How to Don and Doff a Lab Coat

OSHA requires that all lab employees be able to demonstrate how to don and doff a lab coat. For written instructions go to the CDC link at: http://www.cdc.gov/ncidod/dhqp/pdf/ppe/ppeposter148.pdf

Classification of Flammables and Combustibles

Ever wonder how to classify flammables and combustibles? Check out NFPA 30 from the National Fire Protection Association. This is a link to an EZ-Fact from Lab Safety Supply that includes a chart and explains NFPA 30 http://www.labsafety.com/refinfo/ezfacts/ezf180.htm

Eyewash Stations and Doors

A colleague asked the following question:

I recently attended an audio conference on Safety and learned that if the eyewash must be accessed by walking through a door, then the door must open out to the eyewash. Before I have my door swing direction changed, I wanted to confirm this with you.

Check out this link to the ANSI standard that covers eyewashes. Go to page 4 for more information about the door placement.
http://www.bradleycorp.com/products/techdata/4002.pdf

Potential Exposures During Proficiency Testing

Although this was reported over a year ago by the CDC in its MMWR, it bears repeating. Are your procedures up to date?

On November 27, 2007, CDC was notified by New York State Department of Heath (NYSDOH) officials of potential Brucella abortus RB51 (RB51) exposures to laboratorians at a state laboratory from an isolate used in a recent Laboratory Preparedness Survey (LPS). RB51 is an attenuated vaccine strain of B. abortus used to vaccinate cattle against brucellosis; human illness is known to have resulted from RB51 vaccine--related exposures (1). The LPS is a voluntary proficiency-testing program developed jointly by the College of American Pathologists (CAP), Association of Public Health Laboratories (APHL), and CDC. The program is designed to exercise protocols for "rule-out" or "referral" of potential bioterrorism agents. During the October--November LPS exercise, 1,316 laboratories participated. Written LPS instructions instructed laboratories to handle and manipulate all samples under a Class II Biological Safety Cabinet (Class II BSC), using Biological Safety Level 3 (BSL3) primary barriers. The reported exposures occurred when an LPS RB51 specimen was mislabeled as a routine patient specimen and was submitted by an LPS participating laboratory to the New York state bacteriology laboratory. As a result, routine benchtop procedures were used to handle the isolate by NYSDOH lab personnel outside of the Class II BSC, resulting in 24 laboratorians with potential exposure to RB51. After this incident, NYSDOH contacted all New York LPS-participating laboratories to determine whether other exposures had occurred. Of the participating laboratories contacted, 80% had performed at least one procedure outside of the Class II BSC, despite the LPS written instructions outlining appropriate biosafety handling practices.

CDC was consulted and recommended that those laboratorians who conducted procedures with exposures placing them at high risk receive postexposure prophylaxis. The findings in New York also raised concern that participating laboratories outside of the state might not have followed all prescribed biosafety instructions, possibly exposing other laboratory personnel to RB51. CDC is collaborating with CAP, APHL, and public health officials to 1) determine exposure risk in participating laboratories, 2) provide interim guidance on risk assessment and postexposure prophylaxis recommendations, 3) identify any illnesses associated with potential RB51 exposures among laboratorians participating in the LPS, and 4) identify follow-up actions and the need for additional guidance (e.g., education or training).

During December 3--10, 2007, CDC took steps to provide information regarding the RB51 incident to public health officials. State public health officials were notified via a broadcast e-mail and through an alert on the Epidemic Information Exchange (Epi-X). National conference calls were conducted with state public health laboratory directors and state epidemiologists to provide interim guidance on risk assessment and postexposure prophylaxis recommendations. Formal notification was sent by overnight letter from CAP to all participating LPS laboratories. Laboratories were recommended to review their biosafety practices during handling of RB51 specimens and report breaches in biosafety practices to their local public health officials for risk determination and recommendations. A set of questions was distributed to facilitate review of biosafety practices used during the LPS to identify potentially exposed persons. Laboratories were advised to ensure their ability to comply with standard biosafety protocols as defined in Biosafety in Microbiological and Biomedical Laboratories, 5th Edition* and to take steps to avoid specimen handling errors. To date, CDC has not learned of any illness consistent with brucellosis in any laboratory staff member potentially exposed to an LPS RB51 isolate.

