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Preparing for an Effective Lab Safety Inspection.
The typical research facility contains a multitude 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 focus of this column will be on conducting safety audits in research laboratories, but the steps and the process can be applied to all the different areas of the facility. This Safety Guy’s column will step you through conducting a meaningful laboratory safety survey. Our intent is to stimulate you to set up and implement a successful in-house program.
A great starting point for any lab using hazardous chemicals is the OSHA Laboratory Standard,1 an excellent resource and the current regulation for private-sector facilities. Appendix A of the standard recommends performing inspections at least semiannually or quarterly for labs with high personnel turnover.
Personally, we feel there is no substitute for face-to-face interviews and a physical walkthrough of each laboratory. The crucial thing here is that the inspector or auditor must have specific training and/or experience. He or she must possess specialized knowledge about the type of research performed in the laboratory undergoing the safety inspection. 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. You need to look for and spot the same health and safety issues that the regulating agencies would cite if they visited the lab. The different agencies potentially involved could include OSHA, EPA, USDA, CDC, DEA, and NIH, depending on the research focus of the lab.
Therefore, a complex lab may require more than one visit and/or inspector.
We prefer unannounced safety inspections, as this methodology can provide insights into true day-to-day lab operations. However, there are drawbacks to this approach. If the lab is very busy, the principal investigator (PI) or lab manager might not be available. Or some areas might not be accessible due to ongoing experiments. Flexibility is needed, and a mix of scheduled visits and unannounced inspections is the best option.
In reality, a lab safety survey involves performing a walk-through inspection and trying to spot obvious safety hazards while observing overall conditions in the lab. One goal of the inspection is to ensure that regulatory requirements are met and the lab is in compliance with all applicable rules.
Obviously, special research labs such as those dealing with radiation, select agents, or biosafety level 3 and above must receive focused inspections. These specialty labs contain more serious potential safety and health issues and require a closer look as well as experienced and knowledgeable inspectors.
We suggest you start the inspection with a records review, or as we call it, the paper trail. Seek out the lab manager or PI and identify yourself and the purpose of the visit. Opening with the paperwork gives you an opportunity to begin the interview while becoming familiar with the focus of the lab. We usually request the chemical hygiene plan, chemical inventory with safety data sheets (aka MSDS), and lab SOPs (standard operating procedures).
Prior to entering the lab, make note of any signs, hazard indicators, and warnings. Lab entrances should have appropriate signage to alert those preparing to enter about the hazards present. Most important, emergency contact information for after-hours incidents should be listed. Double-check this again when exiting to note if all hazards are represented and that any newer ones have been added.
After the records review, it is time to begin the walkthrough. A quick Google search will produce myriad checklists available on the Web; the University of
Florida has a good example.2 We recommend using one. There are just too many things to cover. You will want to tailor your checklist to cover the majority of your labs. However, leave plenty of space to expand, as labs are dynamic and change from year to year, especially in an academic setting. For the technologically astute, you may want to use electronic lists on touchpads, net books, or notebook computers that record data directly to a database. However you choose to do it, we suggest that you take some time before the audit to read over your checklist and the previous year’s findings to focus on all the different areas involved, such as:
• General lab signage and safety equipment such as hoods, eyewash stations, and safety showers
• Personal protective equipment that is appropriate for the task: 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
A lab safety audit is a serious undertaking and preparation beforehand is paramount to success and ensuring your findings are ultimately useful. If there is a golden rule for lab safety audits it is “do not rush.” 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 or function, or any potential hazards. It will add to your knowledge base for the next inspection. 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 in your follow-up report. This will encourage quick action and help all parties involved make safety a priority.
References
1. Occupational Exposure to Hazardous Chemicals in
Laboratories, 29CFR 1910.1450. U.S. Department
of Labor, Occupational Safety and Health
Administration, Washington, DC. March 2012.
http://www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=standards&p_id=10106
2. Laboratory Safety, University of Florida, Environmental
Health and Safety. July 2012. http://www.ehs.ufl.edu/
Lab/checklst.htm