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Review EPA’s Guidance on New Nanotechnology Reporting and Recordkeeping Rule

EPA’s Nanotechnology Reporting and Recordkeeping Requirements Rule became effective on August 14, 2017. Manufacturers and processors of certain chemical substances are subject to reporting and recordkeeping requirements pursuant to Section 8(a) of the Toxic Substances Control Act (TSCA). In an effort to clarify the requirements for nanomaterials, EPA has issued a Working Guidance on EPA’s Section 8(a) Information Gathering Rule on Nanomaterials in Commerce.

This guidance document is a compilation of questions and answers developed based on input received from the draft guidance earlier this year. It is intended to be a work in progress with updates being published as necessary. If your facility works with nanomaterials, taking the time to review this rule guidance would be beneficial. If further clarification is still necessary after reviewing this guidance, EPA is urging individuals to reach out to the EPA directly to have their specific questions answered directly.

Maintain a Sealed Source Inventory

If your facility is licensed to work with radioactive materials, there are more than likely sealed sources at your facility that need to be accounted for. Depending on when and how your radioactive material license was completed, they may be included on your license. They may also be covered under a separate general license with the MA Department of Public Health Radiation Control Program (RCP). Either way, the sealed sources need to be accounted for and maintaining an inventory of the sealed sources present will help ensure that all sources are covered as necessary.

The sources found in liquid scintillation counters generally need to be registered with RCP, and some require leak testing on a regular basis. Check sources for G-M survey meters should be accounted for on the inventory even if they do not require registration with RCP. Maintaining an accurate inventory of all sealed sources present will help ensure compliance […]

Address Chemicals of Specific Concern

Do you know which chemicals in your inventory are highly hazardous, require special handling procedures, or require specific storage considerations? There are various measures that can be put into place to screen and track chemicals of special concern so the answer to this question is always yes.

Establishing a form of chemical gatekeeping to screen for chemicals that require special attention is one of the first steps to take to flag incoming chemicals before they arrive on site. This is a critical step to ensure that proper engineering controls are available prior to the material being received, and a thorough review can initiate proper receiving and handling practices. When conducting chemical inventories, keep an eye out for chemicals of special concern that may need follow up to determine how they are being utilized. The chance of finding surprises during chemical inventories is reduced if a gatekeeping system is implemented, but the possibility […]

Don’t Let Safety Training Just Check a Box

It is easy to say that the importance of developing an effective safety training program should not be overlooked, but how do you put a fun and therefore effective safety training program into practice? The consequences of viewing safety training simply as a task that must be completed to check a box rather than promote a high regard for the overall safety program can be significant.

Developing a robust new employee safety orientation that encompasses a safety tour of the facility and interactive sessions to demonstrate the safety policies will likely improve material retention. If new hires are forced to sit through hours of lectures to cover material that checks the boxes for various regulations, the details will be lost in the myriad of information given to them on their first day at a new job. Encourage questions, ask questions, and get to know the new hires’ previous experiences with safety. Encourage […]

 Review Ventilation Requirements

Have you taken the time to thoroughly review the ventilation system at your facility?  The answer to this question is hopefully yes, and as facility changes are initiated, ventilation consequences should be taken into consideration.

There are various sources for laboratory ventilation requirements, with some being recommendations and some being regulatory citations that stipulate specific requirements.  The importance of verifying a compliant ventilation system should not be overlooked when establishing laboratory space.  As the hazardous materials in use evolve over time, different engineering controls may be necessary which can impact the overall HVAC system.  Directional airflow is important to keep the air flowing from clean to dirty as much as possible.

Whether you are considering new laboratory space, expanding your existing space, or making modifications to current lab space, be sure to consider the ventilation requirements.

Should You Offer First Aid and CPR Training?

Does your company offer first aid and CPR training to employees on a voluntary basis? Of course if an AED is present in the company’s space, CPR and AED training needs to take place. Even if your company does not have an AED or require employees to respond to medical emergencies, it is a good idea to offer first aid and CPR training on a voluntary basis.

Offering CPR and first aid training even when an AED is not present is not only a good idea but also can be required by regulation. OSHA’s Medical services and first aid standard, 29 CFR 1910.151 states “In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.” There are interpretation […]

Happy Fourth of July!

I hope everyone in enjoying a safe and happy July 4th!

As you are hopefully enjoying your favorite pass times, remember to be safe at home as well as in the workplace. Many hobbies and activities are associated with risks, which are far outweighed by the happiness and fun experienced while enjoying them. So remember to be safe and have fun!

Do You Know What Happens After Hours?

watchWith a holiday weekend approaching, and many people getting ready for vacations and weekend plans, ask yourself if you are confidently aware of what happens after hours at your facility. Is there an established policy for signing in and out after hours? Are there restrictions on the type of work that can be conducted? Are visitors allowed to accompany employees stopping in for a quick visit on the way to a barbecue?

Establishing a policy that requires all employees to sign in and out after hours not only establishes what ‘after hours’ means, but helps ensure that people are aware of others present in the building while they are working after hours. When signing in, employees can check to see if others are present so they are not startled when they turn the corner and run into their coworker. And of course, having a record of the employees present is critical in […]

Assess the Financial Impact of Incidents and Accidents

MoneyHave you ever wondered how much money an incident or accident could cost your company? OSHA’s “$afety Pays” program is an interactive program that allows users to assess the potential impact that an occupational injury or illness could have on their bottom line.

This program allows users to select a workplace injury or illness that could result from the hazards present at the facility and then displays the dollar value of that particular injury or illness. Even though this is a very general program that does not take the site specific information into account, it can be used to demonstrate the general financial impact that one incident or accident could have on a company. Everyone is concerned about the company’s profitability and impacts to the bottom line. This information can be used to support the need to develop a robust workplace safety program, and can also be used to support reporting […]

Consider Expanding Project Registrations

bio inventoryWhat do the biological project registration documents in use at your facility cover? Are project registrations required for work utilizing recombinant DNA technology only, or are they required for all proposed work with biological agents?

It is prudent to conduct a thorough review of all biological agents in use, and implementing a project registration process prompts the review prior to the work being initiated. If your current program only includes project registrations for the use of rDNA technology to be reviewed by the Institutional Biosafety Committee, consider expanding the project registration process. A full IBC review may not be necessary, but the biosafety officer, safety committee, or other select group of safety officers could be involved in the review of the additional registrations. This is particularly useful in settings where there is not an active biological inventory being maintained.

There may be resistance to the idea initially, but implementation of a complete […]