For information regarding risk assessments and postexposure prophylaxis recommendations for potentially exposed persons, laboratories can contact state or local health officials. Information regarding B. abortus RB51 is available at the CDC Bacterial Zoonoses Branch, telephone 404-639-1711, or the CDC brucellosis website.† Public health officials can access updated information and risk assessment tools in Epi-X forum, "Brucella abortus/RB51 Exposure." Specific questions regarding the LPS can be directed to the CAP website§ or hotline, 800-443-3244. Questions regarding laboratory biosafety procedures can be directed to the CDC Laboratory Response Network, by e-mail, lrn@cdc.gov, or telephone, 866-576-5227.

Automatic Flushing Toilets are Safety Hazard

A Texas Hospital had a women come into the ED unaware of her pregancy and impending birth. She went to the public restroom at the hospital and suddenly delivered an infant into a toilet. The auto-flushing mechanism activated when the woman stood up and the suction began to pull the baby into the commode. Fortunately, medical staff responded, cut the umbilical cord and pulled the infant out. There were no serous injuries to the baby and both mom and baby are doing fine. The hospital has subsequently turned off the auto flushing feature for all toilets.

Cell Phone Photos and Patient Privacy

If your hospital doesn’t have a policy for cell phone photography in the building, it may be time. Cases continue to pop up where visitors and workers snap pictures using their cell phone cameras.

Last month, the University of New Mexico Hospital in Albuquerque, NM, fired two employees for allegedly taking close-up photos of patient injuries and then posting them on a MySpace Web page, the Associated Press reported. A hospital manager received a tip about the photos and began an investigation. Hospital officials personally oversaw the removal of the photos from the employees’ cell phones and the MySpace page, according to the Associated Press. The faces and personal features of the patients in the photos had been electronically removed before the pictures were posted. Other employees who knew of the photos were disciplined for not bringing the matter to the hospital’s attention.

OSHA Violations for Physician's Offices

In the last six months OSHA has fined medical practices for violating standards on hazard communications, exit routes, personal protective equipment, sanitation, portable fire extinguishers, and medical services and first aid. That last category included a $1,375 initial fine for not providing an emergency eyewash station.

Immunizations

National Adult Immunization Awareness Week (NAIAW), September 21-27, is a good opportunity for healthcare workers to check that they are up-to-date on recommended immunizations. According to "Immunizations Strongly Recommended for Health-Care Personnel," Morbidity and Mortality Weekly Report, December 19, 2003, healthcare workers should have documented proof of the following immunizations:
Hepatitis B
Influenza
Measles
Mumps
Rubella
Varicella-zoster

Waste Dumping Draws Felony Charges

A Pennsylvania dentist, Thomas W. McFarland Jr., 59, of Wynnewood, has been charged with two third-degree felonies after illegally dumping medical waste that washed up on a New Jersey beach in late August, according to Waste News, September 8. On August 22, 2008, McFarland, who practices in Pennsylvania but owns a beach house in Middle Township, NJ, allegedly took his small motor boat to the Townsend Inlet and dumped syringes, cotton swabs, and capsules used to store filling material. A day later the debris washed onto the Avalon shore. After admitting to the crime, McFarland may now face up to 5 years in prison for each charge and as much as $125,000 in fines.

Cleaning Blood Spills From Carpets

In a letter of interpretation on June 10, 1994, OSHA stated "that carpeted surfaces cannot be routinely decontaminated," but it makes no specific recommendations for decontamination. The letter explains that even though in most cases there is minimal dermal exposure to carpeting, employers must make a reasonable effort to clean and sanitize carpeting with carpet detergent/cleaner products. Carpet should not be used in areas where the chance of blood and body fluid spills can occur.

