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Commitment to Lab Safety

Employer/employee obligations, controls and key organizations are explored

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Vol. 23 • Issue 6 • Page 12

Cover Story

The medical laboratory can be a very hazardous place. Specimens may harbor pathogenic and contagious organisms; laboratorians are routinely exposed to bio-hazardous material, potentially dangerous chemicals and radioactive matter. There are also environmental concerns. The risk for exposure is real and the effects can be both immediate and long term.

It is the obligation of each laboratory to ensure that the workplace is as safe as possible. Employees should be educated early in their employment cycle on how to avoid, mitigate, identify and react to risks. It is the employee's responsibility to adhere to the employer's safety protocol so as not to put herself, her colleagues or her employer at risk.

Key Organizations

Several entities develop and provide safety guidelines for the clinical laboratory. They include College of American Pathologists (CAP), The Joint Commission, Clinical and Laboratory Standards Institute (CLSI), Occupational Safety and Health Administration (OSHA) and the State.

CAP and Joint Commission are accreditation agencies that grade organizations against specific standards that must be met if the organizations want to receive the proverbial Good Housekeeping Seal of approval.

CLSI uses experts in the field to develop consensus guidelines that are recommended best practices. CLSI has several guidelines that address laboratory safety; one of the most comprehensive is document GP17-A3 - Clinical Laboratory Safety; Approved Guideline, Third Edition, written for laboratorians who are responsible for developing and implementing a safety program. Aspects of a safety program addressed in this guideline include maintenance and inspection, personal safety, and warning signs and labels. The guideline also addresses fire prevention, electrical and radiation safety, and other potential laboratory hazards.

OSHA, as a federal government agency, in addition to the state carries the weight of law and may impose sanctions or fines if mandated protocols are not followed. Roughly half the states and U.S. territories follow OSHA standards strictly. Others (like Hawaii, Maryland, Oregon and Virginia) have an OSHA-approved state plan of their own. When there are differences between state and federal regulations the employer is expected to adhere to both-or the more stringent. While these various responsible agencies have different focuses, there is significant overlap in what they require.

Hierarchy of Controls

Safety experts use a system called the hierarchy of controls that prioritizes intervention strategies based on the premise that the best way to control a hazard is to systematically remove it from the workplace, rather than relying on workers to reduce their exposure. The types of measures that may be used to protect laboratory workers, prioritized from the most effective to least effective, are:

• engineering controls

• administrative controls

• work practices

• personal protective equipment (PPE)

Most laboratories will use a combination of strategies based on their own workplace and the specific safety hazards they face.

One of the major requirement of OSHA's Laboratory Standard is that each laboratory develop a written , customized Chemical Hygiene Plan (CHP) which addresses the policies, Standard Operating Procedures, etc. that ensure that employees are protected from harm due to chemicals.

The CHP details how to store and handle chemicals. Each chemical has traditionally had a Material Safety Data Sheet (MSDS) that must be accessible to employees in case of a chemical exposure. OSHA has mandated that by June 2015 MSDSs should be replaced by Safety Data Sheets (SDS), which will all have a standardized 16-section format. Chemicals must also have newly designed primary (on container) hazard communication labels with pictograms and signal words. These will be more intuitive than current labels.

Safety Concerns

Two safety concerns, often given short shrift, are ergonomics and noise. Ergonomics come into play whenever the laboratorian interacts in some way with his environment- sitting, standing, leaning, walking, lifting or reaching. Ergonomics should be assessed periodically and measures taken to reduce stressors. Employee input is always more significant and realistic than third party subjective assessment.

Noise is not just uncomfortable but can be a safety issue if it obscures instrument signals, alarms and telephone ringing. Productivity, comfort and safety are also dependent on colleagues being able to hear each other clearly. Therefore, noise should be assessed like any other hazard and should be addressed in any safety plan.

What about laboratory-specific hazards and those that are not specifically mentioned by any relevant agency? Section 5(a)(1) of the Occupational Safety and Health Act of 1970, the General Duty Clause, requires that each employer "shall furnish to each employee employment and a place of employment which are free from ­recognized hazards that are causing or likely to cause death or serious physical harm to his employees."

Therefore, even if a standard has not been promulgated that deals with a specific hazard or hazardous operation, protection of workers from all hazards or hazardous operations may be enforceable under law and breaches may be cited by even regulatory agencies.

Obligations

Laboratory safety is everyone's responsibility. The employer has certain obligations:

• Train each employee early in the employment process on how to identify and mitigate risk, as well as how to identify and react to injury.

• Retrain individuals periodically to ensure current competency. Drills should be conducted, and while some drills may be "tabletop" scenarios, the majority should be simulated incidents requiring actual realistic response. Drills must be conducted on all shifts, with all staff participating.

• Develop a Chemical Hygiene Plan that's accessible to all employees on all shifts.

• Provide resources like personal protective equipment (PPE), safety showers, and eyewashes.

• Make use of visible, recognizable aids when possible (e.g., colored signs and Quick Cards).

• Reassess hazards on an ongoing basis and address as necessary.

Each employee should:

• Know hazards that exist in the workplace.

• Protect himself so as to reduce the risk of harm to himself and his colleagues.

• Recognize signs of exposure.

• Know what to do if he identifies a potential risk or has been exposed. Staff should know what immediate actions to take and how, when and where to report breaches.

• Know how to access resources such as CHP, policies and procedures, SDS, PPE, first aid, etc.

Safety guidelines are best seen not as traffic laws that must be obeyed at the risk of attracting some punishment or retribution, but as routine adoption of best practices (by both employer and employee) that reap huge dividends in the end. Everyone benefits from a safe workplace.

Glen McDaniel is a healthcare consultant, clinical lab scientist, speaker and freelance writer based in Atlanta, GA.


Additional Resources

CLSI Guidelines:

• GP-05-A3- Clinical Waste Management

• GP-21-A3- Training and Competency Assessment

• M-29-A3 Protection of Laboratory Workers from Occupational Acquired Infections

OSHA

• OSHA Laboratory Safety Guidance: available at https://www.osha.gov/Publications/laboratory/OSHA3404l aboratory-safety-guidance.pdf


 

This is an interesting article to read. I think one of the overlooked aspect of lab safety is the obligation to train staff well. We go through some rote training and drills, but we don't very often review changes to see any new risks, whether ergonomic or otherwise.

It made for interesting reading, a good refresher and some things I hadn't thought about. I will make it required reading for staff. Thank you.

Rachel TownsendJune 06, 2014
St Petersburg, FL




     

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