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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 […]

Conduct Routine Inventories of Flammable Storage

flammableWhen was the last time that you conducted an inventory of the flammable materials stored at your facility? A weekly or monthly inventory may be necessary if you are strictly limited by the volumes allowed in accordance with the Massachusetts Comprehensive Fire Safety Code.

Many companies run into challenges with the storage of Class I flammable liquids in accordance with the thresholds allowed per control area. The higher the floor in the building, the more stringent the permitted storage becomes, and some multi-tenant buildings require tenants to share control areas. In some cases, facilities are forced to look for additional storage on the first floor of the building to accommodate their raw material and waste storage needs. This dictates the need for delivery of raw materials in time for use, and daily checks for removal of full waste containers.

In cases where the storage needs are not as close to the allowable thresholds, […]

Check Expiration Dates

calendarWhen conducting monthly checks of the emergency equipment available throughout your facility, be sure to check the expiration dates. This includes supplies in the first aid kits, AED supplies, emergency eyewash bottles, and any other emergency supplies with expiration dates.

It is easy to skip over checking expiration dates when conducting these checks and only focus on verifying that the necessary supplies are in place. You want to avoid running into a situation where it appears that a supply is available, but someone discovers that it is expired when they are in a situation requiring the use of that supply. If the supply vendor is conducting the monthly checks, it is a good idea to spot check the kits and supplies on a routine basis to verify that the expiration dates are being monitored.

When developing a program to check the emergency equipment on a routine basis, it is a good idea to […]

Safe and Sound Week is Rapidly Approaching

successNow that the kick off of OSHA’s inaugural Safe + Sound Week is less than three we
eks away, it is time to start finalizing your plans and programs for the week.  If you have not considered taking advantage of this opportunity to highlight and invigorate your EHS program, please reconsider!

All types of organizations are encouraged to participate in this campaign.  Businesses of any size and in any type of industry are asked to show their commitment to safety during the week of June 12-18, 2017.  If you are interested in finding out more about how to participate and earn a certificate of recognition, visit OSHA’s Safe + Sound Week webpage.

Finding the time and building the momentum to hold a safety week can be quite a challenge.  Soliciting help from your safety committee, safety officers, and workers with a high regard for safety will share the burden of work as well as […]

Document Review of Dosimetry Reports

signaturesWhen establishing a radiation safety program, be sure to assign the responsibility of reviewing the dosimetry reports to one individual. Whether you are exchanging dosimeters on a quarterly basis, monthly basis, or some other frequency, a specific person needs to own the responsibility of reviewing the reports and notifying individuals of their results as necessary.

When the review takes place, the responsible individual should make record of their review. This can be as simple as writing the date of evaluation on the report itself and signing off on it. The results for the current reporting period should of course be reviewed for each individual, as well as the annual dose to date. Remember there are notification requirements that must also be adhered to.

What Is Your View of the Hazards?

HazardsHave you ever asked the scientists working in the labs at your facility what they view as the highest hazards associated with their work? Do you know what their answers would be if you did ask them this question?

It is possible that you would discover some hidden hazards associated with particular pieces of equipment, processes, or procedures if you asked this question. This is also an excellent way to find out more about the hazardous materials being manipulated within each lab. If you have asked this question in the past, consider how long it has been since you explored the answers and how many staffing changes have occurred since then.

It may seem like a relatively simple question to ask, but the importance of exploring this question should not be underestimated. You may discover that the scientists’ views of the highest hazards associated with their day to day activities are different than […]

Review Permit and License Conditions

conditionAs EHS permits and licenses are received, amended, and renewed, be sure to review the conditions stipulated in the permit or license upon receipt. Avoid the temptation to be happy that the final document has been received, and just file it away in your central recordkeeping location. It is important that everyone involved in the application process is aware of this requirement to avoid potential issues of non-compliance.

If permits and licenses are issued to different individuals within the company, be sure that one person is responsible for ensuring that all permits and licenses are received and current. This will avoid the potential for renewals falling through the cracks, or confusion around the permits and licenses held. This point person should also be responsible for verifying that the conditions of issued permits and licenses have been reviewed, and a plan is in place to ensure compliance with those conditions. There may be […]

Keep an Eye on Wastewater Discharge Volumes

wastewater increaseIf you are the holder of a Low Flow/Low Pollutant wastewater discharge permit with the Massachusetts Water Resources Authority (MWRA), be sure to keep an eye on the average daily discharge volume.

It is not uncommon for wastewater effluent volumes to be minimal when operations begin at a small biotechnology research and development company. In these cases, facilities are able to obtain Low Flow/Low Pollutant discharge permits with the MWRA due to falling below the 300 gallon per day discharge threshold. As operations grow and processes evolve, wastewater volumes can sneak up and exceed the threshold over time.

The certified wastewater operator that is checking the pH neutralization system on a daily basis should be aware of the need to keep an eye of the average daily discharge. They should also be aware of the person to contact if they notice a trend toward exceeding this threshold.

If you are not the person conducting […]

How Do You Communicate Hazards?

warning signWhat does hazard communication mean in your laboratories? Are there hazard warning signs posted everywhere, are you constantly having to remind lab employees to label their chemical bottles appropriately, or do you need to update the door signs that have not been looked at in years?

There are numerous regulations that stipulate requirements for communicating hazards, some more stringent than others. Of course following the specific regulatory requirements is important and must be done, but otherwise finding a balance between not communicating hazards sufficiently and over labeling/signing can be a challenge. When hazard warnings are posted everywhere they can lose their value and be ignored because the meaning is lost. And on the flip side, if signage is not sufficient, compliance can be lacking because the hazards are not recognized appropriately.

Be sure to evaluate hazard communication in your labs on a regular basis and find the right balance.