Pediatric Source Blood Draws

Labs in a pediatric faciity need to draw source-patient blood after a needlestick exposure just as in an adult facility. You cannot claim to observe universal precautions, which OSHA requires, when you assume that blood or body fluids from a pediatric patient pose no risk in an occupational exposure. If you don't obtain a blood sample, even from a pediatric patient, you are not in compliance with the OSHA bloodborne pathogen standard.

Workplace Safety

On this Labor Day, OSHA reminds everyone to make workplace safety and health a top priority. Through its balanced approach, OSHA helps to assure employee safety and health by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual process improvement in workplace safety and health. There are a number of OSHA resources available to assist employers and employees in identifying workplace hazards and possible solutions to those hazards.

OSHA Fines

Ever wonder what OSHA really fines facilities for violations? Most places keep that under their hat unless there is a death that occurs and the incident makes the papers. However, a recent edition of Medical Environment Weekly, published by HCPro stated that OSHA fines for a first time violation of the safety needle requirement was $394.

Designing, Implementing and Evaluating a Sharps Injury Prevention Program

The Centers for Disease Control and Prevention (CDC) has updated its Workbook for Designing, Implementing and Evaluating a Sharps Injury Prevention Program, a 62-page document that guides healthcare facilities in assessing safety culture and designing programs to eliminate needle and sharps injuries.

The new edition was made possible through an alliance with The Premier Safety Institute, Charlotte, NC. It incorporates feedback from eight hospitals that initiated programs based on the first edition issued in 2004. It also includes posters and tools for collecting data, evaluating devices, documenting exposure incidents, and implementing prevention devices and work practices.

For a free copy go to:
http://www.premierinc.com/safety/topics/needlestick/downloads/sharps-workbook-2008-high.pdf

Exposure Incidents

Needlesticks are not the only exposure incident that is reportable. Healthcare workers who are bitten by a patient must also report their exposure. According to OSHA, an exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's job duties. Parenteral contact, as defined in the OSHA bloodborne pathogens standard, includes needlesticks, bites, cuts, abrasions, and similar injuries that result in a piercing of the skin or mucous membranes.

Needlesticks

According to an article in the August 8th issue of the American Journal of Infection Control that was conducted by the Center for Healthcare Policy and Research and the Department of Public Health Sciences at the University of California in Davis, CA, white female nurses between ages 35-44 are the most frequent demographic and occupational category for a needlestick.

The study examined Bureau of Labor Statistics (BLS) data on needlestick injuries requiring one or more days of lost work time from 1992 to 2003.Women comprised 73.3% of persons injured by needlesticks in the BLS data.

NIOSH Fact Sheet

NIOSH has just published a new fact sheet that indicates bloodborne pathogen exposure control plans must be specirfic to your facility, updated yearly and accessible to all employees. Recently OSHA fined a physician office $2,000 for not making the exposure control plan available to all its employees.

Hepatitis B Vaccination Titer

The OSHA bloodborne pathogen standard requires that all facilities who have employees exposed to bloodborne pathogens offer Hepatitis B vaccination at no cost to the employee. In addition, OSHA follows the current U.S. Public Health Service guidelines which call for testing one to two months after completion of the three-dose series to make sure the titer is appropriate.

Chairs

Herman Miller, maker of the ergonomically correct Aeron office chair is now producing a line of ergonomically correct patient-oriented chairs for the clinical market. The company based its new chair on the aeron design that let it tilt easily and can help patients sit up with ease. Designers and engineers visited patient rooms in nine hospitals and met with nearly 200 nurses and doctors to make sure the product would do the job. Nurses and physicians advised on several crucial details such as making sure an IV line wouldn't catch on the chair's arms and the need to find antimicrobial upholstery that could be cleaned if blood or body fluids got trapped in the seams. The chair is visually pleasing and comes with a footstool for more comfort. It debuted June 9th at Chicago's NeoCon World Trade Fair and will go on sale to hospitals in the fall for a list price of $1,800.

