Knock! Knock!
The how, when and what for a meaningful lab safety audit.
We all know why we should conduct periodic laboratory safety audits or inspections. But do we give much thought to how they should be done? When is the best time? What we should be looking for?
This month’s column will answer all these questions and guide you through a meaningful laboratory safety survey. Our intent is to stimulate you into setting up and implementing a successful program.
The typical research facility contains a variety of hazards. Most facilities will have a mix of research laboratories, instrument rooms, chemical storage areas, waste-handling areas and busy receiving/loading docks. The OSHA Laboratory Standard1 is an excellent resource and the starting point for any lab using hazardous chemicals.
Appendix A of the standard recommends performing inspections at least semiannually and quarterly for labs with high personnel turnover. The focus of this column will be on conducting safety audits in the laboratories, but the steps and the process can be applied to all areas of the facility.
How should the lab safety audit be conducted?
This apparently innocent question may cause you the most agony. A quick Google search will produce scores of audit instructions and checklists. But should you go with self-audits and let the lab manager complete the checklist or should you try something different?
Personally, we think there is no substitute for face-to-face interviews and a physical walk-through of each laboratory. The crucial thing here is that the auditor or surveyor must be trained and knowledgeable about the type of research being performed in the laboratory undergoing the safety audit. Checklists can help guide the process, but you need to know what you are looking for and what questions to ask if something does not appear right.
Lab safety auditors are basically “in-house inspectors” who must be able to look for and spot the same health and safety issues that would be identified by the regulating agencies if they visited the lab. Depending on the research focus of the lab, those agencies could include OSHA, EPA, USDA, CDC, DEA and NIH, to name a few. Therefore, a complex lab may require more than one visit and/or auditor, as it is rare that one person is well versed in all these different areas.
When should the audit be done?
This question boils down to— should the safety audit be scheduled with the lab manager or should the auditors show up unannounced? We prefer the latter, as this can provide insights into true lab operations. However, there are drawbacks to this approach. If the lab is very busy, you might not be able to gain the full attention of the principal investigator (PI) or lab manager, and all areas might not be accessible because of ongoing experiments. You need to be flexible, and that means a mix of scheduled audits and unannounced surveys might be the best option.
What do we look for?
Now we get to the heart of this column and the question everyone wants answered—what are we looking for during a lab safety audit? The simple answer, of course, is—everything! The reality is that we are performing a walk-through inspection and trying to spot obvious safety hazards.
We also are gaining insight into the day-to-day operations of the lab by interviewing the PI or lab manager and observing overall conditions in the lab. A final goal of the audit is to ensure that regulatory requirements are being met and the lab is in compliance with all applicable rules. So let’s get started on our virtual lab safety audit.
The virtual lab safety tour
Our virtual inspection will visit a general chemical research lab, although brief mention of other specialty labs is also given. Obviously, special research labs such as those dealing with radiation, select agents or biosafety level 3 and above must receive a focused audit in addition to what is presented here.
Let’s begin by approaching the main entrance. We should know that we are about to enter an area with special hazards. Lab entrances should have appropriate signage to alert those preparing to enter about the hazards that are present. One excellent method is posting a notice board that includes all hazards present and, most important, emergency contact information. Be sure to check this again when exiting to note whether all hazards are represented and that any new ones have been added.
Upon entry, we suggest that you seek out the lab manager or PI and identify yourself and the purpose of the visit. We recommend opening with the paperwork, as this gives you an opportunity to begin the interview while becoming familiar with the focus of the lab. Start by asking for the chemical hygiene plan, the chemical inventory, the MSDS (material safety data sheets) and the lab SOPs (standard operating procedures). For labs working with select agents or BSL3 materials, make sure to review their registrations.
When you have completed the records review, it is time to commence the walk-through. As mentioned above, copious checklists are available on the Web; the University of Florida has a good example.2 Our recommendation is to use one. There are just too many things to remember to do justice with a blank notebook.
We also recommend that you tailor your checklist to cover the majority of your labs. But do not be shy about expanding beyond the checklist. If something looks wrong, it probably is. Additional lists can be included for those “special” labs, e.g., lasers, radiation, rDNA.
Technologically advanced reviewers can use electronic lists on touchpads, netbooks or notebook computers that record data directly into a database. However you choose to do it, we suggest that you take a few minutes before the audit to read over the list and bring your focus to all the different areas involved:
• General lab signage and safety equipment such as hoods, eyewash stations and safety showers
• Personal protective equipment that is appropriate for the tasks: lab coats, aprons, gloves, eye protection, etc.
• Overall lab housekeeping and organization
• Chemical safety and proper storage
• Electrical safety (this is a big one)
• Basic fire safety (another major category)
• Lab waste disposal
Are you getting the picture? A lab safety audit is a serious undertaking, and preparation is paramount to success and useful effort.
If there is a golden rule for lab safety audits it is this: Do not rush. More than likely, you are only going to do this once per year, per lab. So take your time and look carefully at each counter, each shelf and each cabinet. Do not be afraid to ask lab personnel if you are not sure about equipment setup, function or potential hazards. It will add to your knowledge base for the next one.
Discuss all discrepancies and needed corrections with the PI or lab manager during a brief exit interview. That way, any questions can be addressed immediately. Finally, do not forget to follow up with a written report or you could find out the hard way that if it is not documented, it did not happen.
One last suggestion is to include a certain time or date to complete the corrections. This will encourage quick action.
Keep safety first!
References
1. http://www.osha.gov/pls/oshaweb/owadisp.show_ document?p_table=standards&p_id=10106 – Occupational Exposure to Hazardous Chemicals in Laboratories, 29CFR 1910.1450. U.S. Department of Labor, Occupational Safety and Health Administration, Washington, D.C.
2. http://www.ehs.ufl.edu/Lab/checklst.htm – Lab Safety Checklist, University of Florida, Environmental Health and Safety.