Mari Ishak Gabra, MS
The Occupational Safety and Health Act of 1970 marked Congress’s creation of the Occupational Safety and Health Administration (OSHA) to ensure the safety of workers by setting and enforcing standards and providing necessary training, resources, and assistance. To ensure their safety, all clinical laboratory workers, and especially clinical lab managers, should have basic knowledge of the regulations set by OSHA that directly affect clinical laboratories.
Laboratories in the US employ more than 500,000 workers, who can be exposed to a myriad of potential hazards in the workplace.1 Finalized in 1990, OSHA regulation for laboratory safety was designed to protect workers from chemical, biological, physical, and other safety hazards. Compliance with OSHA laboratory safety regulations starts with implementing a written Chemical Hygiene Plan (CHP) and a designated officer.2 This article aims to highlight the steps clinical lab managers should take to cover the major OSHA requirements and the resources available to prevent workplace injuries and illness.
STEP ONE: Familiarize yourself with relevant standards and requirements
The first step toward a safe laboratory environment is understanding the various OSHA standards that directly apply to many health care and clinical laboratories. The following are the most important and relevant regulations:
Hazard Communication Standard (29 CFR 1910.1200):3 This standard is based on the simple concept that employers need a written plan to inform their workers of all hazardous chemicals on-site. This is achieved by maintaining an inventory of all chemicals, ensuring all containers are properly labeled, and confirming all safety data sheets (SDSs) are current and accessible.
Bloodborne Pathogens Standard (29 CFR 1910.1030):4 OSHA initiated this standard to protect employees whose jobs put them in direct contact with blood and other infectious materials. The Center for Disease Control and Prevention (CDC) indicates that HIV and hepatitis B and C viruses are the main concern and employers should provide controls to prevent exposure to biological samples.5 This standard also requires a written Exposure Control Plan (ECP). The ECP must document possible routes of exposure to bloodborne pathogens, the implementation of various controls (such as universal precautions, engineering controls, and good work practices), hepatitis B vaccination, and recordkeeping of training and incidents.6
Personal protective equipment (PPE). Although not a standard, PPE is a requirement under the OSHA laboratory safety guidance. Clinical lab managers or safety officers must perform an assessment of their workplace and determine all the required PPE for each task. PPE is the final protective barrier between clinical laboratory workers and the hazard, after implementing engineering controls (such as the use of biosafety cabinets) and work practices (including limiting time of exposure to hazardous material).7
STEP TWO: Recognize hazards in clinical laboratories
In addition to those outlined in step one, there are several other potential safety and health hazards at a clinical laboratory. Here are some examples of these hazards and the resources to assist in compliance with OSHA requirements:
Chemical hazards. Hazardous chemicals, including carcinogens, irritants, and corrosives, can pose a threat to the health of clinical laboratory workers.8 As specified by federal regulation, employers are required to limit the exposure of all workers handling hazardous chemicals at or below permissible exposure limits specified in the standard on air contaminants (see CFR 1910.1000, Table Z). Therefore, employers and clinical lab managers must use the written CHP to identify criteria to reduce employees’ exposure to chemicals used in the laboratory. The written CHP should also include requirements to ensure that chemical fume hoods function properly and that other protective measures are in place such as certification, instructions for proper use, waste management, and routine cleaning. Additionally, employees must be trained to recognize hazardous chemicals, know the inventory of the types of hazardous chemicals in the workplace, and know which measures to use to protect themselves from exposure. They must be provided with information about who to contact in the case of a medical emergency.
Ergonomic hazards. According to OSHA, laboratory work can pose several ergonomic stressors, which include static or awkward postures and repetitive motions.9 Tasks such as examining slides under the microscope, pipetting several samples, or even using the biological safety cabinets can result in injuries or repetitive stress disorder. Thus, employers should provide their workers with general tips to prevent these injuries.10
Quick Tips on Ergonomics
STEP THREE: Survey workplace for additional hazards
A clinical lab manager or safety officer must identify any additional types of hazards and proper controls through a job-hazard analysis or risk-evaluation checklist. This will allow laboratories to identify potential risks associated with all techniques used by their employees and to devise the most suitable way to reduce chances of injury. The OSHA website provides a wealth of resources and templates on how to perform this type of assessment and ways to customize reports for any workplace.11
STEP FOUR: Train your employees
OSHA requires employers to provide updated training to workers exposed to any type of hazard to perform their job in order to prevent illness and injury. Inspectors will often test workers’ knowledge of hazards and safety. Training can be in the form of online modules or in-person workshops. There are also different types of continuing education material available through the OSHA website,12 including booklets, fact sheets, and posters to keep employees up to date on safety information. All employee training documentation should be saved in order to satisfy the first question typically asked by an incident investigator: “Did the employee receive adequate training to do this job?”
STEP FIVE: Recordkeeping, reporting, and posting
Unless the laboratory has 10 or fewer employees, all employers are required to keep record of workplace injuries and illnesses (29 CFR 1904). All incidents, from needlestick and sharps injuries to bloodborne pathogen exposures, should be logged by the laboratory manager or environmental health and safety officer. A new rule by OSHA requires certain employers with 250 workers or more to submit incidents electronically. In addition, all employers are required to report to OSHA within eight to 24 hours all work-related fatalities, hospitalizations, amputations, and losses of an eye. Finally, an OSHA poster or state plan equivalent should be posted in a prominent location in the workplace.
All managers and laboratory workers should recognize that violating any safety laws poses risks to their employers and can lead to serious consequences. Thus, it is important to keep up to date with regulations and standards as required by OSHA, as well as other clinical regulatory institutions. Getting involved in the regulatory process and hiring or designating safety officers are the best ways to ensure compliance.
- “Safety and health topics: laboratories.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/SLTC/laboratories/index.html.
- “OSHA fact sheet: laboratory safety chemical hygiene plan (CHP).” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/Publications/laboratory/ OSHAfactsheet-laboratory-safety-chemical-hygiene-plan.pdf.
- “Hazard communication guidelines for compliance.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/Publications/osha3111.html.
- “Quick reference guide to the bloodborne pathogens standard.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/SLTC/blood-bornepathogens/ bloodborne_quickref.html.
- “CDC - bloodborne infectious diseases - HIV/AIDS, hepatitis B virus, and hepatitis C virus - NIOSH workplace safety and health topic.” Centers for Disease Control and Prevention, Centers for Disease Control and Prevention, www.cdc.gov/niosh/topics/bbp/.
- “Appendix D model exposure control plan.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/OshDoc/Directive_pdf/CPL_2-2_69_APPD.pdf.
- “OSHA fact sheet: personal protective equipment.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/OshDoc/data_General_Facts/ppe-factsheet.pdf.
- “OSHA fact sheet of hazardous chemicals in labs.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/OshDoc/data_General_Facts/hazardouschemicalsinlabs- factsheet.html.
- “Ergonomics.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/SLTC/ ergonomics/identifyprobs.html.
- “Laboratory ergonomics.” Environment, Health and Safety, The University of North Carolina at Chapel Hill, www.ehs.unc. edu/workplace-safety/ergonomics/lab/.
- “Compliance assistance quick start.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/dcsp/compliance_assistance/quickstarts/ health_care/index.html#step3.
- “Training and reference materials library.” Occupational Safety and Health Administration, United States Department of Labor, www.osha.gov/dte/library/materials_library.html.