OSHA

OSHA Violations and the Bloodborne Pathogens Standard

Did you know that the most frequent cause of OSHA violations related to the Bloodborne Pathogens Standard is outdated, or otherwise non-compliant, Exposure Control Plans?

It is generally known in the biotech community that Exposure Control Plans are required to be in place for any facility working with blood or other potentially infectious material (OPIM). What is often overlooked is that there is a specific regulatory requirement to update the Plan.

The Bloodborne Pathogens Standard (in section 1910.1030(c)(1)(iv) ) specifies that the Exposure Control Plan must be reviewed and updated at least annually and whenever necessary to include new or modified tasks and procedures which affect occupational exposure and to address new or revised employee positions with occupational exposure.

The review and update of the Exposure Control Plan must also reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens and document annually consideration and implementation of appropriate commercially available and effective safer medical […]

Remember to Post OSHA Form 300A!

OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, is used to summarize the recordable injuries and illnesses for the previous year and includes the number of days work was lost or restricted, and the types of injuries and illnesses that occurred.

Information about the company, including the average number of employees and total hours worked by all employees, must also be recorded.

Form 300A must be posted from February 1 through April 30 each year.  If no recordable incidents or illnesses occurred during the previous year, the form must still be completed and posted reflecting zero recordable cases. The information in Form 300A is based on information recorded in OSHA Form 300, Log of Work-Related Injuries and Illnesses. However, certain employers are exempt from these reporting requirements.

Employers with 10 or fewer employees are not required to prepare Form 300 or Form 300A. In addition, only industries within certain North American Industrial Classification (NAICS) codes are […]

Have You Conducted Refresher Safety Training in 2020?

It’s not too late to conduct your annual refresher safety training! With all the COVID 19-related changes that everyone has had to make in the workplace this year, it’s easy to see how this requirement could slip through the cracks.

In light of the pandemic, OSHA is making some allowances for lapses in annual training requirements such as for companies that were required to close for a period of time.

That said, OSHA is requiring that companies demonstrate that they have made a good faith effort to comply with annual training requirements including the use of virtual training options and other means of remote communication. The use of virtual training has been a great option for many companies and has even proven to make annual refresher training easier to schedule!

Which OSHA standards specifically require refresher training?

  • The OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) requires that annual training be provided within one year (i.e., 12 months) […]

The 6th Edition of the BMBL Has Been Published!

In a November 17th, 2020 Lab Advisory, the CDC announced the release of the 6th Edition of Biosafety in Microbiological and Biomedical Laboratories (BMBL)! The BMBL has become the foundation of biosafety practice since it was first published in 1984. Historically, the information in this publication has been advisory in nature although some legislation and regulations, in particular local recombinant DNA ordinances, have made compliance with the guidance provided mandatory. The previous version of the BMBL (5th Edition) was published in December 2009.

So what’s different about the 6th Edition? The updated BMBL is more detailed in many sections and has increased in length by ~160 pages! For example, the section describing Standard Microbiological Practices (Section IV) for BL1 and BL2 labs now includes a detailed description of content requirements for a written Biosafety Manual.

In addition, there is a new requirement that long hair be restrained so that it cannot contact hands, specimens, containers, or […]

The Bloodborne Pathogens Standard and the Needlestick Safety & Prevention Act: Not Just for OSHA Compliance

Often companies seek to check off all of the regulatory boxes so non-compliance doesn’t interfere with their work and timelines. While this may be reasonable, regulations can be general and do not always achieve safety standards that appropriately address workplace hazards.

The OSHA Bloodborne Pathogens Standard went into effect in 1991 and was updated in 2001 to incorporate the requirements of The Needlestick Safety and Prevention Act.

This Standard is an example of a sweeping and effective regulation that has significantly reduced the risk of occupational transmission of bloodborne viruses.

In this post, we’re going to focus on the Needlestick Safety and Prevention Act and the changes that have been made to reduce sharps injuries. The Act itself is only four pages and lays out the problem (occupational exposure to contaminated sharps), the empirical evidence for the need to resolve it, and specifies the requirements related to sharps with engineered sharps injury protections that were added to […]

Coronavirus Regulatory Enforcement- Are You Ready?

In an October 23rd news release, OSHA announced that since the start of the Coronavirus pandemic through October 15th, they have cited 112 establishments for violations related to Coronavirus, resulting in proposed penalties totaling $1,603,544. Approximately half of these violations occurred in the month of October!

Coronavirus-related violations cited by OSHA have included failures to:

  • Comply with the OSHA Respiratory Protection Standard including not implementing a written program, and not providing medical evaluation, fit testing, and training
  • Record injuries or illnesses on OSHA recordkeeping forms
  • Report an injury, illness, or fatality
  • Comply with the General Duty Clause which states that each employer shall furnish to each of his employees, employment, and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

Of the 112 establishments with violations, five were located in Massachusetts. These included four nursing homes […]

Is Your Facility Prepared for an Emergency?

September is National Preparedness Month (NPM)! NPM is recognized each September to promote family and community disaster planning now and throughout the year.

The 2020 theme is Disasters Don’t Wait- Make your Plan Today.

The same principles promoted for NPM apply to prepare for workplace emergencies. Specifically, starting with an up-to-date Emergency Action Plan!

Emergency Action Plans and Contingency Plans are required by various regulations, including  OSHA 29 CFR 1910.38 and 157, Massachusetts Comprehensive Fire Safety Code 527 CMR 1.0, and the Massachusetts Department of Environmental Protection 310 CMR 30.000.

It’s important to know if your facility is required to have an Emergency Action Plan or a Contingency Plan because regulators will look for the appropriate implementation during inspections.

All employees must have access to the written Plan and be trained on it. It’s critical that everyone be well-versed in proper response procedures should an incident occur! It’s good practice to hold drills for the […]

OSHA’s Annual National Safety Stand-Down to Prevent Falls

OSHA’s 7th annual National Safety Stand-Down to Prevent Falls will be taking place during the week of September 14th – 18th, 2020This is a voluntary event meant to raise fall hazard awareness across the country to stop fall fatalities and injuries.
 
OSHA encourages all employers where fall hazards might exist to take part, despite the fact its geared toward the construction industry.
 
OSHA is partnering with key groups to assist with this effort. These include the National Institute for Occupational Safety and Health (NIOSH), the American Society of Safety Professionals (ASSP), and the […]

August 27th, 2020|Categories: Insights|Tags: , |

OSHA Safe + Sound Week: Never Underestimate the Importance of Fall Protection

To honor OSHA’s 2020 Safe+Sound Week we are sharing another story from our recently released Incidents, Accidents, and Near Misses in Lab Research, Vol. 5.  

Violations related to fall protection have been #1 on OSHA’s top 10 most cited violations list for 9 consecutive years.

An excerpt from Incidents, Accidents, and Near Misses in Lab Research, Vol. 5

Never Underestimate the Importance of Fall Protection

It was the day before Thanksgiving. I was looking forward to having a few days off to hang out with my family, relax, and eat delicious food. I was doing some last-minute measurements for a new pH pit at work. The pit is essentially a tank that holds wastewater while the pH is adjusted to a neutral level, before it can be drained back into the municipal water system. I was measuring the old pit, so that we would know what kind of capacity we would need for the new one. It was a simple task that would take only a […]

OSHA Safe + Sound Week

The fourth annual OSHA Safe + Sound Week is being held August 10-16, 2020. 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! During the COVID-19 pandemic, occupational safety and health programs have never been more important, and this is a perfect time to reinforce yours.

It’s also a great 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. […]