemicals.

Performing waste audits is the final step in the waste program management. Reviewing regulations, physically inspecting lab waste streams, and reviewing waste records will help you understand what your lab needs are. If you need help with training, contact your waste vendors, they may have the education materials you need. Management of the laboratory waste program is important, and it accomplishes multiple goals – money savings, regulatory compliance, and the safety of your staff.

 

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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.

 

Perspectives on Lab Safety

I attended a work shop where different people were allowed to express their views on life from their generation’s perspective. One group representative said that members of the “Millennials” generation often acted as if entitled to things in life and don’t feel as if they have to work for it. A Millennial representative spoke up. She said that she did not feel entitled, but felt a victim of broken promises. She watched the generation before her live the good life- go to school, get a job, get married, buy a house, etc. – and now she was done with school, full of debt and still living at home. The economy and the world had changed, and the life she hoped for was not the one she now faced. Listening to a different perspective was truly eye-opening, and it reminded me about an important aspect of lab safety coaching.

In conversations with long-term lab safety professionals (or those lab managers, POCT supervisors and others who share the lab safety role), I often hear about the constant frustrations with lab safety compliance. Staff does not wear PPE, they don’t follow safe work practices, or they don’t think about chemical or bloodborne pathogen safety. Some who oversee lab safety have become so frustrated that they have given up on coaching or talking to the people they are assigned to keep safe. That is most definitely an incorrect approach, and if you find yourself in that situation, it may be necessary to take a step back, look in the mirror, and notice that the problem could be you.

That’s not meant to sound accusatory, but if your lab is suffering from a poor safety culture, the best place to begin with a solution is in your head, and understanding that can be powerful. First, remember that each time you are in the laboratory and you see a safety issue that you ignore, you are seriously damaging the culture. Few are scrutinized more than those who manage the safety program in the lab, and if ignoring safety regulations is witnessed by staff, they will know how unimportant safety is in the department, and they will act accordingly. If you are burned out from years of battling the culture, it may be time for someone else to enter the safety role so that the culture is not damaged further.

Next, if you plan to remain the safety role, it may be time to examine your approach to staff. Instead of becoming frustrated with people when the need to coach arises, try to change your perspective. How a safety coaching episode will play out is largely determined by what you (the coach) are thinking as you approach the situation. It is important to remember that each time a staff member does not act in a way you wish or expect as it relates to safety, there are several possible reasons or influences on the situation, and all should be considered before acting.

Janet is in chemistry handling specimens without gloves. This alone could generate a range of negative feelings when you see this- anger, frustration, or even apathy. What are the possibilities? She was not trained properly, there are no gloves that fit her, she is having a reaction to gloves and is embarrassed to confess it, or gloves are kept in the store room and she doesn’t know the door combination. Any of these scenarios and more is possible. Your emotions about the situation are real, they can result from a broken promise (you’ve spoken to Janet before), judgement (she’s not a stellar tech anyway), or failed expectations (you recommended she be hired). However, you should not act on those emotions; there is little chance the coaching will go well. Approach Janet with a question that will start a reasonable, two-way conversation. “Hi, Janet. I notice you aren’t wearing gloves. What size can I get you?” Or “Janet, I see you are handling samples with no gloves and that is dangerous. Can you tell me why?” If this is a repeat situation, put the ball in Janet’s court. “Janet, we discussed glove use last week, but you are not wearing them. You told me you would. What’s going on?” Now the focus is on the important issue for you, Janet’s broken promise. The answer may help you understand her behavior, and help you to rectify the situation permanently. Remember to use a soft approach and a civil tone. Otherwise, the work of your thought-out coaching will be for naught.

Everyone has their own perspective. That in no way excuses all behaviors, especially failing to follow lab safety guidelines, but understanding a perspective will go far in helping you succeed with coaching those bad behaviors when needed. Think first, always act, and be the safety role model you need to be for your department. Those are the powerful steps to a strong lab safety culture.

 

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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 Your Surroundings- the Physical Environment

Over the years, many safety standards and guidelines have been published regarding the Physical Environment of the laboratory (or the Environment of Care). The laboratory environment is not inherently a safe space, so training lab staff about their physical environment is critical so that they may work there without harm. The Physical Environment (PE) includes the overall laboratory space, electrical safety, and compressed gas safety. Physical Environment safety is concerned with ensuring that the facility is constructed, arranged, and maintained to ensure staff and patient safety.