Bloodborne Pathogen Costs

According to the July 2007 issue of Infection Control and Hospital Epidemiology, the costs of an exposure to a bloodborne pathogen ranged from a low of $71 to a high of $4,838 per incident depending on the circumstances. Calculations included time spent reporting, managing and following up the exposures, salaries, laboratory testing, and postexposure prophylaxis. The mean cost of exposures was $2,456 from HIV infected sources, $376 from unknown or HIV-negative infected sources, and $650 from hepatitis C infected sources.

And while we are talking about costs, did you know there is a fine associated with failure to review and update your bloodborne pathogex exposure control plan? According to Medical Enviornment Update published on June 17, 2008 by HCPro, failure to review the exposure control plan at least annually and whenever necessary to reflect new hazards, work practices, and engineering controls is one of the most frequent fines cited by OSHA for physician practices. Initial fines have averaged $590 per citation.

New Latex Glove

The FDA has approved a new patient examination glove made from guayule latex, a new form of natural rubber latex. The glove is made by the Yulex Corporation of Maricopa, AZ, and has shown that even patients who are highly allergic to traditional latex do not react on first exposure to guayule latex proteins. Until further study is conducted, the Yulex glove will still carry a warning about the potential for allergic reactions, which the FDA requires for all medical devices made with latex.

Luminol for Infection Control

In the May 23rd issue of Reuters Health is an article about how Dutch researchers are using Luminol, a bioluminescent chemical, to detect blood contamination in kidney dialysis units. Units that were just cleaned and appeared to be free of contamination still showed traces of blood on numerous surfaces, including control panels, telephones and floors, when tested with Luminol. This is a great teaching tool for discussions about proper laboratory disinfection and infection control.

Stockpiling Respirators and Facemasks for Pandemic Flu

Is your facility concerned about a possible pandemic flu? Are you stockpiling respirators and facemasks in anticipation? OSHA has a proposed guideline on just this issue and you have until July 8, 2008 to coment. Check out the May 9th Federal Register for details on how to submit coments.

Hurricane Matrix from OSHA

June is fast approaching and for those of us living in Hurricane Alley it is time to review our safety policies and procedures. OSHA has tools on its website (http://www.osha.gov/SLTC/etools/hurricane/index.html) that can help. In this Hazard Exposure and Risk Assessment Matrix, OSHA provides information on many of the most common and significant additional hazards that response and recovery workers might encounter when working in an area recently devastated by a hurricane. This Matrix highlights a number of tasks and operations associated with disaster response and recovery. The Matrix is designed to help employers make decisions during their risk assessment that will protect their employees working in hurricane-impacted areas. In this Hazard Exposure and Risk Assessment Matrix, OSHA provides information on many of the most common and significant additional hazards that response and recovery workers might encounter when working in an area recently devastated by a hurricane. This Matrix highlights a number of tasks and operations associated with disaster response and recovery. The Matrix is designed to help employers make decisions during their risk assessment that will protect their employees working in hurricane-impacted areas.

Hepatitis B Vaccination

Any employee who declines the hepatitis B vaccination is still covered by the bloodborne pathogen standard, 1910.1030(f)(2)(iii), and may accept the offer of vaccination at any time even if the request is months or even years from the original offering. Furthermore, the employer must still make the vaccination available at no cost to the employee.

Hepatitis Vaccinations and Identity Theft

Identity theft has become a real concern in today's world. Some facilities use Social Security numbers for hospital IDs. OSHA does NOT require the use of your Social Security number for medical records such as Hepatitis vaccination records. OSHA recommends following the CDC definition of a "reliable vaccination history to be a written, dated record of each dose of a complete series".

Preparing Your Lab for a Major Disaster

In just a few short weeks the hurricane season begins in many parts of the country. Joint Commission requirement EC.4.10 received a major overhaul in January (split into EC.4.11-EC.4.18) that addresses issues associated with the devastation of Hurricane Katrina. One of the most important components involves the requirement that hospitals determine whether they can survive on their own without community support for up to 96 hours during a disaster. This means the entire hospital, including the laboratory. Has your lab assessed its ability to stand alone during a prolonged disaster?

