management/administration – Page 3

A Culture of Safety Transparency- Three Reasons Why

Gena was working in the microbiology lab when she failed to notice a possible N. meningitidis from a cerebrospinal fluid culture. Not thinking there was any danger, she prepped the organism for identification on the analyzer, but she used a vortexer that was not in the biological safety cabinet and did not cap the tube. The next day when she saw the organism identification, she realized she had created an aerosol the previous day in the open lab when co-workers were nearby. She was afraid of getting in trouble, so she did not report the incident. Three days later, Gena was in the hospital and not expected to recover. Two other co-workers had also fallen ill with minor symptoms. After the investigation, the manager did not relay the details of the incident to all of the staff fearing that the department would get in trouble with hospital administrators. One lab employee decided to call OSHA and report what she felt were unsafe working conditions.

There are at least three reasons it is important to create a safety culture in the laboratory where all staff members feel comfortable discussing potential safety issues, incidents, and near-misses. The first reason is so that every single safety incident in the department will be reported. Even something as minor as a paper cut that occurs within the walls of the lab should be reported. A tiny wound can quickly become an infection if skin is broken while working in an area where bloodborne pathogens are present. Staff should understand why reporting is essential, and they should be aware of the follow-up procedures that are put in place by the organization. To get lab employees to realize near-miss situations may be more difficult- there needs to be education about unsafe practices and potential consequences. For example, an employee might successfully retrieve a lost specimen from a sharps container without injury, but they and others should understand the high potential consequence of that action, and it should be reported. That is a tie to discuss unknown source exposures and potential impacts.

A second reason for a culture of transparency in the lab is to help the staff know the organization s working to keep them safe and to make them comfortable enough to talk to leadership about incidents and questions they may have about them. Sometimes, if employees feel leadership is not doing a good job of this, they will report to agencies outside of the workplace. It is easy for an employee to report incidents to OSHA, and if that happens, the lab will need to do much more work for the response. When an incident occurs, being open and honest about the details, the response, and the follow up to ensure it does not happen again can go a long way toward comforting staff. Hiding information just helps to generate rumors and a feeling by some that they are not working in a place that is doing all it can to keep their employees safe. It can be difficult after certain events to tell the story. While names may not be mentioned, it is likely in many situations that staff will know who the involved parties are. That is still better than hiding information. When OSHA responds to a safety report, even if the response is written and no inspectors come on site, the incident report and the written response from the organization must be posted in the department per regulation. The employees are going to know what happened either way. It is always best to be up front about incidents and to make staff aware that their safety is important and monitored, and that issues have swift follow-up.

Safety transparency also has a third benefit- it generates an overall better safety culture for the laboratory. When staff are comfortable reporting issues without punishment or pushback, and when they see they can work with leadership to continually correct issues, safety becomes a natural part of the job. Openly reporting incidents in staff huddles, discussing routine safety fixes and improvements, and educating about near-misses are all normal in a department where the safety culture is strong. A strong safety culture means fewer incidents and fewer injuries and exposures, a goal for which all labs should strive. Once Gena realized her mistakes in the microbiology lab, she should have felt comfortable enough to report them for her safety and for the safety of others in the department. Even if she were new to the field or to the department, her leadership should have conveyed to her how vital it is to report safety incidents or potential safety issues. When staff understand that their organization cares about them and will work to protect them, even when something goes wrong, they will feel confident they work in an environment where safety transparency is the norm, and where the safety culture is strong.

–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.

It’s Getting Hot in Here

Each laboratory is required to create and maintain a fire prevention plan. What exactly does this plan entail? A fire prevention plan should include, at minimum, the identification of potential fire hazards in your lab, your available firefighting tools, and an action plan that outlines employees’ responsibilities during a fire or evacuation.

