OSHA

Chemical Sensitivities in Lab Employees

Safety Partners’ is about to release our 5th version of Incidents, Accidents, and Near Misses in Laboratory Research which includes a real-life story of a lab employee who developed a chemical sensitivity to a commonly used lab chemical. She experienced allergy-like symptoms when exposed at exposures below established Occupational Exposure Limits (OELs) for this chemical, while her colleagues exposed to the same levels exhibited no adverse effects. It should be noted however, that OELs, including OSHA PELs and ACGIH TLVs, have been established for the protection of the average healthy worker and may not be protective of more sensitive populations including those with chemical sensitivities.

What is Chemical Sensitivity?

Chemical sensitivity is a physiological response that occurs in an individual following exposure to a chemical at levels that would not affect the vast majority of people.  Often chemical sensitivity can present as allergic type reactions including scratchy throat, watery eyes, and runny nose. In other instances, headache, rashes, […]

New OSHA Guidance on Returning to Work

On June 18th, OSHA issued Guidance on Returning to Work to assist employers reopening non-essential businesses and their employees returning to work during the Coronavirus pandemic. The guidance supplements OSHA’s previously published Guidance on Preparing Workplaces for COVID-19. The guidelines are consistent with the requirements outlined in the Massachusetts Mandatory Safety Standards for Workplaces and recommend that employers continue to focus on strategies for basic hygiene, social distancing, identification and isolation of sick employees, workplace controls and flexibilities, and employee training.

OSHA’s Guidance on Returning to Work includes a section on Employer Frequently Asked Questions. Some of the questions asked have been coming up at our clients, so I thought it would be helpful to share a few. The responses below are summaries, and the OSHA guidance document should be referred to for the full responses.

Can employers conduct work site SARS‑CoV-2 testing?

Yes. Employers may consider implementing strategies to reduce risks to the safety and […]

Massachusetts Safety Standards for Office Spaces During the COVID-19 Reopening Period

On May 18, Governor Baker announced the State’s Plan to safely reopen the Massachusetts economy, while minimizing the health impacts of COVID-19. The guidance includes mandatory sector-specific standards and recommended best practices for sectors that are eligible to open in Phase 1. In my May 20th blog, I discussed the Safety Standards for Laboratories. Since that blog was posted, the State has clarified that offices associated with laboratories must comply with The Safety Standards for Office Spaces. Like the Safety Standards for Laboratories, these standards are organized around four categories: social distancing, hygiene protocols, cleaning and disinfecting, and staffing and operations.

Social Distancing

Social distancing requirements for offices include limiting occupancy within the office space to no more than 25% of the maximum occupancy limit specified in the certificate of occupancy, or the typical occupancy as of March 1, 2020. Any business or other organization that has been operating as a “COVID-19 Essential […]

Are Workplace-Related COVID-19 Cases Recordable and Reportable?

On April 10, 2020, OSHA published interim guidance regarding the enforcement of employers’ obligation to record and report employees’ COVID-19 cases.

The OSHA guidance recognizes that determining whether an employee contracted COVID-19 at work will often be difficult, and because of this, relaxed COVID-19-related recordkeeping obligations for many employers.

However, for employers of workers in the healthcare industry, emergency response organizations (e.g., emergency medical, firefighting, law enforcement services), and correctional institutions, COVID-19 is a recordable illness.

These employers are responsible for recording cases of COVID-19, if:

  • The case is a confirmed case of COVID-19, as defined by theCDC
  • The case is work-related as defined by the OSHA standard on recording and reporting occupational injuries and illnesses 29 CFR 1904.5 and
  • The case involves one or more of the general recording criteria: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.

For other employers, including […]

SARS-CoV-2: Determining Your Employees’ Exposure Risk Level

OSHA recently issued a guidance document on Preparing Workplaces for COVID-19 that focuses on determining employees’ risk of occupational exposure to SARS-CoV-2 in order to identify the appropriate control measures that can be put in place to protect employees from exposure.

OSHA has divided job tasks into four risk exposure levels:

Very high exposure risk

Jobs with high potential for exposure to known or suspected sources of COVID-19 during specific medical, postmortem, or laboratory procedures. Workers in this category include healthcare workers (e.g., doctors, nurses, EMTs) performing aerosol generating procedures (e.g., intubation, cough induction procedures, invasive specimen collection); healthcare or laboratory personnel collecting or handling specimens from known or suspected COVID-19 patients; and morgue workers performing autopsies on people known or suspected of having COVID-19.