Many labs I have visited are old, and space is often at a premium. Technology has changed over the years in the field of lab medicine, and that has led to the need for different floor plans, counter arrangements, and even work flow patterns. In any lab, the space should be arranged so that the quality of work performed, the safety of the staff, and any patient care given are not compromised. That means there should be enough space to perform the testing required in the department. There should also be room (offices or counter space) for those who perform the administrative work it takes to keep a lab running. Other facilities needs should be available as well such as storage space, rest rooms, staff lockers, a break room, and even meeting space.

One aspect of PE that needs scrutiny is the actual environment (temperature and humidity) of the lab space. The room temperature and humidity need monitoring and controls in order to properly store items in the space, and to ensure that testing is performed in the proper environment determined by the test manufacturer. Working outside of those parameters can have a direct negative impact on patient care. The other important consideration for the environment is staff comfort. Many building systems struggle with maintaining the proper temperature and humidity, especially in the extremes of hot and cold weather months. Will the lab staff remove PPE because it’s too hot? Of course that is an unsafe practice, and finding ways to manage the environment for staff comfort is critical.

Electrical safety should also be considered when evaluating the laboratory Physical Environment. Make sure employees have electrical safety training, and teach them about common errors made from not properly understanding electrical safety. One common error is the use of extension cords. In most locales, extension cords may be used in the lab in an emergency situation (such as accessing emergency power outlets during a power outage), but they should never be permanently placed and used for any lab equipment. The use of “daisy chains” is another common mistake. A daisy chain is made by plugging one multi-plug adapter into another for length. This is a fire hazard and should be avoided.

Compressed gas tanks are often found in the lab environment, and staff needs to adhere to special safety considerations regarding those tanks. Make sure all tanks are secured with a chain or other stabilizing device. A tipping tank, if it breaks open, can blast off like a rocket and cause great damage or even kill. Some tanks have even been propelled through walls or floors. Always transport tanks of compressed gas on a cart, dolly, or hand truck, and ensure all tanks are clearly labeled at all times.

Other considerations in the lab physical environment include the overall neatness and cleanliness of the space. Safety for the staff is improved in a clean and orderly work area. Biohazard work area floors should be wet-mopped at least once a day. Histology and other lab areas that use paraffin in their procedures should make sure the floors are cleaned and scraped so that they are not slippery from the wax. Laboratory counter tops should be neat and orderly, and they should be disinfected after each working shift using a 10% bleach solution or bleach product.

Education and training about PE topics is clearly important, but it is also valuable to regularly monitor the lab space to ensure that safety is maintained. Perform regular (monthly or quarterly) audits on the lab physical environment using a checklist. Use a complete list that covers all of the areas discussed, and be sure review every item on the checklist each time the audit is performed. It is surprising how quickly and easily things change in the lab work space. For example, an analyzer may have been moved for repair and placed back into its original location- but what if that movement caused fraying in the electrical cord? Now there is a fire hazard that didn’t exist just days before, and it needs to be rectified quickly. Sometimes we take for granted the spaces in which we work, but in the laboratory it is important to remember that PE safety needs attention, maintenance, and regular checks. Performing these functions can transform an inherently dangerous space into one in which patient results can be obtained safely.  

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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.

 

Special Safety Considerations in the Anatomic Pathology Laboratory

Margie had worked in the histology department for years. She never used the chemical fume hood when pouring formaldehyde, but lately she had been coughing quite a bit, so she decided it was time to use the hoods. Soon she would be diagnosed with lung cancer.

Steve was a cytotechnologist working in the radiology department for a fine needle aspirate procedure. The radiologist was in a hurry, and when he handed the uncapped sample needle to Steve, the needle pierced the skin in Steve’s hand. The patient had Hepatitis C.

Jane had finished her long day of assisting with frozen sections and had to clean the cryostat. It was the end of the day, and she wanted to go home. She reached into the cryostat to change the blade with her gloved hands. She received a nasty cut on her finger, and since the blade had been used for multiple patients, Jane had to be treated for an exposure from an unknown source.

Anatomic Pathology laboratories present unique safety concerns that can differ from clinical lab concerns. Formaldehyde and other hazardous chemicals are used to preserve tissue specimens, workers can be exposed to large amounts of blood and body fluid during autopsies, and the sharp blades in cryostats and microtomes create additional cause for concern. Histology and Cytology employees need to be ever-vigilant to protect themselves from these exceptional hazards.