Figuring out what factors will limit you is a challenge for anyone. For example, you might have a two-week supply of gloves or a 10-day supply of reagents, but only a two-day supply of vehicle fuel for the courier's cars to transport specimens to and from the laboratory. It is easy to address the big things that we order frequently, but we tend to overlook the everyday purchases that we take for granted, such as gas for our automobiles.

If you haven't done your assessment, do so this week and rest easier knowing you are prepared for any disaster, no matter what time of year it is.

Chemical Hygiene

Under the OSHA Chemical Hygiene Standard of 1990, chemicals that are in kits or contain less than 1% of a hazardous chemical do not have to be listed or treated differently. Many of the stains and reagents come in kits and rarely contain any chemical that is more that 1%. One colleague asked specifically about the Hematek packs. Under OSHA's definition they are considered a kit. They can remain on the shelf until they are opened and put on the machine where they remain until the pack is empty.

May is Healthy Vision Month

Healthy Vision Month is an annual observance coordinated by the National Eye Institute of the National Institutes of Health (NIH) each May. It encorages workers to make vision a health priority in the workplace. OSHA is reminding everyone about the importance of eye protection on the job. Here is what you can do to protect your eyes:

• Choose effective protective eyewear deisgned for your specific lab task
• Make sure the eyewear is properly fitted
• Know where the protective eyewear is located and how it should be used

For more informatio on prevening workplace injuries visit OSHA's Web site.

Workplace Safety Programs Pay Off

OSHA is teaming up with other organizations promoting safety to get the word out that "Safety Is Good Business," which is also the theme of North American Occupational Safety and Health Week (NAOSH), May 4–10, 2008.

Investing in health and safety programs is a sound strategy for business of all sizes and types, according to the American Society of Safety Engineers (ASSE), which sponsors the NAOSH Week activities. For every $1 invested in safety programs, $4-$6 are saved in decreased injuries, illnesses, medical costs, and workers' compensation costs while worker productivity increases, according to a NAOSH Week fact sheet.

Zip Bags for Transporting Specimens

If you use zip bags without the biohazard symbol you can reuse them (a hassle) or throw them out with the regular trash unless they are visibly contaminated with blood or body fluids. If you use zip bags with the biohazard symbol they must go in red bag waste or your waste hauler won't take them.

As long as you are transporting specimens in a clear bag so that anyone can see blood or body fluids in them, you can use bags without the biohazard symbol but only within your facility. Any specimen that is sent across a public street or highway must have the symbol on the bag. This is part of the DOT regs.

What is Considered a Sharp?

I have received several queries about plastic pipette tips and whether they must be considered a sharp when they are disposed of and, as a result, placed in a sharps container. There has been discussion as to whether this is an OSHA or DOT regulation. When OSHA was contacted through the Denver office, it indicated that there was no OSHA regulation regarding plastic pipette tips being declared a sharp and having to be placed in a sharps container.

However, in the CFR 173.134 reads, in part, “Sharps means any object contaminated with a pathogen or that may become contaminated with a pathogen through handling or during transportation and also capable of cutting or penetrating skin or packaging material. Sharps include needles, syringes, scalpels, broken glass, culture slides (glass), culture dishes (glass), broken capillary tubes, broken rigid plastic, and exposed ends of dental wires.” According to the definition, only broken glass or plastic is considered a sharp. The potential to break is not specifically addressed.

The issue then becomes, will the plastic tips puncture the red bag and cause the healthcare worker potential exposure? Each facility should address this issue in its safety committee and come up with a policy and procedure for dealing with this type of waste.

OSHA Posts TB Enforcement Letter

OSHA finally got around to posting a notice on its Web site, www.osha.gov, that it will start enforcing annual fit-testing in healthcare facilities for respirators used to protect from tuberculosis (TB) exposure. OSHA received Congressional approval to reactivate this provision of the Respiratory Protection Standard, 1910.134, December 26, 2007, but the notice appeared last week, even though it is dated March 24. OSHA will now cite employers for failure to conduct annual fit testing for employees required to wear respirators as protection from TB.