First, it is best to determine what fire risks are present in your labs. The best way to begin would be to inventory any flammable chemicals used and stored on-site. Some flammable materials such as alcohol can accumulate quickly, and it is necessary to know how much is stored in the department and where. The Occupational Safety and Health Administration (OSHA) mandates that quantities of flammable liquids greater than 25 gallons in a single room must be stored inside of a flammable storage cabinet (1926.152(b)(2)). The National Fire Protection Agency (specifically standards NFPA 45 and 30) takes it a bit further and focuses on limits based on total square footage in the lab. The NFPA limits the amount of flammable liquid stored outside a flammable storage cabinet to no more than 1 gallon per 100 ft², or 2 gallons per 100 ft² if you use fire safety cans. This storage limit doubles if an automatic fire suppression system is in place. The limitation of flammable materials in a concentrated area enables a fire suppression system to more easily extinguish a fire if one were to occur.

Next, look at the amount of combustible items stored around the lab. Are there several boxes of paper stacked next to photocopiers? Large amounts of combustible material in a single area can help fuel a potential fire. Are items stored too close to the ceiling? Check to see that there is at least 24 inches of clearance from the ceiling so that sprinklers are not blocked. Finally, inspect your electrical equipment. Look for daisy chains or permanently placed extension cords in the lab. As part of routine physical environmental rounding, it is best to search for these prohibited situations while also seeking out frayed cords and damaged electrical equipment.

Another component of the labs’ fire prevention is having the correct tools in place to combat a fire should one occur. The local fire authority will determine how many fire extinguishers are required in the laboratory and where they should be placed. To ensure adequate operation of this firefighting equipment, extinguishers should undergo routine checks which include annual maintenance. OSHA also requires a monthly visual inspection of all portable extinguishers (OSHA-1910.157(e)(2)). Verify that staff know the locations of their nearest fire extinguishers and that they can operate the specific types provided. Is there an automated sprinkler system in the facility? Staff should be aware of the location of fire pull alarms and have education about the alarm process (including calling any emergency numbers).

Lastly, the fire prevention plan should detail information about staff response to a fire, including fire drill and evacuation training. The safest way to evacuate is to have a predetermined evacuation route and muster (meeting) location. Staff should physically walk their full evacuation route annually all the way to their muster location and back. If this route becomes impassable, there should be an alternative evacuation route. During drills, walk one route to the muster location, then walk back via the alternate route. It is also wise to outline the expectations of staff members once they reach that muster location during the drill. If a large group evacuates at the same time, using a checklist or a buddy system can help staff keep track of who is present and who is not. Encourage your staff to stay at the muster location and not to wander off. If a supervisor is taking a roll call at the muster location, a staff member might be counted as missing if they leave to chat with a buddy in a different area. The last thing anyone wants is for a rescue worker to run into a burning building to search for a person who is not even at work that day. As the laboratory grows, so should the fire prevention plan. The addition of new equipment or a change in the current procedure warrants a review of the plan. It is recommended that fire safety policies and procedures are reviewed annually, and when changes are made, communicate that information to staff quickly. Ensuring that equipment is in place, that items are stored properly, and that staff are made ready to respond can lead to much better outcomes should a real fire occur in the laboratory.

-Jason P. Nagy, PhD, MLS(ASCP)^CMis a Lab Safety Coordinator for Sentara Healthcare, a hospital system with laboratories throughout Virginia and North Carolina. He is an experienced Technical Specialist with a background in biotechnology, molecular biology, clinical labs, and most recently, a focus in laboratory safety.

Journey into Mystery: Unknown Source Exposures

In 1962, Marvel Comics introduced a new super-hero in their comic book titled “Journey into Mystery!” That character would become famous both in the book and eventually on the big screen. He was the mighty Thor. Through the years this Norse god of thunder would have many adventures and travel into many strange and unusual places all to protect his home of Asgard and to save the people of his adopted home planet, Earth. While the character of Thor willingly chose to journey into those many unknown places, those who work in the laboratory with bloodborne pathogens should not.

Evan popped the tops off of the serum separator tubes and placed them into the analyzer rack. He used a counter-mounted shield to protect himself from a splash. He picked up the rack containing five specimens and walked over to the chemistry analyzer to run them, but as he neared the analyzer his grip loosened, and he dropped the rack. It fell about an inch onto the analyzer and serum splashed up into Evan’s eyes. He did not know from which tube or tubes was the source of his exposure.

Rose was running late when she started her shift in the histology grossing lab. She did not notice that the small sharps container for scalpel blades was over full at the bench. When it was time to change her blade, Rose reached up without looking to eject the blade into the sharps container. She felt a sharp pain and saw that she had cut herself on several used blades that were sticking up out of the container access hole. Her injury had to be treated as an unknown source exposure.