Formaldehyde and xylene are two chemicals typically handled in the AP lab. Xylene is a strong-smelling flammable liquid, and formaldehyde is listed by OSHA as a known carcinogen. If using these chemicals in the lab, you should have specific safety procedures for them, and vapor concentration monitoring should be performed to determine employee exposure levels. It is important to review the monitoring results as soon as possible, and never more than 10 ten days after receiving them. Discuss the results with each monitored employee individually or post the results in the department. Because monitoring is performed for tasks as well as locations, it is considered representative monitoring. That means one result may represent several employees who perform the same tasks or work in the same area.

If vapor concentration levels are elevated, make sure to take measures (such as using engineering controls) to reduce or eliminate staff exposure. OSHA’s Formaldehyde Standard requires annual monitoring if results are above the STEL (short term exposure limit). To discontinue sampling, the lab needs to obtain results from two consecutive sampling periods taken at least 7 days apart show that employee exposure is below the action level and the STEL.

OSHA requires a specific safety formaldehyde training for all employees who are exposed to formaldehyde concentrations of 0.1 parts per million (ppm) or greater. This formaldehyde training must include specific elements including education of the contents of the Formaldehyde Standard, the contents of the formaldehyde Safety Data Sheet (SDS), the health hazards of formaldehyde exposure, the proper use of necessary PPE, and spill response and clean-up procedures. This training is required by OSHA annually, and it may need to be provided to some employees who work outside the laboratory (operating room staff, labor and delivery staff, etc.). Even though the laboratory may not be responsible to provide this training, it is a good idea to communicate with other department leaders to ensure they get the required training for their staff.

Blades and other sharps pose great risks in AP procedure areas. Most microtomes and cryostats are equipped with knife guards- insist that they be used. Remove used blades with magnetic-tipped implements and insert new blades using rubber-tipped tweezers. Place disposable knives in sharps containers after use.

Odd as it may seem, there are Cytology procedures where the hand-off of uncapped needles containing samples sometimes occurs. Unprotected needles should never be passed from one person’s hand to another. These needles should be placed on a counter or the technologist should only take them from the collector with an implement such as tweezers. Be sure there is ample space to safely perform the cytology tasks in the procedure area away from the lab.

Laboratory Safety is not a “one-size fits all” umbrella for all areas where laboratorians work. Risk assessments and task assessments are critical to determine the particular hazards in a specific lab. In the Anatomic Pathology laboratory, these assessments should guide safety leaders to those specific safety measures which can help your staff prevent injuries and exposures which can be career and life-changing.

 

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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.

Anatomy of a Safety Stand Down

In March of 2016, the United States Government Accountability Office (an independent agency that works for Congress) produced a report stating that stronger oversight mechanisms are needed to improve safety in high-containment laboratories. The laboratories referred to are those which work with hazardous biological agents in order to protect public and animal health and the food supply against contamination of those agents. Because of several very public lab safety lapses in the past two years, the report makes 33 recommendations to improve lab safety. These recommendations include the development and update of policies that contain missing safety elements, the reporting of oversight activity to senior officials, and the development of plans with time frames to implement the safety recommendations. The report basically recommends a “Safety Stand Down.” Has your laboratory seen a similar situation? Have you encountered a series of like safety events that created the need to stop and review?

OSHA’s definition of a safety stand down is “an event for employers to talk directly to employees about safety.” Because of the danger to employees, a more specific definition means that all work stops until the issue is corrected and all affected (or potentially affected) staff has been educated to make sure the issue does not re-occur. However, in the real world, unless someone is in imminent danger, the work of the laboratory must go on for the sake of patient care. Still, a stand down can be important, and there are ways to run one successfully.

Once you have decided there is a need for the stand-down, develop the stand-down education. This can include a set of presentation slides, a hand-out, or talking points to use as the information is delivered. Make sure you stick to the topic(s) at hand, and do not include extraneous information, but be certain to include all items that are pertinent to the stand-down subject.

The next step is deciding on the stand-down delivery approach. Will you meet with staff one-on one, in small groups, or with everyone at the same time? Choose the meeting location(s) and schedule the meetings. Because this is a stand-down and a safety issue that must be dealt with, these steps should occur quickly. If you are facilitating the stand-down but not delivering it personally, be sure to give a short deadline for its completion and mandate that all involved personnel are included. Keep documentation of attendance and subject matter for future reference.

