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Regulatory Compliance

 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 11th, 2021|Categories: Insights|Tags: , , , , |
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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 […]
March 10th, 2021|Categories: Insights|Tags: , , , , |
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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, […]

February 25th, 2021|Categories: Insights|Tags: , , , , , , , |
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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 […]
February 19th, 2021|Categories: Insights|Tags: , , , , , |
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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 […]

February 11th, 2021|Categories: Insights|Tags: , , , , , |
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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 […]

January 21st, 2021|Categories: Insights|Tags: , , , , , , |
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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 […]

January 14th, 2021|Categories: Insights|Tags: , , , , , |
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Safety Doesn’t Break for Parties: IANM V5

With the holidays, there’s a guarantee of rushing around which makes errors more likely to happen in the lab. Many people are typically off on vacation which adds another variable for accidents to happen.

Learn how to prevent accidents this season with this ‘near miss’ from our publication Incidents, Accidents, and Near Misses Volume 5:

It was the annual institute-wide holiday party and everyone in Charlie’s lab was excited to celebrate, relax, and have fun! It was the end of a long week and the weekend before many would be taking time off to go home for the holidays.

Charlie and most of his lab went just as the party was starting, but Ed stayed behind to finish up some of his work.

It wasn’t until Saturday morning that Charlie checked his email and noticed a flurry of messages from Ed the night before.

Ed is a graduate student in Dr. Brown’s lab and was finishing up some of […]

December 31st, 2020|Categories: Insights|Tags: , , , , |
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Have you Conducted Your Annual Fit Testing?

 Have you Conducted Your Annual Fit Testing?

The OSHA Respiratory Protection Standard requires that respirator fit testing be performed initially (before the employee is required to wear a respirator), and it must be repeated at least annually when respirator use is required.

Fit testing must also be conducted whenever respirator design or facial changes occur that could affect the proper fit of the respirator. Examples of conditions that would require additional fit testing include the use of a different size or make of respirator, weight loss, cosmetic surgery, facial scarring, the installation of dentures, or the absence of dentures that are normally worn by the individual.

What is the purpose of fit testing? Fit testing confirms the correct fit of any respirator that forms a tight seal on the user’s face. This ensures that users are receiving the expected level of protection by minimizing contaminant leakage into the facepiece.

When a respirator doesn’t fit properly, a portion […]

December 17th, 2020|Categories: Insights|Tags: , , , , |
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Have You Conducted Your MWRA Wastewater Sampling?

For Category 2 MWRA permit holders, semi-annual wastewater sampling results for the July through December sampling period must be conducted by December 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 permit holder is responsible for repeating the sampling and submitting the […]

December 10th, 2020|Categories: Insights|Tags: , , , , |
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