If a bloodborne pathogen exposure occurs in the lab, there are several regulations that should be in place to help protect the exposed employee. OSHA’s Exposure Control Plan includes hepatitis vaccinations for employees, and follow up source testing instructions to discover the HIV and hepatitis status of the known source patient. Prophylaxis for an HIV exposure in the lab must be administered quickly to be effective, usually within 2 hours of the exposure, so rapid testing is key.

There are, unfortunately, accidents that occur for which the bloodborne pathogen source cannot be determined. The incidents described above could have been prevented, and they should have been, because treatment for an unknown source exposure is a journey no ne should want to make. In some cases, like with the sharps exposure, it is impossible to determine the source. In other cases, as with a rack of tubes, it is too costly and there is no time to test all possible exposure sources.

In some facilities, after an unknown source exposure, the policies call for complete serological testing of the exposed victim for HIV and hepatitis. This does not provide useful information, however, it only provides the serological status before the exposure, it does not alter the necessary treatment.

Treatment for an unknown source exposure usually consists of the immediate administration of prophylactic drugs. While these drugs are designed to help prevent the post-exposure development of HIV or hepatitis, they are known to be toxic to the body and can have many ill effects. Personal consequences can occur as well after such an exposure. As a precaution, the exposed victim may be told to avoid intimate relationships for six months. Clearly, this is not a journey anyone would willingly want to take.

All exposure incidents in the laboratory setting should be prevented, and the majority of them can be prevented easily. Pay attention to the surroundings and look for potential sources of exposure. Consistently use proper PPE including face protection whenever handling open specimens or performing maintenance on an analyzer where tubing or reservoirs are involved. Empty sharps containers when ¾ full, and never allow anyone to open them or dig through them, even for a lost specimen. The risk is too high.

In many ways, the work of a laboratorian should be a journey into mystery. There are test results to produce, diagnoses to be made, and new techniques to discover. With the work in the lab environment, all exposure risks should be assessed, and they should be mitigated using engineering controls, safe work practices, and PPE so that this work can be performed safely. Let the scientific mysteries be those that prevail and not the scary alien consequences of an unknown source exposure.

You Can’t Hide Those Safety Eyes!

Jamie, the manager of a large metropolitan hospital lab, has many responsibilities. She must spend most of her time in the office, on the phone, or in meetings. She does find time to come out to speak with the employees, but only for a second to check on things or maybe make a request. During a recent safety audit, Jamie received feedback that several employees were seen working in the lab without using the proper PPE. One tech was working the bench without gloves, one individual had their lab coat on but not buttoned, and one auditor noticed that no one in the lab was wearing face or eye protection. This came as a shock to Jamie, she had never noticed this before. This doesn’t necessarily mean that Jamie is a bad manager, it could be that she was so focused on daily operation issues and she failed to notice other problems.

We have all heard the term “nose blind.” It’s when a person is around a bad smell so frequently that they become oblivious to its presence, and this can actually happen with vision as well. Have you ever heard the phrase, “you can’t see the forest for the trees,” or maybe the term “snow blind?” This phenomenon occurs when someone is concentrating so hard on one problem they may miss a more serious safety issue directly in front of them. Lucky for us, we have a tool to help those safety issues stand out. We have our “Safety Eyes!”

Ok, so what exactly are Safety Eyes? Are they some kind of new eye protection device that fit directly on your eyes? Are they indestructible eyes? Not exactly. Safety Eyes is a term used to describe the ability to spot current or potential safety issues more easily. It is the ability to walk into a room and immediately scan the environment for safety issues. This ability doesn’t just magically develop, it takes time and effort to master, and once you have it, you will begin to notice issues without even trying.