Once the stand-down is completed, gather the documentation of attendance and any other associated information and keep it for your records. This does not end the stand-down, however. Make a plan and a schedule to follow-up on the safety issue. The plan may include daily or weekly checks to ensure new processes are being followed or that staff has understood the information completely.

Conducting a laboratory safety stand-down can seem difficult and time-consuming. It may interrupt the work you planned to do, and it may change your schedule for the next couple of days or weeks. While that may be inconvenient, remember that this course of action was chosen to help prevent harm to employees or patients, and that is what laboratory professionals are here to do.

During the week of May 2, 2016, OSHA called for a construction fall prevention safety stand-down. This was in response to a high number of preventable worker deaths due to falls on the job. What safety issues have you seen in your lab? Have you seen multiple needle sticks? What about slips, trips, and falls? If you notice a group of similar safety events, it may be time to conduct a safety stand-down. If you deliver the information, provide the education, and document the attendance of all affected staff, you will prevent further injury and continue to raise awareness in the lab of vital safety issues.

 

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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.

The Gloves Are Off … Or Are They?

The manager of the microbiology laboratory walked into the monthly staff meeting to discuss safety. Her first announcement was that the one clean hand washing sink in the department was going to be removed. The techs were shocked, and some were angry. Didn’t the manager care about infection prevention and control? Didn’t she know that hand hygiene should always occur after PPE is removed and before leaving the lab? The manager waited for the reactions to subside, then she explained that since the staff treated the lab as a clean area in many instances, that there should be no need for hand washing. The staff went on to argue that they were working with microbiological pathogens, and that they did wear lab coats and gloves, especially when handling specimens and setting them up for cultures. Some of those specimen containers were pretty disgusting, in fact.

That was when the manager dropped the charade. She had no real intention of removing the sink, but she wanted to make a point. She was tired of watching her staff reading culture plates with no gloves. She had spoken about it before, but no one agreed- they had been handling incubated plates for years.

One of the most common issues lab managers and safety professionals face is maintaining Personal Protective Equipment (PPE) compliance in the work area. An effective weapon in this battle is telling stories of lab incidents with bad outcomes, or explaining the consequences of this unsafe behavior. That is a valuable piece of lab safety education. It is unfortunate that we sometimes have to learn from others’ mistakes, but when it comes to safety, that’s better than learning from your own. Some lab accidents and exposures can be career-altering or career-ending.

OSHA’s Bloodborne Pathogen Standard states that PPE (specifically gloves) must be worn when there is a risk of exposure. That is as specific as they get on the topic. Anytime patient specimens are handled or opened, it follows that gloves should be worn. That means that in the microbiology area, staff is handling specimens and agar plates with gloves while they streak plates and set up gram stain slides. These contaminated gloves are handling plate after plate, and then those plates are placed into the incubators. Like any other contaminated item in the lab, those plates should be treated and handled with gloves until properly discarded. That means that gloves are necessary when removing plates from the incubator, and when reading those cultures. Not only is staff handling contaminated plates, but they are working with bacterial and fungal colonies. There is a high risk of exposure in those processes.

OSHA also requires PPE under its Chemical Hygiene Standard (or Lab Standard). Gloves are required when handling chemicals, so they would be needed when performing simple chemical tests (oxidase, catalase, etc.) and when performing gram stains. Make sure you use chemical-resistant gloves when selecting the appropriate PPE for these tasks.

In 2010, OSHA responded to an inquiry specifically about the use of gloves while handling culture plates in the microbiology laboratory. The letter “strongly suggests” the use of gloves for the task, but OSHA’s own standards already address the issue and clearly require the need for PPE in that situation.

The story at the beginning of this entry is true- there was a lab manager who was fed up with her staff not wearing gloves, so she told them she was removing the sink. She was kidding, but she made her point. In that microbiology lab they all wear gloves to read cultures today.

Laboratory-acquired infections occur every year, and some of the easiest ones to investigate are the cases in which techs are infected with pathogenic bacteria. It is fairly easy to trace the sources of those exposures. What is the staff doing in your microbiology laboratory? Are they doing everything they can to prevent exposure to pathogens? As a manager or safety professional, are you enforcing the use of PPE when exposure is possible? Keep your staff from becoming a safety statistic- provide PPE, teach consequences of unsafe behaviors, and monitor the continual use of those safe work practices in your lab.

 

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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.