Regulatory Compliance

Does Your Company’s PPE Policy Address Appropriate Summer Lab Attire?

The warm summer months can be an even more challenging time than normal for enforcing rules related to appropriate lab attire. This is a great time to review your company’s personal protective equipment (PPE) policy and see if it adequately addresses personal lab attire.

Including rules related to appropriate laboratory attire in a formal policy can help significantly with enforcement and compliance. If the PPE policy already includes this, it’s a perfect time to review the policy with all lab employees and others who may enter the lab when work is being conducted.

Appropriate laboratory attire should cover the torso, legs, and feet. Depending on the work being conducted at your company, this generally means that:

  • Full leg coverage is required. Shorts or cropped pants that leave any part of the leg exposed should not be worn. Skirts should not be worn unless they completely cover the leg.
  • Shirts or tops that cover the upper torso […]

June Deadline for MWRA Wastewater Sampling!

For Category 2 MWRA permit holders, semi-annual wastewater sampling for the January through June sampling period must be conducted by June 30th.  Reports, including pH and flow logs, are due by July 31st.

Even though the sampling results are sent directly to the MWRA by the analytical testing laboratory using the MWRA’s electronic reporting system, permit holders are responsible for reviewing the results and notifying the MWRA of any issues of non-compliance.

If the sampling results show that any regulated chemicals are detected above the discharge limits specified in the facility’s permit or the Sewer Use Regulations (360 CMR 10), the MWRA must be notified within 24 hours of becoming aware of the violation. 360 CMR 10.024 specifies the specific daily maximum discharge limitations for regulated pollutants including formaldehyde, cyanide, phenol, specific metals, and listed toxic organics for both the Metropolitan Sewerage Service Area and the Clinton Sewerage Service Area.

If a violation is identified, the […]

The OSHA Lab Standard and the OSHA Hazard Communication Standard: Which Standard Applies in Your Workplace?

It’s not always straightforward to determine if the OSHA Lab Standard or the OSHA Hazard Communication Standard applies at a given facility. Often it’s either one standard or the other, but in some cases, both standards will apply. Making the correct determination is critical as it dictates the type of written safety manual that has to be in place (Hazard Communication Program vs. Chemical Hygiene Plan), the required content of the safety training, and other essential aspects of safety program implementation.

Background on the Standards

The OSHA Hazard Communication Standard (29 CFR 1910.1200), or Hazcom Standard, was published in 1983 to cover chemical use in manufacturing industries. In 1987 it was amended to apply to all industries where employees are exposed to hazardous chemicals. It was updated again in 2012 to align with the third revision of the UN Globally Harmonized System (GHS) of Classification and Labelling of Chemicals. More recently, in February 2021, […]

Risk Groups and Biosafety Levels: Understanding the Differences

It’s often assumed that a biological agent’s risk group (RG) and the biosafety level at which it should be handled are synonymous, when in fact this is not always the case. In addition to an agent’s risk group, there are many other factors to consider when designating a biosafety level for a biological agent.

Risk group describes the relative risk to the individual and the environment by the organism. There are four risk group classifications described in the NIH Guidelines and in the World Health Organization’s Laboratory Biosafety Manual:

  • 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 which preventative or therapeutic interventions may be available
  • Risk Group 4 agents are likely to […]

 Top 10 OSHA Violations from 2020

On February 26, 2021, OSHA announced its preliminary list of the top 10 most frequently cited workplace standards for the fiscal year 2020 (October 1, 2019, through September 30, 2020).

Although the top 10 list included all of the same standards cited for the fiscal year 2019, the ranking within the top 10 list changed for several standards including the Respiratory Protection Standard which moved from the fifth position to the third. The Fall Protection Standard remains the most frequently cited OSHA standard for the 10th consecutive year.

The top 10 most frequently cited standards for the fiscal year 2020 are:

  1. Fall Protection- General Requirements(1926.501)─ There were 5,424 violations including not having adequate fall protection in residential construction, unprotected sides and edges, and lack of fall protection systems for roofing work on low-slope roofs.
  2. Hazard Communication(1910.1200)─ There were 3,199 violations including lack of developing and/or implementing a written Hazard Communication Program, lack of adequate […]

March is Workplace Eye Wellness Month

Prevent Blindness, the nation’s first eye health and vision care nonprofit organization, has declared March as Workplace Eye Wellness Month.

Because one of the many negative effects of the COVID-19 pandemic is the increase in screen time for many remote workers, Prevent Blindness is raising awareness of digital eye strain and providing tips on ways to decrease the effects of increased screen time. Prevent Blindness also recently launched its Take a Screen Time Out awareness campaign.

Symptoms of digital eye strain also referred to as computer vision syndrome, include tired, burning, or itching eyes, sore dry eyes, difficulty focusing, and headaches. To help reduce the effects of increased screen time, Prevent Blindness recommends:

  • Placing computer screens an arms distance (~25 to 26 inches) away from your eyes and a little bit below eye level
  • Using a document holder placed next to the computer screen (it should be close enough so you don’t have to […]

A Mouse and a Needlestick

“A Mouse and a Needlestick” featured in Incidents, Accidents, and Near Misses in Laboratory Research, Volume 3, tells a real-life story about what can happen when safety procedures aren’t followed in animal care facilities. Read on to learn what happens:

I had just started a new job in an Animal Care Facility at an academic research lab in the heart of Kendall Square. I had three years of lab experience. I was confident in my new role and new procedures. I learned the hard way that I was overconfident.

A New Procedure

During my first month of on-the-job training, I learned how to do intraperitoneal (IP) injections into the body cavities of mice. We were working with a blank carrier and with a pretty potent chemical that basically stimulates the blood stem cells to evacuate the bone marrow. We did this to collect bone cells.

I’d done the IP Injection three or four times with no problems. So, […]

OSHA Issues Proposed Rule to Update the Hazard Communication Standard

On February 16, 2021, the Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rule Making (NPRM) to amend the Hazard Communication Standard (HCS). The current HCS was last updated in 2012 to align the standard with the third revision of the United Nations (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The proposed changes are to update the HCS to align it with the seventh revised edition of the GHS.

Highlights of the proposed changes include:

Definitions

  • Updates to three existing definitions (exposure/exposed, hazardous chemical, physical hazard)
  • Addition of eight new definitions (bulk shipment, combustible dust, gas, liquid, solid, immediate outer package, physician or other licensed health-care professional (PLHCP), and released for shipment)

Hazard Classification

  • Clarification that the hazard classification has to consider both normal considerations of use and foreseeable emergencies
  • Additional requirements that the hazard classification must include any hazards associated with a change in the chemical’s physical form or […]

Are You Ready for the March 1st Tier II Reporting Deadline?

Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) describes reporting requirements for facilities that possess chemicals above established reporting thresholds. For those facilities subject to reporting, submission of a Tier II Emergency and Hazardous Chemical Inventory Form to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local Fire Department is required by March 1st of every year for the previous calendar year.

These reporting requirements allow state and local emergency response and planning committees to be aware of the hazardous materials present within their communities and to prepare for emergency responses.

Which facilities have to report?

Facilities storing a hazardous chemical that is an Extremely Hazardous Substances (EHS) in an amount equal to or greater than 500 pounds or above the Threshold Planning Quantity (TPQ), whichever is lower, are required to submit Tier II reports. EHS and TPQs can be found in 40 CFR part 355 Appendix B and the EPA’s […]

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 […]