There are methods you can use to develop your safety eyes. Like any other sense, it is important to practice using it frequently so that its use becomes second nature to you. Think about this in terms of a wine sommelier. A sommelier may train for several years to acclimate their nose and palate in order to detect various nuances in different types of wine. It is through experience and exposure to many different types of wine that they are able to pick up on the slightest hint of a flavor or scent. This same repeated exposure works for sharpening your Safety Eyes as well. It is probably unlikely that you have a Safety Unicorn in your lab who can pick up on potential safety issues on their first day on the job. To become better at seeing safety issues, perform periodic rounding in the department and look for specific safety issues. Start by covering one specific safety area such as PPE use, waste management or fire safety. Your ability to quickly notice issues in these areas will sharpen, and you will be able to expand your newly honed power to other areas.

By developing your Safety Eyes, you will become more aware of various types of safety issues and where they are most likely to be encountered. It is easy to become “nose blind” to safety issues in a lab where you work every day. Start by simply using a checklist to focus specifically on one new safety area and soon the issues that may have been there all along will be more easily detected. Now that you can see the forest, you can make those important changes which will improve your overall lab safety culture!

Guess Who’s coming to the Lab?

When we enter the laboratory, we know of the dangers that can be encountered. Our training tells us there could be microbes and other potential pathogens in the samples we are about to analyze. We also learned how to protect ourselves; how our behavior while in the lab has consequences. We even know how to dress properly and what engineering controls we have at our disposal to keep us safe. We put on our personal protective equipment (PPE) before we start to work and remove it before leaving the lab. For some, these behaviors are automatic, actions that are done almost without even thinking. But is this the same for all who enter the lab? Do visitors who comes into the department know what they are really walking into or how to keep themselves safe in an environment that may be foreign to them? One common question asked by lab staff regarding visitors is “do they have to adhere to the lab safety policies and if so, why?”.

On a recent safety audit, I visited a lab that happened to be getting a new chemistry analyzer installed. I noticed the vendor team, which consisted of 5 individuals, were not wearing any PPE. There were backpacks, open water bottles, and cell phones sitting on the counters and floors. The new instrument was not hidden in a back corner of the lab far away from the daily work. It was close to the area where the lab process, spins, and runs patient samples. Members of the vendor team were lying on the floor and crawling around. How does that scene make you feel?

Vendors and service representatives are regular visitors in your lab. A laboratory can have a representative on site a dozen times before you even begin to use that piece of equipment. Once it is installed, you can bet you will see them multiple times for preventative maintenance and service calls. How does your lab welcome these guests? Do you let them in and have them get right to work? If they are there to repair an analyzer you are likely eager to have them get started, but do you ask them to wear a lab coat? Did they bring one of their own that was kept in their backpack? If so, do you think that coat is clean or was it used in a different lab, packed up, and brought to your lab? Vendor compliance is a safety issue for many labs because these visitors are not lab employees, yet they are in your department and may be putting themselves and your team at risk. Often vendors are seen with drinks in labs, using cell phones or touching instruments without gloves – behaviors lab folk are told not to follow. So why is it tolerated? It shouldn’t be, and you have the right to speak up and ask them to adhere to your lab policies.

What about other potential laboratory visitors? Do pathologists come in to look at a patient slide in Hematology? Do they just sit down at your bench and look at the slide without gloves or a lab coat? Is lab staff allowed to scan a smear without PPE? Probably not, and no one else should be allowed too either. The microscope has most likely been touched with dirty gloves, and no one else should touch the same scope without gloves. Even lab doorknobs are a consideration. Staff should wash hands before leaving the department. That means no one should use contaminated gloves to open the door.

Speaking up about these safety issues to lab visitors can feel uncomfortable. A conversation with a physician about safe practices in the lab can be daunting, but the cost of not speaking up can be high. Take the opportunity to show you care about visitors and want to keep them protected. Sometimes you know who is coming to the lab, and you feel confident they have been trained and will use the best safety practices. At other times, though, those guests may be unexpected and lacking in safety knowledge. Make sure to treat them with respect, give them the safety training and tools they need so they can leave both happy and healthy.

Quicker Than the Eye

Len began his shift in the hematology department. He liked to use the counter-mounted safety shield when opening specimens because he did not like to wear goggles over his eyeglasses. When it was time to read differential slides, he knew he could not look into the microscope with his glasses on, so he reached up with his gloved hands, grabbed his frames and set them on the dirty hematology workbench next to the scope.