Computer Vision Syndrome (CVS)

CVS is an ergonomic illness associated with individuals who use a computer on a regular basis. The aging workforce is susceptible to a variety of workplace safety risks. According to the American Optometric Association, computer vision syndrome leaves older employees vulnerable to problems like dry eye, eyestrain and fatigue. Here is what employers can do to prevent this problem:

Encourage older employees to have a comprehensive eye exam at least once a year especially if they are experiencing symptoms of CVS such as eye redness, frequent rubbing of the eyes, blurriness or eye fatigue or limited attention to visual tasks.


Remind employees to use the 20-20-20 rule. Every 20 minutes look 20 feet away from the computer and blink 20 times to minimize the development of eye focusing problems and eye irritation caused by improper blinking.


Make sure the computer monitor is adjusted to the individual user’s height. The top of the monitor should be at eye level.

MSDS for Infectious Substances

The Health Canada website at http://www.phac-aspc.gc.ca/msds-ftss/index.html#menu?
now has material safety data sheets for infectious substances. These MSDS are produced for personnel working in the life sciences as quick safety reference material relating to infectious micro-organisms.


The MSDS are organized to contain health hazard information such as infectious dose, viability (including decontamination), medical information, laboratory hazard, recommended precautions, handling information and spill procedures. The intent of these documents is to provide a safety resource for laboratory personnel working with these infectious substances. Because these workers are usually working in a scientific setting and are potentially exposed to much higher concentrations of these human pathogens than the general public, the terminology in these MSDS is technical and detailed, containing information that is relevant specifically to the laboratory setting. It is hoped along with good laboratory practices, these MSDS will help provide a safer, healthier environment for everyone working with infectious substances.

Training for Couriers

It is the responsibility of the employer of the couriers to training the couriers. If it is an outside firm, you must state in the contract that the employer is required to provide bloodborne pathogen as well as shipping training to each courier that picks up from your site.

If your couriers are in house, you are responsible for their training. They are to be trained on bloodborne pathogens and shipping as well. They are to understand that they are responsible for the package when it is in their possession. They have the right to refuse to take a package that is not appropriately packed and labeled therefore they need to know what is required for proper packaging so they can tell at a glance whether to accept the package or not. They are not responsible for packaging the shipment. That has do be done by whomever is shipping the package. Anytime blood or body fluids go across a public street or highway they must be packaged according to DOT. If it is a doctor’s office that is shipping to you, then they need to have shipping training also.

Information from OSHA about Physician Offices

Physicians and other medical professionals are dedicated to helping patients mend their injuries and cure their illnesses. Employers whose workplaces are in medical facilities must be aware of the importance of protecting their staff from hazards as well. Doctors, nurses and other staff face potential dangers from needlesticks, exposure to infectious diseases, contamination and dangerous chemicals. OSHA recognizes the significance of medical employees having a work environment reasonably free of occupational hazards. OSHA's Medical and Dental Offices: A Guide to Compliance with OSHA Standards (OSHA 3187), provides a brief overview of the hazards most frequently found in medical and dental offices. It also highlights the OSHA-approved standards and guidelines employers must follow to promote employee safety and health. The brochure summarizes standards on :
Bloodborne Pathogens
Hazard Communication
Ionizing Radiation
Exit Routes
Electrical

Visit OSHA's Web site for more informational materials focusing on safety and health dangers. Look for "Quick Tips" on a new occupational safety and health topic in your next issue of QuickTakes.

Rapid HIV Testing Following a Needlestick

The following question was submitted to OSHA:

Is it a violation of 29 CFR 1910.1030 for a medical facility subject to OSHA authority not to perform "rapid HIV antibody testing" on a source individual after an exposure incident?

