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Mandatory Respirator Program Implementation

When implementing a mandatory respirator program, be sure to adhere to the applicable stipulations in OSHA’s Respirator Standard, 29 CFR 1910.134.  Requiring the use of respirators can be driven by several factors, including a company deciding to require the use of respirators even when exposure levels are below permissible exposure limits.

Are Your Door Signs Effective?

In the event of a hazardous material spill at your facility, are door signs used to notify individuals of the spill situation? Or do you use caution tape, cones, or some other physical barrier to prevent unauthorized entry into the hazardous material spill area?

Consider Cell Phone Distractions

On a day like today when people are making last minute dinner plans, the use of cell phones and people’s desire to be constantly connected to their phone may be exemplified. In addition to the possibility of cell phones being fomites when allowed in laboratories, the distraction factor is also a concern.

How Many Risk Assessments Have You Conducted?

If you were to think back about this past year and how many risk assessments you conducted, what do you think the number would be? Do you have a plan in place to ensure that a thorough risk assessment is conducted prior to new biological agents being introduced into the laboratory?

Universal Waste Management

The Massachusetts Department of Environmental Protection (MA DEP) regulates Universal Waste, which includes hazardous batteries, mercury containing devices such as thermometers, mercury containing lamps, and pesticides. Be sure that your facility is properly collecting, storing, and disposing of universal waste streams.

Evaluate Available Gloves

As of January 18, 2017, the FDA has banned powdered surgeon’s gloves, powdered examination gloves, and absorbable powder for lubricating a surgeon’s gloves. Manufacturers of powered gloves have been sending notices to customers to advise them of the ban and request that any banned products currently available in the workplace be disposed of.

OSHA Issues New Beryllium Rule

On January 6, 2017, OSHA issued a final rule to reduce workplace exposure to beryllium. Previous standards were based on out dated studies and data, and more recent data demonstrates that serious lung disease can result from low level exposures to beryllium.

2017 Update to Coordinated Framework

The 2017 Update to the Coordinated Framework for the Regulation of Biotechnology was released by the EPA, FDA, and USDA on January 4, 2017. The so-called Coordinated Framework is accompanied by the National Strategy for Modernizing the Regulatory System for Biotechnology Products.

Check Ceiling Clearance Compliance

When walking around your facility, be sure to check for compliance with ceiling clearance requirements. Most people are aware that storage of materials within 24 inches of the ceiling and 18 inches of a sprinkler is not permitted. However, these requirements are very easy to forget when space is limited.

Consider Archiving Rather Than Pitching

Many of you are likely spending some time going through your EHS records for this year, and preparing recordkeeping systems for the new year. As you know, there are numerous regulatory requirements for how long you must maintain specific records.