Preparing for a Health and Safety Compliance Audit
A step-by-step guide for the safety audit process and how to be prepared
Today’s modern research laboratories are complex operations with many health and safety challenges. A phalanx of biological, chemical, and physical hazards is faced each day. Equipment such as autosamplers, autoclaves, gas chromatographs, sonicators, vacuum pumps, etc. present unique potential hazards. During a normal, hectic workday, employee health and safety can sometimes get overlooked—and sometimes consequences are grim.
This article intends to prepare the lab manager for a health and safety audit. The basic Occupational Safety and Health Administration (OSHA) regulations and programs will be covered, addressing recognized hazards in the typical research lab. With these tips, lab leaders can better identify and minimize the most common hazards associated with running a busy research laboratory.
Always provide a safe work environment
The OSHA requirement that employers provide a workplace “free from recognized hazards” is the foremost tenet of worker safety. This is known as the “general duty clause,” Section 5(a)(1) of the OSH Act, which covers all recognizable hazards, especially those for which specific standards may not exist. Examples of the latter include ergonomic issues and exposures to anesthetic gases or experimental drugs, among others.
Many specific OSHA standards apply to research laboratories. The two most notable within 29 CFR are the occupational exposure to hazardous chemicals in laboratories, also known as the OSHA Lab Standard (1910.1450), and hazard communication (1910.1200). Other standards that might apply include respiratory protection (1910.134), electrical and fire safety, and those dealing with certain toxic and dangerous chemicals such as benzene, methylene chloride, etc.
Entrance and pre-audit conference
When first approaching any area that may contain hazards, lab professionals should recognize that the room they are about to enter is different. It is not an office. There are things that set this area apart and have the potential to harm or injure. So, all entrances should have complete and proper signage to alert anyone planning to enter to the hazards within.
Signs should indicate if chemical hazards are present—and if so, what type. Corrosive, toxic, flammable, carcinogenic, and other signs, as appropriate, should be posted on or near the entrance door. Also, be sure to include emergency contact information and names and phone numbers for the principal investigator (PI) and laboratory manager, at a minimum.
Upon entry, most auditors will ask to see the lab’s chemical inventory, chemical hygiene plan (CHP), and standard operation procedures (SOPs). Training records and source(s) of safety data sheets (SDS) may also be requested. After perusing the inventory and SOPs, the auditor, especially if unfamiliar with the lab, might ask for a brief tour and description of the basic lab operations and work areas.
The survey or walk-about
Following the pre-audit conference, the auditor will begin the health and safety survey, or walk-about. Protecting worker health and safety begins with recognizing workplace hazards. Generally, these fall into three main categories: chemical, biological, or physical. Examples of chemical hazards include corrosive chemicals, solvents, cleaning agents and disinfectants, drugs, anesthetic gases, paints, and compressed gases. Potential exposures to chemical hazards can occur during handling, use, transport, or storage.
Biological hazards are usually limited to specialty labs and include potential exposures to allergens, zoonotic diseases (animal diseases transmissible to humans), and experimental agents such as viral vectors. Allergens, ubiquitous in animal research facilities, are one of the most common, yet frequently overlooked, health hazards.
Physical hazards are always present in laboratories and research facilities. The most obvious are slips and falls from working in wet locations and the ergonomic hazards of lifting, pushing, pulling, and repetitive tasks. Other physical hazards that are often unnoticed include electrical, mechanical, acoustic, or thermal hazards.
Focusing on the most common hazards
The number one hazard in labs—chemical misuse or mishandling—provides the potential for significant harm or injury. Auditors will usually zero in on areas of chemical use and storage. To avoid problems, be sure to have and implement a robust chemical control and handling program.
The OSHA standard that helps mitigate these potential problems is the Hazard Communication Standard, which deals with employers’ requirements to inform and train employees on the use of chemicals. In addition, the OSHA Lab Standard, 29CFR1910.1450, requires laboratories to identify hazards, determine employee exposures, and develop a CHP. The “lab standard” mandates written SOPs addressing the particular hazards and precautions required for safe use. Both standards require maintaining SDS and providing employee training.
Number two on most auditors’ lists would cover physical hazards. The inherent, significant physical hazards present include electrical safety hazards, ergonomic hazards associated with manual material handling and equipment use, handling sharps, and basic housekeeping issues.
Check for proper usage of extension cords and an easily accessible and well-labeled circuit breaker panel, for starters. Equip all electrical power outlets in wet locations (outlets within six feet of a sink, faucet, or other water source) with ground fault circuit interrupters, or GFCIs, to prevent accidental electrocutions. Do not substitute flexible extension cords for permanent wiring. Ensure all cord insulation is in good condition without cracks, breaks, cuts, or tears. Take care to not run extension cords through doors or windows, where they can become pinched or cut. Use only grounded equipment and tools with grounding pins present, and always be aware of potential tripping hazards when using them.
Review all laboratory operations that necessitate workers performing sustained or repetitive motions. Conduct an ergonomic work survey, and ensure a neutral, balanced posture for these tasks.
Use only puncture-proof and leak-proof sharps containers that are clearly labeled. Train employees never to remove the covers or attempt to transfer the contents. Make sure they get replaced when three-fourths full to prevent overfilling.
Finally, do not overlook general housekeeping. Slips, trips, and falls are very common, yet easily avoided with safe and organized storage areas. Store materials in tiers stacked, blocked, interlocked, and limited in height so that they are stable and secure against falling or collapse.
Specialty biological labs entail hazards with infectious microbes, recombinant organisms, and viral vectors. Much of the work with recombinant DNA, acute toxins, and select agents is now regulated by federal agencies such as the US Department of Agriculture, the Department of Homeland Security, and the Department of Health and Human Services, including the National Institutes of Health. If your facility is conducting research in these areas, you should have an institutional biosafety committee to keep everything in order and running smoothly.
The most prevalent biological hazard, in terms of frequency of occurrence, is exposure to allergens associated with the use and care of laboratory animals. Health surveys of people working with laboratory animals show that up to 56 percent are affected by animal-related allergies. Health and safety issues should address containment, the ability for replication, and potential biological effect.
Post-audit conference
The health and safety audit should usually end with a post-audit conference. The auditor reviews all issues with the PI or manager and discusses appropriate corrective actions and a timeline for completion. A written summary is transmitted shortly after the visit and should include the agreed upon corrections and completion dates. A follow-up visit should be performed to ensure corrective actions are finished.
Research laboratories present many health and safety challenges. However, with proper guidance, a trained eye, and practice in conducting in-house audits, laboratory leaders can find and correct many common mistakes and prevent illness or injury.