The end of the year presents the perfect opportunity to reflect on accomplishments achieved in your EHS program throughout the year and set goals for the coming year. Is your EHS program as robust as you would like it to be?
Something as basic as annual revisions to safety manuals is a task that is often overlooked. For employers engaged in laboratory use of hazardous chemicals, 29 CFR 1910.1450(e)(4) requires an annual review and evaluation of the effectiveness of the Chemical Hygiene Plan. 29 CFR 1910.1030(c)(1)(iv) requires that Exposure Control Plans for facilities working with human source material or other potentially infectious material be reviewed and updated at least annually. In addition, an annual review of safer devices designed to eliminate or minimize occupational exposure to human source material must be conducted with input from end users and documented. For facilities licensed to work with radioactive material, 105 CMR 120.210(C) requires an annual review of your radiation protection program content and implementation.
In addition to conducting annual reviews, the beginning of the New Year is the perfect time to ensure that a regulatory compliance calendar is established for requirements 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, and when annual refresher training sessions will be held. In addition, properly archiving documentation for easy retrieval in the event of a regulatory inspection maintains an organized program. There are way too many elements of a comprehensive and compliant EHS program to discuss here, so if it is not part of your EHS program already, establishing a means of evaluating your program overall will increase productivity and compliance. If you are looking for ways to make your EHS program more resilient, consider implementing quarterly lab walk-throughs (which fosters interactions between researchers and EHS staff), increasing the frequency of your safety committee meetings if your agendas are always packed, or consider increasing the frequency of conducing job safety analyses on the hazardous processes at your facility.
Wishing everyone a happy holiday season and successful New Year!