OSHA’s Bloodborne Pathogens Standard was promulgated (put into effect as law) in 1991. Its purpose was to prevent employee exposures to infectious organisms that may be present in blood or body fluids. For those employers covered, that meant creating an Exposure Control Plan, providing certain vaccinations, educating staff about exposure follow-up, and providing personal protective equipment (PPE).

Much has changed in healthcare since 1991, but the standard remains unchanged. Changing an OSHA standard does not happen often, and it does not happen quickly. In many ways, for the Bloodborne Pathogens Standard, that’s a good thing. The same protective measures must be in place in workplaces like laboratories, and despite the appearance of novel pathogens over the last 30 or so years, the basic required risk assessments and mitigation steps still apply.

Some people, however, complain that the standard doesn’t speak clearly enough about issues that have changed over time and that now need to be addressed. Do the regulations speak to personal electronic devices in the lab like smart phones, smart watches, and ear buds? There is mention of not having food or drink in the department, but what about chewing gum or candy? Sometimes you need to dig a bit deeper to discover that those issues are also addressed, even though some of those issues did not exist when the standard was written.

If you read the line, “Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure,” it seems very clear that OSHA is trying to prevent hand to face contact. While they did not cover every possible action, this likely includes gum chewing and touching cell phones which are then brought to the face (or worse, used at home by a toddler wanting to play). It can be argued that lab employees use telephones often on the job, and that gloved hands are near the face because of that.

So what other actions occur in your lab that could potentially create bloodborne pathogen exposure – actions that may occur every day or so quickly you don’t notice? Have you thought about wireless headsets or speaker phones in the lab? Do you look in cabinets and drawers for food or drink (especially during off-shifts)? Is gum chewing allowed in your lab (hint: if you’re in a CAP-accredited lab this is strictly forbidden)?

And what about poor Len with his glasses? Has anyone trained him to remove his gloves, wash his hands, and place his spectacles on a clean surface before using the microscope? There might be other things you did not notice. If you have an employee with hearing aids, do they remove them to answer the phone? Do some staff wear gloves when opening the lab exit door and others use bare hands? Are computer keyboards used with and without gloves? Is PPE worn into lab rest rooms? These are all instances where a lab-acquired infection could begin, and they happen in a flash. Perform risk assessments to not only locate the risks, but to implement ways to mitigate them. Magicians claim that their hands can move faster than the eye can see in order to work their tricks. Employees will perform “tricks” as well, but the outcomes may not be as entertaining. Providing safety education and observing people at work to see where other risks exist are important steps toward complying with the Bloodborne Pathogens Standard. The regulations are not new, but with updated lab policies and safety measures, they can be powerful tools to protect you and your staff from the new pathogenic threats headed our way.

Laboratory Ergonomics: Safe Today, Healthy Tomorrow

Ergonomics is a safety topic that gets little respect in the laboratory, but it can become very important over time. The effects of poor ergonomics are cumulative, and they can appear suddenly. When they arise, the pain and treatment are often difficult, and as people age, healing is slower as well. Because the consequences of repetitive motion injuries are slow to appear, it can be a challenge to raise concerns and create solutions regarding ergonomics. Education and action today can prevent a great deal of future injuries and staff shortages.

There are several areas in the lab where a focus on ergonomics can create benefits, and creating healthy movement and comfort does not need to be expensive or difficult. Laboratory workstations have a primary and secondary work zone. Keep the most frequently used objects in the primary zone (within 18 inches of reach) and less frequently used in the secondary zone (within three feet). Every employee is a different size. Teach staff to take a minute before beginning work to adjust the chair and other work items to make the workstation more comfortable. Eliminate clutter beneath the workstation to allows room to stand or sit allowing for foot and leg comfort.

Chairs should have 4-way and preferably 6-way adjustability and come in a variety of sizes to fit the employees who work in the lab. Chairs should have five legs with casters that are appropriate for the surface being used (e.g.: hard casters on carpet and soft casters on tile). The backrest should flex between 90 and 113 degrees with arm rests removed on chairs in the technical area to allow the chair to get closer to the benchtop.