Here is the reply from OSHA's Richard Fairfax at the Office of Health Enforcement:

Reply: As you may know, the bloodborne pathogens standard provides that "the source individual's blood shall be tested as soon as feasible" after an exposure incident and after consent is obtained [29 CFR 1910.1030(f)(3)(ii)(A)]. At the current time there are at least four FDA-approved tests available for "rapid HIV antibody testing," which usually can confirm negative HIV status in less than an hour after blood is drawn from a source individual. They are widely available, easy to use, and inexpensive. Standard enzyme immunoassay (EIA) testing can take a much longer time, especially if facilities to perform the tests are not available locally. Therefore, an employer's failure to use rapid HIV antibody testing when testing as required by paragraph 1910.1030(f)(3)(ii)(A) would usually be considered a violation of that provision. The use of rapid HIV antibody testing is supported by the current CDC recommendations for HIV post-exposure prophylaxis (PEP) in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis, published on September 30, 2005. The CDC states on page 7 that having a "rapid HIV test could result in decreased use of PEP and spare personnel both undue anxiety and adverse effects of antiretroviral PEP." The document goes on to note on page 8 that "rapid HIV testing of source patients can facilitate making timely decisions regarding use of HIV PEP after occupational exposures to sources of unknown HIV status." Current guidance on the management of HBV and HCV exposure and PEP, as well as guidance for evaluation of the exposure source, is also contained in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV and HIV and Recommendations for Postexposure Prophylaxis (June 29, 2001), Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Teaching Tools

Need some tools for teaching safety. The CDC has a set of cards covering infectious diseases that are free. Go to www.cdc.gov/ncidod for more information. Also check out some of the great animated bugs at http://www.nanobugs.com/. These are great teaching tools for all ages.

Planning for an OSHA Inspection

Concerned about what happens during an OSHA inspection? Like to know how to plan for such an event. Get a copy of our white paper, "Planning for an OSHA Inspection" by sending an email to info@safetylady.com and requesting it.

Shoes for the Clinical Laboratory

In 1980, CAP generated a document that said laboratory employee shoes must adequately cover the foot – not be made of canvas or be sandals or sneakers or open toed.

CLSI document GP17-A2 states:

“Shoes should be comfortable, rubber-soled, and cover the entire foot. Disposable, fluid-resistant shoe covers can be worn for jobs where splashing is expected. Because canvas shoes will absorb chemicals or infectious fluids, they are not recommended (if worn, they should be covered with disposable, fluid-resistant shoe covers). Leather or a synthetic, fluid-impermeable material is suggested.”

The committee that worked on GP17-A2 was made up of physicians and representatives of both CAP and CLSI. The document was also crafted to meet ISO 15190 requirements for medical laboratories.

I can’t speak for the whole facility, but these are the requirements for lab employees. Crocs do not cover the entire foot therefore they are not allowed in the lab.

Proper Laboratory Temperature

The temperature in the lab should be maintained at 65-70 degrees Fahrenheit with a humidity between 35 and 55%. The American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) have guidelines covering these ranges. As laboratories add more automated equipment, the room temperature goes up due to the amount of heat generated. Old labs are often a composite of several small rooms that lack the proper circulation and ventilation. If it is too hot, the equipment doesn’t work properly and the lab results are erroneous. ASHRAE also states that air exchange is important. Twelve exchanges per hour removes 99% of airborne particulates in 23 minutes. Armed with this information, laboratory management should work with the facility’s engineering department to assure employee comfort.

Is There Mustard or Ketchup on Your Safety Program?

The following story was adapted from an article by Torrey M. Garrison of Mobile, AL in the September, 2006 Safety+Health magazine from the National Safety Council

Have you ever been to a fast food restaurant and ordered a hamburger with just ketchup? Just as you take the first bite, the strong flavor of mustard overcomes you. You stated your order as clearly as you could, but they still got it wrong. How in the world can you relate a hamburger with safety? Read on.

As a safety officer, you continually stress the importance of safety at your monthly meetings. You want every employee to know that Safety is the lab’s number one priority. You never want employees to get the order wrong so you speak as clearly as you can when conducting training.

