The start of the new year is a time for resolutions. Often the focus is on eating healthier, exercising more, or starting a new hobby. For those of us in EHS it’s a perfect time to re-evaluate our safety programs and plan for and set goals for the new year. Is your EHS program as robust as you would like it to be? If you think there’s room for improvement some program areas to reassess include:
Compliance Deadlines
The beginning of the new year is the perfect time to ensure that a regulatory tracking calendar is established for ensuring ongoing compliance throughout the year. Considerations include when the Institutional Biosafety Committee (IBC) meeting will be held; when the chemical inventory will be conducted and SDS reconciled; when annual refresher training sessions will take place; and when permits will need to be renewed. Don’t forget to include facilities-related items such as fume hood and biological safety cabinet certifications and annual fire extinguisher servicing.
Safety Program Documentation
Something as basic as annual revisions to safety manuals is often overlooked. For employers engaged in the laboratory use of hazardous chemicals, the OSHA Lab Standard requires an annual review and evaluation of the effectiveness of the Chemical Hygiene Plan. In addition, the OSHA Bloodborne Pathogens Standard requires that Exposure Control Plans for facilities working with human source material or other potentially infectious material be reviewed and updated at least annually. An annual review of safer sharps devices designed to eliminate or minimize occupational exposure to human source material must also be conducted and documented. Emergency Action Plans are also required to be updated whenever there is a change to the plan or employees’ responsibilities described in the plan change.
Safety Program Records Organization
Consider taking time now to organize your EHS records and start the new year off headed in the right direction. Ensure your records are clearly organized, and key personnel are well aware of their organizational structure. Take the time to archive older records as needed. Several individuals should be familiar enough with the record keeping system to able to present well organized records to an inspector in the event of an unannounced regulatory inspection. Having an organized record keeping system demonstrates the value that your organization places on safety, which can set the stage for a much smoother inspection. Even if your EHS records are already well organized, take a moment to review the records from last year and set up your files for 2020.
New Safety Program Initiatives
This is also a great time to begin new safety program initiatives. If you are looking for ways to make your EHS program stronger, consider implementing regular (e.g., monthly, quarterly) lab safety walkthroughs if not already in place. These not only help identify safety issues that need to be addressed, but they can also foster productive interactions between researchers and EHS staff. Initiating safety committee meetings, or increasing their frequency, can also be a great way to energize your safety program. Remember to add an agenda item to safety committee meetings focused on sharing success stories related to your EHS program! In addition, consider conducting job safety analyses on the hazardous processes at your facility if you have not done so already. Last but not least think about making safety more interactive by creating incentives for things like personal protective equipment compliance, or months without incidents or near misses. Incentives can go a long way in motivating employees and creating a stronger safety program.
Almost every safety program can be improved on some level. Take advantage of the start of 2020 and set goals for enhancing yours. For more information, please email [email protected]
Wishing everyone a happy and safe new year!