The tops of computer monitors should be at eye level. Since many employees may use the same monitor, having it on a movable arm will help each user move the monitor to an acceptable level. Any glare on the monitor screen can be reduced with a glare screen or by reducing the light in the department. Keyboards should lay flat to allow the hands and wrist to work in a neutral position and the arms to work at a 90 degree level for comfort.

When using a centrifuge, stand directly in front and work over the top when loading and unloading, and use two hands to close the lid. Centrifuges should be placed low enough so that employees can see into the body of the machine easily. Place antifatigue mats in front of laboratory equipment that requires standing for long periods of time. These mats relieve lower back and leg discomfort. When bending and lifting, employees should lift using their thighs and not the back. Teach staff to hold objects close to the body when lifting. Never lift more than 50 pounds without assistance from other employees or an assistive device such as a hand truck.

Capping and uncapping tubes for an extended period, phlebotomy, and transcription are laboratory tasks that require the use of the same muscle groups in the hands. When working in these areas, it is important to vary the tasks every 2-3 hours per day and take mini-breaks to stretch fingers and arms in order to prevent carpal tunnel issues.

Breaks are an important part of overall ergonomic health. It is better to take a five minute break every hour than to take a 15 minute break every four hours. It is especially important if you are using a microscope or a computer for an extended period of time. Remember the 20-20-20 rule: Every 20 minutes look up to focus on something 20 feet away and blink your eyes 20 times. This will allow you to moisturize your eyes and give them a short rest. This can help to prevent ergonomics issues such as Computer Vision Syndrome which can result in neck pain, vision problems, and headaches.

Ergonomics safety is important on all areas of the laboratory, and the best way to ensure good work practices is to perform an ergonomics assessment. An ergonomic assessment should include identifying physical work activities or conditions of the job that are associated with work-related musculoskeletal disorders (MSDs) and how to eliminate these hazards. For additional information, review the Occupational Safety and Health (OSHA) laboratory ergonomics fact sheet (https://www.osha.gov/sites/default/files/publications/OSHAfactsheet-laboratory-safety-ergonomics.pdf).

Over one third of all U.S. worker injuries are related to MSDs caused by poor ergonomics. Laboratory employees are valuable resources, now more than ever, and preventing time away from work, surgeries and medical bills for laboratorians should be a priority. The results of poor ergonomic practices in the lab do not show up today, but they will have effects tomorrow if we don’t pay attention to them. Those effects can be career-altering, career-ending, and they can interfere with the happy and healthy retirement that we all want to enjoy. Take steps today to prevent that future- provide training, raise awareness, and perform ergonomics assessments to make sure staff remains comfortable and healthy for all of their tomorrows.

Three Rules to Manage Chemical Waste- It’s Complicated!

The lab technologist approached the Lab Safety Officer to ask what should be done with a collection of liquid wastes that were collected from the chemistry analyzers. The LSO had worked with multiple labs for years helping to determine how to dispose of their liquid chemical wastes according to the regulations. He thought he was pretty well aware of the hazardous chemical wastes coming from the labs, but he had no idea this chemistry analyzer waste existed. He dug a bit deeper. As he called around to the different labs in the system, he learned not all sites were handling the waste the same way. Some sites saved the excess waste and poured it into other containers to use on the analyzers. Some labs threw the containers in the trash with liquid inside, and other sites simply poured the excess chemicals down the sink drain.

Some laboratories and lab systems are very large, and there are probably many practices, some newer, some older, that have developed over time, because “someone said so,” or because a vendor said it was acceptable. The LSO may not always be able to know about every practice in each lab. Staff should always escalate questions about waste processes when there is a concern.

Managing hazardous (chemical) wastes is a complicated process, and training and education is needed in all laboratories. The regulations surrounding waste are numerous and complicated, and it would be unlikely that every lab employee would aware of all of them. Here are some basics that are true for all laboratories:

Pouring Bulk Wastes Down the Drain is (Usually) Incorrect and Possibly Illegal

In general, manually pouring bulk amounts of chemical waste down the drain is not permitted by the EPA. What is a bulk waste? It is defined as 200 mL or more. That means if you have >200 mL of a reagent left over in a container, you cannot pour it down a drain for disposal. That chemical is now waste and must be properly collected, labeled, and stored until a waste contractor can pick it up.