 High exposure risk

Jobs with high potential for exposure to known or suspected sources of COVID-19. Workers in this category include healthcare and support staff (e.g., doctors, nurses, and other hospital staff who […]

Risk Assessments: The Key to Working Safely with COVID-19 Positive Samples

We have been getting many questions from clients on appropriate precautions to take when working with COVID-19 positive samples in the lab. The World Organization (WHO), the Centers for Disease Control and Prevention (CDC), the Public Health Agency of Canada (PHAC), and the American Biological Safety Association (ABSA)  have all published extremely informative guidance on this topic:

WHO: Coronavirus Disease (COVID-19) Technical Guidance: Laboratory Testing for 2019-nCoV in Humans

CDC: Information for Laboratories

PHAC: SARS-CoV-2 (Severe acute respiratory syndrome-related coronavirus 2)

ABSA: COVID-19 Toolbox

The information is consistent among these agencies and all stress the importance of starting with a risk assessment. This includes a site and protocol-specific assessment of the procedures to be performed, the identification of the hazards of the processes and procedures, an evaluation of the laboratory facility and equipment, as well as an assessment of available resources including personal protective equipment (PPE).

Coronaviruses generally infect the upper or lower respiratory tract, therefore work with respiratory specimens poses the highest risk. […]

Hazard and Risk Analysis

The terms risk and hazard are used often in the safety world, many times interchangeably. They have very different meanings, however, and when using these terms, care should be taken to use them appropriately. When evaluating a process or procedure, assigning these terms appropriately can help simplify the safety assessment process.

What is a hazard?

A hazard refers to a potential source of harm. Examples can include chemical, biological, radiological, and physical hazards. Toxic chemicals, infectious biologics, and moving mechanical parts are all different types of hazards. The hazard level of a particular item or condition is static, meaning it does not vary. However, it can be evaluated relative to other hazards. Simply put, a hazard is a material or condition that can have an adverse effect on a person’s health or physical property.

What is risk?

Risk is the potential for interaction with a hazard. Generally speaking, risk is referenced in relative […]

Biennial Reports Are Due March 1, 2020!

 

If your facility is registered with the MA DEP as a Large Quantity Generator (LQG) of hazardous waste, don’t forget that 2020 is a year when biennial reports must be filed.  Biennial reports are due by March 1st of even numbered years for any facility that exceeded the LQG threshold during the preceding odd numbered year, even if your facility is no longer registered as an LQG.  Treatment, Storage, and Disposal Facilities (TSDFs) are also required to report every two years.

Biennial reports provide the DEP with information on the quantity and nature of the hazardous waste that was generated in the previous year and whether the waste was sent for recycling, treatment, storage, or disposal. As of 2018, biennial reports need to be filed electronically using the RCRAInfo Industry Application. The electronic submission includes the following:

  • RCRA Subtitle C Site Identification Form
  • Waste Generation and Management (GM) Form
  • Waste Received From Off-Site (WR) Form, and […]

OSHA Safe + Sound Week- Do you want to energize your safety program?

The third annual OSHA Safe + Sound Week is being held August 12-18, 2019. This national event is intended to promote the value of workplace health and safety programs. Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week. It has been a huge success at Safety Partners’ clients who have participated in previous years!

Why participate?

Participating in the program is a great way to recognize your safety successes and show your commitment to safety! It’s also a perfect opportunity to raise awareness of your safety program in a fun and engaging way. Participating in Safe + Sound Week can help get your program started, energize an existing one, and provide a chance to recognize your safety successes.

Remember- safe workplaces are sound businesses. Successful safety and health programs can proactively identify and manage workplace hazards before they cause injury or illness, improving sustainability and […]

August 7th, 2019|Categories: Events|Tags: |

How to Protect Your Company From OSHA HazCom Violations

Did you know that violations related to the OSHA Hazard Communication standard ranked #2 in the OSHA top 10 list for most frequently cited violations in 2018? Common citations included not having a written program or safety data sheets (SDS) for all chemicals, lack of employee training, and deficiencies related to secondary container labels.

What can you do to protect your company from HazCom violations? Employers are responsible for ensuring that the labels and SDSs are readily available to all employees.  They are also responsible for training employees on how to properly recognize the hazards associated with chemicals and how to properly handle the chemicals based on the hazards conveyed.  For laboratories that use chemicals this specifically means that employers must ensure that:

  • Labels on incoming containers of hazardous chemicals are not removed or defaced. Incoming container labels must include the identity of the hazardous chemical(s), appropriate pictograms and signal word, and hazard and precautionary statements.
  • Labels […]