That being said, you still remember the time when safety protocols were lax and you got a call from the CEO that the OSHA inspector was on his way down to the lab to conduct a safety audit based on an employee complaint. You start to scramble. It’s now time to play KETCHUP.

It is so much easier to start a solid laboratory safety program from the beginning than having to play catch up. It never will be the same, and the time you have wasted getting it rolling could be costly. Start it from the beginning and speak clearly. You never want your employees to get the order wrong.

Need help with your safety training? Check out our new DVDs at http://www.safetylady.com/products.html

Do alcohol-based hand sanitizers kill all types of bacteria and viruses?

There are three main categories of viruses and bacteria that require the use of soap and water to physically remove the spores from the surface. The Centers for Disease Control and Prevention (CDC) recommends that healthcare workers wash their hands with non antimicrobial or antimicrobial soap and water for the following categories of viruses and bacteria that are not susceptible to alcohol-based hand gels:

Nonenveloped or nonlipohilic viruses:
Norovirus
Calicivirus
Picornavirus
Parovirus
Bacterial spores:
B. anthracis (anthrax)
B. cereus (food poisoning)
C. botulinum (botulism)
C. tetani (tetanus)
C. perfringens (gas gangrene)
C. difficile
Protozoan oocysts:
Amebic dysentery
Giardia lamblia

Spill Kits for the Clinical Laboratory

Chemical Spill Kits

Locate spill kits near chemicals and make sure they are easily accessible. Check the kits on an annual bases and re-stock them if they are used. The content should be specific to the chemicals used at your facility. The kit should contain:

Personal Protective Equipment (PPE)
Goggles or a Face Shield
Corrosive-resistant gloves and booties
Disposable lab coat and corrosive apron
Appropriate respiratory protection

Appropriate absorbents for the chemicals
All-purpose absorbents are good for spills of most chemicals
Absorbent spill pillows can also be used
Acid and base spill neutralizers are also available
Inert absorbents like vermiculite, clay or sand can be used

Clean-up and disposal materials
A plastic dust pan or scoop
Plastic bags for PPE waste
A plastic pail for spill residues and waste
Check the MSDS to determine if your chemical is incompatible with certain materials

Other items for specific hazards
If you use hydrofluoric acid, add calcium gluconate antidote gel in the kit
Mercury also requires special spill cleanup materials (there are specific spill kits for use when cleaning up mercury

Biohazard Spill Kits

Locate spill kits near area where blood and body fluids are being collected or tested and make sure they are easily accessible. Check the kits on an annual bases and re-stock them if they are used. The kit should contain:

Personal Protective Equipment (PPE)
Goggles or a Face Shield
Latex or vinyl or nitrile gloves
Disposable lab coat

Appropriate absorbents for the spill
All-purpose absorbents are good for spills containing blood or body fluids

Clean-up and disposal materials
A plastic dust pan and brush or scoop
Plastic bags for PPE waste
A plastic pail for spill residues and waste

Responding to a Spill

Check the MSDS for cleanup procedures and hazards of the material when dealing with chemicals
Always wear the proper PPE
Do your best to safely contain the spill
Use proper materials for cleanup
Follow proper disposal procedures for the resulting waste

Eyewash Stations

Is your eyewash station within 100 ft or a 10 second walk of hazardous chemicals? What about your water temperature? In 1998, the American Nation Standards Institute (ANSI) Z358.1 included a general requirement the water temperature for the eyewash be tepid and that the water must run for 15 minutes for proper flushing of the eye. Prior to this requirement, eyewash stations were attached to the cold water tap and could cause an uncomfortable chilling effect. In the 2004 revision, ANSI clarified the definition of “tepid” to be in the range of 60 degrees F to below 100 degrees F. Very few labs have implemented this requirement and if cited by OSHA could lead to fines in the five figures. According to an article by Casey Hayes in the May 2007 issue of Occupational Health and Safety, the fines levied against a lab for non-compliance often equal the cost of the changes needed to comply.