There are, of course, exceptions to every rule. If a waste drain line is connected to a drain, for example, that is not considered “pouring,” and it is acceptable provided a lab has informed the local wastewater treatment center about what is going down the drain. Performing a gram stain in microbiology and letting the residual chemicals go down the drain is allowed also. That is considered part of the gram stain process, and it is not viewed as “pouring” chemicals down the drain. Also, the wastewater facility is aware that these chemicals are going down the drain.

Another exception exists in some laboratories that have an external “chemical pit” which is tied to certain sinks and drains in the lab. That means that all wastes poured down these drains go straight to a collection tank which neutralizes the chemicals. The tank is emptied periodically by a contracted vendor. Since there is no waste going to the local wastewater system, the local authority does not need to be contacted about what goes down the lab drains.

Hazardous Waste Must be Properly Stored

Anytime a lab collects chemical waste, it must be properly stored. There are two types of waste storage areas, Satellite Accumulation Areas (SAA) and Central Accumulation Areas (CAA). A Satellite Accumulation Area is a storage area near to where the waste is generated. The SAA must be within the line of sight of where the waste is made, it cannot be in another room or around the corner. You must store the waste where it can be seen from where it was generated. You cannot move waste from one SAA to another SAA. You can. However, move waste from a SAA to a Central Accumulation Area (like a hazardous waste shed outside, for example).

SAAs can store up to 55 gallons of waste. Waste must be stored inside of a flammable cabinet if it is flammable, and acid wastes cannot be stored next to bases. SAAs and CAAs must have a specific emergency contact poster hung nearby which indicates the location of the nearest fire extinguisher as well as an emergency contact in case of a spill or accident. CAAs must be checked weekly for proper labeling, open containers, and leaking, and these checks must be documented.

Hazardous Waste Must be Properly Labeled

Anytime a lab collects chemical waste, it must be properly labeled per EPA regulations. All waste containers must be labeled with the identity of the contents and the words “Hazardous Waste.” There must also be an indication of the waste hazard(s), such as a pictogram or an NFPA diamond. If waste is collected into an empty reagent jug, you may not use the wording or warning label from the original jug.

Dates should never be placed on chemical waste labels when stored in a Satellite Accumulation Area, but dates always need to be on containers once moved to the Central Accumulation Area. If the waste vendor picks up containers directly from your SAA, you never need to place dates on the containers.

Again, the proper management of the laboratory hazardous wastes is complicated. There is a great deal to learn and to put in practice. Many regulations have exceptions, and some of them depend on the facility’s waste generator status. If you have questions, reach out to your EPA (or state branch) representative, or ask an available safety expert. Make sure your lab is handling chemical wastes appropriately and safely.

Safety Succession

In many laboratories, managing safety is rarely a full- time job. Many have to oversee the safety program while also managing day-to-day operations, and overseeing the quality or point of care programs. Some are lucky enough to be able to spend all of their time on the lab safety program. Either way, the role can include managing safety policies and procedures, performing audits, providing education and training, and consistently working to improve the overall culture.

But what happens when the lab safety officer has a job change, a promotion or is ready for retirement? What happens to all of that safety knowledge and experience? Wouldn’t a gap like that be a detriment to the lab’s safety program? Yes, and laboratories should always be preparing for such an event.

One way to get prepared for a transition of lab safety duties is to identify a potential replacement while you are still working in your role. Look for someone who has shown interest in your work or has asked good questions about safety issues. Ask them to shadow you as you perform your safety tasks. Ask them to review safety procedures that are due to be revised. Have them watch a lab safety audit and describe how it should be performed. Ask them to create and possibly present safety education for the staff.

This may seem more difficult if you are the lab manager with safety responsibilities. However, there can be a benefit to identifying someone among the staff to perform some of the safety tasks as they can eventually come off of your plate. Leaders should also always have an active succession plan, so if safety must remain under your purview, make sure it is part of your discussions with your potential leadership replacement(s).

If, as a safety leader you run a laboratory safety committee, look for potential future safety leaders in that group. There may be one or more good candidates for future lab safety leadership. You can assess their readiness by delegating projects and tasks. Again, things like creating safety education, working on policies, and performing audits are great “auditions” for a future job. You can also ask the committee to create a safety fair, or to develop a safety poster contest or other projects which help to raise safety awareness in the department.

