End of Year Program Review

It is hard to believe Thanksgiving is next week, which means the end of the year will be here before we know it!  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.  If you have one more safety committee meeting scheduled for 2018, consider focusing on all of the improvements made throughout the year.  Ensure all of the annual meetings required by regulations have either taken place or are on the calendar.

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 […]

OSHA Announced Top Violations

OSHA has announced the list of the top 10 violations for fiscal year 2018.  There are two new citations on the list this year that have not shown up previously.

Personal Protective and Lifesaving Equipment – Eye and Face Requirements and Fall Protection – Training Requirements are the two violations that have not been on the top 10 previously.  According to the announcement, the top 10 violations accounted for approximately 32,266 violations in total.

Check out the top 10 list and take a moment to reflect on OSHA compliance at your facility.  Note that number two on the list is Hazard Communication, with 4,552 violations, and number four is Respiratory Protection with 3,118 violations.   How would your programs fair during an inspection?

Relocations Require Thorough Lease Language Review

Lease requirements can be vague when it comes to stipulating the level of decontamination or decommissioning necessary upon exiting a space.  Some leases are very clear that a full decommissioning must be completed in compliance with the ANSI standard, but other times there is room for interpretation.   When vacating lab space, it is necessary to determine the level of decontamination or decommissioning necessary far in advance of the relocation date.

There are many factors to consider when relocating, but the overall level of detail required for leaving the space in compliance with lease requirements is one of the initial questions that needs to be answered.  Some companies opt to complete a full decommissioning even when lease conditions do not require it.  When a full decommissioning is conducted, a Certified Industrial Hygienist (CIH) is involved in the process.  The CIH develops a sampling plan and decontamination protocol based on a review of the hazardous materials used […]

Avoid Offering Respirators ‘Just in Case’

Has anyone ever suggested ordering N95 respirators just in case they want to use them for a particular process or procedure?  Have you ever found a box of N95 respirators sitting on a bench while walking through the labs?  Try to avoid these scenarios and ensure the use of all respiratory protection is reviewed and approved.

OSHA’s Respiratory Protection Standard, 29 CFR 1910.134, stipulates requirements for mandatory and voluntary respiratory protection programs.  A step wise process needs to be conducted to determine which program needs to be in place for your specific situation.  A job safety analysis should be conducted on the process to determine if other controls can be put into place, and then sampling needs to be conducted to determine exposure levels.  Voluntary programs arise from conditions that are below exposure limits, but employees still feel they need respiratory protection.  Common situations where a voluntary program is put into place include making N95 […]

Review Disinfection Procedures Regularly

When was the last time you walked through your labs paying close attention to the available disinfectants? And how long has it been since your Institutional Biosafety Committee or safety committee reviewed the disinfection procedures in place?

105 CMR 480, Minimum Requirements for the Management of Medical or Biological Waste (State Sanitary Code Chapter VIII), promulgates requirements for the storage, treatment, disposal, and transportation of medical or biological waste. There are numerous stipulations in the Sanitary Code, including the four disinfection methods approved for rendering medical or biological waste noninfectious. Not only are there specific methods approved for disinfection, but there are validation and recordkeeping requirements established for the approved methods. Many facilities generating biological waste are required to have their Institutional Biosafety Committee review and approve the appropriate disinfection procedures.

Although approved disinfection methods are established in the Sanitary Code, it is the responsibility of the organization to establish policies appropriate for the waste being […]

Risk Group Classification Factors

The BMBL, Biosafety in Microbiological and Biomedical Laboratories, and the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules (NIH Guidelines) establish four risk groups for biological agents.  These four risk groups address the risk to the laboratory worker, the environment, and the community.

Risk Group 1 agents are not associated with disease in healthy adults, Risk Group 2 agents are associated with human disease that is rarely serious and for which preventative or therapeutic interventions are often available, Risk Group 3 agents are associated with serious or lethal human disease for with preventative or therapeutic interventions may be available, and Risk Group 4 agents are likely to cause serious or lethal disease for which preventative or therapeutic interventions are not usually available.  Risk Group 3 agents have high individual risk and low community risk, while Risk Group 4 agents have both high individual risk and high community risk.

The various factors that are […]

What is Considered Work-Related?

OSHA stipulates recording and reporting criteria for work-related injuries and illnesses in 29 CFR 1904.0-1904.11. There are various considerations to take into account when determining if an incident, injury, or illness is considered work-related and therefore needs to be evaluated for recording and reporting criteria.

29 CFR 1904.5 covers determination of work-relatedness for recording and reporting. At the surface, it may seem like it would be fairly straightforward to determine if an injury, accident, or illness is work-related, however this determination can become extremely complicated. OSHA defines the ‘work environment’ and also explains situations where an injury or illness in the work environment is not considered work-related, but there are still grey areas that require thorough investigation to determine work-relatedness. A few of the many factors that can affect work-relatedness are travel status, working from home, and pre-exiting medical conditions. OSHA has published guidance and numerous standard interpretation letters that can be referenced when determining […]

Remember to Monitor Wastewater Discharge Volumes

Ensure your industrial discharge volumes are monitored on a regular basis to verify regulatory compliance.  If 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 to confirm that this permit remains applicable to your facility.

It is possible for the effluent volumes from laboratory operations to be minimal when operations begin and increase significantly over time.  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 when operations commence.  Then 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.  […]

October is Biosafety Month

October is ABSA’s 2018 Biosafety Month! The theme of this year is “Promoting a Culture of Biosafety and Responsibility”, and institutions are encouraged to take the opportunity to promote their biosafety and biosecurity programs.

If you visit ABSA’s Biosafety Month website, there is a flyer that can be customized with your organization’s information and events that will take place during the month. All levels within the organization should be encouraged to participate in promoting a strong biosafety culture. Senior management can actively participate in biosafety events held during the month, and researchers can encourage each other to actively foster the biosafety efforts. Consider hosting interactive biosafety training sessions, or develop fun games to encourage participation. There is time to brainstorm on creative options that will fit the culture of your organization!


Safe + Sound Week is Here

The second annual OSHA Safe + Sound week has arrived!  It is not too late to participate in this fun event.  Take a moment to check out who else is participating and what activities they are holding. 

Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week.  Developing creative events that relay the information in a manner that is entertaining and engaging will encourage participation.  If there are any elements of your EHS program that employees need to be reminded of, take the time to engage employees during the next few days!

It is possible to download a certificate and web badge after your events have been completed.  This is a great way to recognize your participants and organization as a whole!