As a lab safety consultant, I get questions from many different lab professionals, and I share the answers to those questions in my monthly newsletter so that others with similar issues may benefit from the information. Most of the answers are derived from safety regulations or guidelines that are in place, but there are some questions that just don’t allow for an answer that is easy or straight-forward. Here are some examples:
Q: Why should chemicals be stored below shoulder level?
The closest standard that addresses this is from CAP which mandates that strong acids and bases are stored near the floor. However, other chemicals stored on high shelves or in high cabinets can be a danger as well. There have been many incidents where personnel have reached up to grab a chemical and had it spill into their face. Even new packages of chemicals or reagents can be defective and may leak. It is best to store all chemicals in the lab below shoulder level. Whose shoulders? The shoulders of the shortest person who may be working with those chemicals in the lab.
Q: Do trash cans need lids in the lab?
OSHA’s Bloodborne Pathogens Standard and CAP both have regulations dealing with this issue, but it often remains unclear to many. While in the lab and while in use, regulated medical waste containers do not need a lid. If the bags in the containers are removed from the lab, they should be placed into a bigger container with a tight-fitting lid. If the actual lab containers will be removed, they then need a tight-fitting lid for the removal process.
Sharps containers are different- they should always have a lid and should be prevented from tipping over. If the container does tip, the contents should be prevented from spilling out.
Q: Do employees need to physically walk to the lab evacuation location every year?
CAP removed its standard in 2014 requiring labs to perform this particular duty, but they still require labs to perform and document a physical evaluation of the escape routes annually to ensure that fire exit corridors and stairwells are clear and that all fire exit doors open properly. The best way to do this is to continue walking staff to their evacuation location every year. Not only does this provide a check of the route, but it regularly reminds staff how to proceed in any evacuation situation.
Q: How long do I need to keep Safety Data Sheets?
The language in the OSHA Hazard Communication Standard can be confusing, but the bottom line is this: if a chemical has been involved in an employee exposure, you should keep the SDS for 30 years in case there is any legal follow-up. If you have hundreds of chemicals, or if you have not worked in the location for very long, you may not know which chemicals have been involved in an employee incident. In that case, it is best to keep all SDS in storage for 30 years. Keep old copies in a binder marked “retired.” If you have converted to an electronic SDS system and it contains the SDS from your current or past inventory, you would not need to keep any paper copies on site provided you can access them.
As you can see, not all lab safety situations are easy to tackle, and the answers are not always straightforward. When a written regulation cannot be found to provide guidance to a safety question, I immediately look at what would be the best or safest practice. Regulations do not cover every area of lab safety, so as lab safety professionals, we need to think through those situations for which regulations are not clear. It is also very helpful to know what resources you have to use to help you solve safety issues. Know your internal resources (maintenance, infection control, biomedical engineering, etc.), and your external resources (chemical waste contractor, industrial hygienist, safety consultant, etc.) as well. Utilize all of these tools, and you will make smart safety decisions in your laboratory.