Provide resources for potential leaders such as safety documents and regulations. Involve them in lab safety inspections. If the EPA, the local fire department, or even the wastewater authority arrives for an audit, allow those staff members to be involved in the process. Getting a taste of these typical lab safety events can help people discern whether or not they want a future in the field. Preparing the lab for an upcoming accreditation inspection is also great experience.

Another way to help someone on their path if they are interested in safety is to help them get certified. ASCP offers a Qualification in Lab Safety (QLS). Preparing for the certification will help someone learn more about specific safety topics like Bloodborne Pathogens, Chemical Hygiene, and Waste Management among others. The suggested study resources and references will remain important in the hands of a future lab safety leader.

Given the growing shortage of laboratorians, it is clear that it will become more difficult to fill job openings as the years pass. Labs cannot operate without specific people, however. Leaders are vital, bench staff are key, and safety professionals will always be necessary. Planning for succession is something that should be inherent in the department for most positions. The organizational chart should be designed with succession in mind and a staffing plan that goes beyond today. Lab Safety should always be a key piece in the lab’s overall succession process.

Safety in the Moment

Often I am asked how one who is responsible for laboratory safety (yet has other duties as well) can get the job done well. In today’s labs there is tight staffing, tight budgeting, and a score of regulatory duties that must be accomplished, and not all of these things revolve around safety. Many who oversee the lab safety program also must run the point of care program, the lab quality program, or even manage all of the day to day operations of the department. It’s a great deal to juggle, but there are methods you can use to make sure that laboratory safety doesn’t take a back seat.

One way to incorporate safety into your multiple roles each day is to start every meeting or huddle with a safety moment or story. Ask for a team member to discuss a safety story they witnessed or in which they were involved. Placing safety first lets the team members know it has priority, and relating an issue or incident has benefits as well. The safety moment may be as brief as reporting on how an employee provided PPE to a vendor that came into the department. That is a safety success worth mentioning, and there are doubtless others that can be mentioned. These safety stories may also be those that do not necessarily illustrate a success. Telling people about an incident and asking how it could have been avoided is a fast yet educational plus for your safety culture. Reviewing safety incidents is also beneficial so that others know what happened and they can be thinking of how to avoid the same thing from happening to others or themselves. Talking about safety in these ways takes little time, but if safety is incorporated into the language of the department, the culture will remain improved, and it is easy to fit this habit into your schedule.

Acting as a consistent role model is another way to incorporate safety into your multiple roles. Make sure you wear the correct clothing and shoes. If you walk in and out of the department, you should dress the part. Open-toed shoes or mesh sneakers should not be worn. Wear PPE when performing any work in the lab, including huddles or team meetings. It doesn’t take any extra time to model the safety behaviors you expect from the staff, and doing this shows the staff where safety stands in the department.

A third way to insert safety into your busy day is to make sure you are able to quickly spot safety issues and address them immediately. Developing your “Safety Eyes” is a vital tool – learn how to notice safety problems as you work in the lab. Train yourself to be able to do this by looking for one thing each week. For instance, look for PPE and dress code issues on week one. Purposely notice what people are wearing on their feet, look for proper PPR like lab coats and gloves. Check to see that they are worn properly. If you do this for one week, you will become much better at noticing issues with just a glance. The next week look for proper chemical labels, then fire safety issues, etc. Once your Safety Eyes are enabled, you will be able to easily see issues and manage to rectify them while performing your other lab duties.

No matter your role in the laboratory, part of the job involves talking to other people. Make safety a part of those conversations when the opportunity arises. You might speak to your lead technologist about an instrument installation. Ask about new reagents that might need to be added to the chemical inventory. Find out if there will be new waste streams generated. Was a risk assessment performed to look for other possible dangers?

Incorporating safety into your already busy day might seem like an impossibility, but it can be done. It is important that it is done. You are managing different parts of the lab, but if people are getting injured and exposed because there is no focus on safety, there won’t be much left to manage! Try these few ways to blend safety into your schedule- add one at a time and see how it works. In time you will notice that these small tasks make a big improvement on your lab safety culture.